Gibson Dunn Releases Comprehensive Cross-Border Guide to Global Stablecoin Regulation
International law firm Gibson Dunn & Crutcher LLP on March 13, 2026 published a sweeping cross border regulatory guide titled "Global Stablecoin Rules in Focus: A Cross Border Guide to the New Era of Stablecoin Regulation," covering six major jurisdictions and providing the most detailed comparative analysis yet of the regulatory frameworks shaping the global stablecoin market [1][2]. The guide arrives at a moment when issuers, exchanges, and institutional users face a patchwork of national rules that diverge on licensing, reserves, custody, and foreign issuer access. Six Jurisdictions, One Fragmented Landscape The guide covers the United States (GENIUS Act), the European Union (Markets in Crypto Assets Regulation, or MiCA), the United Kingdom , Hong Kong , Singapore , and the United Arab Emirates [1]. Each jurisdiction mandates 1:1 reserve backing, but the similarities thin rapidly from there. Reserve composition rules, disclosure frequency, custody structures, and the treatment of foreign issuers vary materially across borders. Gibson Dunn's authors, a nine lawyer team spanning New York, London, Singapore, Hong Kong, Dubai, and Washington, frame the stakes plainly: "Stablecoins have moved from experimental rails to core market infrastructure, prompting regulators around the world to define who may issue them, how reserves must be held, and what rights users have upon redemption." | Jurisdiction | Framework | Reserve Ratio | Reserve Assets | Yield to Holders | Audit/Disclosure | | | | | | | | | United States | GENIUS Act (signed July 2025) | 1:1 | USD, deposits, T bills (93 days or less), approved liquid assets | Prohibited | Monthly public; CEO/CFO certified; annual audit | | European Union | MiCA (in force mid 2024) | 1:1 | Highly liquid instruments; min. 30% EU bank deposits | Prohibited | White paper; 6 month audit for significant EMTs | | United Kingdom | FSMA 2023 (transitional) | 1:1 | Secure, liquid, low risk; min. 5% UK bank deposits | Prohibited (proposed) | Quarterly disclosure; annual audit | | Hong Kong | Stablecoins Ordinance (Aug 2025) | 1:1 + over collateralization | Bank deposits (3 months or less); govt debt (1 year or less); overnight repos | No explicit prohibition | Weekly attestations to HKMA; white paper required | | Singapore | Payment Services Act (amendments pending) | 1:1 (marked daily) | Cash/equivalents; govt debt (3 months or less residual maturity) | Not permitted | Monthly public attestation; annual audit | | UAE | CBUAE PTSR; VARA; FSRA; DFSA | 1:1 | High quality liquid reserves | Prohibited | Varies by regulator; VARA requires monthly audit | The U.S. GENIUS Act: Three Paths, One Prohibition Under the GENIUS Act, signed on July 18, 2025 , domestic issuers must choose among three pathways: operating as a subsidiary of an insured depository institution, obtaining a federal charter from the OCC, or securing state approval [1]. Foreign issuers may register with the OCC beginning July 18, 2028 , provided their home jurisdiction receives a "comparable" determination from the Treasury Secretary. Reserves must be held in USD, deposits, short term Treasuries with 93 days or fewer remaining maturity, and other approved liquid assets. Rehypothecation is prohibited. Monthly public reporting on reserve composition, certified by the CEO and CFO, is mandatory. The guide flags that reserve localization requirements for foreign issuers, which demand U.S. based reserves sufficient for domestic customer liquidity, represent a significant operational constraint [1][2]. MiCA's Passport and Its Dollar Problem The EU's MiCA framework, fully in force since mid 2024, offers a powerful competitive advantage: a single regulatory passport valid across all member states [1]. Only EU authorized credit institutions or electronic money institutions may issue e money tokens. At least 30% of received funds must be deposited with EU credit institutions. Yet the guide identifies a structural tension. MiCA's "multiple issuance" structures allow non EU issuers to circulate dollar denominated stablecoins backed by non EU reserves, a loophole that potentially undermines the euro's role in European payments [1]. The European Commission is considering granting the European Banking Authority more direct oversight over "significant CASPs" and tighter controls on delegation to third countries. The UK's Missing Exemption The United Kingdom is moving toward a comprehensive framework under the Financial Services and Markets Act 2023, with FCA authorization applications expected between September 30, 2026 and February 28, 2027 , and the full regime anticipated to commence in October 2027 [1]. Reserve rules would require a minimum 5% of reserves in on demand UK bank deposits, with assets held in statutory trust. Gibson Dunn flags a notable gap: the Cryptoassets Regulation omits a clear "overseas persons exemption," meaning foreign firms issuing stablecoins into the UK may avoid full FCA regulation while domestic issuers shoulder strict prudential and disclosure obligations [1]. The resulting uneven playing field could discourage UK domiciliation. Hong Kong and Singapore: Divergent Signals Hong Kong's Stablecoins Ordinance, effective since August 2025, stands out for its strict localization requirements and its expectation of over collateralization above the 1:1 floor [1]. Senior management must reside in Hong Kong. Only HKMA licensed stablecoins may be offered to retail investors. Singapore's approach under the Payment Services Act applies only to single currency stablecoins referencing a G10 currency or the Singapore dollar [1]. Issuers meeting all MAS requirements can market their products as "MAS regulated stablecoins," a quality signaling mechanism unique among the jurisdictions surveyed. The UAE's Layered Architecture The UAE presents the most complex regulatory map, with federal rules under the Central Bank (CBUAE) coexisting alongside free zone regulators VARA (Dubai), FSRA (Abu Dhabi Global Mar…