UK and US Treasury Tag-Team Stablecoin Rules Across the Pond 🏛️

The US Department of the Treasury and HM Treasury published four joint recommendations on digital assets under the Transatlantic Taskforce for the Markets of the Future, set up by Chancellor Rachel Reeves and Treasury Secretary Scott Bessent during President Trump's UK state visit in September 2025. The recommendations, issued Tuesday, call on the Bank of the England, the Financial Conduct Authority, the Securities and Exchange Commission, and the Commodity Futures Trading Commission to identify shared approaches to regulating tokenized assets, including how tokenized securities reach settlement finality and whether stablecoins and tokenized money market funds can serve as collateral at clearing houses.

The task force also recommended that authorities convene a private-sector-led group to spend a year testing cross-border use cases for tokenized assets, and called for a "multi-money ecosystem" in which stablecoins, tokenized bank deposits, and other forms of digital money coexist. Alongside the digital-asset recommendations, the two governments are developing a joint statement on stablecoins aimed at building a "dynamic stablecoin market across borders," with payment stablecoins required to be "fully backed, on at least a one-to-one basis, by high-quality, liquid assets." The principles echo the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, the federal stablecoin law signed last year with an effective date of January 2027.

"Each government intends to tailor its requirements to seek comparable outcomes for comparable risks and activities, seeking to advance financial stability while avoiding market distortions or disincentivizing cross-border competition," the joint statement said. A fifth recommendation asks both sides to push for a technology-neutral review of how the Basel Committee treats banks' crypto exposures. The recommendations are non-binding, leaving each country to complete its own regulatory processes under a shared direction.

The alignment effort comes as both jurisdictions build out domestic regimes: the US is implementing the GENIUS Act ahead of its 2027 effective date, while the UK's cryptoasset regime is due to take effect in October 2027. Both are moving to keep pace with the European Union, whose Markets in Crypto-Assets (MiCA) rules have been fully in force since the end of 2024 and are set to be revised in 2027. A UK government-backed industry report released alongside the statement projected that the UK could add up to $44 billion to its annual economic output by 2035 if it becomes a leading jurisdiction for tokenization, and called on the country to issue tokenized bonds by the first quarter of 2027.

Industry participants welcomed the direction. Katie Harries, Coinbase's head of policy for Europe, called the recommendations a "critical moment for transatlantic cooperation" and highlighted the opportunity for the two financial centers to "reimagine global capital markets through tokenisation." Lucy Rigby, Economic Secretary to the Treasury, said at the Financial Times Digital Assets Summit that digital assets have the potential to effect sweeping changes on UK financial markets. The recommendations stop short of mutual recognition, with a stablecoin licensed in one country still required to clear the other's rules to operate there.