Regulating cryptocurrencies

The experience of Hong Kong

In August 2025, Hong Kong discussed a¹ draft regulation on virtual asset trading. It provides for mandatory licensing of companies engaged in transactions with virtual assets (such as cryptocurrencies) and the extension of AML/CFT requirements to them. The proposed rules expand on existing regulations, which previously only covered crypto exchanges and the issuance and circulation of stablecoins. Now, all companies that help clients buy, sell, or store cryptocurrencies will be subject to regulation, from crypto exchanges and crypto brokers to crypto wallets, consultants, and crypto asset managers.

The EU experience

The European Banking Authority (EBA)² has published draft rules requiring banks to account for their investments in crypto assets and determine the amount of reserves needed to cover the risk of crypto asset volatility in accordance with the EU Capital Requirements³ Regulation (CRR 3). Banks may acquire crypto assets (e.g., cryptocurrencies, stablecoins) as part of their own investment portfolio or to serve their customers.

According to the draft, different categories of cryptocurrencies are assigned different risk weights, which determine how much capital a bank must reserve for such investments. For example, tokens backed by real assets (e.g., gold) (ARTs under MiCA regulations ) have a 250% weighting, while unbacked cryptocurrencies (such as Bitcoin) have a maximum risk weighting of 1250%.

For comparison, the risk coefficient for gold is 100%, and for stocks it is 250%. In other words, a coefficient of 250% makes even secured tokens riskier than conventional assets, while a coefficient of 1250% for unsecured cryptocurrencies equates them to the riskiest investments, effectively prohibiting banks from holding such assets.

Thus, if, for example, a bank buys Bitcoin for €100bn, a risk weight of 1250% is applied to such an asset. This means that to calculate the⁴ risk-weighted assets, the amount is multiplied by 12.5 times and amounts to €1.250 bn. However, since banks are required to hold capital equal to at least 8% of their risk-weighted assets, in this case, the bank would be required to reserve €100 m of its own capital. In other words, for every €1 invested in Bitcoin, the bank must hold another €1 in capital.

Quantitative restrictions are also being introduced: the total volume of unsecured crypto assets on a bank's balance sheet must not⁵ exceed 1% of its Tier 1 capital. These measures are effectively aimed at limiting the large-scale accumulation of volatile cryptocurrencies by banks.

The US (Louisiana) experience

The Blockchain Basics Act has come into force in Louisiana, prohibiting certain foreign companies from acquiring or owning cryptocurrency mining businesses in the state, namely citizens and organizations from countries under US sanctions (e.g., Russia, Iran), as well as companies that the US State Department has identified as entities of particular concern. Such companies are prohibited from engaging in mining, otherwise they will face a fine of up to $1 m or up to 25% of the value of the share owned by the violating company in this business.

The law also prohibits Louisiana authorities from accepting payments in central bank digital currencies and participating in their testing. However, in Louisiana, it is possible to participate in maintaining the blockchain — to maintain computers that help the network operate, as well as to engage in mining at home.

The experience of Thailand

In August 2025, the Thai Securities and Exchange Commission proposed a regulatory⁶ sandbox concept for cryptocurrencies to enable foreign tourists to exchange cryptocurrencies for Thai baht to pay for purchases in the country. The TouristDigiPay⁷ pilot project was launched, allowing tourists to convert cryptocurrencies into baht through licensed cryptocurrency platforms and wallets. After the exchange, the funds are credited to a special tourist e-wallet, from which goods and services can be paid for using QR codes at local merchants. The project is scheduled to run for 18 months and is intended only for foreign tourists temporarily residing in Thailand. At the same time, limits have been set on transactions, for example, no more than 50,000 baht ($1,500) per month for small purchases. The project is particularly relevant for Russian tourists, who face restrictions when paying with bank cards abroad.

The experience of Russia

Russia has already adopted measures similar to the EU's approach, providing for a quantitative limit of 1% of capital for cryptocurrencies: in May 2025 the Bank of Russia published Information Letter recommending that credit institutions independently assess the risks of transactions with digital currencies, ensure full coverage of such investments with their own funds (capital), and set a limit of no more than 1% of their own funds.

Also, unlike Hong Kong and Thailand, where attention is focused on regulating service providers and creating “sandboxes” to stimulate tourism, there are no such initiatives in Russia yet. However, there is a law on mining: only companies and individual entrepreneurs registered in the Federal Tax Service registry can engage in it. This approach is comparable to measures in the US, where the participation of foreign companies in the mining business is restricted.

From the monitoring issue No. 8 (20), August 2025. Download the full issue (PDF) · issue page at the Gaidar Institute