Cross-Border & International Digital Asset Compliance
International compliance for U.S.-based blockchain companies serving users abroad, from MiCA in the EU and the FCA regime in the UK to VASP licensing and the FATF travel rule.
A U.S.-based crypto project serving foreign users faces each market’s rules. Providing crypto-asset services in the EU requires MiCA authorization through an EU-established entity, cryptoasset exchange and custodian wallet businesses carried on in the UK need FCA registration under the Money Laundering Regulations until the new UK regime takes effect, and the FATF travel rule requires VASPs to obtain, hold, and transmit originator and beneficiary information on virtual asset transfers (in the EU, on crypto-asset transfers of any amount).
Industria Business Lawyers advises U.S.-based blockchain companies on international compliance frameworks, including the EU’s Markets in Crypto-Assets Regulation (MiCA), the UK’s FCA cryptoasset regulatory requirements, VASP licensing in Hong Kong, Singapore, and the UAE, cross-border stablecoin distribution under the GENIUS Act’s foreign issuer provisions, and FATF travel rule compliance for cross-border virtual asset transfers. Each framework has its own registration process, compliance requirements, and enforcement mechanisms, and the firm coordinates the U.S. and international compliance strategy to avoid gaps. A consultation is free.
The Frameworks That Apply Abroad
Blockchain projects with international users or operations face regulatory obligations in every jurisdiction where they serve customers.
EU MiCA Compliance
Providing crypto-asset services in the EU requires MiCA authorization through an EU-established entity. Advisory for U.S.-based blockchain projects covers MiCA’s requirements for crypto-asset service providers, token issuers, and issuers of asset-referenced tokens and e-money tokens serving EU markets, including authorization requirements, whitepaper obligations, and ongoing compliance.
UK FCA Cryptoasset Framework
The UK’s new cryptoasset regime, expected to take effect on October 25, 2027, will require FCA authorization for regulated cryptoasset activities, including issuing qualifying stablecoins in the UK. Until then, firms need MLR registration and must follow the cryptoasset financial-promotions rules. Guidance covers FCA registration and compliance requirements for firms providing cryptoasset services to UK customers, including the financial promotions regime and anti-money laundering obligations.
International VASP Licensing
Coordination of VASP registration and licensing in Hong Kong (SFC and AMLO), Singapore (MAS), UAE (VARA and ADGM), and other jurisdictions. Industria Business Lawyers oversees the U.S. regulatory strategy while coordinating with local counsel in each target market.
GENIUS Act Foreign Issuer Compliance
Advisory for non-U.S. stablecoin issuers seeking access to U.S. markets under the GENIUS Act’s foreign issuer provisions (12 U.S.C. 5916), and for U.S. issuers on the rules of each target market when distributing abroad.
FATF Travel Rule Compliance
The FATF travel rule requires VASPs to obtain, hold, and transmit originator and beneficiary information on virtual asset transfers, and whether a minimum amount applies depends on the jurisdiction (the EU applies it to crypto-asset transfers of any amount). Implementation work covers the data-sharing requirements between originating and beneficiary institutions and the technology tools that facilitate compliance.
International AML Coordination
Structuring of AML programs that satisfy requirements across multiple jurisdictions simultaneously, including the intersection of U.S. BSA obligations with EU Anti-Money Laundering Directives and local AML requirements in target markets.
Who This Serves
Cross-border engagements come from digital asset businesses whose users, customers, or distribution reach beyond the United States.
U.S.-based blockchain companies with international user bases. Projects that began in the United States and now serve users in the EU, the UK, or Asia, and need to know which of those markets’ rules their activity reaches.
Stablecoin issuers seeking multi-jurisdictional distribution. Non-U.S. issuers looking to the GENIUS Act’s foreign issuer provisions for access to U.S. markets, and U.S. issuers that must satisfy the rules of each target market when distributing abroad.
Crypto exchanges serving customers in the EU, UK, or Asia. Platforms that need MiCA authorization through an EU-established entity, MLR registration in the UK, or VASP licensing in the Asian markets they serve.
VASP operators needing registration in multiple countries. Operators whose registrations and licenses run in parallel across several jurisdictions, with travel rule obligations on the transfers between them.
Any digital asset business that needs a coordinated strategy. Industria Business Lawyers handles the U.S. regulatory strategy and coordinates with local counsel in target international jurisdictions. This structure is designed to keep the U.S. compliance posture and the international filings consistent, which can be a failure point when companies use separate firms in each jurisdiction without coordination.
