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The Payments Newsletter including Digital Assets & Blockchain, June 2025

24 June 2025
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The Payments Newsletter including Digital Assets & Blockchain, June 2025
Chapter
  • Chapter

  • Chapter 1

    Regulatory Developments: Payments
  • Chapter 2

    Regulatory Developments: Digital Assets
  • Chapter 3

    Market Developments
  • Chapter 4

    Surveys and Reports

Key developments of interest over the last month include: the EBA publishing an opinion on PSD2 and MiCA overlap; the Council of the EU announcing member states' representatives’ (COREPER) approval of the Council’s amended texts of the proposed PSD3 and PSR; the UK FCA launching a consultation on stablecoin issuance and cryptoasset custody as well as a consultation on a prudential regime for cryptoasset firms; the U.S. Senate voting to advance a federal bill to regulate fiat-referenced stablecoins (the GENIUS Act); and the Hong Kong Legislative Council passing a Stablecoins Bill establishing a licensing regime. 

In this Newsletter:

  • Regulatory Developments: Payments
  • Regulatory Developments: Digital Assets
  • Market Developments
  • Surveys and Reports

For previous editions of the Payments Newsletters, please visit our Financial Services practice page.

Chapter 1

Regulatory Developments: Payments

expanded collapse

European Union: EBA publishes opinion on PSD2 and MiCA overlap

On 10 June 2025, the EBA published an opinion (or “No Action letter”) on the interplay between the revised Payment Services Directive (PSD2) and the Regulation on markets in cryptoassets (MiCA). This is in response to a December 2024 request from the European Commission to address issues arising from the interplay between MiCA and PSD2 relating to cryptoasset service providers (CASPs) that transact electronic money tokens (EMTs) (as reported in the December 2024 Newsletter).

The EBA’s letter aims to clarify the PSD2/MiCA interplay by providing advice to:

  • The Commission, the Council of the European Union and the European Parliament on how the issue of dual authorisation being required for the activity of transacting EMTs (under PSD2 and MiCA) can be addressed in the long term. The EBA suggests that use is made of the ongoing legislative process for the proposals for a Directive on payment services and electronic money services (PSD3) and a Regulation on payment services (PSR).
  • National competent authorities (NCAs) for the intervening period of two to three years during which PSD2 applies. The EBA sets out the types of EMT transaction that are not to be regarded as payment services and which PSD2 provisions should be deprioritised for supervision and enforcement purposes.

Take a look at this Our Thinking article for more on this development. 

European Union: Council amended texts of the PSD3 and the PSR

On 18 June 2025, the Council of the EU announced member states' representatives’ (COREPER) approval of the Council’s amended texts of the European Commission’s June 2023 legislative proposals for a Directive on payment services and electronic money services (PSD3) and a Regulation on payment services in the EU (PSR).

This gives a green light to the start of trilogues (inter-institutional negotiations) with a view to the European Parliament and Council agreeing final texts for PSD3 and the PSR.

The Council’s text proposes some changes to the original text from the Commission and the version published by the Parliament.  Interestingly, the Council has rowed back on the Parliament’s suggestion to expand liability for impersonation fraud to cover any impersonation (not just that of the payment service provider), and reintroduced the requirement for outsourcing agreements with technical service providers that provide and verify elements of strong customer authentication (which the Parliament had removed).

Take a look at this Our Thinking article for more on this development. 

United Kingdom: PSR publishes consolidated APP scam reimbursement policy statement

On 21 May 2025, the Payment Systems Regulator (PSR) published a consolidated policy statement (PS25/5) on the authorised push payment (APP) scams reimbursement requirement. The policy statement aims to provide a single point of reference for those who want to understand the PSR's reimbursement requirements and how it may affect them. It includes summaries of the most frequently asked questions the PSR received.

The PSR has issued the policy statement as general guidance. It makes it clear that, although it is intended to help readers interpret its policy, its definitive requirements are set out in its legal instruments, which are on the PSR’s website. In addition, Pay.UK, as the Payment System Operator for Faster Payments, maintains the Faster Payments reimbursement rules which are on its website.

The PSR has also published its requirements for reimbursement of APP fraud committed over the CHAPS payment system, which are substantially the same as for Faster Payments. Except where otherwise indicated, the policy statement applies to payments made over both Faster Payments and CHAPS. The Bank of England, as the Payment System Operator for CHAPS, maintains the CHAPS reimbursement rules which are on its website.

If any of the contents of the policy statement vary with the PSR’s legal instruments or the Faster Payments or CHAPS reimbursement rules, the latter three prevail.

The PSR will aim to keep the policy statement under review and, if necessary, updated in line with any material revisions it makes to its reimbursement requirement. It will communicate any such revisions and, if necessary, consult on them before formally announcing or implementing them.

