2025 Review: From MiCA Cleaning Stablecoins, AI Breaking KYC to the Year of RWA, the Complete History of the Birth of a New Crypto Order

Author: trustin

Part 1: Timeline Review — The Establishment of Order

January: MiCA Fully Enforced, European Market Completes “Quality Upgrade”

• **【Event】**The EU’s Markets in Crypto-Assets Regulation (MiCA) officially comes into force, regulating electronic money tokens (EMT) and asset-referenced tokens (ART). The European Banking Authority (EBA) has phased out more than 15 unlicensed algorithmic stablecoins and offshore USD stablecoins.
• **【In-Depth Analysis】**This marks the world’s first major economy to complete a “big cleanup” of the stablecoin market. Algorithmic stablecoins’ historical mission in compliant markets is essentially over. The market logic shifts from “efficiency first” to “solvency first.” This also forces global exchanges to upgrade their token listing review mechanisms—without real-time reserve proof (PoR) and clear legal entities, these assets will lose eligibility to enter European liquidity pools.

February: Hong Kong Sandbox Acceptance, Custody Rules “Penetration”

• **【Event】**Hong Kong Monetary Authority (HKMA) completes sandbox testing for fiat-backed stablecoin issuers, with the first batch of institutions receiving preliminary approval. The released “Custody Guidelines” mandate licensed institutions to implement “Customer Asset Segregation” and have daily on-chain reconciliation capabilities.
• **【In-Depth Analysis】**Hong Kong’s regulation has evolved into a “granular management” stage. Simply storing funds in cold wallets is no longer enough; regulators now require “auditable real-time” capabilities. This marks a shift in Asia-Pacific compliance focus from “access” to “ongoing supervision.” Automated on-chain auditing tools are beginning to replace manual audits, becoming a necessity for licensed institutions.

March: AI Breaks KYC Defense, Lazarus Organization Resurges

• **【Event】**According to on-chain security data, North Korean hacker group (Lazarus Group) has seen a surge in activity this month. Unlike previous code vulnerability exploits, this round heavily uses Deepfake (Deepfake) technology to bypass video KYC verification at multiple secondary exchanges.
• **【In-Depth Analysis】**This is an extremely dangerous signal: Traditional KYC (Identity Verification) is failing. When “identity” can be perfectly forged by AI, the risk control anchor must shift. The industry is forced to move from “static identity verification” to “dynamic behavioral analysis (Behavioral KYT).” Only through the historical interaction trajectories and fund linkage on-chain can AI agents disguised as legitimate be identified.

April: Global Privacy Coin “Retreat”

• **【Event】**Under FATF pressure, Dubai VARA, Japan FSA, and Korea KoFIU simultaneously tighten policies, requiring exchanges to delist tokens with enhanced anonymity features (AEC) (such as XMR, ZEC).
• **【In-Depth Analysis】**This is a declaration of the regulatory bottom line for “on-chain transparency.” Liquidity is pragmatic; when privacy coins cannot meet AML (Anti-Money Laundering) penetration requirements, they are abandoned by mainstream capital markets. “Traceability” officially becomes one of the core factors in asset pricing—funds that cannot be tracked are considered “toxic assets” by 2025.

May: DeFi Front-End Regulatory Precedent Established

• **【Event】**U.S. regulators win a lawsuit against a decentralized exchange (DEX) front-end operator. The court rules that entities operating the front-end interface are obliged to prevent access from sanctioned addresses.
• 【In-Depth Analysis】“Decentralized” is no longer a shield to evade regulation. This directly spurs the rise of Permissioned DeFi (Permissioned DeFi). Mainstream DeFi protocols begin integrating third-party wallet screening APIs, completing risk scans at the moment users connect their wallets. Non-compliant addresses are barred from entering the protocol.

June: G7 Summit Focuses on P2P Underground Networks

• **【Event】**The G7 finance ministers’ communiqué specifically mentions underground money laundering and cross-border illegal payments using USDT, calling for enhanced penetration regulation of OTC (Over-the-Counter) markets.
• **【In-Depth Analysis】**This means regulatory fire has reached the “fund inflow/outflow” stage. For OTC traders and P2P platforms, KYC alone is no longer sufficient; they must have fund source tracing capabilities. OTC traders unable to prove the “cleanliness” of funds face large-scale bank account freezes.

