The much-awaited approval of spot bitcoin [BTC] exchange-traded funds (ETFs) by the U.S. Securities and Exchange Commission (SEC) can give unprecedented momentum for similar regulatory approvals in and around Asia, even if some regions may not necessarily or immediately be able to create the ideal policies for such a move, multiple analysts have told CoinDesk.
U.S. based industry analysts and experts have feared for some time now that the nation “could miss the bus” if it doesn’t put in place clear, and perhaps favorable, regulatory policies for the crypto space. The approval of spot bitcoin ETFs in the U.S., though, gives it an edge ahead of at least Asia and Africa (the European Union and other nations already have bitcoin ETF products).
Given jurisdictions in and around Asia have particularly been vying to become crypto hubs, expectations for a bitcoin ETF are higher there than in Africa. The UAE, Singapore and Hong Kong have, to different degrees, framed policies that attract retailers and financial institutions interested in the crypto space. But none have so far given regulatory approval to a bitcoin ETF-like product.
CoinDesk spoke to more than a dozen analysts and industry participants, a majority of whom said that Australia would likely be the next country to approve spot bitcoin ETF products. Hong Kong has voiced the most interest in achieving the reality of a bitcoin ETF approval and that the U.S. approval could move things along faster for almost all the jurisdictions in the area.
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Now that the U.S. has allowed nearly a dozen products to launch, other countries like the U.K., Hong Kong, Singapore and Japan could introduce policies “to prevent large and medium-sized financial institutions from transferring their funds out” of their regions, said Ryan Lee, Chief Analyst at Bitget Research.
Australia is in the lead
Australia is expected to be among the first with approval with the Australian Securities Exchange (ASX) imminent in the “first or second quarter of 2024,” said Liam Hennessy, a Brisbane-based lawyer at Clyde & Co.
“Australia is definitely leading over Hong Kong and Singapore at this stage,” said Hennessy in an interview with CoinDesk. “In Australia, the Monochrome Bitcoin ETF is number one since it applied in July 2023.”
Technically, Australia already has two exchange-traded products providing exposure to spot crypto assets on Cboe Australia. However, Australian industry experts said there’s more excitement over the potential for a similar product to begin trading on Cboe Australia's larger rival, ASX, where the anticipation lies due to the larger volumes available there.
The Australian Securities and Investment Commission (ASIC) is the market regulator which had effectively “allowed” such products in 2022.
Monochrome Asset Management is “anticipating that the Monochrome Bitcoin ETF becomes quoted in the second quarter of this year,” said Derek Vladimir Henningsen, general counsel and head of Legal and Compliance, the digital asset manager, in an interview with CoinDesk.
"It makes sense that the ASX is a fast follower, so the U.S. approval may give the ASX some assurance," Henningsen said.
While both Hennessy and Henningsen said the number of applicants for a spot-bitcoin ETF-like product in Australia isn’t “public knowledge,” the Australian Financial Review reported that Bitcoin ETFs are lining up for approvals.
“The Australian Securities Exchange (ASX) is set to approve an exchange-traded fund linked to the price of bitcoin in the first half of this year,” the report said.
The Australian Securities and Investment Commission (ASIC) and ASX, which falls under ASIC, are responsible for a license and an approval respectively. Monochrome has already got a license from ASIC through a separate entity, Vasco Trustees Limited.
An ASIC spokesperson said it is ultimately for the market operators that quote ETFs (currently ASX and CBOE) to be comfortable that a product meets their operating rules and procedures.
An ASX spokesperson said it had amended the rules in August 2022 to allow crypto ETFs and that it continues to engage with a number of issuers interested in admission while saying it does not comment on investment product applications.
“Others may have filed an application, but they certainly aren’t talking about it publicly,” Hennessy said. “But there are a number of other people who have filed closed ended funds or private ETFs, which are a fund to invest in digital assets not traded on an exchange.”
Hong Kong, Singapore and UAE
Hong Kong, Singapore and the UAE have projected an interest to be seen as crypto hubs of the world, but have not seen bitcoin ETFs in their regions.
Hong Kong lawmaker Johnny Ng, one of the city's loudest advocates for crypto, took to X hours after the U.S. approvals to say “Hong Kong must dare to be a 'leader' in the field of virtual assets” and “promote the implementation of spot ETFs as soon as possible.” Hong Kong’s attempts to reclaim its title as a crypto hub has seen it roll out a new licensing regime that gives crypto exchanges a pathway to operate in a regulated manner. It's also said it's ready to consider applications for spot crypto ETFs.
“Hong Kong looks likely to be the next to approve spot crypto ETFs,” said H.B. Lim, managing director of APAC for BitGo, which is also the bitcoin custodian for Hashdex, one of the applicants for a spot bitcoin ETF.
Previously, Lim spent 13 years as a regulator across Singapore’s central bank and Abu Dhabi Global Market’s regulatory authority. He said that U.S. approvals may prompt Family Offices and High Net Worth Individuals to avoid generational questions of why none of the Family Office portfolio was allocated to crypto back in the day.
“In addition, HK's reputation as a strong financial center with some of the deepest capital markets and the largest stock market when compared to Singapore or those in the Middle East, strategic position within the Greater Bay Area, coupled with the HK government’s public support for web3, are factors that will draw spot crypto ETF issuers to HK,” Lim said.
Singapore’s attempts to strike a balance between favorable and protective regulations while continuing to promote technology without speculation have reflected a hot and cold approach to crypto. But analysts believe the approvals in the U.S. might be just what the city-state needed to allow products like bitcoin ETFs.
A spokesperson from the Monetary Authority of Singapore (MAS) said spot Bitcoin ETFs are not approved for offer to retail investors and reiterated that people who choose to “trade in Bitcoin ETFs in overseas markets must exercise extreme caution.”
Angela Ang, a senior policy adviser for blockchain intelligence firm TRM Labs pointed to Singapore’s strong and longstanding concerns around speculative retail trading.
“One piece of the puzzle could be whether would-be issuers in Singapore can satisfactorily address MAS' concerns around retail participation,” Ang said.
Perhaps the region least likely to immediately promote bitcoin ETF-type products is the UAE, according to a former regulator from a UAE financial free zone authority who sought anonymity because the person wasn’t authorized to speak to the media in their current role.
“The conditions are not quite right in the UAE/MENA in general to launch a spot bitcoin ETF,” the person said. “To do so, there needs to be sufficient market liquidity from traditional finance players, who may not already have connectivity to UAE markets.”
The person explained that if you’re going to tap TradFi, you need to go where there is TradFi liquidity and the issue in the UAE is connectivity. If the UAE authorities list a spot-bitcoin ETF, interested investors in other parts of the world – for example India or the United Kingdom – need to have a relationship with a member of a stock exchange market in the region like the Dubai Financial Market.
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“The rules in the UAE to establish such links make it expensive,” said the person. “I wouldn’t rule out the UAE finding a way past this but at the moment, it’s unlikely to be worth it to just trade one product; there needs to be a compelling suite on offer to attract TradFi players who can provide retail and institutional investors with the necessary market access.”
