BIS Flags Group Loopholes in Global Stablecoin Rules
Stablecoins are moving beyond crypto trading into payments and cross-border settlement, prompting major markets to establish dedicated regulatory regimes. The European Union began applying MiCA’s stablecoin provisions in June 2024, while the United States adopted the GENIUS Act in 2025. Both frameworks address issuer eligibility, reserve assets, custody and redemption rights, but differences in their requirements could shape where providers establish operations and how they structure international businesses.
The Bank for International Settlements compared stablecoin rules across five jurisdictions and found significant variation in issuance thresholds, reserve custody and redemption procedures. All five nevertheless prohibit issuers from paying interest to stablecoin holders. The BIS warned that entity-based rules may leave a structural loophole: non-bank companies could place wallet, payment or yield-related services in separate affiliates within the same corporate group, preserving the economics of restricted activities while moving them beyond the regulated issuer’s formal perimeter.
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The history behind this eventCircle Policy Chief Urges UK to Blend EU and U.S. Rules for Crypto and Stablecoin Regime
Stablecoins are digital assets pegged to fiat currencies, and Circle-issued USDC is one of the company’s main products. The European Union has established rules through MiCA, while the United States has advanced regulation through the GENIUS Act. How Britain aligns itself with the two major markets will help determine whether London can retain its position as a fintech and cross-border payments hub.
Circle policy chief Dante Disparte recently told a UK House of Lords committee that Britain should combine MiCA’s regulatory clarity with the institutional strengths of the GENIUS Act to develop its own crypto and stablecoin rules. He warned that continued regulatory inaction would drive related businesses and capital overseas, weakening London’s global competitiveness.
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