PRIMER: Global Capital and Liquidity Regulations for Digital Assets
Updated: Sep 23
Below is a summary of the capital and liquidity regulations for banks for holding digital assets as at the time of writing (Sept 17th, 2026).
The below was prepared using the research function in Claude. I have vetted it and questioned Claude in certain areas where I think it had misinterpreted something; however, one should do their proper due diligence before relying on AI to take any financial positions. For me, the intent was educational, i.e., to get a high-level understanding of the current status of key regulatory regimes as well as understand any developing discrepancies. I am comfortable relying on AI for these purposes because, if you know me at all, I’m all about working smarter, not harder and AI was able to prepare this summary way faster than I could have.
For reference, my initial prompt was:
I would like to prepare a comparison table of the different regulatory requirements for banks holding of digital assets from a capital and liquidity perspective. I want to focus on Basel, Canadian, US, UK, European, Singaporean, HK, and UAE regulations. I recognize the landscape is changing so I want to focus on current regulations so need you to include a summary of where things stand (whether finalized or in progress), as of what date (it should be the most current), any announcements of pending finalization or amendments coming. Do not guess so ask if you have any questions.
I want it to be relatively high-level, as if I was talking to the CEO, CFO, CRO, and Treasurer about the implications of different strategies. Please provide the sources to all information that you include in the table. You can include a section on industry rumours but otherwise all information should be from official regulatory websites/channels.
Bank Holdings of Digital Assets: Capital & Liquidity Regulatory Comparison
Executive summary
The global Basel crypto standard technically took effect on 1 January 2026, but it is under an expedited review, and of the seven national or regional regimes covered here only Canada and Hong Kong have fully implemented it. The US and UK have not adopted it, Singapore has deferred to 2027 or later, and the EU is operating a transitional regime. Canada has just gone further: OSFI published its final 2027 guideline on 10 September 2026, easing hedge recognition and the exposure limit. The Basel Committee has promised an update later in 2026, so the rules we plan against today may change.
Three practical messages emerge. First, tokenised traditional assets are converging on "same asset, same capital": the US, UK and Hong Kong (subject to conditions) now allow this even on permissionless blockchains, whereas the Basel standard as currently written does not [1]. Second, stablecoins held on balance sheet remain capital-intensive almost everywhere Basel applies, because most major stablecoins run on public blockchains, and none qualify as HQLA for liquidity purposes. Third, principal positions in unbacked crypto such as bitcoin remain close to dollar-for-dollar capital in every Basel-aligned jurisdiction, with Canada the most permissive on volume (5% of Tier 1) and the US the least prescriptive but narrowest on permissibility.
Because home-country consolidated rules generally apply at group level, booking an exposure in a more permissive jurisdiction will not by itself avoid a stricter home-regulator treatment. Please treat this note as a regulatory summary, not legal or risk advice; bracketed numbers refer to the source list at the end.
