US and EU Take Divergent Paths on Crypto Regulation

The United States and European Union have taken different approaches to regulating cryptocurrencies. The GENIUS Act, passed in the US on July 18, 2025, specifically targets payment stablecoins, while MiCA, implemented in the EU since June 2023, covers a wide range of crypto assets, issuers, and service providers under a single rulebook.

Under the GENIUS Act, only bank subsidiaries, OCC-approved federal nonbank issuers, and state-qualified issuers with less than $10 billion in outstanding coins are allowed to issue stablecoins. These issuers must hold reserves equal to the outstanding coins and report them monthly, with a registered accounting firm examining the reports.

Contrastingly, MiCA requires that stablecoin issuers be authorized credit institutions or licensed e-money institutions. At least 30% of the reserves must be held in EU bank deposits, rising to 60% for significant tokens under the EBA's technical standards.

Tether's CEO, Paolo Ardoino, has cited this 60% rule as a reason why his company chose not to apply for an EU license. As a result, Tether has left the European market, while Circle has secured licenses in both the US and Europe.