International Finance
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The great crypto reckoning

Crypto reckoning
The European Union fully implemented its Markets in Crypto-Assets regulation in late 2024 and throughout 2025

The year 2025 has proven to be a watershed moment for the digital asset ecosystem, characterised by a complex interplay between unprecedented institutional integration and the enduring volatility inherent to nascent asset classes. International Finance will provide a detailed analysis of the sector’s performance, shaped by three key developments.

These include the total cryptocurrency market capitalisation surpassing the $4 trillion threshold, the enactment of the GENIUS Act, which established the first comprehensive federal regulatory framework for stablecoins in the United States, and a parabolic price trajectory for Bitcoin that saw it breach new all-time highs before succumbing to a macro-induced correction in November.

While the breach of the $4 trillion mark signalled a structural re-rating of the asset class and placed it on par with major global equity exchanges, market dynamics revealed a bifurcation between asset performance and infrastructure growth.

Bitcoin’s ascent to a peak of approximately $126,000 was fuelled by the “Trump trade” and massive ETF inflows, yet its subsequent 30% correction underscored the market’s continued sensitivity to macroeconomic shocks, specifically stagflationary signals from the US labour market. Conversely, the stablecoin sector, now buttressed by federal law, decoupled from speculative volatility to process transaction volumes rivalling global payment networks like Visa, which confirms its utility as a settlement layer for the digital economy.

We dissect these trends through six core sections, including a detailed analysis of legislative reform. By synthesising data on regulatory shifts and on-chain metrics, we offer a nuanced perspective on how the industry has transitioned from a speculative fringe to a regulated, albeit volatile component of the global financial architecture.

Welcome to the big leagues

In July 2025, the digital asset sector achieved a historic valuation milestone as the total market capitalisation surpassed $4 trillion for the first time. The event was not merely a psychological victory for early adopters but a quantitative signal of the asset class’s integration into the broader financial system. To contextualise this growth, the market cap effectively doubled from its previous cycle highs, driven by a confluence of retail resurgence and institutional capital deployment.

The ascent to $4 trillion was underpinned by distinct structural factors that differentiate this cycle from the speculative manias of 2017 and 2021. Foremost among these was the deepening of liquidity pools facilitated by the approval of spot ETFs across multiple jurisdictions.

The “ETF wrapper” served as a critical conduit for wealth management platforms and pension funds to allocate capital without the operational burden of custody, effectively unlocking trillions in previously sidelined capital.

Data from the third quarter of 2025 indicates that the rally was supported by extensive institutional demand, which was further catalysed by legislative advancements in the United States. The market did not rise in a vacuum; rather, it was buoyed by a “pro-crypto” administration and a tangible shift in regulatory posture. The correlation between legislative clarity and capital inflows became undeniable, as evidenced by the sharp uptick in valuations following the passage of the GENIUS Act.

However, the composition of this market capitalisation reveals a significant evolution in capital allocation. While Bitcoin retained its dominance as the primary store of value and accounted for over $2.4 trillion of the total market cap at its peak, the 2025 cycle witnessed a broadening of the value spectrum. Capital rotated aggressively into programmable blockchains and stablecoins, reflecting a market that increasingly values utility and yield over pure speculation.

The psychological impact of crossing the $4 trillion mark forced a reassessment of risk models among global macro strategists. At this scale, the asset class becomes too large to ignore for sovereign wealth funds and endowment managers who must now consider digital assets as a necessary component of a diversified portfolio to hedge against debasement and capture technological alpha. Industry analysts noted that crossing this mark signals a “structural re-rating” of crypto, moving it from an asymmetric bet to a staple allocation.

The market demonstrated resilience by holding above the $3.88 trillion level during periods of consolidation, dipping only approximately 2% from peak levels during initial profit-taking phases. Such consolidations are characteristic of maturing markets where rapid appreciation is digested through time rather than deep price corrections. The ability of the market to sustain valuations above the $4 trillion line for extended periods in mid-2025 suggested that the capital base had shifted from highly leveraged retail traders to “sticky” institutional holders with longer time horizons.

As liquidity deepened, it also fragmented across a growing number of venues and chains. Layer 1 has seen good growth, but introducing Layer 2 solutions on top of it means that execution and infrastructure have become as critical as asset selection. And experts reiterate that sustaining this growth would require resilient systems that are adept at handling high-frequency institutional flows and smart risk frameworks to manage the disparate liquidity pockets.
Uncle Sam legalises digital dollar

If the $4 trillion market cap was the quantitative highlight of 2025, the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 (GENIUS Act) was its qualitative cornerstone. Signed into law by President Donald Trump on July 18, 2025, this bipartisan legislation ended years of regulatory purgatory for the digital asset industry. It established a comprehensive federal framework for payment stablecoins, effectively legitimising the sector’s most practical application, which is dollar-denominated digital settlement.

The GENIUS Act is transformative primarily because of its definitional clarity and establishment of a dual-track regulatory system. It amends US federal securities laws and the Commodity Exchange Act (CEA) to explicitly state that a payment stablecoin is not a “security” or a “commodity”. This jurisdictional carve-out is the “holy grail” for issuers who have spent years navigating the aggressive enforcement actions of the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC).