New Zealand: Upgraded standard for open banking implemented

On 30 May 2025, Payments NZ announced the third major milestone in its Minimum Open banking Implementation Plan. Payments NZ declared that the four largest banks in New Zealand – ANZ, ASB, BNZ, and Westpac NZ – are due to implement version 2.3 of their Payment Initiation API standard. Kiwibank is also set to implement the same standard by May 2026. The upgraded standard introduces additional functionality in the form of enduring payment consent and decoupled authentication.

Payments NZ was established in 2010 by New Zealand’s (Aotearoa’s) payments industry with the support of the Reserve Bank. It governs the core New Zealand payment systems and works with the industry to lead open banking and the future direction of payments in New Zealand. 

United States: Open banking - CFPB plans to repeal Personal Financial Data Rights rule

In October 2024, the Consumer Financial Protection Bureau (CFPB) announced that it had finalised a rule – the Personal Financial Data Rights rule - giving consumers greater rights, privacy, and security over their personal financial data. According to the CFPB’s press release, this was to be its ‘first significant rule to accelerate responsible open banking in the U.S.’ (see the October 2024 Newsletter for further details).

However, on 23 May 2025 the CFPB filed a status report to the U.S. District Court for the Eastern District of Kentucky in relation to a lawsuit challenging the rule, informing the court that the "Bureau leadership has determined that the [rule] is unlawful and should be set aside". The CFPB subsequently filed a brief in support of its motion for summary judgment in the case, noting that it "agrees with Plaintiffs that the Rule is unlawful and should be set aside". 

Serbia: Serbia joins SEPA

On 22 May 2025, the European Commission announced that Serbia has joined the Single Euro Payments Area (SEPA) following a positive decision by the European Payments Council (EPC).

The decision of the EPC will allow payment service providers in Serbia to adhere to various SEPA schemes that are managed by the EPC. This allows financial transfers in Euros and will reduce the cost and processing time of these transactions. 

United States: Illinois state legislature votes to delay implementation of interchange fees law

On 1 June 2025, according to the Illinois General Assembly's website, the Illinois state legislature voted to delay the implementation of the Interchange Fee Prohibition Act. The Act would stop companies from charging interchange fees on the tax and tip portions of credit and debit transactions. The Act was due to enter into effect on 1 July 2025, but the vote delayed this until 1 July 2026.

There have been mixed opinions in response to the delayed implementation. The American Bankers Association (who had filed a lawsuit challenging the law) published an article on 1 June 2025 in which they stated that the Executive Vice President of the Illinois Bankers Association thanked lawmakers for the delay in implementation. On the other hand,  the Illinois Retail Merchants Association published a press release stating that they are "disappointed the General Assembly is delaying implementation of this law". 

Europe: European Card Payment Association calls for EU payments sovereignty

On 3 June 2025, the European Card Payment Association (ECPA) published a whitepaper analysing the relevance, importance and growth of European Card Schemes in today's geo-political landscape.

Key points include:

  • Members of the ECPA agree that the strengths of existing European Card Schemes (ECS) infrastructure can be leveraged to uphold payments sovereignty and security.
  • The ECPA stressed that the importance of payment autonomy extends beyond individual transactions, directly impacting monetary policy, financial stability, and broader economic security.
  • Initiatives like EuroPA, the European Payments Initiative and SEPA Payment Account Access were highlighted as examples of steps towards reducing dependence on international schemes for cross-border transactions.
  • The ECPA advocates for a balanced approach where ECSs serve as essential components within a broader European framework.

The ECPA states that the evidence suggests that targeted regulatory interventions would contribute significantly to a more balanced payments ecosystem in Europe and allow ECSs to contribute to European sovereignty. 

United Kingdom: Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 made

On 12 June 2025, the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 (SI 2025/688) were made.

As previously reported in the May 2025 Newsletter, the changes introduced under the Regulations are aimed at tackling “de-banking” and apply to framework contracts entered into on or after 28 April 2026.

The FCA will update the guidance on contract terminations its Payment Services and Electronic Money Approach Document to reflect the legislative changes.

See this Our Thinking article for operational implications and compliance guidance as well as remaining areas of uncertainty. 

European Union: ECB decision postponing timing for non-bank PSPs' access to central bank operated payment systems and central bank accounts published in Official Journal

On 10 June 2025, Decision (EU) 2025/1148 of the European Central Bank (ECB) amending Decision (EU) 2025/222 on access by non-bank payment service providers to Eurosystem central bank operated payment systems and central bank accounts was published in the Official Journal of the European Union. Decision (EU) 2025/1148 was made by the ECB on 2 June 2025 and entered into force "as a matter of urgency" on 11 June 2025.