Part 2: Timeline Review — The Breakthrough in Legislation

July: US “Payment Stablecoin Act” Establishes Entry

• **【Event】**The U.S. House of Representatives passes the “2025 Payment Stablecoin Clarity Act.” The bill breaks the tradition that only banks can issue currency, allowing non-bank entities to issue payment stablecoins if they meet 1:1 high-quality liquid asset reserves, bankruptcy isolation, and monthly independent audits.
• **【In-Depth Analysis】**The U.S. finally enters the game. The bill establishes the legal status of dollar stablecoins as an extension of the “digital dollar.” For issuers, the core of competition shifts from “yield” to “transparency.” Whether a Wall Street giant or a small issuer, as long as they can provide transparent audit reports, they gain equal access.

August: Chain Reaction of OFAC Sanctions List

• **【Event】**U.S. OFAC intensifies sanctions on addresses related to Russia and Iran, and for the first time sanctions several “middleware service providers” and “mixing nodes” that support sanctioned entities.
• **【In-Depth Analysis】**Long-arm jurisdiction extends to infrastructure. This causes a serious “contamination spread” effect—if funds from an ordinary user pass through a sanctioned node, their address may be flagged as high risk by centralized exchanges. This imposes high demands on on-chain risk control systems: they must have Multi-hop Analysis (Multi-hop Analysis) capabilities to avoid false positives and missed detections.

September: Latin America Tax Storm

• **【Event】**Brazil’s central bank, in cooperation with tax authorities, launches a special crackdown on crypto tax evasion, requiring all VASP (Virtual Asset Service Providers) to report the final beneficiary information of each cross-border transfer.
• **【In-Depth Analysis】**Regulatory focus in emerging markets differs from Europe and America; they pay more attention to capital controls and taxation. For payment companies serving these regions, the core compliance challenge is “how to quickly generate transaction reports that meet local tax standards.”

October: Russia Establishes “Foreign Currency Asset” Attribute

• **【Event】**Russia officially legislates cryptocurrencies as “foreign currency assets.” Cross-border trade settlement is allowed within a regulatory sandbox, but domestic payments are strictly prohibited, with strict transaction limits for intermediaries.
• **【In-Depth Analysis】**This is a milestone qualitative change. It separates crypto assets from “payment tools” and formalizes them as “financial commodities.” This “assetization and de-payment” model could become the mainstream paradigm among BRICS countries. For intermediaries, this means establishing a KYT system capable of intercepting payment flows and only releasing transaction flows.

November: CARF Framework Launch, Global Tax Transparency

• **【Event】**OECD-led crypto asset reporting framework (CARF) begins first-round data exchange testing across 48 jurisdictions.
• **【In-Depth Analysis】**This completes the last piece of the compliance puzzle. As exchange data connects with tax authorities worldwide, the era of “concealed assets” is over. High-net-worth individuals and institutions will see a surge in compliance cleanup and audits of historical assets in the coming year.

December: Final Battle and New Order

This month’s intensive major events mark the end of 2025 and point toward the direction of 2026.

• December 5: Italy’s MiCA Deadline

• Event: Italian regulators issue a final ultimatum, requiring all VASP to apply for MiCA licenses by December 30, or shut down operations and return assets.
• Analysis: The era of simple “registration” ends, and the strict “authorization” era begins. Small and medium exchanges lacking compliance capacity face forced exit.

• December 9: U.S. SEC Regulatory Shift

• Event: New SEC Chair Paul Atkins announces the launch of “Project Crypto” and plans to introduce “Innovation Exemption (Innovation Exemption)” in early 2026.
• Analysis: This is the biggest positive turnaround of the year. The U.S. shifts from “defensive enforcement” to “competitive regulation.” Compliant projects will gain valuable “regulatory sandbox” periods.

• December 15: UK Establishes “Digital Asset Property Law”

• Event: The UK passes the “2025 Property (Digital Assets, etc.) Act,” legally recognizing digital assets as “property,” and announces a complete regulatory framework by 2027.
• Analysis: Establishing “property attributes” is the legal foundation for institutional capital entry, greatly benefiting RWA (Real-World Assets) issuance under UK jurisdiction.

• December 22: Ghana Legalizes and “Gold Stablecoin”

• Event: Ghana legalizes crypto trading via legislation and announces exploration of “Gold-backed Stablecoin” in 2026.
• Analysis: African countries are skipping traditional banking, using RWA tokenization to reconstruct national credit and trade settlement systems. This creates a huge market space for regional compliance infrastructure.

Part 3: In-Depth Topic — RWA, Tokenization, and the New Paradigm of Stablecoins

In the second half of 2025, with regulatory frameworks clarified, Tokenization (Tokenization) and Stablecoins (Stablecoins) have become the eye of the compliance storm. This is not just a change in asset form but a reconstruction of legal rights confirmation and risk control.

