Stablecoins and banking risk why banks fear cash like assets

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I have been running COREDO since 2016, and every year I see entrepreneurs increasingly using stablecoins in corporate payments and cross-border settlements. The speed of settlement, access to global liquidity and predictability of costs look attractive, especially against the backdrop of increasingly complex requirements for international transfers through traditional channels. At the same time, banks are tightening control, regulators are clarifying the frameworks, and business compliance teams are seeking a balance between innovation and reliability.

COREDO’s practice confirms: the success of stablecoin operations rests on three pillars, a correct legal structure, strict AML/CFT discipline and a sober assessment of the issuer’s reserves. When an entrepreneur sees the whole picture – from MiCA requirements for stablecoin issuers and licensing in Europe to KYC/CDD procedures for VASP and the Travel Rule: they reduce operational risk and at the same time strengthen their position with the bank.
In this article I will break down the key topics: regulation of stablecoins in the EU and Asia, stablecoin liquidity and reserve models, the impact of stablecoins on banks’ liquidity and regulatory capital, AML requirements/CFT and custody practice for corporations. I will add cases that the COREDO team encountered when registering legal entities, obtaining financial licenses and building an international payments infrastructure.

Logic of stablecoins and banks

Illustration for the section «Logic of stablecoins and banks» in the article «Stablecoins and banking risk - why banks fear “cash-like” assets»

Stablecoins: these are digital “cash-like” assets that offer instant settlement and ownership transparency on the blockchain. Banks assess such instruments from a banking risk perspective, because stablecoins and the banking system are connected through common liquidity channels. Issuers hold reserves in banks and money-market instruments, and corporate clients interact with banks when converting and redeeming (redemption).

Why do banks fear cash-like assets in the form of stablecoins? Two factors drive the risk. First, behavioral “runs” on stablecoins during market stress, which can trigger scenarios of mass liquidity withdrawals and banking stress due to stablecoins. Second: credit contiguity: the transmission of risk from issuers to banks via reserves and correspondent relationships. The higher the share of reserves in bank deposits and short-term markets, the more noticeably stablecoins affect banks’ interest-rate risk management and their short-term funding.
Banks also analyze stablecoins and regulatory capital through the lens of exposures to issuers and custodians. If a bank accepts stablecoins as collateral or holds them on its balance sheet, it applies capital adequacy approaches and treats stablecoins as risk-weighted assets. COREDO’s practice shows: it is easier to build a dialogue with the bank when the client has a transparent policy for working with stablecoins, clear counterparty risk limits and compliance rules.

Regulatory frameworks in Europe and Asia

Illustration for the section Regulatory frameworks in Europe and Asia in the article Stablecoins and banking risk - why banks fear cash-like assets

Regulatory frameworks in Europe and Asia are being formed amid active digitalization of financial markets, but they differ significantly in priorities and supervisory instruments. First we will examine the European approach, MiCA and associated prudential requirements, and then compare them with the practices of Asian regulators.

MiCA: EU prudential requirements

The European regulatory approach to stablecoins relies on MiCA — Markets in Crypto‑Assets — and supervision by the EBA/ECB. MiCA requirements for stablecoin issuers include capital, reserve management, redemption mechanisms, disclosure, reporting and audit. For e‑money tokens the regulator emphasizes redeemability at par and strict segregation of client assets, which effectively brings the model closer to electronic money. Licensing of a stablecoin issuer and the e‑money licence are synchronized with payment licences and e‑money tokens, where AML/CFT procedures and IT infrastructure resilience are important.

The ECB conveys a cautious approach to large issuers whose growing volume may affect the money market and payment systems. When assessing exposures, banks take into account the impact of stablecoins on banks’ LCR and NSFR: if reserves are held in highly liquid instruments and do not create maturity transformation, pressure on the LCR (liquidity coverage ratio) and NSFR (net stable funding ratio) is reduced. The COREDO team executed projects where we synchronized a corporate stablecoin policy with the internal metrics of a correspondent bank, which helped reduce questions in KYC questionnaires and speed up servicing.

