US–EU Split Creates Two Stablecoin Markets, CertiK Warns

Key Takeaways

• CertiK says U.S. and EU regulations are creating two separate stablecoin liquidity zones.
• The U.S. GENIUS Act integrates stablecoin issuers into the banking system and reinforces dollar strategy.
• MiCA’s banking-reserve rules raise concerns about concentration risk and barriers for smaller issuers.

Instead, the firm argues, 2025 marked the beginning of a structural divide — one in which stablecoin liquidity clusters around two incompatible regulatory systems: a U.S.-centric model and a European Union model shaped by MiCA.

A Shift Driven by Washington, Not the Market

Rather than letting market forces determine how stablecoins evolve, U.S. policymakers have now imposed a blueprint that redefines their role inside the financial system. CertiK singles out the GENIUS Act as the catalyst. Signed by President Donald Trump, the law draws bright lines around who may issue stablecoins, what their reserves must look like, and what forms of yield or financial engineering are prohibited.

The most important consequence, however, is political: stablecoins are now treated as extensions of U.S. monetary power. Issuers operate under a regulated framework that is tightly integrated with the domestic banking system, giving the U.S. a high degree of influence over dollar liquidity in digital markets.

This approach naturally pulls liquidity inward. CertiK describes it as the emergence of an American stablecoin zone, where compliance and reserve structure are aligned with U.S. financial norms rather than international harmonization.

Europe Moves in a Different Direction — For Different Reasons

While the U.S. has wrapped stablecoins into its monetary strategy, Europe’s motivations are more defensive. MiCA, the EU’s flagship crypto regulation, was built to mitigate risk, tighten supervision, and strengthen consumer protection.

One of its more contested provisions requires that most reserves backing a stablecoin be deposited in European banks. Policymakers see this as a stability safeguard, but industry participants warn it could amplify banking-sector concentration. Tether CEO Paolo Ardoino recently cautioned that forcing issuers into fractional-reserve institutions creates vulnerabilities rather than eliminating them.

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Other critics — especially smaller fintech firms — fear that MiCA’s compliance costs and capital thresholds will cement a market dominated by a handful of large issuers. What the EU views as prudential oversight, startup operators experience as a barrier to entry.

Divergent Rules Produce Divergent Markets

CertiK’s report concludes that the divergence is more than philosophical — it is operational. U.S. stablecoins and EU stablecoins are now governed by rules that make mutual interchangeability difficult. Liquidity pools are hardening along jurisdictional lines, and the firm expects cross-border flows to experience new friction.

This could lead to price gaps between U.S. and EU-issued stablecoins, regional arbitrage strategies, and settlement inefficiencies, especially for businesses operating across both markets.

Stablecoins Become a Tool of Dollar Strategy

Perhaps the most striking observation in CertiK’s analysis is the explicitness of U.S. intentions. Treasury Secretary Scott Bessent publicly stated earlier this year that stablecoin regulation is part of a broader financial strategy designed to reinforce the dollar’s global role.

His remarks confirm a shift: stablecoins are no longer viewed only as payment tools or fintech products, but as instruments of economic statecraft. That recognition all but guarantees continued divergence between the U.S. and EU, each now prioritizing its own strategic and regulatory agenda rather than global uniformity.

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