The regulation of stablecoins has become a pressing issue for governments and financial institutions worldwide. In the US, the Office of the Comptroller of the Currency (OCC) has issued guidance on national banks' authority to provide cryptocurrency services, while in Hong Kong, the Financial Services and the Treasury Bureau have introduced a new regulatory framework for digital assets.
The EU's approach is more complex, with the European Banking Authority's (EBA) 'no-action letter' clarifying the interaction between MiCA and PSD2. The EBA has proposed two legislative amendments to revise MiCA and amend PSD3, aiming to establish a single framework for e-money token activities.
Despite these differences, five core principles have gained global consensus: the 1:1 reserve principle, reserve segregation, prohibition of interest payments, anti-money laundering compliance, and consumer protection. The 'convergence of principles but differentiation in details' reflects a competition among jurisdictions for rule-making power.