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This article critically analyses recent policy initiatives at international and national level regarding the regulation of the crypto-asset sector, including the European Commission's consultation document. It also aims to provide a comparative analysis of two notable crypto-asset frameworks which have been established in the EU, namely the frameworks established by Malta and France, which cover the conduct, prudential and market integrity aspects of the sector. The article identifies the relative strengths and weaknesses of the respective frameworks and extract the positive elements which could be incorporated into a holistic, harmonised crypto-asset framework for EU adoption.