Table 1. Where each regime stands
Jurisdiction | Current regime & legal status | Most recent official action (date) | Pending / announced changes |
Basel (BCBS) | Final standard, but under review. SCO60 (Dec 2022, amended Jul 2024) sets the global prudential treatment; agreed implementation date 1 Jan 2026 [1][2][3]. Not self-executing: applies only once each jurisdiction transposes it. | 20 May 2026: Committee "took note of progress" on its expedited targeted review [6]. 9 Mar 2026: GHOS endorsed the targeted review in light of market developments [4]. | Update promised "later this year" (2026) [6]. Scope of the review not published. This is the single biggest swing factor for every Basel-aligned jurisdiction below. |
Canada (OSFI) | Finalised and in force. The final 2027 Guideline was published 10 Sep 2026 and takes effect 1 Nov 2026 / 1 Jan 2027 [33][34]. Basel-based, but more permissive than Basel (see Table 2). | 10 Sep 2026: final Guideline (2027) published, with two changes: cross-exchange hedge recognition for Group 2a, and exclusion of client-clearing derivative exposures from the Group 2 limit [33][34]. 21 May 2026: draft published; consultation closed 20 Jul 2026 [9][10]. | OSFI is still examining the Group 2a risk weight and crypto as collateral; no change proposed yet [8][34]. Stablecoin Act (Bank of Canada) received Royal Assent 26 Mar 2026; not yet in force [11]. OSFI says it will update the guideline as international standards evolve [34]. |
United States (Fed / OCC / FDIC) | Basel crypto standard not implemented. No crypto-specific bank capital or liquidity rule; general capital rules apply. Agencies have stated the capital rule is technology-neutral for tokenised securities [12][13]. | 5 Mar 2026: interagency FAQs on capital treatment of tokenised securities [12][13]. Feb–Aug 2026: GENIUS Act proposals: OCC (25 Feb) [16][17], FDIC (7 Apr) [18], Treasury (18 Aug; comments to 19 Oct 2026) [19]. | The statutory rulemaking deadline of 18 Jul 2026 passed without final rules. No final OCC, FDIC, Fed or Treasury rule had been published as at 17 Sep 2026 [17][18][19]. Effect: the Act takes effect on the earlier of 18 Jan 2027 or 120 days after final regulations, so the Jan 2027 date now governs [16][17]. Proposals include capital, liquidity and reserve requirements for bank-subsidiary issuers [17][18]. |
United Kingdom (PRA / BoE) | Interim supervisory expectations; Basel standard not yet implemented. PRA Dear CEO letter (18 May 2026) replaces the 2022 letter and applies existing PRA rules [20]. | 18 May 2026: PRA letter on tokenised assets, stablecoins and other cryptoasset exposures [20]. 22 Jun 2026: BoE policy statement and draft Code for sterling systemic stablecoins [21]. | PRA expects to consult on a future framework in 2028 at the earliest, after the Basel review [20]. BoE systemic stablecoin Code: consultation closes 22 Sep 2026 with finalisation targeted end-2026 [21]. |
European Union (EC / EBA) | Transitional regime in force under CRR3 Art. 501d since 9 Jul 2024 [22][23]. Permanent regime not yet proposed. | 5 Aug 2025: EBA final draft RTS on calculating/aggregating crypto exposures, submitted to the Commission [23]. Commission legislative proposal was due by 30 Jun 2025 [22]; none appears on the Commission prudential timeline (updated 17 Jul 2026) [24]. | Commission legislative proposal for a dedicated regime (capital, liquidity, leverage, limits) outstanding [22][24]. I could not confirm Commission adoption of the EBA RTS; please verify. |
Singapore (MAS) | Consulted, finalisation deferred. Basel-aligned amendments to MAS Notices 637 (capital), 649 (liquidity) and others proposed Mar 2025 [25]. | 9 Oct 2025: MAS response deferring implementation to 1 Jan 2027 or later [26]. | MAS to provide updates on final standards and implementation date "in due course" [26]. No 2026 update located. Interim: banks must notify and engage MAS on the prudential treatment of any cryptoasset exposure [26]. |
Hong Kong (HKMA) | Finalised and in force from 1 Jan 2026. Banking (Capital), (Disclosure) and (Exposure Limits) (Amendment) Rules 2025, plus new SPM module CRP-1 [27][28]. | 3 Jun 2026: HKMA circular easing a CRP-1 condition for tokenised traditional assets on permissionless blockchains (effective immediately) [29]. 27 Nov 2025: final SPM modules, disclosure templates and returns [27]. | HKMA will reflect the Jun 2026 clarification in CRP-1 "in due course" [29]. Expect further alignment once the Basel review concludes (no official date). |
UAE (CBUAE) | No crypto-specific bank capital or liquidity standard located on the CBUAE Rulebook. General Basel-based Capital Adequacy Standards apply [30]. | No bank-prudential crypto publication located. CBUAE AML guidance on virtual-asset risks for licensed FIs [32]. | No bank capital or liquidity change announced on official channels that I could locate. Separately, the one-year transition under the new CBUAE Law (Federal Decree-Law No. 6 of 2025) expired on 16 Sep 2026, bringing virtual-asset payment services and enabling technology into the licensing perimeter. Dates are from law-firm commentary, not a CBUAE notice. DIFC (DFSA) and ADGM (FSRA) free zones have separate regimes, not covered here. |
How Digital Assets are Classified for Regulatory Purposes
Most of the regimes in Table 2 use four categories which the Basel standard created. The labels matter commercially: the charge for the same economic exposure can differ more than tenfold depending on the box it falls into, and the classification is the bank's own documented assessment, open to supervisory override [1].