Tokenization (Tokenization) — The Compliance Paradox and Its Solution

2025 is called the “RWA Year.” From BlackRock’s tokenized government bond fund to Hong Kong Monetary Authority-led Ensemble project, hundreds of billions of dollars of traditional assets are flowing onto the chain. However, this also introduces a core compliance paradox: The conflict between blockchain’s “permissionless liquidity” and the “conditional rights confirmation” of real assets.

If a tokenized US Treasury flows to a North Korean address sanctioned by OFAC, how is it legally enforced? This is the core question regulators will pose to issuers in 2025.

Compliance Evolution:

1. Proliferation of ERC-3643 and other compliance standards: The industry begins large-scale adoption of token standards embedded with compliance logic. These standards require that each transfer function call first queries a on-chain identity registry. Only if the recipient passes KYC/KYT verification will the transfer succeed.
2. Secondary market “Walled Garden”: RWA assets no longer pursue full network liquidity but are limited to “whitelist liquidity pools.” Trustin observes that more RWA issuers are demanding integration of KYA (Address Profiling) oracles at the protocol layer to ensure assets never end up in blacklisted addresses, guaranteeing Legal Finality (Legal Finality).

Stablecoins (Stablecoins) — From “Chips” to “Settlement Layer”

In 2025, stablecoin trading volume surpasses Visa for the first time and accounts for a significant share in cross-border trade settlement (especially B2B payments). Regulations are “banking” stablecoins and forcibly splitting them into two logical categories:

1. Payment Stablecoins: e.g., compliant USDC/USDT. The regulatory focus is on 100% rigid redemption and AML. The core risk point is “fund flow visibility”—not only proving the money is in the reserve but also that circulating coins are not used for terrorist financing.
2. Yield Stablecoins: Regulatory logic approaches “securitization management.” In 2025, multiple stablecoin projects attempting to distribute dividends to holders are halted by the SEC.

Conclusion: Stablecoins have upgraded to become the “underlying settlement protocol” of global finance. For payment companies and OTCs, being able to distinguish these two attributes and providing penetrating tax and AML reports for “payment stablecoins” is a prerequisite for engaging in international trade funding.

2026 and Future Outlook — The “Embedded Compliance” Era

If 2025 is the “physical implementation” of rules, then 2026 will be the “chemical reaction” of compliance. We believe the industry will undergo three profound qualitative changes.

1. From “Post-Event Accountability” to “Embedded Compliance (Embedded Compliance)”

Past AML was passive: transaction occurs -> dark money detected -> account frozen -> fines. Future AML will be proactive: transaction initiated -> smart contract calls compliance oracle -> high risk determined -> transaction Revert (rollback/reject). Outlook: Compliance will be codified. Regulatory rules will be embedded into smart contract logic. If a transaction fails KYT checks, it may not even be recorded on-chain. This will thoroughly eliminate money laundering risks but requires market participants to connect to real-time compliance networks.

2. “Unified Ledger (Unified Ledger)” and Integration with Public Blockchains

The Bank for International Settlements (BIS)‘s proposed “Unified Ledger” concept will enter practical implementation in 2026. Outlook: We may see a rise of a “hybrid chain architecture”**. Banks and central banks’ CBDCs will run on permissioned chains but interoperate with compliant RWA assets on Ethereum/Solana via cross-chain bridges. Under this architecture, “Cross-Chain Compliance Proofs” will become key—when assets move from public chains into bank consortium chains, they must carry a “clean provenance” proof document.

3. Strong Binding of Identity and Assets (Identity-Bound Assets)

The era of “anonymous high-value asset holding” will be gone.

Outlook: Web3 is introducing Verifiable Credentials (Verifiable Credentials/DID). Future wallets will no longer be just public key hashes but containers holding a series of verified tags (such as “KYC passed,” “non-sanctioned region,” “qualified investor”).

Trustin predicts that by the end of 2026, mainstream DeFi protocols and RWA platforms will refuse to interact with “naked wallets” lacking any “credential tags”.

Conclusion

The wheels of history keep rolling forward. 2025 will be remembered as a turning point: Crypto is finally no longer outside the law but becomes a more transparent and efficient within-the-law domain.

In this new era, Tokenization grants assets liquidity, Stablecoins provide a value anchor, and Compliance (regulation) forms the foundation of trust.

For all institutions committed to long-term development, embracing compliance is no longer a choice but a necessity. Trustin is willing to be your guardian in this new financial order, using data and technology to safeguard the bottom line of safety and expand your business potential.