Comparing Stablecoin Regulation in the US and Singapore

As the digital asset ecosystem matures, stablecoins — cryptocurrencies pegged to fiat currencies — have emerged as a cornerstone of decentralised finance and digital payments. The promise of price stability and utility in cross-border transactions has caught the attention of regulators. The question arising is: what is the optimal way to regulate the issuance and use of stablecoins? Generally, a stablecoin regulation would be dependent on the policy pursued by each sovereign state in relation to the specific facts and circumstances of an individual country. And among the most prominent jurisdictions leading this effort are the United States and Singapore. While both countries aim to ensure financial stability, consumer protection and fostering responsible innovation, their regulatory approaches reflect distinct philosophies and structural differences.

Legislative v Executive Approach to Regulation

The United States took a legislative route in regulating stablecoins. The Guaranteed Electronic Dollar for New Innovations and United States Stability (GENIUS) Act is a federal statute, which was signed into law by President Donald Trump on July 18, 2025, following its passage in the House of Representatives the previous day.

The GENIUS Act is a landmark legislation that provides a federal framework while allowing state-level initiatives, such as the Frontier Stable Token, which was recently issued by the state of Wyoming. This duality reflects the US’s complex regulatory architecture but also enables innovation at the state level.

Other key features of the GENIUS Act provide for:

• Permitted Issuers, where only insured depository institutions, approved nonbank entities, or state-qualified issuers can issue payment stablecoins;
• Reserve Requirements, under which Stablecoins must be backed 1:1 by high-quality liquid assets such as US Treasury bills or cash;
• Audit and Transparency, whereby Issuers are subject to regular audits and must disclose reserve composition;
• AML/CFT Compliance, which mandates that issuers must comply with anti-money laundering and counter-terrorism financing rules; and
• Consumer Protection, in that stablecoin holders are granted priority repayment rights in case of issuer insolvency.

In contrast, Singapore’s approach to stablecoin regulation could be described as a principles-based, executive-led framework. The issues concerning the problems and prospects of regulating stablecoins were not debated in the Singapore parliament (which is the law-making body of the Republic). The authority to supervise the issuance and use of stablecoin in Singapore comes under the oversight of the Monetary Authority of Singapore (MAS), which functions as Singapore’s central bank and financial regulator. In exercise of this executive mandate, the MAS, in consultation with the industry players, finalised its stablecoin framework in August 2023. This was part of a broader effort to position Singapore as a hub for responsible digital finance, and the key features include:

• Application: the scope of the regulatory framework applies to single-currency stablecoins (SCS) pegged to the Singapore Dollar or G10 currencies issued in Singapore;
• Reserve Asset Requirements: whereby Issuers must maintain a portfolio of low-risk, high-quality liquid assets, with monthly attestations.
• Capital and Liquidity: Minimum base capital and liquid assets are required to reduce insolvency risk.
• Redemption at Par: Issuers must redeem stablecoins at face value within five business days.
• Licensing: Issuers exceeding S$5 million in circulation must obtain a Major Payment Institution license (under the Payments Services Act)
• Labelling and Disclosure: Only compliant issuers may label their tokens as “MAS-regulated stablecoins,” helping users distinguish them from unregulated digital payment tokens.

Singapore’s framework, which was issued after the collapse of the algorithmic stablecoin TerraUSD (UST) is a centralised and prescriptive, emphasising value stability, consumer protection, and operational resilience. It avoids the ambiguity of multi-agency oversight and provides clear pathways for compliance.

Strategic Contrast

The GENIUS Act signals a progressive shift toward harmonised regulation but retains flexibility for state-level innovation. This could spur diverse stablecoin models but may also create compliance complexity. In contrast, the MAS’s framework offers clarity and predictability, making it attractive for institutional players seeking regulatory certainty. However, its strict requirements may limit smaller issuers in the FINTECH space.

Conclusion

The US and Singapore provide two distinct regulatory models. The US emphasises federal oversight with room for state-led innovation, while Singapore champions centralised prudence and consumer trust. As global stablecoin adoption accelerates, these regulatory models will influence not only domestic markets but also international standards for digital asset governance.

Comparing Stablecoin Regulation in the US and Singapore was originally published in Pundi X on Medium, where people are continuing the conversation by highlighting and responding to this story.