Examples are illustrative only. No regulator publishes a list of named assets by group, and similar-looking instruments can land in different groups depending on legal rights, ledger and reserve arrangements. Each holding needs its own assessment.
Category | What it covers | Illustrative examples | Broad capital outcome |
Group 1a Tokenised traditional assets | A digital representation of a conventional asset (a bond, a money-market fund unit, a loan) recorded on a ledger, where the holder has the same legal rights as holding it directly. | The UK Government's Digital Gilt Issuance Pilot in the Bank of England's Digital Securities Sandbox: the PRA has said it would expect treatment aligned with traditional government debt [20]. In the US, an "eligible tokenised security" — a tokenised Treasury, equity or ETF [12]. | Same as the equivalent non-tokenised asset, plus any infrastructure risk add-on a supervisor chooses to apply [1]. Requires all four classification conditions. |
Group 1b Qualifying stablecoins | Tokens designed to hold a stable value against a reference asset, typically a single fiat currency, backed by a reserve. | Necessarily generic, as no regulator publishes a list: a fiat-referenced token from a regulated issuer, fully reserved and redeemable at par. The closest official analogues are MiCA-compliant e-money tokens and asset-referenced tokens [22], and prospective permitted payment stablecoin issuers under the GENIUS Act [17]. | Capital based on the risks of the specific structure and the reserve assets, rather than a flat charge [1]. Requires the four conditions plus reserve-asset and redemption tests, tightened in July 2024 [2]. |
Group 2a Hedgeable other crypto | Anything failing Group 1, but liquid enough to meet the hedging-recognition criteria. In practice the large, actively traded tokens. | Bitcoin and ether are the standard candidates, given deep regulated derivatives markets. This is candidacy, not classification: the bank must show the hedging criteria are met, and Canada's draft 2027 guideline concerns hedges on regulated exchanges [9][10]. | Broadly a 100% capital charge on the net position, with limited recognition of hedges [1]. |
Group 2b All other crypto | Everything else: illiquid or unbacked tokens, non-qualifying stablecoins, and funds or derivatives whose value primarily derives from 2b assets. | Algorithmic stablecoins, expressly excluded from Group 1 [1]. Spot crypto ETFs and funds deriving value primarily from 2b assets, plus equity, derivative or short positions in them — stated explicitly by Hong Kong [28]. Any long-tail or illiquid token, and anything held before classification is agreed. | 1,250% risk weight and no hedging recognition, close to dollar-for-dollar capital. Canada deducts these from CET1 instead [1][7]. This is also the default while a classification is unconfirmed. |
Central bank digital currencies are excluded from the standard; Hong Kong clarified their treatment separately [1][27].
The four classification conditions cover: the nature of the asset and its redemption or transfer mechanics; legal enforceability and settlement finality; the identification and management of material risks, including the ledger itself; and whether the entities running the arrangement are regulated and supervised [1].
The third condition does most of the work. The Committee's position has been that the risks of public, permissionless blockchains cannot presently be sufficiently mitigated, so assets on those chains cannot reach Group 1 — and since almost all major stablecoins and most tokenisation projects run on public chains, they land in Group 2 [1]. It is the point on which the US, UK and Hong Kong have each departed from or softened the standard, a likely focus of the Basel review, and the condition to track if the strategy depends on public-chain activity [12][20][29].
