Outline

1. Introduction  

2. Why Have Stablecoins Come Under Regulatory Scrutiny?  

3. The European Union and the MiCA Transitional Period  

4. The United States and the GENIUS Act  

5. Hong Kong and the HKMA Stablecoin Licensing Regime  

6. Conclusions: Why Is This an Opportunity, Not Just a Burden?  

Introduction
According to FATF data, in 2025, 84% of all illicit virtual asset transactions involved stablecoins. And this is truly striking, just imagine: in 2025, stablecoin trading volume reached USD 33 trillion, while Visa and Mastercard combined accounted for only USD 25.5 trillion.

But let us take it step by step.

So, what exactly are stablecoins?

Stablecoins are cryptocurrencies whose value is pegged to a stable asset, such as a fiat currency (e.g., the US dollar) or gold. This is precisely what enables transactions to be conducted without the fear of sharp price volatility.

The first stablecoin, called BitUSD, was launched by BitShares (hereinafter – BTS) back in 2014. As of today, market leaders include Tether (USDT) and USD Coin (USDC), both of which operate on reliable full-reserve backing principles.

Why Have Stablecoins Come Under Regulatory Scrutiny?

As already clear from the introduction, leaving things “as they were” was no longer an option, so regulators did not delay action. If a stablecoin is used as a payment instrument, it is only fair that it should be regulated accordingly. For a long time, stablecoins were perceived as a neutral “bridge” between cryptocurrency and traditional money.

Let us examine the situation geographically:

1) United States:

• issuers could obtain licenses only at the level of individual states;  

• registration with FinCEN was required;  

• there was no unified federal regulatory framework.  

2) European Union (hereinafter — the EU):

• companies registered in jurisdictions with minimal requirements while providing services across EU Member States;  

• there was no unified approach to transaction monitoring;  

• algorithmic stablecoins were barely supervised, which ultimately led to the collapse of the Terra (LUNA) ecosystem in 2022.  

A key turning point came with the update of FATF Recommendations № 15 and № 16, under which stablecoin issuers were classified as Virtual Asset Service Providers (hereinafter – VASPs). From that moment onward, companies became subject to a package of AML obligations, while regulators around the world began to act – and rather swiftly.

The European Union and the MiCA Transitional Period

The Markets in Crypto-Assets Regulation (hereinafter – MiCA) is the EU’s first comprehensive legal framework establishing unified rules for the crypto-asset market.

For companies operating within the EU or serving EU-based clients, the key date is 1 July 2026. This marks the end of the MiCA transitional period, after which compliance with MiCA requirements becomes mandatory.

Stablecoin Categories under MiCA:

• E-Money Tokens (hereinafter – EMTs) – crypto-assets pegged to a single official currency, such as the euro.  

• Asset-Referenced Tokens (hereinafter – ARTs) – crypto-assets whose stable value is maintained by reference to other assets, including currencies or commodities.  

• Other crypto-assets, including utility tokens.  

Therefore, in order to lawfully issue or distribute stablecoins in the EU from July 2026 onward, companies will be required to:

• obtain the relevant electronic money license;  

• implement a reliable reserve management system based on liquid assets;  

• establish a framework for regular disclosures;  

• adapt their corporate governance structure in accordance with the requirements of the European Banking Authority (hereinafter – EBA).