United Kingdom vs Lithuania

The UK has an evolving and increasingly comprehensive crypto regulatory framework. The FCA registers crypto firms for AML/CFT compliance and has imposed strict financial promotion rules requiring risk warnings and banning incentives. HMRC treats crypto as property subject to Capital Gains Tax (10% basic rate, 20% higher rate, with £3,000 annual exemption from 2024/25). The Financial Services and Markets Act 2023 brought crypto assets into the UK regulatory perimeter, and HM Treasury is developing rules for a full crypto regime including exchange licensing, stablecoin regulation, and a potential UK CBDC ('Britcoin').

Cryptocurrency is legal and regulated in Lithuania. The Bank of Lithuania oversees VASPs under AML regulations and has been an early mover in crypto regulation within the EU. Lithuania attracted a large number of VASP registrations due to initially favorable conditions, though it tightened requirements significantly in 2022-2023. The MiCA framework now applies.