Capital and Liquidity Treatment by Asset Type
Columns follow asset type rather than regulatory category, so Groups 2a and 2b share the final crypto column: they are the same assets sorted by whether the hedging criteria are met, and the cells distinguish them where the treatment differs.
Jurisdiction | Tokenised traditional assets (Group 1a) | Stablecoins (Group 1b, or Group 2 if they fail the tests) | Unbacked and non-qualifying crypto (Groups 2a and 2b) | Exposure limits | Liquidity (LCR / NSFR) |
Basel SCO60 | Group 1a: same as underlying asset if classification conditions met; supervisors may add an infrastructure add-on. Permissionless blockchains currently cannot qualify for Group 1 [1]. | Group 1b if reserve/ redemption tests and other conditions met (tightened Jul 2024) [2]; otherwise Group 2. Most public-chain stablecoins therefore fall into Group 2 [1]. | Group 2a (hedgeable): 100% capital charge on net position with limited hedge recognition. Group 2b: 1,250% risk weight, no hedging [1]. | Group 2: should generally be below 1% of Tier 1 and must not exceed 2%; breaches above 1% trigger 2b treatment [1]. | Only Group 1a can count as HQLA (if the underlying is HQLA). Group 1b and Group 2 are non-HQLA [1]. |
Canada | Group 1a: consistent with CAR/LAR treatment of the related asset [7]. | Group 1b if Annex 1 conditions met; otherwise Group 2 [7]. | Group 2a via modified market-risk approach (fully recognized for applicable same-maturity positions; partially recognized for applicable spot vs future hedges); 2b fully deducted from CET1 [7] [33][34]. | 5% of Net Tier 1 for total gross Group 2; automatic 2b treatment above 1% removed [8]. From Nov 2026 / Jan 2027, client-clearing derivative exposures are excluded from the limit [33][34]. More permissive than Basel. | Treatment follows classification and LAR; OSFI may adjust outflow/stable-funding factors for issuing or transacting roles [7][10]. |
United States | "Eligible tokenised securities" get the same capital treatment as the non-tokenised form; no distinction for permissionless vs permissioned chains [12][13]. | No bank-capital rule for holding stablecoins identified. GENIUS proposals set reserve, capital and liquidity rules for bank-subsidiary issuers [17][18]. | No crypto-specific capital rule. OCC permits limited principal holdings (network fees, platform testing) and riskless-principal trading [15]. | No crypto-specific limit identified; general limits and supervisory review apply. Prior notification/ non-objection requirements withdrawn in 2025 [14]. | No crypto-specific liquidity guidance identified. The Mar 2026 FAQs address risk-based capital only [12]. |
United Kingdom | Generally same as non-tokenised equivalent where legal rights identical and risks comparable, regardless of ledger type (permissioned or permissionless) [20]. | Firms should look at specific risk characteristics; the Basel classification conditions are a reference point where PRA rules allow discretion [20]. | 100% capital requirement under market risk remains appropriate; direct holdings classed as intangibles are deducted from CET1 [20]. | No UK-specific crypto limit set in the letter; full framework incl. Pillar 2/ICAAP applies [20]. | No crypto-specific liquidity rule; firms apply the full prudential framework and supervisory engagement [20]. |
European Union | Tokenised traditional assets treated like the underlying traditional assets (CRR3 Art. 501d) [22]. | MiCA-compliant asset-referenced tokens referencing traditional assets: 250% risk weight. Other crypto: 1,250% [22]. | "Other" crypto-assets: 1,250% risk weight [22]; EBA RTS set out hedge-recognition criteria for this category [23]. | Total "other" crypto exposures must not exceed 1% of Tier 1; breaches must be notified [22][23]. | No dedicated crypto liquidity treatment yet; to be addressed in the permanent regime [22]. |
Singapore | Proposed Basel-aligned (Group 1a). Not yet in force [25][26]. | Proposed Basel Group 1b with MAS consultation on scope of eligible reserve assets [25]. Not yet in force. | Proposed Basel Group 2 treatment. Not yet in force [25][26]. | Proposed Basel limits, incl. single-counterparty rules (Notice 656) [25]. | Proposed amendments to Notices 649/651 (LCR) [25]. Interim: case-by-case with MAS [26]. |
