Regulatory reforms in the cryptocurrency sector have intensified through 2025 and are now visibly impacting the development and implementation of token sales in some of the largest markets globally. In the United States and European Union, new regulations seek to protect investors, create suitability and thoroughness checks to limit illicit activities while promoting innovation and amplifying optimism without stifling growth. For new participants and founders of projects looking into future token sales, it is crucial to understand regulatory developments so that they can comply with some of the new regulations and navigate the compliance process while maximizing opportunities in a more formalized environment.

Throughout 2025, US regulatory activity has been inconsistent, with some federal legislation (for example, the GENIUS Act) addressing some aspects of stablecoin regulation, while MiCA in the EU has been implemented across a wider group of EU members creating consistency. These developments factor into long-standing concerns around market manipulation and consumer-related fears, which will hopefully encourage a rise in participation and increase ticket size for token sales as it builds more confidence. Following-the-date and prior to the September 2025 token data, any revenue generated increased by 45% in the number of compliant tokens sold when compared to the prior twelve months, showcasing the formulating strategies from the projects.

A significant model impacted by regulations is an Initial Dex Offering (IDO) or token launch, where projects launch tokenize on a decentralized exchange allowing people to freely buy any tokens without restrictions; tokens provides an engaging proposition to buy grin-and- bear-it liquidity. With MiCA, IDOs must adhere to their white paper disclosures and models, while the SEC closely examines which IDOs become securities offerings. Consequently, more projects have begun to hybridize good aspects of centralization and decentralization; while maintaining both aspects of normalized conditions to meet the risk appetites of larger audiences.

Changing Regulatory Landscape Overview

The worldwide trend of crypto regulation is prompted by the need to fit cryptocurrency alongside traditional financial infrastructure.

Both the United States and the EU have prioritized 2025 as setting the stage for clarity around token classification, licensing for service providers, and anti-money laundering regulations. The newly proposed framework clarifies some of ambiguities concerning institutional participation in token sales. Regulators can distinguish among utility tokens, security tokens, and stablecoins, and the structure of the sale may impact the profile.

Each project must assess if the token being sold will fall within stop signs set out for securities (and risk registration or being required to find an exemption to registration). To think through whether a token is appropriately classified, the following may help:

1.       Determine the type of token - utility for application usage or security for expected return;

2.       Review exact regulations for our jurisdictions - the US looks specifically at the required criteria for the Howey Test, and the EU will look only as their definitions from MiCA;

3.       Bring in your legal team early to be able to address certain questions when startups inevitably encounter delays.

Each of these steps may help the founder reduce risk, such as selling to investors who cannot afford to be fined or to have the sale cancelled.

Key Developments in the US

Affecting Token Ideally for cryptocurrency sales - In the US, since the GENIUS Act was passed by the United States hall-of-legislation, which establishes a federal framework for payment stablecoins requiring issuers to hold 100% of reserves in high quality assets (i.e., US Treasuries), there remains uncertainty.

Congress passed the bill in July of 2025, intending to improve US leadership in the global digital finance space, while avoiding systemic risk. On the other hand, the SEC would still enforce registration of offerings under what they designate as crypto-securities outlined in the guidance provided previously in April 2025.

The IRS has stated that beginning in January 2025, brokers will be required to report gross proceeds from crypto sales to the IRS, which if they participate in token sales, will affect tax treatment depending upon the transaction. In concert with the foregoing federal efforts in the United States, a few states have acted, passing legislation in 2025 to regulate digital assets between that state and digital assets to be regulated at the state level.

The Trump administration's supportive position on crypto has diverted enforcement actions away from specific token transactions, which incentivizes even further token sales. Founders can have their opportunity to adapt by:

• Applying the Howey Test on their tokens to determine whether the tokens are securities.
• Applying for an exemption under Reg D, if it relied solely on private sales.
• Applying through a licensed broker that can register the sale and be in compliance.

All three steps will assist with the obstacle of fragmentation in U.S. rule implementations.

The Changes coming due to MiCA in the EU for token sales

The EU's MiCA regulation is fully operational for token sales in early 2025 with harmonized crypto rules across its 27 member states. MiCA mandates Crypto-Asset Service Providers (CASPs) apply for a license and the provision of white papers whenever they open to token issuances. As a result, the ICO compliance levels will meet 65% compliance (up from 38% in the year 2024).

MiCA defines asset-referenced tokens, e-money tokens, and tokens not referenced to legal tender and will require strict disclosure information to avoid market abuse. In preparation for token sales, issuers will be required to prepare extensive documentation that includes risk assessment documentation and documentation on reserve references in the case of stablecoins.

There are a series of grandfathering measures in place to allow existing providers to comply with changing regulations but new providers will face substantive approval requirements (by January 2025).

