Europe versus the United States: who will seize the lead in crypto?

Trading activity by European users on crypto platforms has risen markedly since the MiCA regime came into force. Over the same period the United States has seen a decline. ForkLog gathered expert views on the reasons for the divergence.

Paybis co-founder Konstantins Vasilenko told Cointelegraph that EU investors have been making larger and “thought‑through” deals.

“It is hard to ignore the coincidence. The window for MiCA licensing opened on 1 January 2025. In the same quarter our volumes in the EU jumped by 70%, although the number of trades barely changed. That tells me the new money was larger and more deliberate,” he said.

Other platforms report similar patterns. According to Kaiko, the share of retail clients in spot trading on Coinbase has fallen to 18% from 40% in 2021. Crypto trading volumes on Robinhood fell by 35% in the first quarter of 2025.

Against this backdrop, crypto firms Coinbase, OKX and Gemini have already secured licences in the EU.

Problems in the United States

In America, regulatory uncertainty is holding the market back. Despite statements by President Donald Trump, there is still no federal cryptocurrency law.

“A tangled licensing system in every state, SEC lawsuits and sudden delistings create uncertainty for users,” Vasilenko explained.

France, the new leader

France stands out among European countries for a marked increase in crypto activity — up 175%, according to Paybis. The PACTE law, which came into force in 2019, helped propel this, requiring exchanges to register under AML. Adoption is forecast to reach 24% of the population in 2025.

Vasilenko thinks the notion of a single “hub” will become outdated. Operations may be distributed across different EU countries “under MiCA’s common umbrella”.

In his view, America could regain ground if it passes GENIUS Act. He argues the law “will do for retail investors in the United States what MiCA did for Europeans”.

America is not ceding ground

Tehnobit CEO Alexander Peresichan told ForkLog he does not expect a wholesale shift of capital and innovation from the United States to Europe. In his view, “America is now busy shaping highly attractive regulatory norms for doing business in the country”.

“Crypto firms’ interest in the EU is the result of active work by local regulators, who have created a clear legal environment. Clear rules allow business to be conducted with confidence; however, the United States looks more attractive over the longer term,” he thinks.

The expert doubts that MiCA’s regulatory clarity will turn the EU into the world’s new crypto hub. He stressed that American authorities are more accommodating to the industry and that, so long as “Donald Trump is at the helm”, the United States will continue to attract crypto business. Entering the American market remains the chief dream of many companies, he said, and with a pro‑crypto president that goal is closer.

Speaking of the GENIUS Act, Peresichan noted that in some respects it could become an analogue to MiCA. As an example, he cited JPMorgan, which is already considering launching its own stablecoin in anticipation of a shake‑up of the “stablecoin” segment after the law is approved.

At the same time he stressed that the GENIUS Act targets the stablecoin market specifically, whereas the EU’s approach under MiCA is “far more global”. In his words, US regulators’ attitude to crypto projects has improved markedly following Gary Gensler’s departure as chair of the SEC.

Diversification, not flight

Bitget Research’s chief analyst, Ryan Lee, confirmed that many crypto firms, including his own platform, are actively seeking licences in the EU. The ability to operate legally in EU countries has been enabled by MiCA’s “passport”, which lets firms, after a single check, serve all countries in the EEA. Such conditions do not yet exist in the United States, he noted.

Even so, Lee stresses this is not a mass exodus to the EU but a diversification of business. The United States still offers the deepest capital market and concentrates specialist funds, talent and infrastructure, remaining “the juiciest prize” for crypto business.

In his view, MiCA is turning the EU into one of several peer global crypto centres, but not the sole leader. He thinks it is too early to speak of America losing its position, as US regulators, under a crypto‑friendly Trump, are actively working to enhance the jurisdiction’s appeal.

Lee added that comparing the US GENIUS Act with Europe’s MiCA is inappropriate, as they pursue different aims. The initiatives differ in orientation and are not comparable in essence.

“If the GENIUS Act is about stablecoins and strengthening the dollar on the world financial stage, then MiCA is a multifaceted set of rules designed to regulate the entire crypto market, not just one of its parts,” concluded Bitget Research’s chief analyst.

The EU’s approach does not foster innovation

In the view of trader and author of the Telegram channel Coen+ Vladimir Coen, “the EU’s rigid bureaucracy loses to America’s pragmatic strategy, which will in future lead innovative companies to migrate to the States”.

He noted that MiCA is a comprehensive regime for the entire industry, including exchanges, custodial services and other crypto‑service providers, setting strict licensing standards that are mostly accessible to large players. By contrast, the GENIUS Act is focused solely on stablecoins; its main task is to promote the dollar as a global means of payment and to stimulate demand for US government bonds.

Coen explained big firms’ rush for EU licences as an attempt to grab share in a huge, well‑capitalised market while it remains relatively open. He added that for Coinbase this is part of a global expansion that the platform’s head, Brian Armstrong, began after pressure from American regulators intensified.

However, in Coen’s words, the European approach does not encourage innovation.

“MiCA, true to the tradition of European bureaucracy, imposes too many constraints. With such regulation, the EU has no chance of becoming the centre of the world crypto industry,” the speaker said.

He believes MiCA’s main aims are consumer protection; reshaping the market in favour of large, easily controlled players; and a hard line against money‑laundering and preventing capital outflows from the EU. Innovation, in this paradigm, comes second to last.

In conclusion, Coen predicted that after the United States adopts its own, presumably more liberal, crypto‑regulation law (the Market Clarity Act), smaller Web3 companies will begin migrating from Europe to America’s jurisdiction.

Earlier, Coinbase was criticised for sponsoring a military parade in the United States.