Hong Kong | Basel Group 1a. Permissionless chains can qualify subject to additional CRP-1 conditions; Jun 2026 circular accepts supervision of the tokenisation activity in lieu of product approval [28][29]. | Basel Group 1b with CRP-1 conditions (incl. for permissionless chains) [28]. | Basel Group 2; Group 2b includes funds/ETFs primarily deriving value from 2b assets [28]. | Large-exposure rules amended from 1 Jan 2026 [27]. Pre-2026 holdings and (generally) new types of cryptoasset are treated as 2b until HKMA agrees the classification [28]. | Liquidity-rule amendments not located in the documents reviewed; to confirm with HKMA. |
UAE | No crypto-specific rule located; general Capital Adequacy Standards apply [30]. | PTSR governs issuance, conversion, custody of payment tokens (licensing, reserves, audits) [31]. No bank holding-capital rule located. | No crypto-specific rule located. General standards cap the maximum single-exposure charge (effective 952% RW at 10.5% minimum) [30]. | No crypto-specific limit located. | No crypto-specific liquidity rule located. |
Implications for strategy
For the CEO: where to play
Tokenisation of traditional assets (tokenised deposits, bonds, money-market funds) is the lowest-regret area: capital neutrality is either confirmed or available in all Basel-aligned regimes if classification conditions are met, and the US, UK and Hong Kong have removed or softened the permissionless-blockchain barrier. Unbacked crypto on balance sheet remains a niche, capital-heavy activity everywhere, and agency or riskless-principal models (as the OCC has endorsed) are capital-lighter than inventory positions.
For the CFO: capital planning
The same exposure can attract very different charges: a tokenised bond on a public chain is underlying-equivalent in the US, UK and HK but could be Group 2 under a literal reading of the Basel standard. Hong Kong generally requires new types of exposure to be treated as Group 2b (1,250%) until the HKMA agrees the classification, so plan lead time for supervisory sign-off. Any business case should be stress-tested against the outcome of the Basel review, which could move treatment in either direction.
For the CRO: classification, controls and disclosure
Classification is a control process, not a one-off calculation. Banks are responsible for assessing classification on an ongoing basis, must fully document the information used, and supervisors can override the conclusion [1][7]. That makes this an area needing clear ownership, evidence standards (including legal opinions on whether a tokenised instrument really confers identical rights), and periodic re-testing, since an asset can migrate between groups as its arrangements or reserve assets change.
The default treatment on uncertainty is the punitive one. Hong Kong requires pre-2026 holdings and, generally, new types of cryptoasset to be treated as Group 2b until the HKMA agrees the assessment [28]. Under the Basel standard, supervisors expect to be told of the classification with enough time to review and potentially override it before acquisition [1]. Practically, the risk function needs to sit ahead of the front office, not behind it: an exposure taken before classification is agreed is a 1,250% exposure.
Operational and third-party risk is where the novel exposure actually sits. The standard covers custody, key management and the resilience of the ledger itself, and the Basel Committee's concern about public, permissionless chains is grounded in reliance on parties the bank cannot fully diligence or oversee [1]. Where the US, UK and Hong Kong permit public-chain activity, they have not removed that risk — they have moved it from a capital charge into supervisory expectations and the bank's own control framework [12][20][29]. The UK is explicit that firms should consider risks from first principles where existing methodologies do not capture the features of these markets, and should adjust methodologies and calibrations accordingly [20].
