New US rules for stablecoins are reshaping the structure of the global crypto market. According to a new CertiK report, the GENIUS Act — signed by President Donald Trump in July — brings long-awaited regulatory clarity but also a significant structural shift: the market is beginning to split into two regions, the United States and the European Union.

The GENIUS Act represents the first federal framework for payment stablecoins. It introduces strict reserve requirements, bans yield-bearing stablecoins, and integrates issuers deeply into the US financial system. CertiK notes that this may strengthen institutional confidence and attract additional capital, but it also creates a separate US liquidity pool increasingly detached from the rest of the world, especially the EU.

Europe’s MiCA faces criticism over banking risk

The EU’s MiCA regulation, which also bans yield-bearing stablecoins and requires immediate redemption at par, is drawing a different wave of criticism. One of the most contested rules requires issuers to keep most reserves in banks headquartered in the EU. Tether CEO Paolo Ardoino has called this potentially dangerous, noting that European banks operate on fractional reserves and lend out deposits, exposing stablecoins to traditional banking risks.

Anastasija Plotnikova of Fideum adds that strict EU rules may strengthen dominant players and increase entry costs, pushing the market toward consolidation and limiting innovation.

Regulations serve domestic priorities, not global market unity

CertiK stresses that neither US nor EU policymakers aim to preserve global fungibility of stablecoins. The US focuses on reinforcing dollar dominance, while Europe prioritizes banking stability and oversight. These diverging goals are shaping the emergence of two distinct market ecosystems.

The US approach also carries geopolitical weight. Treasury Secretary Scott Bessent has said the US will use stablecoin regulation as a tool to maintain global monetary influence — a stance that widens the gap with Europe.

Liquidity fragments as cross-border friction increases

CertiK expects liquidity flows to become increasingly regionalized. Fragmentation may raise the cost of cross-border settlement, complicate infrastructure, and create opportunities for regional arbitrage. Digital assets originally designed to be global are becoming products constrained by jurisdiction.

According to CertiK, 2025 will be a turning point. Instead of one global market for stablecoins, two separate systems are emerging — shaped not only by economics but also by geopolitical ambitions.

Sources:

https://www.todayonchain.com/news/article/01KBMVJEQPKKEYZHH8M3GTQTX9/

https://www.cryptopolitan.com/imf-sets-stablecoin-risk-principles/