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| Dimension |
Pinned 🇯🇵 Japan partly open Verified 2026-08-15
|
🇺🇸 United States
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Crypto-Asset Exchange Service Provider (CAESP) registration with the Prime Minister (delegated to the FSA), under Article 63-2 of the Payment Services Act (PSA). Crypto derivatives trading is separately regulated as a Type I Financial Instruments Business under the Financial Instruments and Exchange Act (FIEA). A parallel intermediary-only registration category was introduced by the 2025 PSA/LPAI amendments. | No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement. |
| Regulator | Financial Services Agency of Japan (FSA / JFSA), registration authority, acting via the Prime Minister's delegated power and Local Finance Bureaus. The Japan Virtual and Crypto-assets Exchange Association (JVCEA) is the FSA-certified self-regulatory organisation that runs mandatory token-listing screening and conduct rules; JVCEA membership is the de facto baseline for registration even though not a strict legal requirement. | No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act. |
| Capital requirement | Japan capital requirement is included in the £349 pass. | United States capital requirement is included in the £349 pass. |
| Timeline to authorisation | Japan timeline to authorisation is included in the £349 pass. | United States timeline to authorisation is included in the £349 pass. |
| Local substance | Japan local substance is included in the £349 pass. | United States local substance is included in the £349 pass. |
| Application cost | Japan application cost is included in the £349 pass. | United States application cost is included in the £349 pass. |
| Ongoing cost | Japan ongoing cost is included in the £349 pass. | United States ongoing cost is included in the £349 pass. |
| Passporting | Japan passporting is included in the £349 pass. | United States passporting is included in the £349 pass. |
| MiCA CASPs approved | Japan mica casps approved is included in the £349 pass. | United States mica casps approved is included in the £349 pass. |
| Key restrictions | Japan key restrictions is included in the £349 pass. | United States key restrictions is included in the £349 pass. |
| Recent changes | The FIEA and Payment Services Act amendment was promulgated on 23 July 2026. The first tranche, raising penalties for unregistered business and expanding SESC investigative powers, took effect on 12 August 2026. The core crypto-to-FIEA reclassification takes effect within one year of promulgation on a day to be fixed by cabinet order, so the exact date remains pending and cannot be later than 23 July 2027. | The GENIUS Act's 18 July 2026 deadline for federal implementing rules passed with no agency having finalised a rule: the OCC, FDIC, NCUA and Treasury (with FinCEN and OFAC) have issued proposed rules since December 2025, the Federal Reserve joined a five-agency customer identification proposal on 18 June 2026, and on 27 July 2026 the OCC sought approval for stablecoin issuer application forms (comments due 25 September 2026). The Act sets no penalty for the missed deadline; it takes effect on the earlier of 18 January 2027 or 120 days after final rules. The CLARITY Act remains stalled in the Senate: reported by the Banking Committee on 1 June 2026 with a substitute amendment, no cloture motion filed and no floor vote expected before the August recess; Senate Republicans circulated revised negotiating text on 22 July 2026. The SEC's three planned crypto rulemakings (token issuance safe harbour, broker-dealer capital and custody amendments, market structure) remained unpublished as of late July 2026. |
| Difficulty rating | Japan difficulty rating is included in the £349 pass. | United States difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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