Instead of shoehorning stablecoins into 1930s securities laws, the Act places them under the supervision of banking regulators through two distinct pathways. One through the Federal Track for Non-Banks. Federally licensed non-bank stablecoin issuers are now subject to oversight by the Office of the Comptroller of the Currency (OCC). This allows fintech companies to operate with a national charter without becoming full-fledged banks. Secondly, there are subsidiaries of insured depository institutions that fall under the supervision of their primary federal regulator, such as the Federal Reserve or the FDIC.

Crucially, the Act also preserves the state regulatory system. Issuers with less than $10 billion in outstanding stablecoins can opt for regulation under a state-level regime provided that the state’s standards are deemed “substantially similar” to the federal framework. That provision was a major victory for state regulators like the NYDFS, ensuring that local innovation hubs are not crushed by federal preemption while still maintaining a high national standard.

A central pillar of the GENIUS Act is the imposition of strict prudential standards designed to prevent the “bank runs” that plagued the sector in previous cycles. As per the legislation, all stablecoin issuers must maintain 1:1 reserves backed by high-quality liquid assets (HQLA).

The prohibition on rehypothecation is particularly significant as it prevents the specific type of leverage-driven contagion that caused the collapse of algorithmic stablecoins and unregulated lending desks in 2022. By mandating that reserves be held in bankruptcy-remote accounts with priority claims for holders, the Act effectively creates a digital equivalent of cash that is safer than uninsured bank deposits.

One of the most debated aspects of the GENIUS Act was the prohibition on interest payments. Issuers are explicitly forbidden from passing the yield generated by their reserve assets (such as Treasury bills) on to the holders of the stablecoins. That provision was the subject of intense advocacy from the traditional banking lobby, including the American Bankers Association.

They argued that if stablecoins offered a risk-free yield comparable to Treasuries, they would suck liquidity out of the traditional banking system and destabilise community banks that rely on low-cost deposits.

For the crypto industry, this creates a clear business model trade-off. While issuers cannot compete on yield, they are forced to compete on utility, speed, and integration. This has pushed issuers to focus on building payment rails and merchant networks rather than simply marketing their tokens as savings vehicles.

The GENIUS Act also integrates stablecoins into the national security apparatus. Issuers are explicitly subject to the Bank Secrecy Act (BSA), obligating them to implement rigorous Anti-Money Laundering (AML) and Know Your Customer (KYC) programmes.

The Act grants the Treasury Department enhanced powers to combat illicit finance, including requirements for issuers to possess the technical capability to “seize, freeze, or burn” tokens when legally ordered. That provision addresses the “sanctions evasion” narrative often used by critics, ensuring that compliant stablecoins cannot be used as a tool for rogue states or criminal enterprises.

Issuers are also forbidden from using “deceptive names” or marketing materials that imply their product is backed by the “full faith and credit of the United States” or covered by federal deposit insurance. Such rules prevent the dangerous misconception that a private stablecoin is a government-guaranteed instrument.

Wall Street’s effect on Bitcoin

The year 2025 reinforced a fundamental truth about Bitcoin. It remains a highly sensitive liquidity gauge capable of delivering parabolic returns and devastating corrections in equal measure.

The narrative of “institutional maturation” did not dampen volatility; rather, it introduced new transmission mechanisms for macro shocks to cascade through the market.

Bitcoin’s performance in the first three quarters of 2025 was nothing short of spectacular. Fuelled by the “Trump trade” following the election, favourable regulatory signals and the relentless bid from spot ETFs, Bitcoin embarked on a parabolic run. By October, the asset had breached the six-figure mark, setting a new all-time high of approximately $126,270. The rally was characterised by a palpable sense of euphoria dubbed “Uptober” as market participants anticipated a “super-cycle” driven by the convergence of sovereign adoption and corporate treasury accumulation.

The role of ETFs in this rally cannot be overstated. BlackRock’s iShares Bitcoin Trust (IBIT) alone amassed massive assets under management by 2025, with the fund becoming the most successful ETF launch in history. The “passive bid” from these products created a constant demand shock that stripped supply from exchanges, forcing prices upward in a classic liquidity squeeze.

The euphoria came to an abrupt halt in November. Bitcoin crashed approximately 30% from its peak, sliding to trade near $82,605 on November 21. The correction wiped out over $1.2 trillion in total digital asset value in just six weeks, a destruction of wealth equivalent to the GDP of a mid-sized G7 nation.

The catalyst for the crash was a “stagflationary” shock delivered by the US labour market. A long-delayed US jobs report released confusing data that showed job creation rebounding while the unemployment rate simultaneously climbed to 4.4%. The mixed signal clouded expectations for Federal Reserve rate cuts, triggering a “risk-off” event across all global markets.

The crash revealed the double-edged sword of institutionalisation. While ETFs provided inflows during the rally, they also provided a frictionless exit door during the panic. United States-listed Bitcoin ETFs recorded $903 million in outflows on a single Thursday as the “paper hands” of the new cohort folded at the first sign of trouble.

