Japan
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Japan's FSA Publishes Survey of Financial Systems in 8 Overseas Jurisdictions, Including Stablecoin Regulation
- US: The GENIUS Act, enacted July 18, 2025, is the first comprehensive federal stablecoin framework; following the OCC's final rule on October 21, 2026, it takes effect January 18, 2027, incorporating the SEC-CFTC joint interpretive guidance of March 17, 2026 on when crypto transactions fall under federal securities law.
- EU/UK: Under MiCA (fully applicable since December 30, 2024), countries like France and Italy used the maximum 18-month transition period for existing operators, ending June 2026; the UK FCA's proposed stablecoin rules require third-party custody of backing assets, next-business-day redemption payment, and a ban on interest distribution to holders.
- China/Hong Kong diverge sharply: China's February 6, 2026 notice (replacing a 2021 rule) bans crypto-fiat exchange, unauthorized offshore yuan-stablecoin issuance, and domestic RWA issuance/trading except with formal approval, while Hong Kong's SFC expanded tokenized securities offerings and allowed cross-border order book integration via two November 3, 2025 circulars.