稳定币政策走向：美国向左，欧盟向右｜封面专题

Core Viewpoint - The article analyzes the differences between the European Union's "Markets in Crypto-Assets Regulation" (MiCA) and the United States' "Guidance and Establishment of a National Innovation Act for Stablecoins" (GENIUS), highlighting significant directional disparities in their approaches to stablecoin policies, particularly regarding the use of foreign and domestic stablecoins, reserve asset allocation, and illegal financial activity prevention [2][3]. Group 1: Overall Framework - Both the GENIUS Act and MiCA Regulation share a similar overall framework, which includes defining stablecoin functions, issuer admission, operational regulation, reserve asset investment, customer redemption oversight, and anti-money laundering measures [5]. Group 2: Functional Definition - Both acts define stablecoins as payment tools and prohibit issuers from paying interest to holders. The GENIUS Act classifies "payment stablecoins" as digital assets for payment or settlement, while MiCA distinguishes between Electronic Money Tokens (EMT) and Asset-Referenced Tokens (ART), both requiring issuers to ensure holders can redeem at face value without interest [6]. Group 3: Issuer Admission - Both regulations require issuers to be registered entities in their respective jurisdictions. The GENIUS Act mandates that payment stablecoin issuers must be U.S. registered entities meeting specific regulatory standards, while MiCA requires ART issuers to establish a legal entity in the EU and obtain authorization from their home regulatory authority [7]. Group 4: Operational Management - Both acts impose capital and risk management requirements on stablecoin issuers, referencing regulations applicable to payment institutions and banks. The GENIUS Act requires compliance with U.S. federal and state capital, liquidity, and risk management rules, while MiCA specifies information disclosure, governance, and risk management procedures for issuers [8]. Group 5: Usage of Stablecoins - The U.S. has no explicit restrictions on the types and usage of stablecoins, reflecting the dominant position of the U.S. dollar in global reserves and payments. In contrast, the EU imposes limitations on the types and scope of stablecoins, influenced by different considerations regarding currency sovereignty [10][11].