When code became cash

Bitcoin dominated the macro narrative of 2025 and has matured as an asset class with store-of-value propositions. But the focus is slowly shifting to high-throughput utility, and all eyes are on alt-coins. The “State of Crypto” report highlighted that Hyperliquid and Solana combined to account for 53% of revenue-generating economic activity, signalling a changing of the guard in where value is actually accrued.

Solana emerged as the undisputed leader of the high-performance blockchain sector. In stark contrast to the broader market, Solana’s ecosystem metrics exploded to the upside. Builder interest increased by 78% over the prior two years, making it the fastest-growing ecosystem for developers. That surge in developer activity translated directly into user adoption, with the network processing a significant plurality of the industry’s transaction volume.

The market acknowledged this differentiation. Even during the November crash, Solana-based investment products showed remarkable resilience. While Bitcoin ETFs bled assets, Solana and XRP ETFs recorded consistent inflows, suggesting that investors were actively decoupling their views on “utility” tokens from the macro-driven Bitcoin trade.

If there was one undeniable success story in 2025, it was stablecoins. The total stablecoin supply reached a record high of over $300 billion. More impressively, stablecoins settled $46 trillion in total transaction volume over the year. Even after adjusting for artificial trading volume, the figure stood at $9 trillion, more than five times PayPal’s annual throughput and more than half of Visa’s.

The data proves that stablecoins have found product-market fit beyond crypto trading. They are being used for cross-border B2B payments and remittances in inflation-stricken nations, and as a dollarised savings instrument globally. The GENIUS Act further catalysed this usage by providing the legal certainty needed for banks and multinational corporations to integrate stablecoins into their treasury operations, effectively turning them into a new rail for global commerce.

Patchwork of progress and pain

While the GENIUS Act provided a unified path for the United States, the rest of the world navigated a fragmented and often contradictory regulatory landscape in 2025. The divergence created significant friction for cross-border projects and forced issuers to adopt regional containment strategies rather than global expansion plans.

The European Union (EU) fully implemented its Markets in Crypto-Assets (MiCA) regulation in late 2024 and throughout 2025. While initially hailed as a pioneering framework, MiCA has revealed the steep cost of compliance. Startups faced immense operational burdens to meet prudential and conduct standards, which diverted resources away from innovation. The stablecoin market in Europe faced a specific crisis of relevance. US dollar-denominated tokens continued to hold a 99% market share globally, leaving Euro-denominated stablecoins on the fringes with a market capitalisation of less than EUR 350 million.

In response to this dominance, a consortium of nine major European banks, including ING and Deutsche Bank, formed a new venture in September 2025. Their goal is to launch a fully MiCA-compliant Euro stablecoin to compete with American giants. However, analysts warn that Europe may be “too late” as the network effects of USD stablecoins are already deeply entrenched in global DeFi and payment rails.

In Asia, the regulatory narrative is split between two primary hubs. Hong Kong moved aggressively to capture the digital asset market by enacting the Stablecoin Ordinance, which became effective on August 1 2025. The law introduced a dedicated licensing regime for fiat-referenced stablecoins and required issuers to maintain full reserve backing with high-quality liquid assets. In parallel, regulators proposed new licensing regimes for OTC dealers and custodians to close remaining oversight gaps.

Singapore took a more restrictive approach to offshore risks. The Monetary Authority of Singapore (MAS) enforced a strict deadline of June 30 2025, for Digital Token Service Providers (DTSPs). Any entity providing services from Singapore to customers outside the country was required to obtain a license or cease operations. The move was designed to prevent regulatory arbitrage where firms would set up in Singapore solely to project an image of legitimacy while serving high-risk jurisdictions without local oversight.

Emerging markets continued to drive grassroots adoption, often outpacing regulatory frameworks. Brazil emerged as a leader by establishing a Central Authority for Digital Assets (CADA) in January 2025 and implementing a comprehensive licensing framework that will be fully enforceable by February 2026. The clarity helped boost daily trading volumes in Brazil to USD 1.8 billion.

Nigeria also witnessed a surge in activity after lifting its banking ban on crypto firms. Monthly trading volumes on licensed exchanges rose by 47% in the first quarter of 2025 alone. India similarly saw a recovery in volumes after the initial shock of its tax regime wore off, with the government launching a “Regulatory Sandbox 2.0” to explore tokenised real estate and carbon credits. Together, these developments signal a decisive shift from the “ban and ignore” policies of the past to a “regulate and tax” approach.

The starkest challenge of 2025 remains the lack of global harmonisation. The GENIUS Act in the US and MiCA in the EU operate on fundamentally different principles regarding foreign issuers. The GENIUS Act encourages the US Treasury to pursue mutual recognition, but currently requires foreign issuers to meet US standards to access the American market.

Conversely, MiCA’s strict localisation requirements have forced some global exchanges to delist non-compliant stablecoins for European users. Such a regulatory “spaghetti bowl” threatens to balkanise liquidity and complicate the dream of a seamless global value-transfer layer.

As we look toward 2026, the trajectory is clear. The infrastructure is ready for prime time, and the regulatory wars are largely over, yet the challenge now shifts from survival to scale in a high-stakes macroeconomic environment.

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