Our authors are experts in their field and include barristers, solicitors, judges, mediators, academics experts from a range of related disciplines.

Yasmin Frischemeier

Trainee Solicitor
Yasmin Frischemeier is a trainee solicitor at Cleary Gottlieb Steen & Hamilton LLP. Email: yfrischemeier@cgsh.com

Articles by author

Mind the gap: UK stablecoin rules create uncertainty

The UK government’s recent decision not to proceed at this time with extending the payment services regulatory framework to fiat-referencing stablecoins marks a significant policy reversal. The previous government’s phased approach offered time and flexibility to address difficult boundary questions and ensure coherent treatment aligned with economic function. By collapsing regulation of cryptoassets into a single legislative phase for both fiat-referencing stablecoins and other cryptoassets, the current Draft Order risks a lack of functional differentiation between payment instruments and investment assets, as well as territorial ambiguity. This article explores the UK’s shift in approach, highlighting points of interpretive uncertainty and divergence from developments in the US.

28 JUL 2025

Cryptoasset regulation: a comparative analysis of UK and EU regimes

This article provides a comparative analysis of the regulatory approaches to cryptoassets in the UK and the EU, focusing on the UK’s recently proposed Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025 (UK Draft Order)1 and the EU’s Regulation 2023/1114 on Markets in Crypto-Assets (MiCAR). The article examines key differences in the approach, definition and categorisation of cryptoassets, scope of regulated activities, and the territorial application of each regime, concluding with a discussion of future outlook and regulatory ‘blind spots’ in each jurisdiction.

9 JUN 2025