The UK Financial Conduct Authority (FCA) has issued a warning over regulatory divergence after it emerged that Donald Trump generated over $1bn from cryptocurrency holdings during his first year back in office. The former president’s portfolio, disclosed under US ethics rules, includes investments in Bitcoin, Ethereum and a range of smaller tokens, with returns buoyed by a rally in digital assets following his return to the White House.
The FCA said the scale of Trump’s crypto earnings highlighted the widening gap between US and UK approaches to digital asset regulation. Britain has taken a cautious line, cracking down on unregistered exchanges and retail crypto derivatives. Washington, by contrast, has embraced a more permissive regime, with the US Securities and Exchange Commission approving several spot Bitcoin exchange-traded funds.
“The divergence in regulatory philosophy presents risks for global financial stability,” the FCA said in a statement. “It also raises questions about the potential for conflicts of interest at the highest levels of government.”
Trump’s crypto gains come from a combination of direct purchases, tokens received in exchange for political endorsements and stakes in blockchain ventures. His holdings were managed by a trust during his first term but he has since taken a more hands-on role, according to associates.
The president has been a vocal advocate for cryptocurrencies, promising to make America the “crypto capital of the planet”. His administration has appointed pro-crypto officials to key financial regulatory posts and pushed legislation to exempt digital asset transactions from certain securities laws.
Industry analysts said Trump’s personal windfall could further entrench US policy. “He has a direct financial incentive to keep the regulatory environment favourable,” said Rachel Lomax, a fellow at the Council on Foreign Relations. “That is a concern for institutional integrity.”
The UK’s FCA has not proposed specific action against Trump but warned that other nations may need to harmonise rules to avoid arbitrage. The European Union’s Markets in Crypto-Assets regulation, due to take full effect next year, is seen as a possible benchmark for global standards.
Downing Street declined to comment on a foreign leader’s personal finances. A White House spokesperson dismissed the FCA warning as “a bureaucratic overreaction to a successful American president’s legitimate investment strategy”.
The episode underscores a broader contest between financial centres vying to attract crypto innovation. Singapore and Dubai have also pursued light-touch regimes, while the UK and EU have stressed consumer protection and anti-money laundering safeguards.
For now, the US appears to be winning the battle for capital and talent. Bitcoin prices have doubled since Trump’s inauguration, fuelling a boom in trading volumes and venture funding. Critics argue that the regulatory race to the bottom could end in disaster.
“This is about more than one man’s billions,” Lomax said. “It is about whether democracies can agree on rules for a technology that is inherently borderless.”
The FCA said it would continue to monitor developments and coordinate with international counterparts. It stopped short of calling for direct restrictions on Trump’s holdings, noting that US law permits such investments. But the subtext was clear: if the world’s largest economy refuses to regulate crypto, others may have to act alone.