Some euro-area member states have not yet transposed the amendments to the Settlement Finality Directive and the revised Payment Services Directive (PSD2) concerning access to central bank operated payment systems for payment institutions and electronic money institutions (collectively referred to as non-bank payment service providers (NB-PSPs)). The ECB has therefore decided to postpone the related required amendments to its Guideline (EU) 2022/912 (TARGET Guideline) to include NB-PSPs among the entities eligible to participate in TARGET. This decision was taken to avoid the legal uncertainty that would arise if NB-PSPs had been eligible to access some, but not all, Eurosystem central bank operated payment systems, including TARGET components.

Decision (EU) 2025/222 provides that NB-PSPs may request access to TARGET from 16 June 2025. Decision (EU) 2025/1148 amends Decision (EU) 2025/222 to defer this date to 6 October 2025, which is the date from which the TARGET Guideline amendments will apply.

Decision (EU) 2025/222 also provides for a transition period until 31 December 2025 to enable the migration of NB-PSPs currently registered as addressable business identifier code (BIC) holders or reachable parties on the Eurosystem central banks' own account for these NB-PSPs to become participants in TARGET. Decision (EU) 2025/1148 extends this transition period to 31 March 2026.

 

Chapter 2

Regulatory Developments: Digital Assets

expanded collapse

United Kingdom: FCA proposes lifting ban on crypto ETNs for retail investors

On 6 June 2025, the FCA announced in a press release its proposal to lift the ban on selling crypto exchange traded notes (cETNs) to retail investors. If adopted, cETNs could be made available to individuals, provided the instruments are traded on an FCA-recognised investment exchange.

The FCA confirmed that financial promotion rules would apply to cETNs in the same way as they do to direct cryptoasset investments. The existing prohibition on retail access to crypto derivatives will remain in place.

The proposal forms part of a wider package of changes included in the FCA’s quarterly consultation paper no. 48 (CP25/16). The closing date for feedback on the proposal is 7 July 2025. 

United Kingdom: FCA consults on stablecoin issuance and cryptoasset custody

On 28 May 2025, the FCA published a consultation paper (CP25/14) setting out proposed rules on the issuance of fiat-referenced stablecoins and the safeguarding of cryptoassets. The proposals follow HM Treasury’s draft legislation introducing new regulated activities and form part of the FCA’s broader roadmap for regulating cryptoasset markets.

The consultation covers a wide range of requirements, including redemption rights at par value, the composition and management of stablecoin backing assets, and the safeguarding of client cryptoassets under a statutory trust. It also proposes new chapters in the Client Assets Sourcebook (CASS) and the introduction of a Cryptoasset Sourcebook (CRYPTO).

The FCA is inviting feedback until 31 July 2025.

For further detail, see this Our Thinking article.

United Kingdom: FCA consults on prudential regime for cryptoasset firms

On 28 May 2025, the FCA published a consultation paper (CP25/15), setting out draft prudential rules for firms that issue qualifying stablecoins or safeguard qualifying cryptoassets. The consultation is part of the FCA’s broader roadmap to implement a new regulatory framework for cryptoasset activities.

The proposed rules include capital and liquidity requirements aligned with existing frameworks for investment and e-money firms, alongside specific rules to address concentration risk. Cryptoasset firms would be subject to a three-part own funds requirement, consisting of a permanent minimum requirement, a fixed overheads requirement, and an activity-based K-factor requirement. Minimum liquidity standards are also proposed, with additional rules for stablecoin issuers to ensure they can meet shortfalls in their backing asset pools.

The consultation proposals would introduce a new two-part rulebook structure: a general prudential sourcebook (COREPRU) and a sector-specific cryptoasset sourcebook (CRYPTOPRU), marking the start of a unified FCA prudential framework across sectors.

The consultation is open for feedback until 31 July 2025.

For further detail, see this Our Thinking article.

United Kingdom: PRA and BoE speeches on innovation and risk

Recent speeches given by the PRA and the Bank of England (BoE) have given further insight into the direction of travel the UK regulators are seeking to take towards credit institutions' engagement with cryptoassets and the developing forms of digital money.

In a speech  titled “Innovation and Regulation – striking the balance” by  David Bailey  (18 June 2025) the PRA confirmed its preference for a cautious yet flexible approach to addressing how regulation should deal with banks’ involvement with cryptoassets, highlighting:

  • its commitment to implementing the Basel Committee on Banking Supervision standards on the prudential treatment of banks’ exposures to cryptoassets while waiting to see if  its approach can be relaxed over time; as well as
  • its desire to ensure that banks that the PRA had previously said should only provide innovations in the form of deposits (for example in tokenised form), can compete openly with non-banks issuing systemic stablecoins.

Andrew Bailey struck a similar note in a speech at the 9th NBU-NBP Annual Research Conference in Kyiv headed “ Central Banking in extreme adversity” in which he made it clear that if there are real benefits in digital technology in payments, then his preference would be for those benefits to be seen in commercial bank money in the form of tokenised deposits.

