Risk & Compliance | Banking & Fintech | Payments & Digital Assets | Views my own

I'm very happy to share a new article — "In Defense of the Second Line of Defense: The Role of Independent Risk Management" — just published in the 2023 Starling Compendium. To access, click through, choose join, and "Observer Status" (which is free). insights.starlingtrust.com/c…
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"To meet these policy goals and satisfy the statutory standard, the Board is proposing to use a simple, standardized #risk_based_capital framework [for permitted payment stablecoin issuers (PPSIs)]. … [T]he Board's approach to capturing financial_risks from managing reserve assets would focus on credit risk from uninsured eligible deposit claims and from undercollateralized reverse repurchase agreements. … [T]he proposal would include capital requirements to address a Board-supervised PPSI's operational risks. Capital requirements for operational risk would include two components: (i) a capital requirement based on outstanding payment stablecoin issuance and (ii) a capital requirement based on non-reserve asset revenue to capture other operational risks." federalreserve.gov/newsevent…
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"The growth of #stablecoins has been robust, and their use in cross border payments and remittances, while still small, has expanded. … Issuers of the currencies in which these stablecoins are denominated—primarily the US today—can benefit from increased demand and liquidity for government debt. … Tokenization could have even more impact than stablecoins over the long term, since both physical and financial assets—everything from land ownership to loans—could eventually be tokenized, speeding transactions, reducing their cost, and making more assets available to more people worldwide." imf.org/annual-report/2026/p…
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The IMF Annual Report webpage is here: imf.org/annual-report/2026/
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"[#Stablecoins could] reduce frictions that have proven persistent in payments, particularly across borders and platforms. Realizing those benefits requires the same five foundations: credible convertibility into a trusted asset, high-quality and transparent backing, a uniform regulatory perimeter, reliable par clearing and settlement infrastructure, and credible crisis management and loss allocation. … Dollar-denominated stablecoins could increase demand for U.S. Treasuries. But dominance ultimately rests on institutional credibility: legal enforceability, fiscal capacity, and the ability to provide liquidity in stress." hoover-s3-website.s3.us-west…
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"Key Preliminary Findings [:] 1. SVB failed in 2023 because it suffered massive losses when interest rates rose, its depositors ran, and it had insufficient contingent liquidity readiness. 2. By June 2022 at the latest, and perhaps as early as March, Federal Reserve supervisory staff knew, or should have known, that SVB was highly vulnerable to massive losses and a potentially ruinous run. 3. Despite that awareness, Board S&R and FRBSF supervisors did not require SVB to reduce its interest_rate_risk or exposure to runs by uninsured depositors. 4. Their failure to do so did not result from the 2018 tailoring statute (EGRRCPA) or a less assertive supervisory culture promoted by the implementation of related policy priorities. ..." 21211564.hs-sites.com/hubfs/…
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The summary timeline from the report...
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"The Eurosystem today launched Pontes, a solution that enables wholesale transactions in #tokenised_assets to be settled in central bank money. ... For wholesale financial markets, this technology has the potential to make transactions faster and more efficient by bundling multiple steps of an asset's lifecycle - from issuance and trading to settlement, custody and servicing - and by enabling automation and the development of innovative solutions through smart contracts. … The market is already showing significant interest in Pontes. An initial group of market participants and DLT operators has completed onboarding and is ready to start using Pontes immediately. Additional participants are committed to connecting to Pontes in the coming months." ecb.europa.eu/press/pr/date/…
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From the related press release: "ECB to invest part of own funds in tokenised securities, with settlement via Pontes" "> ECB has launched preparatory work to gain practical experience with investments in tokenised securities and distributed ledger technology (DLT) > Transactions to be settled in central bank money in Pontes, the Eurosystem's settlement solution for DLT transactions > Initial investments to focus on euro-denominated euro area public sector and European supranational securities." ecb.europa.eu/press/pr/date/…
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"The digital_economy is driving a fundamental shift in #payment_infrastructure. Innovative fintechs are now integrating Distributed Ledger Technology (DLT) to enable faster cross-border settlements. … Looking ahead, three structural shifts merit particular attention from a central banking perspective. First, the unbundling of payment services from credit provision is creating new channels for financial intermediation outside the traditional banking system. ... Second, the increasing adoption of technology enabled innovative services by Irish-domiciled payment firms has the potential to alter the payments infrastructure. ... Third, new payment instruments such as account-to-account (A2A) payments, stablecoins and the digital euro have the potential to reshape competitive dynamics." centralbank.ie/docs/default-…
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From the report, Figure 11 - Stylised depiction of Irish fintech universe.
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"Foreign [#stablecoin] issuers are not required to be regulated under the U.S. [GENIUS Act] regime. If they wish to be available to U.S. persons through intermediaries, they must be regulated in a country with a regulatory regime that the Treasury Secretary has certified as comparable to the U.S. regime, register with the Office of the Comptroller of the Currency, and be capable of complying with lawful orders. ... Congress debated whether commercial firms, such as big tech companies, should be permitted to issue stablecoins. The Stablecoin Certification Review Committee (SCRC), led by the Treasury Secretary, may approve commercial firms that meet various criteria. ... The act requires issuers that are subsidiaries of insured depositories (banks and credit unions that accept deposits) to be federally regulated. The act allows non-depository issuers with under $10 billion in stablecoins outstanding to choose between state and federal regulation." congress.gov/crs-product/R49…
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From the report, Table 3. Illicit Finance Provisions in the GENIUS Act.
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"[#Tokenized_Securities_Venues] and the use of distributed ledger technology can offer several benefits to market participants, including enabling investor self custody, around-the-clock trading, fractional ownership of shares, and near instantaneous settlement, while improving efficiencies and providing greater transparency. … [The] order facilitates trading in tokenized NMS stock using distributed ledger technology while maintaining appropriate investor protections and fair and orderly market principles as the Commission further considers potential regulatory changes or other actions." sec.gov/files/34-106402-fact…
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The Order Granting Temporary Conditional Exemptive Relief is here sec.gov/files/rules/exorders…
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"This examiner guide helps examiners understand how institutions use #artificial_intelligence and assess the governance and risk management of that use. It is a practical tool for examiners of bank and nonbank institutions. … Generative AI and Emerging Use Objective [:] Enable examiners to understand whether the institution is using generative artificial intelligence, large language models, agentic tools, or similar AI capabilities, how those tools are being used, and whether their tool type, deployment model, data controls, output oversight, and evolving risks may warrant additional review. ... Where AI systems can take actions with limited human direction, review how the institution defines the actions the system is permitted to take, human checkpoints, logging, reversibility, and the ability to restrict or halt the system." csbs.org/sites/default/files…
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The CSBS AI Use Case Tiering worksheet is here: csbs.org/node/584231
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"Respondents sought clarification on the distinction between electronic money (e‑money) and #qualifying_stablecoins, and on the treatment of wrapped stablecoins. They also asked for additional guidance on the treatment of stablecoins that use hybrid stabilisation mechanisms. … We have clarified in [Perimeter Guidance Manual] 18.4.5 that, in our view, products using hybrid stabilisation mechanisms (eg part backing assets and part algorithmic) are not qualifying stablecoins. We have also added new guidance to say that wrapped tokens relating to stablecoins are not in themselves automatically qualifying stablecoins." fca.org.uk/publication/polic…
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