Recap: Quarterly Crypto Policy Roundtable, Q3 2024

Last week, TRM’s team of policy experts—Ari Redbord, Isabella Chase, and Angela Ang—sat down to examine the current state of global crypto regulation, industry trends, and emerging risks. Across Europe, the Middle East, the UK, the US, Australia, and Asia—they explored how jurisdictions are adapting to new anti-money laundering (AML) standards, implementing regulatory frameworks like MiCA in Europe, and strengthening information-sharing partnerships.

Read on for a recap of their discussion—including analysis of the impact of global elections on crypto policy, the nuances of AML frameworks, and increased law enforcement focus on crypto ATMs—or watch the full recording below. 

Global policy review by region

APAC

Angela kicked off the conversation with a range of AML reforms and national money laundering risk assessments in Singapore and Australia, noting that both jurisdictions are working towards enhanced compliance in anticipation of FATF evaluations. For example, Australia is looking to implement the FATF Travel Rule by March 2026.

In understanding the risk assessments, Angela explained the importance of looking not just at the headlines, but the nuances. While both risk assessments highlighted the risk posed by the crypto sector, they also noted this risk had grown as a natural consequence of overall crypto adoption. And, the scale of risk is still not comparable to traditional finance, with Singapore noting that the banking sector still poses the highest money laundering risk to the country.

Angela also discussed regulatory implementation across the region. In Korea, the Virtual Asset User Protection Act went live. Hong Kong progressed on stablecoin regulation, and Singapore rolled out its final tranche of investor protection measures, as well as enhanced licensing guidelines.

Finally, Asia also saw more support for innovation. Japanese conglomerate Sony launched its Soneium blockchain amidst a more innovation-forward tone from lawmakers and regulators, while Thailand has launched a digital asset regulatory sandbox.

UK and EU

Isabella then discussed the implementation of the first half of MiCA (Markets in Crypto Assets Regulation) on July 1. She noted the initial confusion around licensing and compliance due to differing definitions between MiCA and the Payment Services Directive regarding the nature of "funds." Confusion remains on whether stablecoin issuers need both a MiCA authorization and an EMI license.

"We’re seeing Europe take the lead in terms of clear regulation, but bumps remain—particularly around how exchanges should ensure stablecoin issuers have the necessary licensing,” said Isabella. “December’s MiCA deadline for exchanges will further pressure the industry."

She also discussed the Travel Rule implementation, highlighting the EBA’s final guidance, which offered businesses ample time to prepare—in stark contrast to the shorter period given by the UK between the guidance being issued and the rule coming into effect. September 1 marked the end of the UK’s grace period for the Travel Rule, with firms now needing to ensure effective compliance with the rule. 

US

Finally, Ari provided insights into enforcement-driven regulatory activity in the US—in particular, the SEC’s aggressive pursuit of exchanges, and the DOJ’s indictment of Hamas leaders which referenced the use of crypto in terrorism financing. He also discussed the implications of the passage of stablecoin legislation out of the House Financial Services Committee, and its focus on reserve and record-keeping requirements similar to MiCA.

"We’re seeing the US still grapple with ‘who will regulate,’ rather than focusing on how to regulate,” Ari said. “Enforcement remains the primary tool, as we saw with the SEC’s record-breaking USD 4.47 billion settlement with Terraform Labs."

Key emerging themes and industry initiatives

Ari, Isabella, and Angela noted several key emerging trends and public-private initiatives currently shaping the crypto policy landscape for regulators, businesses, and law enforcement to be aware of.

Stablecoins

Stablecoins are becoming the subject of increased regulation around the world—with MiCA in the EU, stablecoin-focused legislation in the US, and a new regulatory regime in the UAE.

Isabella explained, "Stablecoins are being addressed globally. Europe is focused on regulation—but issues like sanctions evasion using crypto in Russia and other regions complicate this regulatory landscape. The UAE’s requirement for Dirham-backed stablecoins is another step forward in regulatory clarity."

Crypto ATMs

Crypto ATMs were identified as a growing risk area in both Australia and Germany. A recent TRM report highlighted that illicit activity via ATMs is about double that of the broader crypto ecosystem. 

Angela noted that Australia had become the world’s third largest market for crypto ATMs, driven in part by the entry of a number of North American ATM operators. Unsurprisingly, ATMs were therefore identified as an “emerging vulnerability” in the national money laundering risk assessment, especially in light of the additional risk they faced from the use of cash. 

In Germany, the BKA took a significant enforcement action against operators of illegal ATMs operating in the country. They seized 13 machines and nearly EUR 250,000. UK authorities had similar success this quarter, making their first successful charge against the operator of an illegal crypto ATM. 

Information sharing

Next, Ari noted the importance of strong public-private partnerships in building stronger, more secure financial systems—a principle underscoring TRM’s efforts around the new T3 Financial Crime Unit (FCU). This initiative—a collaboration between TRM, Tether, and Tron—was introduced to improve information sharing between the private sector, working closely with law enforcement to interdict the proceeds of illicit transactions.

In the few months since it was launched, the T3 FCU has already shown significant results, having recovered millions of illicitly gained crypto funds.

"T3 is a great example of information sharing combating illicit crypto activity,” Ari explained. “We’re already seeing tremendous success, and it will become even more crucial as regulations tighten globally."

Elections

Finally, the panel briefly touched on a topic that will be a primary focus for American and EU citizens and businesses as we move into the last few months of the year: the impact of elections worldwide on crypto policy.

"The US presidential election in 2024 is likely to shape the regulatory landscape significantly. Crypto could become a key issue, with both parties taking interest—although we’ve yet to see major policy proposals from the candidates," said Ari. Isabella added, "In Europe, we are now seeing the consequences of post-election government reshuffles, which may impact the speed of the next phase of crypto policy."

Looking ahead: Collaboration and compliance

The TRM policy team rounded out the conversation by emphasizing the importance of continued collaboration between regulators and the private sector—especially as more jurisdictions move towards implementing stricter compliance standards for crypto. The global regulatory landscape is evolving rapidly, and organizations must adapt to keep up with the changes.

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