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They consistently deliver thorough and timely work. We wholeheartedly recommend IBL.”
Felipe Pinto from Revolve Labs
Client testimonials describe individual experiences. You may not obtain the same or similar results.
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I would recommend working with Aaron and team.”
Julien Genestoux from Unlock, Inc
Client testimonials describe individual experiences. You may not obtain the same or similar results.
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As a result, we’ve continued to rely on them as our go-to legal counsel for ongoing corporate matters.”
Zachary Panos from Fourcaster LLC
Client testimonials describe individual experiences. You may not obtain the same or similar results.
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The attorneys were incredibly responsive, guiding me through every step of the process with clarity and professionalism.
They took the time to address all my questions and concerns, ensuring that I felt confident in each decision we made. Their attention to detail and thoroughness were evident in the documents they prepared, which gave me peace of mind. What stood out most was their commitment to my vision. They not only provided legal advice but also offered valuable insights into the industry, helping me navigate potential challenges and seize opportunities.
Overall, working with IBL was a fantastic experience. They made a complex process manageable and stress-free. Thank you for your outstanding support.”
Jeff from Solar Carbon Credit Fund
Client testimonials describe individual experiences. You may not obtain the same or similar results.
How We Handle a Cross-Border Matter
Where the users and customers are, what services they receive, and which entity serves them.
The project’s U.S. regulatory status and obligations, which anchor the cross-border strategy.
Each target market’s framework identified and applied to the activity carried on there.
Local counsel engaged in each target market and coordinated against the U.S. strategy.
Authorization, registration, and licensing applications prepared and tracked market by market.
AML program and travel rule procedures built to address U.S. BSA obligations and local requirements together.
U.S. token structure and international filings kept consistent as markets, products, and rules change.
FAQ
01 • Projects Serving Users Abroad Does MiCA apply to my U.S.-based crypto project?
Providing crypto-asset services in the EU requires MiCA authorization through an EU-established entity. A non-EU firm cannot serve EU clients from abroad except in narrow reverse-solicitation cases. The national transitional periods ended by July 1, 2026. Industria Business Lawyers assesses MiCA applicability and advises on compliance strategies.
02 • Projects Serving Users Abroad What is the FATF travel rule and does it apply to crypto?
The FATF travel rule requires VASPs to obtain, hold, and transmit originator and beneficiary information on virtual asset transfers, and whether a minimum amount applies depends on the jurisdiction (the EU applies it to crypto-asset transfers of any amount). Most jurisdictions have implemented or are implementing travel rule requirements for crypto transactions. The firm advises on compliance and the technology tools that facilitate information sharing.
03 • Projects Serving Users Abroad Can your firm handle international VASP registrations?
Industria Business Lawyers coordinates international VASP registrations by overseeing the U.S. regulatory strategy and working with local counsel in target jurisdictions including the EU, UK, Singapore, Hong Kong, and the UAE.
04 • Projects Serving Users Abroad How does the GENIUS Act affect cross-border stablecoin distribution?
Once the GENIUS Act takes effect (on the earlier of January 18, 2027 or 120 days after federal regulators issue final implementing rules), its foreign-issuer provisions (12 U.S.C. 5916) set the conditions for non-U.S. issuers’ stablecoins to be offered in the U.S. U.S. issuers distributing abroad must also satisfy the rules of each target market. The firm advises on both inbound and outbound stablecoin compliance.
05 • Projects Serving Users Abroad How do international requirements affect a project’s U.S. structure?
The cross-border work integrates with the firm’s domestic blockchain practice. When international compliance requirements affect the U.S. token structure, the token structure is revisited. When VASP licensing requires AML programs, the firm’s KYC/AML practice builds them to satisfy both U.S. and international standards.
U.S.-based blockchain companies, stablecoin issuers, exchanges, and VASP operators serving users abroad. Call (202) 860-1210 or describe your markets through the form. Free consultation. Every market is assessed under its own framework.
This page provides general information about international digital asset regulation, including MiCA, the UK cryptoasset regime, VASP licensing, the GENIUS Act, and the FATF travel rule, and does not constitute legal advice. Reading it does not create an attorney-client relationship with Industria Business Lawyers. Advice on the law of jurisdictions outside the United States is provided in coordination with local counsel admitted there. Whether a requirement applies depends on the facts and the law in force.