Pillar 2 and the ICAAP carry more weight than Pillar 1 in the non-implementing jurisdictions. In the UK there is no crypto-specific rule to comply with; the PRA expects the full framework, including the Fundamental Rules, the ICAAP and Pillar 2, and expects firms to engage supervisors where their approach differs materially from the Basel standard [20]. Singapore similarly expects banks to notify and engage MAS on the treatment of any cryptoasset exposure in the interim [26]. In the US, the withdrawal of the prior notification and non-objection requirements shifted these activities into the normal supervisory process rather than exempting them [14].
Disclosure obligations are already live in the implementing jurisdictions. The Basel Pillar 3 framework for cryptoasset exposures applies from 1 January 2026 alongside the capital standard, with standardised qualitative and quantitative templates [2], and Hong Kong has issued its disclosure templates and returns accordingly [27]. Data lineage and reporting capability should be in place before the first material exposure, not after it.
For the Treasurer: liquidity
Under Basel-based rules only tokenised assets whose underlying is HQLA can count toward the liquidity buffer; stablecoins and other crypto are non-HQLA [1]. Stablecoin reserves are a separate question: the BoE, OCC and FDIC proposals shape where issuers must hold backing assets, which will affect bank deposit and custody flows [17][18][21].
Industry reports and signals (not official)
The items below come from media or industry sources, not regulators. They indicate direction of travel but should not be relied on.
Basel chair says the rules need reworking. CoinDesk, citing a Financial Times interview, reported that BCBS chair Erik Thedéen said the crypto capital rules need a new approach because the US and UK declined to implement them, and that the Fed's Michelle Bowman had called them "not very realistic". Not an official BCBS statement. Source: https://www.coindesk.com/policy/2025/11/19/banks-capital-rules-when-holding-crypto-need-to-be-reworked-says-basel-chair-ft
Industry push for a pause. Global trade associations (GFMA and others) wrote to the BCBS in Aug 2025 arguing the 1,250% treatment is effectively an activity ban and asking for a pause and technology-neutral revisions, including on permissionless blockchains. Industry position, not regulatory policy. Source: https://www.gfma.org/wp-content/uploads/2025/08/bcbs-prudential-letter-final-public-version.pdf
US political pressure on the 1,250% treatment. Media reports (Jun 2026) describe US senators pressing regulators to adopt a calibrated framework for liquid digital assets while the Basel review is under way. Source: https://cryptoslate.com/a-little-known-1250-rule-could-lock-us-banks-out-of-bitcoin/
OCC targeting a November 2026 final GENIUS rule. PYMNTS, citing Decrypt, reported the Comptroller said at the Wyoming Blockchain Symposium that the OCC aims to finalise by November so it can process applications in early 2027. Reported remarks only; no official timetable located. Source: https://www.pymnts.com/legal/2026/occ-races-the-clock-to-finish-genius-act-stablecoin-rules/
UAE transition deadline has now passed. Law-firm commentary reports that the new CBUAE Law (Federal Decree-Law No. 6 of 2025) took effect 16 Sep 2025 with a one-year transition, so the compliance date fell on 16 Sep 2026, with CBUAE discretion to extend. The law brings virtual-asset payment services, platforms and protocols into the licensing perimeter. Not verified on a CBUAE channel. Source: https://www.whitecase.com/insight-alert/uae-enacts-new-cbuae-law-which-repeals-and-replaces-2018-law
No GENIUS Act final rules at the statutory deadline. Trade press reported that 18 Jul 2026 passed with all principal OCC, FDIC, NCUA and Treasury packages still in proposal form, some comment periods running into August, which fixes the effective date at 18 Jan 2027. The absence of a final rule is verifiable; the commentary on consequences is not official. Source: https://www.theblock.co/post/408843/us-regulators-miss-genius-acts-one-year-deadline-for-final-stablecoin-rules
Gaps and items outstanding
EU: as at 17 September 2026 the EBA still lists the August 2025 RTS as submitted to the Commission, so Commission adoption appears outstanding.
