Stablecoin Compliance & Issuance

Stablecoin regulation has undergone a transformation in 2025-2026. The EU MiCA framework now requires e-money token and asset-referenced token authorization. The US GENIUS Act provides federal clarity for payment stablecoin issuers. Hong Kong has enacted its Stablecoins Ordinance. Mauritius has introduced stablecoin reserve requirements. Every major jurisdiction now has specific rules for stablecoin issuance.

Our stablecoin practice addresses the full regulatory lifecycle: reserve structure design that satisfies 1:1 backing requirements, licensing applications under the relevant framework (e-money institution, payment institution, or stablecoin-specific license), and ongoing compliance including reserve audits, regulatory reporting, and holder rights management.

Reserve management is the most critical operational requirement for stablecoin issuers. Regulators require proof that reserves are held in specific asset classes (typically government bonds and bank deposits), segregated from operational funds, and subject to regular independent audit. We design reserve frameworks that satisfy these requirements across multiple jurisdictions.

Multi-jurisdiction stablecoin issuance adds complexity. A stablecoin offered in the EU, US, and Asia may be subject to three different regulatory frameworks simultaneously. We map the requirements of each framework, identify conflicts and overlaps, and design a compliance program that satisfies all applicable regulations without creating operational impossibility.