ARTICLE
21 July 2026

US-UK Digital And Capital Markets Taskforce Makes 'Great Start'

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Cross-border stablecoin regulation faces significant challenges as jurisdictions like the US and EU develop incompatible frameworks for reserves and insolvency treatment. Matthew Bisanz of Mayer Brown examines the complexities of creating a seamless international system when each country insists on holding reserves domestically, and explores the unresolved questions around customer location in cross-border bankruptcy scenarios.
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“At least on the stablecoin side, I would think this is probably a late-2027 priority,” Bisanz said. “The US first needs to determine the prudential requirements for federal stablecoin issuers and what it means for state issuers to operate under a substantially similar regime. It can then decide when foreign countries have a substantially similar regime.”

In short, he said, “In the medium term, at least on the US side, this will probably remain more on the vague side.”

Bisanz said one area that required attention was the treatment of stablecoins in cross-border insolvencies, where he said there was “still a high degree of incompatibility”.

“For stablecoins, that is particularly difficult, because you do not always know where a customer is at a given time. If an issuer goes bankrupt, where is the customer legally located?” Bisanz said.

“The other big one is reserves. This is the money that stablecoin issuers hold to repay coinholders. The Genius Act implies that the reserves for US customers should be held in the US, and MiCA [the European Union’s Markets in Crypto-Assets Regulation] has, I think, a similar view for the EU.” Bisanz added. “How can you have a really cross-border, seamless system if everyone is insisting on reserves being held in their country to make sure they are safe?”

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