A Four-Dimensional Analysis of Cryptocurrency Licensing Regime Evolution in the US, EU, and China (2020-2025)

Abstract

Between 2020 and 2025, systemic risk events such as the FTX collapse and Terra/Luna crisis accelerated cryptocurrency regulatory legislation across jurisdictions, with licensing regimes emerging as the core regulatory instrument, yet existing research broadly discusses regulatory policies without focused attention on licensing regimes and neglects the dynamic dimension of institutional evolution. This study examines the United States, European Union, and China as research subjects, adopting a multi-jurisdictional descriptive approach to construct a four-dimensional analytical framework comprising regulatory authorities, market access thresholds, ongoing obligations, and enforcement mechanisms, tracing the evolutionary trajectories of licensing regimes in each jurisdiction based on primary legal texts from public legal databases. The findings reveal that the United States exhibits a "fragmentation toward incremental consolidation" pathway, the European Union achieved a "fragmentation toward unified framework" transformation, and China completed a unidirectional intensification of "restriction toward comprehensive prohibition," with each jurisdiction's pathway reflecting its own regulatory priorities and institutional context. The contribution of this study lies in providing a methodological reference for multi-jurisdictional fintech regulatory research through the four-dimensional framework, while offering pathway references for regulatory institutional design in emerging market economies.