Global AML standards in Asia

Crypto-asset regulation in Asia is developing rapidly and in diverse directions. MAS in Singapore emphasizes risk management, including AML/CFT requirements for stablecoin providers and disclosure prospectuses, as well as stress tests. Other regulators in the region are actively engaging on the topic: regulators interested in stablecoins in Asia include central banks and financial supervisors of Hong Kong, Japan and the UAE, which closely monitor reserve models and compliance.

Global benchmarks are set by the FATF, the Basel Committee on Banking Supervision and the Financial Stability Board (FSB). FATF codifies KYC / CDD procedures for VASPs, the Travel Rule and VASP cross-border requirements and enhanced AML/CFT Due Diligence (EDD) for high-risk jurisdictions and complex structures. In the UK the FCA maintains its own approach to admitting providers, in the US the SEC and FinCEN operate, and in the EU the EBA and national competent authorities implement MiCA supervision. The solution developed by COREDO for a client with operations in the EU and Asia included unified KYC procedures for touchpoints with VASPs, payment routing via approved exchanges and custodians and a Travel Rule event log – the bank approved this approach without additional review rounds.

Stablecoin reserves and liquidity

Illustration for the section «Stablecoin reserves and liquidity» in the article «Stablecoins and banking risk - why banks fear «cash-like» assets»

Control over stablecoin reserves and liquidity determines their ability to withstand outflows and maintain the peg in stress scenarios. Next we will examine reserve models and how different approaches to supporting liquidity affect banks and user confidence.

Impact of reserve models on banks

The reserve model for fiat-backed stablecoins focuses on reserve composition: fiat, money market instruments, and government bonds. Reserve composition and liquidity risk go hand in hand: the higher the share of T‑bills and overnight cash, the more resilient a stablecoin’s liquidity is during redemptions. Crypto-collateralized stablecoins and liquidity risks depend on collateral volatility and liquidation mechanisms, while algorithmic stablecoins and seigniorage models increase the risk of de-pegging, which explains why algorithmic stablecoins are more dangerous for banks.

Fractional reserve stablecoin models add maturity transformation and liquidity momentum: investors react to news faster than reserves can be turned into cash. Banks look at how banks assess the liquidity of reserve-backed stablecoins: they analyze the average duration of instruments, issuer limits for bonds, and the credit quality of custodians. Our experience at COREDO has shown: if corporate policy restricts dealings to fiat-backed stablecoins with short reserve durations and transparent reporting, banks view that profile as rational.

Proof of reserves: attestation vs audit

proof-of-reserves and auditor attestations for stablecoins are a key element of trust. Proof‑of‑reserves and auditor attestations confirm the composition of reserves as of a given date, but attestation vs audit for reserves differ in depth: a full audit includes sampling, testing of procedures, and independent verification of ownership rights. A Big Four audit opinion for an issuer raises the trust baseline, although banks also assess the legal framework for custodial storage and asset segregation.

The roles of auditors, regulators, and custodians in trust in reserves are synchronized: auditors provide independent verification, regulators set the rules of the game, and custodians implement day-to-day operational discipline. The COREDO team has set up checklists for selecting issuers, where we included verification of attestation frequency, custodial jurisdiction, the presence of segregated trust models, and disclosure of counterparty risk.

Redemptions and depeg: market behavior

Redemption mechanisms and redemption runs determine how quickly an issuer converts stablecoins into fiat. Temporary suspension mechanisms allow surviving an acute stress phase, but the market closely monitors the frequency and reasons for such decisions. Depegging mechanisms trigger behavioral run models on stablecoins and open contagion channels between stablecoins and banks via reserves and money market flows.

In such scenarios banks revise limits and corporate clients restructure liquidity providers. COREDO’s practice confirms: if treasury policy includes a cap on a single issuer, market-price alarm thresholds, and a requirement for immediate unwind on depeg, the company stabilizes the position faster and preserves access to banking services.

Bank liquidity and settlements

Illustration for the section «Bank liquidity and settlements» in the article «Stablecoins and banking risk - why banks fear «cash-like» assets»

Tokenization of deposits and bank liquidity form an alternative to public stablecoins – banks issue wholesale stablecoins for correspondent banks with settlement within a closed network. Banking and tokenization of deposits reduce settlement risk inside the bank and speed up internal payments, while maintaining a direct link to regulatory capital and LCR/NSFR.