In his view the UK is well on the way to having wholesale central bank digital money in any event, as a natural step from the wholesale electronic money that the UK has had for thirty years, but he remains unconvinced as to the need for a retail CBDC.

He also made it clear that in relation to stablecoins, whilst he thought it possible for the latter to provide assurance of nominal value and pass the test of singleness of money, many of the current versions do not yet achieve that test, and that the focus should be on developing standards that ensure they do.

United Arab Emirates: Dubai launches pilot for tokenised real estate investments

On 25 May 2025, the Dubai Land Department (DLD) announced the launch of a pilot programme for tokenised property investment via the Prypco Mint platform. The initiative allows UAE residents with valid Emirates IDs to purchase fractional interests in Dubai real estate starting from AED 2,000, with all transactions processed in UAE dirhams. Cryptocurrencies are excluded from the pilot phase.

The project is being delivered in collaboration with Prypco and Ctrl Alt Solutions, and overseen by multiple public bodies including the Virtual Assets Regulatory Authority (VARA), the Central Bank of the UAE, and the Dubai Future Foundation. Zand Digital Bank is acting as the official banking partner, and the pilot is being conducted through the DFF’s Real Estate Sandbox.

The initiative aims to develop regulatory and operational frameworks for asset tokenisation, promote investor education, and attract specialised tokenisation providers. DLD has stated that tokenised assets could account for up to 7% of Dubai’s property market by 2033, equating to around AED 60 billion (USD 16 billion) in value. Expansion beyond the UAE is planned for future phases.

Hong Kong: Legislative Council passes Stablecoins Bill establishing licensing regime

On 21 May 2025, the Hong Kong Government announced in a press release that the Legislative Council has passed the Stablecoins Bill, introducing a licensing regime for fiat-referenced stablecoin (FRS) issuers. The new law is intended to enhance Hong Kong’s regulatory framework for virtual assets, promote financial stability, and support responsible innovation.

Under the regime, any person who issues a FRS in Hong Kong, or issues a FRS referencing the Hong Kong dollar from any location, will be required to obtain a licence from the Hong Kong Monetary Authority (HKMA). Licensees must meet requirements relating to reserve asset management, par value redemption, segregation of client assets, AML/CFT compliance, disclosure, risk management, auditing, and governance.

Only licensed entities may issue or advertise FRS to retail investors. A transitional arrangement will apply to allow industry participants time to prepare. The HKMA will consult further on detailed supervisory requirements before the law comes into effect later this year.

Kazakhstan: National Bank to introduce digital asset regulation and sandbox

On 22 May 2025, the National Bank of Kazakhstan announced the development of legislative amendments to regulate digital asset turnover, marking a significant step towards formal oversight of crypto activity in the country.

The new framework will consist of two core components. The first will define the legal status of digital financial assets, while the second will introduce licensing for crypto exchange service providers, focusing on the circulation of unsecured cryptocurrencies. The reforms are being developed jointly by the National Bank and other government agencies, in line with a directive from the President.

In parallel, the National Bank plans to launch a Digital Asset Regulatory Sandbox, allowing market participants to test new services and technologies in a controlled environment. The move builds on earlier efforts to implement licensing, AML compliance, and secure custody rules through the Astana Financial Services Authority.

These initiatives are part of Kazakhstan’s broader aim to align with international regulatory standards and improve investor certainty. The government is also investing in public education to raise awareness about the risks and opportunities in the digital asset space.

United States: Senate advances revised stablecoin bill following earlier setback

On 11 June 2025, the U.S. Senate voted 68-30 to advance the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, a federal bill to regulate fiat-referenced stablecoins. This follows an earlier Senate vote of 66–32 to advance the bill on 19 May 2025, after the bill's previous failure to reach the Senate floor earlier in the month, as noted in our May edition.

The legislation establishes licensing requirements, reserve standards, and oversight mechanisms for stablecoin issuers operating in the U.S. It also restricts the issuance of algorithmic stablecoins and requires regular audits.

According to a notice on the official website for Senate Democrats, the Senate has scheduled its final vote on the bill for 17 June 2025. If the bill passes, it will then go to the House of Representatives for consideration. 

United States: Treasury to phase out penny production in 2025

Following a report by the Wall Street Journal on 22 May 2025, the U.S. Treasury confirmed it will stop producing and circulating new one-cent coins by early next year. The decision marks the end of over 230 years of penny production and follows the Treasury’s final order for penny blanks this month. Once existing materials are used, no additional pennies will enter circulation.

Businesses will begin rounding cash transactions to the nearest five cents. While the penny will remain legal tender, it is expected to disappear from day-to-day use as inventories decline. The Mint estimates annual taxpayer savings of $56 million, given that each penny now costs more than three cents to manufacture.

