Adrienne Harris, finishing her stint as New York’s top financial regulator, wants to be remembered for one last idea: a “passport” for crypto firms between the U.S. and U.K. But Harris’s proposal is not the Brussels-style single market with a common rulebook, rather something closer to the mutual recognition deals Washington and London already use in equities and derivatives trading. Those agreements have lowered barriers, cut compliance duplication, and deepened markets. The vision is to graft the same logic onto Bitcoin and stablecoins.
It sounds bold. Regrettably, it is premature. The United States already has a federal framework for digital assets. President Donald Trump didn’t wait for the consultants or the roundtables. In January, his executive orders declared that crypto would no longer live in regulatory purgatory. By March, he had ordered the creation of a strategic bitcoin reserve, a move unthinkable under the technocrats who preceded him. By July, the GENIUS Act—the first federal stablecoin law—was signed into existence. It mandates redemption rights, dollar reserves, and prudential standards. Alongside it came the CLARITY Act, setting the terms of the securities-commodities divide, and the Anti-CBDC Surveillance State Act, blocking the Federal Reserve from smuggling in a Chinese-style state currency. While the latter bills are going through the loops in the Senate, the U.S. has a functional crypto regime, legislated and signed. Washington has acted. London has not.
The U.K. is still busy asking itself questions. The Financial Services and Markets Act 2023 gave ministers the legal powers, but the Financial Conduct Authority is still “consulting” on custody and stablecoin rules. The Bank of England has promised to treat certain issuers as systemic, but the draft sits on the shelf. Final rules will not appear before 2026. America is passing laws; Britain is still sending out questionnaires.
That is the hard reality Harris’s passport ignores. Equivalence, or mutual recognition of regulation is the foundation of any shared system. You trust the other side’s rules enough to let them in. At the moment, the United States has statutes; the United Kingdom has white papers. One side can redeem a stablecoin dollar for a dollar; the other can promise that, at some point, it might draft a framework suggesting as much.
For firms, of course, the attraction of a passport is obvious. Lower compliance costs, immediate cross-border reach, access to consumers on both sides of the Atlantic. But regulators cannot license on wishful thinking. A passport without equivalence invites arbitrage. Companies will choose the weaker supervisor, plant a token office there, and then claim universal access. That is not cooperation; it is the lowest common denominator.
If there is a way forward, it is narrower and more disciplined than Harris suggests. The starting point is stablecoins. The GENIUS Act already sets redemption and reserve rules in America. The Bank of England will eventually need to adopt something similar. Mutual recognition here—on stablecoin standards alone—would give both sides a defensible bridge, one rooted in enforceable law rather than consultation papers. The rest of the market can wait.
There is irony in Harris’s timing. For decades, London exported financial rules and Washington played catch-up. Now the positions are reversed. Trump has given the United States a coherent line: stablecoins in, CBDCs out, bitcoin treated as strategic. Britain, still mourning its lost EU passport, is fumbling toward relevance. If a transatlantic crypto bridge is ever built, it is London that will need to align to Washington, not the other way around.
Harris deserves credit for ambition. She is right that fragmentation serves no one but the compliance lawyers. Yet her grand exit proposal is more slogan than structure. To talk of a passport before the U.K. even has rules is to put the cart not just before the horse, but before the stable is built.
The reality is sharper than the rhetoric: America has already written the rules. Britain has not. The sooner Whitehall accepts that, the sooner any “passport” can be more than a mirage.
Bepi Pezzulli is a Solicitor of the Senior Courts of England & Wales and a foreign policy scholar. He is a member of Advance UK’s College and a councillor of the Great British PAC. He tweets at @bepipezzulli.
Image: Free image, Pixabay license.