- Spotlight
- Apr 09, 2026
The New Financial Order of 2026 and the Transatlantic Stablecoin Divide
Gal Arad-Cohen, partner, and Ilya Kasselman, associate at S. Horowitz & Co., discuss how a global payment revolution is creating a regulatory divide over policy and control of the digital monetary system.

2026 has shown that stablecoins are no longer a marginal phenomenon within the crypto ecosystem. To the contrary, they have evolved into key cross-border financial products, blurring the traditional boundaries between conventional banking and decentralized finance.
Over an astoundingly short period of time, growing stablecoin adoption has pushed total market capitalization beyond $300 billion, representing an over 45% increase since January 2025, when the figure stood at $205 billion. Even in the first quarter of 2025, stablecoins accounted for 3% of global cross-border payments for remittances, with stablecoin circulation having doubled between January 2024 and July 2025.
Individuals, traditional financial institutions, regulators, and governments around the world have all clearly realized how valuable stablecoins are for their ability to serve as a functional bridge between the decentralized blockchain world and the traditional financial system.
Inside the global payment revolution
The draw of stablecoins is clear. They offer a quick and low-cost solution to international transfers, with near-instant payments across borders, regardless of the parties’ geographic location, at a negligible cost compared to traditional alternatives.
Stablecoin transfers can cost as little as $0.01 per transaction, with settlement occurring within seconds or, at most, a few minutes. By comparison, an international wire transfer could cost orders of magnitude higher and take several business days, without factoring in extra costs like currency conversions.
Unsurprisingly, major fintechs and traditional financial institutions have seen the potential. PayPal and JP Morgan have already launched their own stablecoins, while Mastercard announced a definitive agreement to acquire the stablecoin-infrastructure company BVNK for up to $1.8 billion.
But stablecoins provide much more than a novel way of transferring funds around the world.
In countries with foreign exchange controls, high inflation, economic instability, or limited access to stable financial instruments, stablecoins have become a primary means of storing value, conducting daily purchases, and even paying bills. This is evident in countries like Nigeria, Turkey, Argentina, and Venezuela, where stablecoins are widely used for coping with the sustained depreciation of local currencies.
Beyond stability, speed, and cost efficiency, a critical advantage of stablecoins lies in their programmability. As blockchain-based money, stablecoins constitute programmable money, enabling the use of advanced crypto technologies like smart contracts.
The explosive growth of stablecoins comes from their potential for intelligent, accessible financial infrastructure, allowing the creation of innovative financial products that break down barriers without reliance on traditional intermediaries.
Divergent winds of change
Stablecoin regulation is not just a financial issue; it is also a geopolitical tool reshaping the global balance of economic power. With such seismic shifts to global financial infrastructure, governments around the world are introducing regulatory frameworks to not only make sure these tools aren’t misused but also to provide clarity and encourage innovation.
On July 18, 2025, the United States adopted a comprehensive federal framework governing stablecoins by enacting the Guiding and Establishing National Innovation for U.S. Stablecoins Act, more commonly known as the GENIUS Act.
Prior to its enactment, stablecoins operated within a fragmented and inconsistent regulatory landscape, lacking a unified federal framework governing their issuance. Instead, US issuers relied on existing laws, obtained state-level licenses, like New York’s BitLicense, and were sometimes subject to state money transmission laws, resulting in regulatory “grey zones” and legal uncertainty.
The GENIUS Act established a unified regulatory framework for stablecoins, intended to bring order to the stablecoin market, opening new opportunities for financial institutions, businesses, payment service providers, and consumers alike.
More broadly, it makes clear that the United States views blockchain technology and stablecoins as strategic levers to preserve and even strengthen its economic and geopolitical influence.
US regulation follows earlier developments in the EU, which adopted the Markets in Crypto-Assets Regulation (MiCA)in 2023, the first comprehensive crypto-asset regulatory framework within a major economy.
While both aim to provide stability and consumer protection, the EU applies a cautious uniform regulatory regime across all Member States, with stringent licensing and supervision by national authorities. The United States, by contrast, employs a flexible dual federal-state structure.
Behind these differences lies an underlying economic and geopolitical dynamic. U.S. dollar-pegged stablecoins, which dominate global markets, reinforce the dollar’s dominance in the international financial system, even in regions previously less reliant on it. They also directly strengthen the US economy. According to the IMF, the Tether-issued USDT and Circle-issued USDC account for around 90% of the stablecoin market, with both pegged to the US dollar.
Stablecoin issuers have become major holders of US government debt, with holdings comparable to those of large sovereign investors like South Korea, Saudi Arabia, and Germany. This creates a new mechanism for deepening global economic ties with the US financial system.
From the US perspective, stablecoins are a tool for reinforcing US dollar hegemony in the digital era.
In Europe, however, alarm is growing. The European Central Bank and the European Stability Mechanism have warned that widespread adoption of dollar-pegged stablecoins could erode monetary sovereignty and lead to deposit outflows from the local banking system.
Sensing an opportunity, private European banks have announced a joint initiative to launch a euro-pegged stablecoin compliant with MiCA, planned for the second half of 2026.
The European Central Bank is also prioritizing its central-bank digital currency (CBDC) project, aiming for a full rollout of a digital euro across Europe that would be issued by banks and not use a public blockchain.
The US Senate, in contrast, has passed a bill banning the Federal Reserve from issuing CBDCs until 2030.
This divergence reflects a deeper strategic asymmetry between the United States and the European Union. For the United States, the global expansion of dollar-pegged stablecoins is largely beneficial regardless of where issuance occurs. The EU, however, bears greater risks with regard to monetary control and financial stability.
Even so, the growth of the sector in the United States is unlikely to be seamless. Key questions remain around the supervisory authority among federal and state regulators, the practical rigor of reserve management and attestations, consumer and insolvency protections in stress scenarios, and how effectively US standards will translate across international, fragmented jurisdictions.
Preparing for the road ahead
Whatever lies ahead following the recent regulatory developments in the United States and Europe, one thing is clear: stablecoins are no longer confined to the crypto sphere. They are a central pillar of the future global financial system. Alongside geopolitical competition over rule-setting, US and EU regulation brings stability and legal clarity, and also significant potential for economic growth.
These frameworks are establishing a legal foundation that enables institutional players, small businesses, and entrepreneurs to operate securely, leverage competitive advantages, develop new services, and reach audiences previously beyond their reach. At the same time, traditional companies that once hesitated to engage with crypto are beginning to see it as less of a risk and more of an opportunity, firmly established in the financial mainstream. For businesses, the immediate priority is to treat stablecoin compliance as a core product requirement. Map the applicable regimes, select issuance and custody partners with demonstrable reserve and governance controls, and design payment, redemption, and disclosure processes to meet the highest common standards across jurisdictions. Done properly, stablecoin compliance can live up to its name.
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