Transatlantic Stablecoin Oversight Takes Shape with EU, NY Cooperation

The memorandum of understanding, signed in May and made public on 2 Jun, establishes a framework for information sharing and supervisory coordination relating to international stablecoin activities. It builds on a broader cooperation agreement signed by the EBA and NYDFS in 2021, extending an existing banking supervisory relationship into the rapidly growing stablecoin market.

While the arrangement does not create new regulatory requirements for stablecoin issuers, it formalizes how regulators overseeing many of the same firms will share information and coordinate supervisory activities across jurisdictions.

Supervising the same issuers 

The MoU specifically provides for cooperation on matters including reserve composition, liquidity stress testing, governance arrangements, ownership structures, sanctions and supervisory measures. It also establishes quarterly information exchanges covering reserve assets and stablecoin circulation. 

In practical terms, the agreement reflects the reality that regulators on both sides of the Atlantic are increasingly overseeing the same firms and products. 

A fragmented US landscape 

Unlike the European Union, which has established a bloc-wide framework for crypto-assets under the Markets in Crypto-Assets Regulation (MiCA), the United States continues to rely on a combination of federal and state authorities for stablecoin oversight. 

Under the EU's MiCA, the EBA has supervisory responsibilities for significant stablecoin issuers. In New York, NYDFS oversees stablecoin issuers through its limited purpose trust company framework and virtual currency regulations, including the BitLicense regime. The agency serves as the principal state regulator for several dollar-denominated stablecoins, including USD Coin (USDC), Pax Dollar (USDP) and the Gemini Dollar (GUSD). 

Other US authorities also play a role in stablecoin oversight. The Federal Reserve supervises banks that may issue stablecoins or hold stablecoin reserves, while the Office of the Comptroller of the Currency (OCC) oversees national banks and federally chartered trust institutions. The Securities and Exchange Commission (SEC) and Commodity Futures Trading Commission (CFTC) may also assert jurisdiction depending on how stablecoins are used and marketed. 

GENIUS implementation 

The agreement also comes as US authorities implement the GENIUS Act, which created the country's first federal framework for payment stablecoins. The law requires issuers to maintain fully backed reserves, provide redemption rights and regular reserve disclosures, and comply with anti-money laundering and consumer protection requirements. It also establishes a dual regulatory structure under which federal banking regulators supervise larger issuers, while qualifying state regulators may continue overseeing certain state-chartered issuers.  

The act was signed into law in July 2025 and is scheduled to take effect in January 2027 or 120 days after regulators finalize implementing rules, whichever is earlier.