CEU Electronic Theses and Dissertations, 2025
| Author | Liu, Qing |
|---|---|
| Title | The Past, Present, And The Future Of Cryptocurrency -A Comparative Regulatory Perspective From Us, Eu And China |
| Summary | Cryptocurrency has grown rapidly since Bitcoin was launched in 2009, with market capitalization having a high of almost $3 trillion in 2021, and currently at around $1.2 trillion as of April 2025. There are now more than 1,000 various cryptocurrencies in the market. 2025, Major cryptocurrency companies including Circle, BitGo, Coinbase and Paxos are applying for U.S. bank charters or licenses, The United States and Hong Kong issue stable coins, the closer intertwining of cryptocurrency and the traditional financial industry challenge the regulation system. It is urgent to develop unified standards for regulation with flexible, compatible, consensus-based, executable policy. In the United States, the regulation of cryptocurrency involves multiple agencies and legal frameworks at the federal and state levels. There are numerous coordination problems for the federal and state governments in cryptocurrency regulation. The regulatory framework is led by the Securities and Exchange Commission (SEC), SEC views cryptocurrency as a security applying the securities laws, and according to the 'Executive Order on Ensuring Responsible Development of Digital Assets' released by the U.S. government in March 2022, cryptocurrencies are defined as digital assets. The EU adopted the Market Regulation of Crypto Assets Act (MiCA) in 2023 with the aim of creating a harmonized regulatory framework for the crypto asset market. China is the most stringent at present. In the interest of preventing money laundering, financial risks and protecting investors, it prohibits the circulation of cryptocurrency as currency, prohibits cryptocurrency transactions and business activities, and prohibits cryptocurrency mining activities. However, Chinese participants are in the foreign cryptocurrency market regardless, be it as investors, technical talents, coin issuers, or exchanges. Regulatory policies differ greatly in different nations and are indicative of great instability. This instability in regulatory frameworks can be attributed not only to the rapidly evolving nature of technology and associated business models but also by the political party, geopolitical, and political leader preferences. Cryptocurrencies have become a game-changing financial innovation, the anonymity, decentralization and borderless of cryptocurrencies challenge regulation, particularly anti-money laundering and terrorist financing. regulators must strike a balance between risk control and innovation. This thesis seeks to study the development, present status, and future of cryptocurrencies from a comparative regulatory analysis. The findings and recommendations from this study will contribute to the development of more effective regulatory frameworks, helping to prevent future digital asset catastrophes and fostering a safer and more resilient digital asset ecosystem. The author suggests that China, based on the experience of Hong Kong's pilot of stable coin and sandbox, can learn from the MiCA and SEC experience and replicate more proactive and flexible legislation, especially the hierarchical and categorized method adopted by MiCA in regulating virtual currencies, which can identify and contain risks more efficiently. The paper predicts that significant changes are imminent in cryptocurrency regulation in China, which may profoundly reshape the global market. |
| Supervisor | Tibor Tajti |
| Department | Legal Studies LLM |
| Full text | https://www.etd.ceu.edu/2025/liu_qing.pdf |
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