Publication Details
Abstract
Objective: This article examines the systemic compliance risks posed by stablecoins through a comparative legal analysis of three regulatory paradigms: the European Union’s Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114), the United States’ Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act, enacted July 2025), and the nascent frameworks of Central Asian jurisdictions, principally Uzbekistan and Kazakhstan. Method: The analysis draws on FATF guidance, Financial Stability Board recommendations, IMF analysis, and primary legislative sources to examine stablecoin compliance risks within these regulatory frameworks. Results: The article argues that while MiCA and the GENIUS Act represent meaningful regulatory advances, persistent gaps in Travel Rule enforcement, reserve transparency, sanctions compliance, and cross-border supervisory cooperation create systemic vulnerabilities, particularly in emerging markets. Novelty: This article offers a comparative legal perspective on stablecoin regulatory challenges, focusing on the convergence of financial regulation, anti-money laundering law, and digital asset policy across major jurisdictions, with particular emphasis on emerging markets like Uzbekistan and Kazakhstan.