Why crypto rules vary by country

Is crypto regulated?

Yes, but not by one authority and not in one way. Each country decides which activities need permission, who grants it and what protections apply. The examples in this guide come from the published pages of Coinbase, Crypto.com and Kraken, read on the dates shown in the sources. They describe what those companies say about themselves and are not a legal summary of any country’s rules.

One brand, a different company in each country

When you open an account you sign a contract with a local company, and it is rarely the same one twice. UK customers of Coinbase contract with CB Payments Ltd, Canadian customers deal with Coinbase Canada, Inc. and Brazilian residents with a separate Brazilian company.3 sources

The pattern repeats elsewhere. Crypto.com names Foris DAX UK Limited for the UK and Foris DAX CAN ULC for Canada. Kraken names Payward Limited in the UK, Payward Canada, Inc. in Canada and a Brazilian company in Brazil.5 sources

This matters when something goes wrong. Your contract and the rules that apply to it follow the entity you signed with, whatever logo is on the app.

United States, where the state matters

In the US, availability can change at a state border. Coinbase publishes its state licences, including New York, and notes that a licence covers specific activities and does not mean every product is offered in every state. Crypto.com says its App is available in 49 states, Washington, D.C. and US territories, with New York the one state where it is not. Kraken says it does not serve residents of Maine and New York.4 sources

United Kingdom, registration plus extra steps for new customers

All three name a UK company registered with the Financial Conduct Authority under the Money Laundering Regulations for cryptoasset activity. Kraken’s page adds that a registration covers specific activities and does not protect your investment, and Crypto.com notes that cryptoassets themselves are not regulated by the FCA.3 sources

UK sign-up also has steps that the other countries here do not. Coinbase describes a client categorisation, an appropriateness assessment and, for people who signed up after 8 January 2024, a 24-hour wait before trading. Kraken describes a mandatory 24-hour cooling-off period for newly verified retail accounts and says UK retail clients cannot trade derivatives.2 sources

Registration does not put a firm beyond enforcement. In July 2024 the FCA fined CB Payments £3,503,546 for repeatedly breaching a requirement not to onboard new high-risk customers.1 source

Canada, restricted dealers and purchase limits

In Canada the three platforms describe themselves as restricted dealers registered in Canadian provinces. Coinbase and Kraken also cite registration with FINTRAC as money services businesses.4 sources

The effect shows up in what you can do. Coinbase says Canadian applicants answer questions about investing experience, risk tolerance and finances, and may get a net purchase limit of $1,000 over a rolling 12 months depending on the answers. Kraken says Canadian-resident clients cannot trade on margin or trade derivatives.2 sources

Brazil, local entities and open questions

Coinbase’s Brazilian user agreement names a Brazilian company and describes it as an intermediary under Central Bank Resolution 520/2025. Kraken’s Brazilian terms name Payward Brasil, though the contract text does not by itself confirm the authorisation status of each activity.2 sources

For Crypto.com we could not confirm the current structure. The Brazilian terms we could read are dated 24 April 2026 and a later notice says they have been updated since, so we mark that entity as pending.2 sources

What to check for your own country

Then look the entity up on the regulator’s own register. A company’s description of its status is a starting point, and the register is the record.

Expect identity checks wherever you are. Kraken, for example, says its verification requirements depend on your country of residence.1 source

What this guide does not tell you

Everything above is what the companies publish about themselves, plus one regulator’s press release. We have not yet documented the regulators’ own descriptions of each regime, the tax rules in any of the four countries, or which compensation schemes, if any, apply. Those are gaps, and we prefer to show them than to fill them from memory.

Rules and terms also change. Each source on this page carries the date we read it.