How can a crypto company map which rules might apply to it in different countries?
List what the business actually does, then ask each place's rules the same questions: is the token covered, does the activity need a licence or registration, and what anti-money-laundering and sanctions duties follow.1,2,3 Serving customers in a country can bring in its laws, even for a firm set up elsewhere.4,5
Brindlecove and its app are made up. This lesson shows how to list questions, not how to answer them. Rules change, and their status is dated as of 22 October 2026. A real company would ask qualified lawyers in each place.6,7,8
Step 1: describe the activities, not the product
Global standards look at what a business does. The FSB's principle is "same activity, same risk, same regulation".1 FATF's VASP list is a list of activities done for others.9 MiCA lists crypto-asset services, and the Cayman Act lists virtual asset services.10,11
So Maya writes the app as four plain activities: sell new BRDL to the public, swap crypto using Brindlecove's own money, hold customers' crypto and keys, and send crypto for customers.9,10
Step 2: ask where the rules reach
Being a Cayman company does not settle which rules apply. FATF says countries may require VASPs that serve customers in their country to be licensed or registered there.2 MiCA's exception for a client's "own exclusive initiative" does not apply if a non-EU firm solicits EU clients.5 IOSCO notes that serving a country can bring in its laws.4
Step 3: fill in the grid
| Activity | EU (MiCA) | US | Cayman Islands (VASP Act) |
|---|---|---|---|
| Sell new BRDL | Is BRDL a financial instrument? If not, is a white paper needed, or does an Article 4(2) exemption apply?12,13 | Is the sale an investment contract under Howey? Which of the SEC's five groups is BRDL in?14,15 | Is this "issuance of virtual assets", and does CIMA need to approve the issuance?11,16 |
| Swap, own money | Is this "exchange of crypto-assets for other crypto-assets"?10 | Does it involve money transmission, or a commodity or derivative question?17,18 | Exchange between virtual assets, or a trading platform that needs a licence?11,19 |
| Hold keys | Custody and administration, so CASP authorisation?10,5 | Does New York, or another state, require a licence?20 | Virtual asset custody service, so a licence?16,19 |
| Send for customers | Transfer services, so CASP authorisation?10,5 | Money transmission, so FinCEN registration within 180 days?17 | Transfer of virtual assets, so registration?11,19 |
Step 4: add the duties that apply everywhere
Some questions cut across every box:2,3
- Money laundering: what is the firm's risk-based approach, and how will it check customers?2
- The Travel Rule: how will sender and receiver details travel with transfers to other VASPs?2
- Sanctions: will every withdrawal address be screened, in full, against the SDN List and other lists?3,21
- Changing law: which rules are still bills, open to public comment, or in transition periods?7,15,22
Step 5: date everything
Maya puts a date on every line, because these rules move. MiCA's transition periods ended by 1 July 2026 at the latest.22 The SEC's crypto interpretation took effect on 23 March 2026, and the SEC said it may refine it.15 The US market-structure bill had not passed the Senate as of 22 October 2026.7 And the Basel Committee said on 1 October 2026 that it was still reviewing its bank crypto standard.23
- FSB Global Regulatory Framework for Crypto-asset Activities. Financial Stability Board, 17 July 2023.
- The FATF Recommendations: Interpretive Note to Recommendation 15 (new technologies). Financial Action Task Force (FATF), updated June 2026, updated June 2026.
- Sanctions Compliance Guidance for the Virtual Currency Industry. Office of Foreign Assets Control (OFAC), US Department of the Treasury, October 2021.
- Policy Recommendations for Crypto and Digital Asset Markets: Final Report (FR11/2023). Board of the International Organization of Securities Commissions (IOSCO), 16 November 2023.
- Regulation (EU) 2023/1114 (MiCA): Articles 59 to 61, authorisation of crypto-asset service providers. European Parliament and Council of the European Union, Official Journal L 150, 9 June 2023 (read on EUR-Lex; the original text, not later amendments), 31 May 2023.
- FSB finds significant gaps and inconsistencies in implementation of crypto and stablecoin recommendations. Financial Stability Board, press release, 16 October 2025.
- H.R.3633: Digital Asset Market Clarity Act, all actions and titles. Congress.gov, Library of Congress (actions list read through the Congress.gov data service on 22 October 2026).
- Virtual Asset (Service Providers) (Amendment) Act, 2026 (Act 4 of 2026). Cayman Islands Government, legislation.gov.ky, 24 March 2026.
- The FATF Recommendations: Recommendation 15 and the glossary. Financial Action Task Force (FATF), updated June 2026, February 2012, updated June 2026.
- Regulation (EU) 2023/1114 (MiCA): Article 3(1), points 15 to 26, crypto-asset services. European Parliament and Council of the European Union, Official Journal L 150, 9 June 2023 (read on EUR-Lex; the original text, not later amendments), 31 May 2023.
- Virtual Asset (Service Providers) Act (2024 Revision): sections 2 and 3, definitions. Cayman Islands Government, legislation.gov.ky (revised as at 31 December 2023), 15 February 2024.
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA): Articles 2 and 3, scope and definitions. European Parliament and Council of the European Union, Official Journal L 150, 9 June 2023 (read on EUR-Lex; the original text, not later amendments), 31 May 2023.
- Regulation (EU) 2023/1114 (MiCA): Articles 4 to 9, offers to the public and white papers. European Parliament and Council of the European Union, Official Journal L 150, 9 June 2023 (read on EUR-Lex; the original text, not later amendments), 31 May 2023.
- Securities and Exchange Commission v. W. J. Howey Co., 328 U.S. 293. Supreme Court of the United States (Library of Congress copy of the United States Reports), 27 May 1946.
- Application of the Federal Securities Laws to Certain Types of Crypto Assets and Certain Transactions Involving Crypto Assets (Release No. 33-11412). US Securities and Exchange Commission, with guidance from the Commodity Futures Trading Commission, 17 March 2026, effective 23 March 2026.
- Virtual Asset (Service Providers) Act (2024 Revision): sections 3, 4, 7 and 17 to 20, registration, issuance, licences and the sandbox. Cayman Islands Government, legislation.gov.ky (revised as at 31 December 2023), 15 February 2024.
- Application of FinCEN’s Regulations to Certain Business Models Involving Convertible Virtual Currencies (FIN-2019-G001). Financial Crimes Enforcement Network (FinCEN), US Department of the Treasury, 9 May 2019.
- Bitcoin Basics (customer brochure). US Commodity Futures Trading Commission, Office of Customer Education and Outreach.
- Amendments to the Virtual Asset (Service Providers) Act in Effect 1 April 2025. Cayman Islands Monetary Authority (CIMA), supervisory circular, 1 April 2025.
- Virtual Currency Business Licensing. New York State Department of Financial Services (read 22 October 2026).
- Address poisoning scams. MetaMask Help Center (read 22 October 2026).
- Regulation (EU) 2023/1114 (MiCA): Articles 143 and 149, transitional measures and dates of application. European Parliament and Council of the European Union, Official Journal L 150, 9 June 2023 (read on EUR-Lex; the original text, not later amendments), 31 May 2023.
- Basel Committee meets to advance supervisory and regulatory initiatives and discuss risks and vulnerabilities to the global banking system. Basel Committee on Banking Supervision, media release, 1 October 2026.
General education built from the publicly available sources listed above. Not financial, legal, tax or investment advice. Naming a company, project or regulator is not an endorsement either way. Last checked 2026-10-22. Terms and disclaimer.