This development follows the broader payments modernisation strategy announced earlier this year. As noted in our April edition, President Trump signed an Executive Order mandating the phase-out of paper-based federal payments by the end of 2025, with agencies transitioning to digital disbursements such as direct deposit, prepaid cards, and digital wallets.

Together, these measures reflect a coordinated effort by the administration to reduce costs, increase efficiency, and support the shift away from physical cash and paper-based infrastructure.

Singapore: MAS finalises licensing deadline for overseas crypto firms

On 30 May 2025, the Monetary Authority of Singapore (MAS) published its final Response to Feedback confirming that crypto firms operating from Singapore but serving only overseas clients must obtain a licence by 30 June 2025 or shut down.

The rules apply to companies incorporated or staffed in Singapore, regardless of whether they have local customers. Individuals such as consultants and freelancers may also fall within scope depending on their roles.

MAS said it would issue licences only in rare cases. Applicants must hold at least SGD 250,000 in base capital, re-onboard customers with updated due diligence, comply with the FATF Travel Rule, and meet technology and cyber risk requirements.

MAS declined to provide a transition period, stating that a four-week notice is sufficient. The move aims to close regulatory gaps and address the financial crime and reputational risks of unlicensed cross-border crypto activity.

United States: SEC confirms protocol staking not subject to securities laws

On 30 May 2025, the U.S. Securities and Exchange Commission (SEC) published staff guidance stating that protocol staking on proof-of-stake networks does not, in most cases, constitute a securities offering. The announcement ends years of uncertainty over whether common staking practices fall within the scope of federal securities regulation.

According to the SEC’s Division of Corporation Finance, staking activities involving self-staking, self-custodial delegation to a node operator, or custodial staking (where assets are held but not reused by a custodian) do not involve an “investment contract” under the Howey test. The guidance applies only where staking is administrative or technical in nature and not driven by third-party managerial efforts.

The statement excludes more complex forms of staking, such as liquid staking and restaking, which may still trigger securities law requirements depending on their structure. One Commissioner issued a dissenting statement criticising the approach as inconsistent with recent case law and overly permissive.

United States: Congress introduces CLARITY Act to overhaul digital asset regulation

On 29 May 2025, a bipartisan group of U.S. lawmakers introduced the Digital Asset Market Clarity Act (CLARITY Act), a proposal that would remove SEC oversight from most cryptoassets and classify them as "digital commodities" under the jurisdiction of the Commodity Futures Trading Commission (CFTC).

The bill would amend the Securities Act of 1933 and the Securities Exchange Act of 1934 to exclude crypto tokens that are intrinsically linked to blockchain systems from the definition of securities. This would apply to most major cryptocurrencies including Ethereum, Solana, XRP and various governance tokens.

To qualify as a digital commodity, a token must be used to transfer value within a blockchain system. The bill also introduces a separate category for "mature blockchain systems" that meet certain decentralisation and transparency criteria, although registering as one is optional and offers limited regulatory relief.

The CLARITY Act establishes new compliance obligations for brokers, dealers and custodians, including asset segregation, customer disclosures and operational safeguards. It also introduces a registration regime for digital asset firms seeking to operate in the U.S. 

Russia: Bank of Russia opens access to crypto-linked derivatives for qualified investors

On 28 May 2025, the Bank of Russia confirmed that financial institutions may offer crypto-linked derivatives and other instruments to qualified investors, provided they are non-deliverable. This means that investors will not obtain ownership of the underlying cryptoassets such as Bitcoin or Ethereum.

The instruments can include derivatives, securities, and digital financial assets tied to crypto prices. The central bank advised firms to adopt a conservative risk approach, including full capital coverage and individual exposure limits.

Retail access remains restricted, with the Bank of Russia continuing to warn against direct crypto investment and planning further test regimes limited to “certain categories of investors.”

United States: California Assembly passes bill to allow crypto for state payments

On 2 June 2025, the California State Assembly unanimously passed AB 1180, a bill that would allow state agencies to accept cryptocurrency as payment under the state’s Digital Financial Assets Law. The bill passed 78–0 and now moves to the Senate for consideration.

If enacted, AB 1180 would require California’s Department of Financial Protection and Innovation (DFPI) to create rules enabling state fees and transactions to be paid in crypto. A pilot programme would begin on 1 July 2026 and run until 1 January 2031. DFPI would also be required to publish a report by 2028 outlining volumes, challenges, and outcomes.

The legislation defines qualifying payments broadly and complements AB 1052, California’s proposed “Bitcoin rights” bill focused on self-custody and private transactions. If passed, California would join states like Colorado and Florida in formally accepting digital assets for some government transactions.

India: RBI expands digital rupee pilots with programmability and offline features

On 29 May 2025, the Reserve Bank of India (RBI) released its Annual Report for 2024–25, confirming the expansion of its digital rupee pilots to include new use cases such as programmable payments and offline functionality.

