A dollar stablecoin that is legal to hold in one country is now, in several others, unlawful to sell. In the four weeks between 7 August and 1 September the United States, Singapore, the European Union and Japan each moved on the same question, which is what a regulator does about foreign stablecoins issued somewhere else. The four answers share almost nothing. They test different things, they are decided by different bodies, and none of them refers to the others.
The United States tests the reserves and the regime
Treasury’s proposed rule under the GENIUS Act, published on 18 August, sets two dates. From 18 January 2027 it is unlawful to issue a payment stablecoin in the United States unless the issuer is a permitted issuer, meaning a bank subsidiary or an OCC- or state-approved nonbank, or a “qualifying foreign payment stablecoin issuer.” From 18 July 2028 a digital asset service provider may not offer or sell any other foreign stablecoins to a US person. Comments close on 19 October.
To qualify as a foreign issuer, a company needs Treasury to have determined that its home regime is comparable, needs to register with the OCC, needs to hold reserves in a US financial institution sufficient for its US customers, needs the technical ability to comply with a lawful freeze or block order, and must not be domiciled in a sanctioned jurisdiction. Treasury has made no comparability determination for any country. The reserve test alone is the harder one. Tether’s most recent attestation shows roughly a quarter of the reserves behind about $190bn of USDT in gold, bitcoin and secured loans, none of which qualify under GENIUS. Tether’s answer has been to launch a separate domestic coin, USAT, issued through Anchorage Digital Bank since January. The largest issuer in the world looked at the foreign-recognition route and chose to add an American issuer instead.
Singapore tests equivalence and cooperation
MAS published its draft legislation on 1 September, three years after it first set out the framework. It creates a stablecoin issuance licence, reserves the label “MAS-regulated stablecoin” for holders of that licence, and makes misuse of the label a criminal offence with fines of up to S$250,000 for a company and up to three years in prison for an individual. Reserves must at least equal the coins in circulation at all times, in segregated trust accounts, redemption must happen at par within a prescribed period, and issuers may not pay “interest, returns or other benefits attributable (directly or indirectly) to the holding of the stablecoin.” Banks that want to issue must do so through a separate non-bank entity. Comments close on 16 October.
The new part is the second label. A foreign stablecoin can become an “MAS-recognised stablecoin” if its home framework is “substantively equivalent” to Singapore’s and if supervisory cooperation arrangements exist between MAS and the home regulator. Recognition is case by case, it is aimed at “cross-border wholesale use cases,” and MAS expects that “only a limited number of stablecoins will be authorised or recognised.” The US test asks where the reserves sit. Singapore’s asks whether the home regulator would pick up the phone.
The EU tests domicile
MiCA has no foreign stablecoin recognition route at all. An issuer of a euro or dollar token in the EEA has to be an authorised credit institution or e-money institution inside the bloc, and non-euro tokens used as a means of exchange face caps on daily transaction counts and value. Tether declined to seek authorisation, Coinbase delisted USDT for European users in December 2024 and Binance followed in March 2025. On 26 August Revolut, with 2 million customers in the first three launch markets, withdrew USDT from the EEA and Switzerland and began converting balances after 31 August.
What Revolut launched in its place shows how the domicile test is being met. Its euro stablecoin, EURR, is issued by Bridge Building S.A., the Luxembourg entity of Stripe-owned Bridge, with reserves managed under MiCA. Revolut distributes a coin that Stripe issues. The same split is behind Open USD in the United States, where the distributor keeps the economics and the issuer holds the licence, and it is the shape MiCA has produced for everyone who wants a euro coin without becoming a European e-money institution. Qivalis, the 37-bank consortium coin, is the other route, and it is still waiting on its Dutch authorisation.
Japan tests the distributor
Japan lets foreign stablecoins in, but through a licensed intermediary that takes on the obligations. A foreign stablecoin reaches Japanese users only through a registered electronic payment instrument service provider, which takes on the asset-preservation obligations for the coins it distributes and must clear the FSA’s equivalence standard for the home regime. SBI VC Trade has distributed USDC under that arrangement since 2025. Tether has no Japanese distributor, so USDT is not on any licensed platform. On 7 August the FSA created a dedicated division with a digital payment planning office, and on 24 August it removed the ¥1m per-transfer cap on stablecoins handled by second-category funds transfer providers, which is the licence JPYC, the yen coin, issues under. The domestic startup coin got its ceiling lifted in the same month the foreign incumbent stayed locked out.
Four tests, one coin that passes
Line the four up and the pattern is a coin-by-coin map. USDC passes in the United States through Circle’s national trust bank, in the EU through Circle’s French e-money licence, and in Japan through SBI, and Circle holds a Singapore payments licence that puts it in position for the new regime. USDT passes none of the four for retail use, and its issuer is rebuilding as a US domestic issuer to get through one of them. Every other coin sits somewhere between.
For a payments company that wants to settle a corridor in foreign stablecoins, the coin is now a licensing decision made twice, once at each end. A remittance that leaves Singapore in an MAS-recognised coin has to arrive in a coin the receiving regulator accepts, and there is no arrangement anywhere yet that says the two lists will match. The US and Singapore comment windows both close in October, and they are the first chance to argue for comparability determinations that line up. Until they do, the workable design is a settlement layer that does not care which coin it carries, with a licensed on-ramp and off-ramp at each end, which is the business that Bridge, BVNK and the network settlement platforms are building. The issuers chose their regulators. The corridors will be built by the companies that can work with all four.