MiCA, which takes effect in 2024, represents the world’s first comprehensive crypto regulation in a major jurisdiction, allowing service providers to operate across the bloc with a single license. As an EU member, Malta wants to align its crypto rules with MiCA and “ensure a smooth transition for Virtual Financial Assets (‘VFA’) Service Providers” in the country, the regulator said in its consultation.

Even where implemented, there are discrepancies. Canada, for instance, requires operators to jot down beneficiaries’ postal addresses, while the U.K. doesn’t, and firms are caught in a quandary when handling a transfer between the two, Caterina Veloso, co-chair of lobby group CryptoUK’s travel rule working group, told CoinDesk.

The Act “gives us control of our financial services rulebook,” following the U.K.’s exit from the EU, enabling regulation of crypto assets to support their safe adoption in the U.K., said Financial Services Minister Andrew Griffith in a statement.