The retail central bank digital currency (CBDC) pilot now spans 600,000 users and 17 banks, while the wholesale pilot has added four standalone primary dealers. To support wider adoption, RBI will permit certain non-banks to offer CBDC wallets.

The programmability feature is aimed at enabling controlled-use scenarios such as subsidies or corporate expense rules. Offline capability is being introduced to support usage in regions with limited internet access.

The move comes amid surging digital payments growth in India, with the RBI highlighting that the country accounted for 48.5% of global real-time payments by volume in the last financial year.

European Union: Summary of recent MiCA developments

Recent developments relating to the Regulation on markets in cryptoassets (MiCA) include:

  • On 6 June 2025, the European Commission adopted a Delegated Regulation (C(2024)3221) containing regulatory technical standards (RTS) specifying the information in an application for authorisation to offer asset-referenced tokens (ARTs) to the public or to seek their admission to trading under MiCA. The Council of the EU and the European Parliament will now scrutinise the Delegated Regulation. If neither object, it will enter into force 20 days after its publication in the Official Journal of the European Union (OJ).
  • On 10 June 2025, the following Delegated Regulations supplementing MiCA were published in the OJ and will enter into force on 30 June 2025:
    • Commission Delegated Regulation (EU) 2025/1140 supplementing MiCA regarding RTS specifying records to be kept of all cryptoasset services, activities, orders and transactions undertaken, under Article 68(10) of MiCA.
    • Commission Delegated Regulation (EU) 2025/1141 supplementing MiCA regarding RTS that specify the requirements for policies and procedures on conflicts of interest for issuers of ARTs, under Article 32(5) of MiCA.
    • Commission Delegated Regulation (EU) 2025/1142 supplementing MiCA regarding RTS that specify the requirements for policies and procedures on conflicts of interest for cryptoasset service providers (CASPs) and the details and methodology for the content of disclosures on conflicts of interest, under Article 72(5).

Note also the item ‘EBA publishes opinion on PSD2 and MiCA overlap’ under Payments Regulatory Developments above.

United Kingdom: Law Commission launches consultation on proposals regarding private international law and digital assets and (electronic) trade documents

On 5 June 2025, the Law Commission published a consultation paper entitled "Digital assets and (electronic) trade documents in private international law". The aim of the consultation is to resolve questions relating to international jurisdiction, applicable law, and the recognition and enforcement of foreign judgments, arising from use of electronic trade documents, digital assets and distributed ledger technologies. The consultation paper includes provisional proposals for reform of certain aspects of private international law that apply in this context. Key points include:

  • Jurisdiction: The consultation considers how the existing jurisdictional gateways for property (gateway 9(a)) and tort (gateways 11 and 15(b)) can be applied in the context of crypto litigation. It also notes that the existing gateway for free-standing Norwich Pharmacal and Bankers Trust orders (gateway 25) has not been widely used because claimants are often unable to satisfy the requirement that the information is sought for proceedings commenced or intended to be commenced in England and Wales as they do not know the identity or whereabouts of the perpetrators. There is therefore a proposal to create a new discretionary power of the courts to grant free-standing information orders against third parties in circumstances where it is not yet clear whether substantive proceedings will be initiated in England and Wales.
  • Applicable law: The consultation proposes a new "supranational" approach to deal with the "omniterritorial nature" of disputes in relation to digital assets and electronic trade documents. This new approach would no longer require the courts to identify a single applicable law, but to take into account a range of factors to determine a just outcome of the dispute, including the legitimate expectations of the parties.
  • Bills of Exchange Act 1882: The consultation also makes proposals for reform of section 72 of the Bills of Exchange Act 1882, which would apply to relevant documents in both paper and electronic form.

The consultation closes on 8 September 2025. Responses can be submitted via the online portal and any queries should be sent to enquiries@lawcommission.gov.uk. The Law Commission plans to publish final recommendations in 2026.

Chapter 3

Market Developments

expanded collapse

United Kingdom: Visa launches A2A payments

On 2 June 2025, it was reported that Visa's new pay by bank solution, Visa A2A, is ready for market in the UK. For businesses, Visa A2A takes advantage of real-time settlement through Pay.UK's Faster Payment System to offer greater visibility over payments and simpler cash flow management. Businesses will be able to receive notifications if a consumer changes or cancels payment permissions and they can be provided with the ability to include more transaction data for reconciliation. Future plans for expansion include expanding Visa A2A to include ecommerce payments in the UK with a phased approach.

Argentina: Argentinian banks join real-time fraud detection network

On 27 May 2025, it was reported that several Argentinian banks and fintechs have joined a new real-time intelligence-sharing network, known as BioCatch Trust Argentina. This network is designed to combat financial fraud and some of the first institutions to participate in this initiative include Banco Galicia, Santander Argentina, and Naranja X.