Singapore: still no official MAS update since the October 2025 deferral.
Basel: no further Committee statement since 20 May 2026; the promised 2026 update had not appeared as at 17 September 2026.
Hong Kong: I did not locate amendments to the liquidity rules in the documents reviewed.
UAE: no CBUAE crypto-specific bank prudential standard was located; DIFC and ADGM free-zone regimes are excluded.
Sources (official)
[1] BCBS, Prudential treatment of cryptoasset exposures (SCO60), 16 Dec 2022. https://www.bis.org/bcbs/publ/d545.htm
[2] BCBS press release: final disclosure framework and targeted amendments, 17 Jul 2024. https://www.bis.org/press/p240717.htm
[3] GHOS press release: implementation deferred to 1 Jan 2026, 13 May 2024. https://www.bis.org/press/p240513a.htm
[4] GHOS press release: targeted reviews endorsed, 9 Mar 2026. https://www.bis.org/press/p260309.htm
[5] BCBS press release: progress on cryptoasset review, 25 Feb 2026. https://www.bis.org/press/p260225.htm
[6] BCBS press release: progresses cryptoasset targeted review, 20 May 2026. https://www.bis.org/press/p260520.htm
[7] OSFI, Capital and Liquidity Treatment of Crypto-asset Exposures (Banking) Guideline (2026). https://www.osfi-bsif.gc.ca/en/guidance/guidance-library/capital-liquidity-treatment-crypto-asset-exposures-banking-guideline-2026
[8] OSFI, Letter to industry: changes to treatment of crypto-asset exposures, 29 Oct 2025. https://www.osfi-bsif.gc.ca/en/guidance/guidance-library/letter-industry-changes-treatment-crypto-assets-exposures
[9] OSFI, Backgrounder: Draft Guideline (2027), 21 May 2026. https://www.osfi-bsif.gc.ca/en/news/backgrounder-draft-guideline-capital-liquidity-treatment-crypto-asset-exposures-banking-2027
[10] OSFI, Draft Capital and Liquidity Treatment of Crypto-asset Exposures (Banking) Guideline (2027). https://www.osfi-bsif.gc.ca/en/guidance/guidance-library/capital-liquidity-treatment-crypto-asset-exposures-banking-guideline-2027
[11] Justice Laws Website, Stablecoin Act (S.C. 2026, c. 3, s. 600), assented 26 Mar 2026. https://lois-laws.justice.gc.ca/eng/acts/S-15.9/FullText.html
[12] Federal Reserve / FDIC / OCC joint press release: capital treatment of tokenized securities, 5 Mar 2026. https://www.federalreserve.gov/newsevents/pressreleases/bcreg20260305a.htm
[13] OCC Bulletin 2026-7: Interagency FAQs on tokenized securities, 5 Mar 2026. https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-7.html
[14] Federal Reserve press release: withdrawal of crypto-asset guidance, 24 Apr 2025. https://federalreserve.gov/newsevents/pressreleases/bcreg20250424a.htm
[15] OCC Interpretive Letter 1188 (riskless principal), 9 Dec 2025, referencing IL 1186 (network fees), Nov 2025. https://www.occ.gov/topics/charters-and-licensing/interpretations-and-actions/2025/int1188.pdf
[16] OCC Bulletin 2026-3: GENIUS Act NPRM. https://www.occ.gov/news-issuances/bulletins/2026/bulletin-2026-3.html
[17] Federal Register: OCC GENIUS Act proposed rule, 2 Mar 2026. https://www.federalregister.gov/documents/2026/03/02/2026-04089/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the
[18] FDIC FIL: GENIUS Act NPRM, 7 Apr 2026. https://www.fdic.gov/news/financial-institution-letters/2026/notice-proposed-rulemaking-establish-genius-act
