Light-Touch vs Heavy Oversight: The US–UK Divide on Digital Assets 

  

Eric Trump’s bold claim last week that cryptocurrencies could “save the US dollar” shows how radically different the United States and the United Kingdom are approaching digital assets. Speaking to the Financial Times, Trump argued that booming demand for bitcoin and stablecoins would funnel “trillions” of capital from weaker currencies into America, strengthening the country’s role as the world’s financial centre. His message, delivered after Nasdaq celebrated the listing of American Bitcoin, a company in which he has a $500mn stake, reflects a distinctly US narrative: crypto as a strategic advantage, a geopolitical tool, and potentially a lifeline for the dollar.

UK Approach

By contrast, the UK’s approach looks far more restrained. The Financial Conduct Authority’s latest consultation paper, CP 25-25, outlines sweeping proposals to integrate cryptoassets into the country’s existing financial regulatory system. Following the powers established by the Financial Services and Markets Act 2023, the FCA is seeking to bring crypto explicitly within established safeguards, requiring issuers to disclose information to investors, subjecting markets to rules against abuse, and ensuring consumers face clear risk warnings before trading. Stablecoins will be treated as regulated payment instruments under joint oversight from the FCA and the Bank of England. Far from promoting crypto as an engine of monetary power, the UK sees potential hazards to market integrity, consumer welfare, and financial stability. 

US Stance

This divergence highlights the competing political and economic contexts shaping policy. In the US, the Trump administration has cultivated an aggressively pro-crypto stance, encouraging innovation and embracing digital assets as part of a larger deregulatory economic vision. The White House hopes that stablecoins, such as those issued by Circle and Tether, will become major buyers of US Treasuries, supporting massive government borrowing needs, while simultaneously embedding dollar dominance in the global system. The first Congressional legislation on stablecoins, passed earlier this year, marks a tentative step toward clarity, but overall oversight remains fragmented across the SEC, CFTC, and state regulators. Innovation and capital attraction, rather than consumer safeguards, are the priority. 

The Trump Family and Stablecoins  

Eric Trump’s rhetoric embodies this entrepreneurial spirit. He cast crypto ventures like World Liberty Financial, which issues the USD1 stablecoin, as an “ultimate revenge” against Wall Street and big banks, praising the independence of building digital currency infrastructure outside traditional financial institutions. The Trump family has tied itself closely to the sector, from Bitcoin ETFs to memecoins, leveraging celebrity and politics to cement America’s branding as the “crypto capital” of the world. 

The UK Framework  

In contrast, CP 25-25 underscores Britain’s determination not to let crypto stray outside the bounds of established financial rules. The UK framework resembles the European Union’s MiCA regulation, reflecting an emphasis on aligning international standards and ensuring the same protections apply whether customers hold shares, bonds, or tokens. The FCA makes clear that crypto should not receive special treatment but should operate under obligations familiar to traditional asset classes. 

The result is a widening regulatory divergence. Washington presents itself as a magnet for global crypto flows, willing to tolerate volatility and risk in service of dollar primacy. London, however,seeks to elevate its reputation as a responsible hub, prioritising investor protection and financial stability even at the cost of deterring speculative capital.  

For businesses and investors, the contrasting approaches pose a strategic choice: should digital finance grow within a tightly defined regulatory perimeter, as in the UK, or flourish under lighter-touch and politically motivated encouragement, as in the US? 

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