Leading in a Future Economy Project — Global Regulatory Frameworks for Digital Assets: Comparative Analysis and Potential International Cooperation

This paper provides a comparative analysis of global regulatory frameworks governing digital assets, emphasizing legal definitions, classifications, and jurisdictional approaches. Digital assets—defined as cryptographically secured digital representations of value—are categorized into cryptocurrencies, utility tokens, security tokens, stablecoins, NFTs, and CBDCs. The study examines regulatory regimes in the United States, European Union, Hong Kong SAR (China), Japan, and Singapore, highlighting varying degrees of regulatory fragmentation, harmonization, and innovation support. Key regulatory goals include transparency, fraud prevention, AML/KYC compliance, consumer protection, and international coordination. The paper concludes with policy recommendations aimed at enhancing global cooperation, regulatory clarity, and consumer education, while acknowledging challenges such as jurisdictional divergence and resource limitations in developing nations.