This article compares the emerging regulatory frameworks governing stablecoins in the European Union, the United States and the United Kingdom. It analyses the approach adopted by the European Union through the Markets in Crypto-Assets Regulation (MiCAR), the proposed federal framework for payment stablecoins contained in the United States GENIUS Act, and the evolving UK regime developed under the Financial Services and Markets Act 2023 and subsequent regulatory initiatives. While all three jurisdictions recognise that stablecoins perform money-like functions and therefore require prudential oversight, they have adopted markedly different regulatory strategies. MiCAR establishes a comprehensive market-regulation framework covering a wide range of crypto-asset activities. The United States approach focuses primarily on prudential supervision of payment stablecoin issuers, while the United Kingdom seeks to integrate crypto-asset activities within its existing financial regulatory architecture. The article argues that these differences reflect deeper institutional choices concerning the governance of private digital money and the evolving relationship between stablecoins, tokenised bank deposits and public monetary systems.

Read the entire article here: https://ssrn.com/abstract=6459583 or here: https://dx.doi.org/10.2139/ssrn.6459583.