The system identifies suspicious behaviour before funds are transferred, and analyses behavioural patterns and device activity to assess the credibility of recipient accounts involved in financial transfers. If an anomaly is detected, the sending institution is alerted in real-time.

Global: Bolt partners with Airwallex to build new payments system for its drivers

On 3 June 2025, it was reported that Bolt, a global shared mobility platform, has announced a partnership with Airwallex, a global payments platform, to build a new payments system for its drivers. Initially, the product will focus on digital wallets before expanding to include additional financial services in the future. This product will be delivered using Airwallex's global financial  infrastructure to streamline payments, reduce transaction costs and improve the speed and efficiency of fund transfers.

By automatically delivering payments in different currencies, the wallet aims to support the drivers and couriers who use the Bolt platform in more than 50 countries. These changes will be rolled out incrementally.

The partnership is currently live in several markets and will progressively include key jurisdictions in the Americas, EMEA, and APAC. 

United Kingdom: allpay launches DOSH to serve unbanked communities

On 3 June 2025, it was reported that allpay, a UK-based payment company, has launched DOSH which is a prepaid Mastercard account, aiming to support unbanked communities in the UK.

DOSH has been created as an alternative to traditional banking by offering flexible ID options through its 'Vouch For' onboarding, transparent pricing, financial literacy tools, and human support. DOSH aims to support those who are paid in cash, don't have a standard ID, or who seek a clearer way of managing their finances. 

United States: Klarna and Visa launch pilot debit card

On 3 June 2025, Visa published a press release announcing the pilot launch of the Klarna Card. Klarna Card is a new product which combines a traditional debit card with access to built-in flexible payment options, allowing consumers to pay immediately or later when needed online or in-store.  The card is powered by Visa Flexible Credential and issued by WebBank.

The Klarna Card is currently in a trial phase in the U.S. before a broader roll out in the U.S. and Europe expected later this year.  Despite still being in a trial phase, the card has already gathered over five million consumers on the waitlist.

Ethiopia: FaydaPass wallet is launched

On 22 May 2025, it was reported that Ethiopia has launched its FaydaPass wallet, a digital ID product developed to grow the country's digital public infrastructure. The FaydaPass wallet has been developed by leveraging expertise and product support from TECH5 and Visa. It has been designed to address the critical need for verified eKYC services in the public and private sectors.

The Fayda wallet streamlines obtaining a digital copy of the Fayda credential by allowing customers to request their digital ID credential through the wallet after downloading the official app. The credential is then delivered directly to the user's phone as a verifiable credential. This verifiable credential allows for secure online and offline verification. Once activated, users can open a bank account with Coopbank and receive a virtual Visa card for instant payments.

Hong Kong: HSBC launches Tokenised Deposit Services for corporate cash management

On 22 May 2025, HSBC published a press release, announcing the launch of their Tokenised Deposit Service for corporate clients. This is the first bank-led, blockchain-based settlement service in the city.

Initially, the service will support treasury management with real-time HKD and USD payments between corporate wallets held by clients. This service also supports the settlement requirements for tokenisation use cases, including those being explored under the Hong Kong Monetary Authority's Project Ensemble.

HSBC's first client to adopt this service has been Ant International. HSBC supported Ant International to successfully complete an instant fund transfer between its entities through the tokenisation of their deposits. 

Thailand: Tourists to be allowed to use cryptocurrency

On 28 May 2025, it was reported that Thailand intends to allow tourists to use cryptocurrency through credit card-linked platforms, aiming to modernise its financial system. This initiative is currently being evaluated by the Ministry of Finance and the Bank of Thailand. The pilot program is anticipated to launch once infrastructure and regulatory assessments are completed.

This initiative will allow tourists to connect their cryptocurrency holdings to credit cards for local transactions. Merchants will receive money in their local currency, unaware that cryptocurrency was used in the process. 

Europe: Schuman Financial integrates Euro-backed stablecoin with Ripple's XRPL

On 22 May 2025, Ripple published a press release announcing Schuman Financial's native integration of its MiCA-compliant euro stablecoin EURØP onto the Ripple XRP Ledger. EURØP is the first MiCA-compliant euro stablecoin to be integrated onto the XRP Ledger. Schuman Financial is a licensed EMT issuer regulated by the ACPR (the supervisory authority of the French Central Bank). EURØP reserves are regularly audited by KPMG and are safeguarded at Europe's leading financial institutions, including Société Générale. 