To meet MiCA compliance, issuers/providers for token sales will need to:

• Draft a high level white paper that describes the mechanics of the token, the tokens risks, risks of the token on its service and any other ancillary weakness in the token.
• Secure a CASP license, applicable if any supporting services (i.e., custodial services).
• Implement a AML/KYC procedure using tools to help like with Chainanalysis.

The MiCA requirements will limit the inconsistencies of national laws and regulations associated with token sales to help with cross-borders sales.

Impacts of these changes of token sales formats

Regulatory changes where many token models will be impacted (ICOs, IDOs & IEOs.). In the US, sales classified as securities must register with the SEC, causing projects to look for compliant platforms. The EU has regulatory obligations via MiCA regarding public offerings dealing with methods that provide investors remedy mechanisms. The so-called IDOs which place a greater emphasis on decentralization at the detriment of compliance, have also instituted KYC tiers that are compliant with both region's AML laws. Recently, we have seen hybrid sales start with private exemptions in the US with an EU based white paper. Some impacts of these developments have been: 

• Average compliance costs (of the raise targets) = 15-20% increase.
• Average lead times from initiation on both sides have increased from 3 months to 6 months.
• Greater degrees of assurance for investors means larger average offers.

All of those changes eliminate fraud risk points since scams were reported at a 40% decrease rate compared to 2025.

Menvi assumes the same height for the Regulatory Compliance for Token Sales

It is essential that founders incorporate regulatory frameworks into their planning and thinking in order to execute their projects. In the US ecosystems related to crypto or blockchain utilizing selected GENIUS Act components to be more stable, whilst in the EU white papers focused on what is compliant with MiCA legislation.

Founders must also consider Regtech solutions to automatically check things and decrease the risk of human errors.

Some ways to signify practical centred approach to sales and compliance: 

• After-market revised jurisdictional audits are a living document. The Thomson Reuters would provide jurisdictional insights into a consultant's law.
• Build tokenomics design programing should be built with compliance in thought, limits on allocations to insiders at most are 20%.
• All Updates are through regulators; ensure anybody reviews governance and alerts from ESMA.

A more proactive approach throughout the sales execution phase will assist in dealing with revision sources such as extend approval notices.

Final Research: Some Case Studies of Token Sale

A few recent sales highlight the overall impact that regulation will have on the future of sales. In the US, during an online offering by a fintech company 2025 (Q2) issued tokenized securities above board with the SEC rules for registered sales to raise $50m through SEC registered sales. The project used Reg A+ exemptions that illustrated how cases like these from 2025 are clarifying stature of tokens - what is a security and securities and what are not.

In the EU, during the roll-out of MiCA mid-2025, there was an ICO launch of a DeFi protocol with a lengthy white paper, they completed their ICO full compliant and raising initial institutional funds. In another example there was a stablecoin issuer who was able to adjust formal offerings to equivalent components of a US GENIUS Act framework for EU jurisdictional offerings creating an observable focus on the harmonization of US and EU starting with above the board tokenized sales.

The takeaways from these three (3) examples.

• Transparency is impactful when trying to create a successful token sale: the public can show disclosures showed decreased external scrutiny.
• Not every organization's financial model fits into national rules. Hybrid models can help bridge jurisdictional aspects for both the US and EU.
• Impact outcomes from the content offered matter. The compliant offerings provided observed average 25% higher ROIs than the non-compliant ones (return on investments).

These case studies act as templates to assist future case studies planning.

What trends or issues are we expecting going forward based on what we learned?

Looking forward, the regulations we experienced in 2025 will provide us with more tokenized assets within the US, while MiCA will lead reforms for US regulations. For example, I see the growing issues with jurisdictional harmonization of the regulations, particularly within the US between the states and federal government, combined with jurisdictional variances across the EU is a challenge that all policymakers face.

There seems to be positive trends though to see the increasing examples of stablecoin integrations for the sales aspects of tokens as a hedging. Founders will be expected to perform audits and reporting.

Ways to plan effectively going forward:

• Subscribe to policy trackers such as TRM Labs.
• Jurisdictional diversification: File in both jurisdictions to maximize your audience.
• Continued education: Prepare your team to stay aware of constantly changing laws because they will be a risk.

The novelty of the future may warrant less concern.

Conclusion

With existing regulations that will modify in 2025 are revolutionizing the outlook professional perspectives on token sales: which will result in a shift, from the current "norm", creating a more secure constraining proposition for the respective US and EU participants. Done through [not complete] and the express intent of enactments such as the GENIUS Act and MiCA create broad-edged framework thinking for sustainability also protects all participants from what complication an absence of framework can create 

Some Founders may flourish with compliance and planning, while through compliance structures building and ultimately be more successful improving investors confidence and engagement.

No one really knows, but ongoing is improving more on other countries along with existing in North America to develop legal structures for identified compliance relating either sustainable assets or any type pops to potentially turn personal products into markets.

All in all, changes are going to create evolutions which means the reporting of "innovative" practices will evolve in the industry, while the innovation is positive on purpose, as accountability is chosen and therefore selected purposefully.