| Jurisdiction | Instrument | Exposure |
|---|---|---|
| European Union | MiCA (Regulation (EU) 2023/1114) | Administrative fines set nationally under Article 111: for legal persons, maximums of at least €5 million or a percentage of annual turnover, rising to 12.5% of turnover for the most serious stablecoin-issuer infringements. Operating as a CASP without authorization is now unlawful across all 27 member states. |
| United States (federal) | GENIUS Act | Issuing a payment stablecoin without an approved issuer license becomes unlawful once the Act is effective. Federal banking regulators and, for state-qualified issuers, state regulators hold examination, cease-and-desist, and civil money penalty authority; knowing violations carry escalated penalties. |
| California | Digital Financial Assets Law (Fin. Code § 3407) | Up to $100,000 per day for unlicensed digital financial asset business activity; up to $20,000 per day per material violation for licensees. Penalties accrue until the violation ceases. |
| New York | BitLicense (23 NYCRR Part 200) | Unlicensed virtual currency business activity violates the Financial Services Law; NYDFS enforcement has produced eight- and nine-figure settlements, and the Department can suspend or revoke licenses and compel restitution. |
| United Kingdom | FSMA 2000 general prohibition | Once the 2026 Regulations commence in October 2027, carrying on a regulated cryptoasset activity without authorization breaches the FSMA general prohibition: a criminal offence punishable by up to two years' imprisonment and an unlimited fine, with resulting agreements potentially unenforceable. |
| Hong Kong | Stablecoins Ordinance (Cap. 656) / AMLO VATP regime | Conducting regulated stablecoin activity without an HKMA licence is a criminal offence carrying substantial fines and imprisonment; operating an unlicensed virtual asset trading platform under the AMLO regime likewise carries fines and up to seven years' imprisonment. |
| Singapore | Payment Services Act 2019 / FSM Act 2022 | Providing digital payment token services without a licence is a criminal offence punishable by fines and imprisonment; MAS has also barred unlicensed overseas-facing digital token service providers since June 30, 2025. |
| South Korea | Virtual Asset User Protection Act | Unfair trading (manipulation, use of undisclosed information) carries imprisonment of at least one year or fines of three to five times the illicit gain; where gains exceed ₩5 billion, sentences can extend to life imprisonment. |
| China | PBOC September 2021 Notice and related criminal law | Crypto trading and related services are illegal financial activities. Participants face administrative action, and organizers can be prosecuted for illegal fundraising, illegal business operations, and related offences. |
| Turkey | Law No. 7518 (Capital Markets Law amendments) | Operating a crypto asset service provider without a CMB licence is a criminal offence carrying multi-year prison terms and judicial fines; the CMB can also block unauthorized platforms' websites. |
| Brazil | Law 14,478/2022 and BCB resolutions | Operating without BCB authorization after the transition exposes firms to administrative sanctions under financial system law, and the statute created a specific criminal offence of fraud involving virtual assets, punishable by imprisonment. |
| India | Income-tax Act §§ 115BBH / 194S; PMLA | No licensing regime, but a 30% tax on virtual digital asset gains with no loss offset, 1% TDS on transfers, and anti-money-laundering registration with FIU-IND; non-compliant offshore platforms have been blocked and fined. |
Two patterns worth naming. Financial-center regimes price violations in percentages of turnover or per-day accruals: MiCA reaches 12.5% of annual turnover for the worst stablecoin infringements, and California's DFAL runs to $100,000 per day of unlicensed activity. East Asian statutes price them in prison time: Korea's VAUPA tops out at life imprisonment for the largest unfair-trading gains, and Hong Kong's unlicensed-platform offence carries up to seven years. The cheapest place to be unlicensed is nowhere on this table.