France and South Korea Both Want Banks-Only Stablecoin Issuance. The US Just Went the Other Way.
The Bank of Korea and Bank of France held a two-day joint seminar on April 7 covering digital assets and central bank policy. The headline takeaway: both countries are converging on the same regulatory model — only licensed banks should issue stablecoins pegged to local currencies. The United States, with its newly passed GENIUS Act, explicitly allows non-bank issuers.
Three major economies. Three different answers to the same question. The divergence matters.
South Korea: Banks Only, No Exceptions
South Korea is drafting legislation that would restrict won-pegged stablecoin issuance exclusively to licensed banks. The goal, according to the Bank of Korea, is preventing capital flight and maintaining monetary policy control. The law is expected by mid-2026.
Context matters here. South Korea saw a 55% plunge in domestic stablecoin holdings earlier this year as residents moved assets offshore through dollar-denominated tokens. The Bank of Korea watched billions in won-equivalent value leave the country via USDT and USDC. The banks-only rule is a direct response — if only regulated banks can issue won stablecoins, the central bank retains visibility and control over the flow.
France: MiCA's Strictest Interpreter
France requires stablecoin issuers to operate under supervision of the ACPR (Autorité de Contrôle Prudentiel et de Résolution), and full licensing under the EU's Markets in Crypto-Assets (MiCA) framework is mandatory by June 30, 2026. France has been running wholesale CBDC pilot programs and views private stablecoins as something to be absorbed into the regulated banking system, not competed against.
The seminar also featured discussions on CBDC interoperability — South Korea's "Project Han River" and France's wholesale CBDC experiments — exploring how sovereign digital currencies might work across borders.
The US Exception
The GENIUS Act, signed into law in mid-2025, takes the opposite approach. Non-bank entities can issue stablecoins under federal or state supervision. Circle is not a bank. Tether is not a bank. Both can continue operating. The FDIC's April 7 proposed rules create a bank-issuer track, but it's optional — not mandatory.
This creates a regulatory arbitrage that will play out over the next two years. A Korean resident who can't buy won-pegged stablecoins from anyone except their bank can still buy USDC from Circle through a Cayman-domiciled exchange. A French user subject to MiCA restrictions can access dollar stablecoins through non-EU platforms. The walls are going up, but the windows stay open.
Why This Seminar Matters
The Bank of Korea and Bank of France have been running academic exchanges since 2024, alternating sessions between Seoul and Paris. The stablecoin market has grown from roughly $50 billion to $311 billion in that period. Both central banks are watching dollar stablecoins erode local currency demand in real time — and choosing the same response: bring issuance inside the banking system or don't allow it at all.
The question is whether that strategy works when the world's reserve currency stablecoins are issued by companies that don't answer to either central bank.