United States: U.S. banks consider joint stablecoin project

On 23 May 2025, it was reported that major U.S. banks, including JPMorgan Chase, Bank of America, Wells Fargo and Citigroup, have engaged in discussions to create a jointly issued stablecoin. The proposed model would allow the consortium members, as well as unaffiliated banks, to use the stablecoin, potentially expanding its adoption across the financial sector. These discussions reportedly involve companies tied to The Clearing House and Early Warning Services which are organisations that facilitate banking infrastructure and payments. 

Europe: Santander shows interest in launching own stablecoin offering

On 3 June 2025, it was reported that Santander's Openbank unit has applied for MiCA licences in Europe to offer a stablecoin and offer its retail customers access to crypto. The bank is considering either launching its own euro or dollar denominated stablecoin, or offering access to an existing one. However, the plan is still in its preliminary stages.

Lithuania: Robinhood Europe is first entity to be granted crypto licence

On 2 June 2025, it was reported that following a decision by the Bank of Lithuania, Robinhood Europe has become the first entity to be granted a licence to offer cryptoasset services in Lithuania. The licence allows Robinhood Europe to provide services such as the custody, administration, and execution of transactions involving cryptoassets both in Lithuania and throughout the European Union. According to the central bank, 29 firms have submitted applications for a similar licence, and 10 of those are currently under review. 

Chapter 4

Surveys and Reports

expanded collapse

Global: Convera publishes industry report on cross-border payments

On 3 June 2025, Convera, a provider of cross-border payment solutions, published the second part of its Payments Pulse industry report. Here, Convera focus on the potential of real-time payments, stablecoins and blockchain decentralised finance.

Key findings include:

  • Real-time payments (RTPs)
    • RTPs are projected to reach $58 trillion by 2028 representing a 161% increase over 2024 volumes.
    • Almost 80 countries already have RTP systems in place, where local banks are connected to their automated settlement system for instance domestic processing.
    • Financial institutions are reluctant to enter the RTP market, with 34% expressing concern that their legacy systems can't support 24/7 functionality.
    • The main issue financial institutions face with RTP systems is the upgrade of legacy infrastructure to handle the speed and volume required for real-time transactions. Security and fraud risks are also significant concerns.
  • Stablecoins
    • The stablecoin market had reached $238 billion market capitalization in April 2025, with suggestions that this figure could double to $400 billion by the end of 2025.
    • Tether's USDT maintains market dominance with a $140 billion market cap, while competitors like Circle's USDC are gaining significant traction in European markets.
    • Stablecoins' ability to provide instant settlements, cost savings, and enhanced financial accessibility is making them an attractive blockchain-based alternative to traditional banking systems.
  • Blockchain decentralised finance
    • Stablecoins, as tokenised fiat currencies, are finding their way into treasury operations with over $120 billion invested in U.S. treasuries.
    • The main barriers to the adoption of blockchain technology in treasury function is limited technical skills and a steep learning curve. 

Global: World Economic Forum publishes report on Asset Tokenisation in Financial Markets

On 21 May 2025, the World Economic Forum published their report on Asset Tokenisation in Financial Markets. The report explores the evolution of asset tokenization and key use cases. The World Economic Forum have used several research methods to create this report, including desk research, interviews and community workshops.

Key findings include:

  • The main use cases of tokenisation are asset issuance, securities financing and asset management.
  • Adoption is slowed by challenges such as legacy infrastructure, regulatory fragmentation, limited interoperability and liquidity issues.
  • The main considerations in relation to tokenisation are cybersecurity, financial stability and regulatory developments.
    • Cybersecurity is crucial in safeguarding digital assets. Many crypto-related breaches still arise from conventional threats rather than lost or compromised private keys.
    • As adoption of tokenisation grows, the Financial Stability Board warns of vulnerabilities such as liquidity and maturity mismatches, and price and quality obscurity from smart contract composability.
    • A major barrier to large-scale tokenisation remains the lack of regulatory clarity in digital assets markets. However, recent political and regulatory shifts suggest a move towards a more defined framework.

Europe: Cleafy publishes whitepaper on preventing digital crime

On 30 May 2025, Cleafy, an online fraud management and prevention solution, published their whitepaper on how banks can prevent digital scams. It explores the impact of scams, regulatory shifts to prepare for and what banks can do to tackle scams.

Key findings include:

  • UK consumers and businesses lost $485 million to APP scams in 2023 alone.
  • In 2023, the European Money Mule Action (EMMA 9) identified nearly 11,000 fraudulent transactions linked to money laundering schemes. This led to the arrest of over 10,000 individuals across 26 European countries.
  • The money mule networks are often an overlooked risk. Money mules are critical to scam operations and disrupting them undermines the entire business model, making fraud more difficult.
  • Banks must take an earlier approach to stopping fraud, which means starting at the customer interaction level and includes real-time visibility, edge AI and privacy first analytics and a shared threat intelligence across banks.

 

Authored by Charles Elliott, Virginia Montgomery, Sofie Gowran and Nurangis Sobirkhonova.

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