[19] Federal Register: Treasury GENIUS Act NPRM on issuance, offer and sale, 18 Aug 2026. https://www.federalregister.gov/documents/2026/08/18/2026-16796/genius-act-regulations-on-payment-stablecoin-issuance-offer-and-sale
[20] PRA Dear CEO letter: Prudential treatment of tokenised assets, stablecoins and other cryptoasset exposures, 18 May 2026. https://www.bankofengland.co.uk/-/media/boe/files/prudential-regulation/letter/2026/tokenised-assets-stablecoins-and-other-cryptoasset-exposures
[21] Bank of England: policy statement and draft rules on systemic stablecoins, 22 Jun 2026. https://www.bankofengland.co.uk/news/2026/june/boe-launches-policy-statement-and-draft-rules-on-regulating-systemic-stablecoins
[22] Regulation (EU) 2024/1623 (CRR3), incl. Art. 501d. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32024R1623
[23] EBA Final Report: Draft RTS on crypto exposure values under Art. 501d(5) CRR, 5 Aug 2025. https://www.eba.europa.eu/sites/default/files/2025-08/616d6b06-cdcf-4246-a7cc-2173dfd32fa6/Draft%20RTS%20on%20crypto%20asset%20exposures%20Article%20501d-5.pdf
[24] European Commission: Prudential requirements page and policy timeline (updated 17 Jul 2026). https://finance.ec.europa.eu/banking/banking-regulation/prudential-requirements_en
[25] MAS Consultation Paper P003-2025: Prudential treatment of cryptoasset exposures, Mar 2025. https://www.mas.gov.sg/-/media/mas-media-library/publications/consultations/ppd/2025/consultation-on-the-prudential-treatment-of-cryptoassets-and-reqs-for-at1-and-t2-capital-instruments.pdf
[26] MAS Response to consultation (deferral to 1 Jan 2027 or later), 9 Oct 2025. https://www.mas.gov.sg/-/media/mas-media-library/publications/consultations/ppd/2025/response-to-consultation-paper-on-crypto-at1-and-tier2.pdf
[27] HKMA circular: Cryptoassets standard SPM modules, code of practice, disclosure templates, 27 Nov 2025. https://brdr.hkma.gov.hk/eng/doc-ldg/docId/getPdf/20251127-1-EN/20251127-1-EN.pdf
[28] HKMA SPM CRP-1: Classification of Cryptoassets (V.1, 1 Jan 2026). https://brdr.hkma.gov.hk/chi/doc-ldg/docId/getPdf/20251125-15-EN/CRP-1.pdf
[29] HKMA circular: SPM CRP-1 update on classification conditions, 3 Jun 2026. https://brdr.hkma.gov.hk/eng/doc-ldg/docId/getPdf/20260603-1-EN/20260603-1-EN.pdf
[30] CBUAE Rulebook: Standards for Capital Adequacy of Banks in the UAE. https://rulebook.centralbank.ae/en/rulebook/standards-capital-adequacy-banks-uae
[31] CBUAE Rulebook: Payment Token Services Regulation, Article 11. https://rulebook.centralbank.ae/en/rulebook/article-11-payment-token-services
[32] CBUAE Guidance for LFIs on risks related to virtual assets and VASPs. https://centralbank.ae/media/avwlktgy/cbuae-guidance-for-lfis-on-risks-related-to-virtual-assets-and-virtual-assets-providers_final-clean-version1.pdf
[33] OSFI, Capital and Liquidity Treatment of Crypto-asset Exposures (Banking) – Guideline (2027) – Letter, 10 Sep 2026. https://www.osfi-bsif.gc.ca/en/guidance/guidance-library/capital-liquidity-treatment-crypto-asset-exposures-banking-guideline-2027-letter
[34] OSFI, Backgrounder: final Guideline (2027). https://www.osfi-bsif.gc.ca/en/news/backgrounder-capital-liquidity-treatment-crypto-asset-exposures-banking-guideline-2027-1
Comments