What Are the Key Differences in ICO Regulation between the US and the EU?

The US, primarily through the SEC, tends to classify most ICOs as securities based on the Howey Test, leading to strict registration and disclosure requirements. The EU's approach is more fragmented, with directives like MiCA (Markets in Crypto-Assets) aiming for unified, comprehensive regulation that distinguishes between different types of crypto-assets.

MiCA focuses on issuer authorization, consumer protection, and market abuse prevention. Generally, the EU has been moving toward a clearer, asset-specific framework than the US's security-centric view.