India: Gripping the Throat, Recreating under the Hood
- The CBDC sandbox with retail activities was introduced
The Reserve Bank of India (RBI) officially introduced a retail sandbox on 8 October 2025 for applications based on the digital rupee (e₹), an important step towards experimentation to controlled implementation. This action is based on the pilot presented in December 2022 and indicates an increasing desire of India to institutionalise its central bank digital currency.
- The Preparation of the Deposit Tokenisation Pilot
Simultaneously, the RBI is designing a pilot concerning deposit tokenisation in the wholesale CBDC segment. The initiative will reflect the bank deposits in the form of tokens in a blockchain, and these tokens will enhance the effectiveness of settlement and friction reduction and traceability in the financial ecosystem.
- Strict actions on offshore exchange
India Financial Intelligence Unit (FIU-IND) has launched its campaign against non-compliant offshore crypto-exchanges. PMLA Notices were also given to 25 foreign platforms that were not registered and were operating under the Prevention of Money Laundering Act (PMLA). Some platforms have been asked to block the access of Indian users or remove their URLs and applications.
- Huge taxation continues
India does not have an offset to losses or trade-off trading costs; it keeps its 30 per cent tax on crypto gains – one of the most severe crypto tax systems in the world.
- New gaming-crypto intersection law
The Promotion and Regulation of Online Gaming Act, 2025, which is to take effect on 1 October 2025, provides a heavy hand on the financial transactions made in online games. Although the Act is not crypto-specific, the laws have a major effect on areas that deal with crypto, NFTs, and in-game tokens, classifying offences as violations, as non-bailable, and platforms that offer token-based gaming as liable.
- Reserved hope on the part of the sovereign
Although the rate of crypto adoption in India is high, the platform is still state-based and moderate. One of the senior officials admitted that the stance of India is under consideration due to the changing global structures; however, as of today, there is more regulation than liberalisation.
- Overview (India)
The future political landscape in India in October 2025 portrays dual impetus, operation crackdown on unregulated crypto channels alongside state-led innovations in CBDC and tokenised finance. The message is clear: either be innovative inside the regulatory frontiers of India, or go.
U.S.: Structuring a Framework, Not a Ban
- The GENIUS Act establishes the standards of stablecoins
In July 2025, the GENIUS Act became law, which has created federal-level guardrails on stablecoins, including requiring reserve backing, third-party Audits, Transparency, and dual state and federal regulation.
- SEC sends no-action letters, develops coordination
In October 2025, the SEC issued two no-action letters, one allowing state trust companies to act as crypto custodians on stringent terms and the other concerning a token offering. At the same time, the SEC and CFTC held a joint round table of oversight to simplify the oversight and reduce the overlap of jurisdictions.
- Innovation freed from rule-making
Chairman of the SEC Paul Atkins declared future rulemaking on crypto innovation exemption, which should be implemented by early 2026. The suggested mechanism would enable qualified fintech and crypto projects to be regulated under a less heavy and more time-constrained regulatory sandbox.
- The Treasury tries to find a popular opinion
The U.S. Treasury sought the public to provide comments on the implementation of the GENIUS Act on 17 October 2025 and encouraged stakeholders to comment on the emerging federal response to the regulation of stablecoins and digital assets. The viewers are manipulated to consider the whole film as a continuous propaganda on terrorism. The viewers are sold to consider the entire film as a non-stop propaganda against terrorism.
- Labour opposition emerges
The AFL-CIO, the unions of millions of American workers, have been fighting the Responsible Financial Innovation Act, claiming that retirement funds will be exposed to danger and a lack of consumer protection.
- The interagency coordination increases
Coherent, risk-based policymaking. Co-ordinated discussion of tokenisation, smart contracts, and digital payments by the SEC, CFTC and Federal Reserve and other U.S. agencies is an indicator of a transition towards coherent rather than fragmented policy-making. (Paul Hastings)
- Overview (U.S.)
In October 2025, the U.S. will be as far off as it can be, regulatory-wise, without prohibition in favour of organised innovation. The objective is simple: to promote technological development in the conditions of plausible management and societal responsibility.
India vs. U.S. Key Contrasts and Convergences
| Aspect | India (Oct 2025) | U.S. (Oct 2025) |
| Overall stance | Restrictive toward private crypto; selective enabling of state-led innovation | Pro-innovation; emphasis on regulation over prohibition |
| CBDC/digital currency | Active rollout of retail CBDC and deposit tokenisation pilots | Explicit prohibition on U.S. CBDC (Executive Order 14178) |
| Stablecoins | No clear framework; taxed heavily; high scrutiny | Regulated via the GENIUS Act; rulemaking in progress |
| Offshore exchanges | Enforcement and deregistration of non-compliant platforms | Licensing and conditional enforcement; no blanket bans |
| Regulatory mechanism | AML laws, taxation, and targeted Acts | Legislative Acts, interagency coordination, and public consultation |
| Innovation potential | Limited to government pilots, the private sector is constrained | Proposals for innovation exemptions and sandboxes |
Outlook and Challenges
- Regulatory transparency vs. excess regulation
India threatens to deter crypto entrepreneurs with its repressive regime, and the U.S. struggles to find a balance in clarity and not suffocating innovations.
- Frictions in cross-border compliance
As India limits offshore participants, American and international interactions will be forced to seek ways of managing a dual compliance environment.
- Stablecoin reserve integrity
The requirements of the GENIUS Act will examine how issuers can maintain transparent and fully backed reserves in the long run.
- Judicial and political opposing winds
The new rules on gaming in India can be a target of judicial review; in the United States, the opposition from labour and consumer groups may alter the final text of the legislation.
- The puzzle of interoperability and tokenisation
The success of tokenised finance by both countries will depend on resolving cross-chain interoperability and cross-border settlement challenges issues as much legal as technical.
Conclusion
A significant milestone in global crypto regulation will be achieved in October 2025. India is strategic in terms of control, compliance, and innovation is limited to state lines. The U.S. is in transition, heading toward an order of controlled liberty, cultivating innovation under prescribed protection.
It is yet unclear which model of control and command will be the ultimate winner between India and America, the structured liberalism model or the command and control model. Yet the difference is very clear: one is constructing walls; the other, a map.
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