[forvis mazars] Quarterly Insights: US Financial Services Regulatory Centre Q3 2025

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Stablecoin Mandate: Why 100% Backing Changes Everything

Q3 2025 marked a definitive pivot point for U.S. financial services: Regulation is actively laying the foundation for the digital asset economy.

Here’s the breakdown of regulatory shifts and why stablecoins are the core catalyst:

Economy & Regulatory Reset

The economic climate demands caution:

  • Inflation remains sticky at 2.9%.
  • Unemployment is cooling the labor market, rising to 4.3%.
  • Regulators are streamlining oversight, focusing intensely on core safety and soundness (capital, liquidity, credit quality). Less emphasis is placed on broad thematic reviews.

Stablecoin Insights: The Disruption is Now

The passage of the GENIUS Act in July 2025 created the first comprehensive federal framework for payment stablecoins.

  • This signals Congress’s stamp of approval for the technology.
  • Stablecoins are fundamentally different: they must be 100% backed by credit risk-free government securities.
  • This model, likened to a narrow bank, threatens to disintermediate traditional deposits.
  • Are banks prepared for disintermediation? Analysts warn that customers moving funds into regulated stablecoins could lead to trillions of dollars flowing out of bank deposit franchises.
  • Banks are “on notice” and must integrate digital asset services—by building, partnering, or leveraging consortiums—to compete.

Compliance Must Accelerate

As new payment rails emerge, compliance frameworks must keep pace.

  • Are your controls ready for high-velocity schemes? Fraudsters are blending traditional tactics with cutting-edge technology, surging the volume of suspicious activity.
  • Action Items:
    • Integrate fraud and AML monitoring for ** real-time intelligence**.
    • Expand digital asset sanctions screening capabilities to cover emerging payment rails like stablecoins.
    • Establish clear AI and model governance to protect against bias and regulatory scrutiny when using advanced analytics.

Scale is key. Consolidation is a certainty, driven by the need for technical and traditional banking skills to manage this complexity.

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