CBDCs as competition and a central bank response expand the options for cross-border settlements. The role of central banks and CBDCs in countering stablecoin risks is to raise reserve standards and the final irreversibility of settlements. In corporate practice we also encounter hybrid schemes using cross-border liquidity and the correspondent network SWIFT, ISO 20022 and the integration of tokenized payments – a company builds an orchestration layer around the ERP, where part of payments goes on‑chain with subsequent reflection in accounting.
Shadow banking and the stablecoin stack arise where operations move beyond the perimeter of regulatory rules. Banks assess counterparty exposure and clearing schemes, in some projects they discuss CCP and clearing of stablecoin networks to reduce mutual risks. Settlement finality on‑chain vs off‑chain is a matter of operational design: the legal finality of blockchain settlements must correspond with the provider’s contractual framework.

Payments, Treasury and ROI

Illustration for the section 'Payments, Treasury and ROI' in the article 'Stablecoins and banking risk - why banks fear \

In corporate practice, effective payments and treasury management directly affects business profitability and key ROI metrics. Developing a payments strategy and properly integrating systems allows reducing costs, accelerating cash turnover, and increasing the transparency of financial results.

Payments Strategy and Integration

Stablecoins in corporate payments bring value where there are frequent cross-border settlements, a distributed supplier network and a need for DvP schemes. Stablecoins and cross-border settlements deliver time savings and improved transaction status transparency, especially during peak hours. How to introduce stablecoins into a company’s treasury: start with a pilot corridor, assess the need for on‑chain payments, then expand by country and counterparty.

Integration of ERP / Treasury with on‑chain payments and ISO 20022 simplifies reconciliation and automation. Methods for assessing the ROI of stablecoin implementation take into account fee savings, cost of capital due to faster collection, reduction in operational time and a decrease in the number of rejected payments. Estimating ROI when introducing stablecoins into payment infrastructure requires clean metrics: integration TCO, provider SLAs and potential penalties for outages.

Compliance AML/CFT KYC Monitoring

How to build compliance procedures for stablecoin operations, codify a “permitted assets” policy, set limits on issuers and networks, appoint responsible parties, implement on‑chain transactional monitoring and AML algorithms. AML for stablecoins touches on sanctions risks and on‑chain screening, blockchain transaction investigations and forensic tools, as well as logging Travel Rule events. What KYC requirements apply for corporate use of stablecoins, proof of source of funds, beneficial ownership structure, evidence of economic purpose and agreed EDD procedures for high‑risk counterparties.
The client asked COREDO to build a compliance map for the EU, the UK and Singapore. We included FATF standards, FCA and MAS requests to providers, routing via licensed VASPs, address verification, and FinCEN‑oriented red flags. This framework helped reduce the number of manual checks by a third and convinced the correspondent bank of the robustness of the process.

Operational Risks: Custody

Best custody practices for institutional use of stablecoins include multisignature and custodial solutions (multisig custody), hot wallet vs cold wallet institutional custody and payment approval flows. Corporate access control and segregation of duties improve governance: one role initiates, a second validates, a third signs. Segregation of client assets and trust models with third‑party custodians reduce counterparty risk, although they do not eliminate it entirely.

Smart contracts and execution risk, oracle risks and price‑oracle manipulation, token bridges and cross‑chain transfer risk, wrapped assets and the risk of double‑counting — these are elements of the technology profile. The COREDO team implemented for the client a contract registry with criticality assessments, SLAs for blockchain service providers and an incident response plan for smart contract exploits and insurance. Such measures include cyber insurance and crime policies; which insurances cover losses in the event of a stablecoin issuer collapse — most policies cover theft of private keys or custodian failures, but do not cover issuer default, so exposure limits to a single stablecoin remain key.

de-risking and banking relationships

How to maintain access to banking services when working with stablecoins: prepare a position paper for the bank in advance: a list of stablecoins used, a description of issuers’ reserves, evidence of attestation/audit, routing through licensed providers, a Travel Rule ledger, a sanctions screening policy and on-chain monitoring. Risks of banks rejecting stablecoins for business decrease when a company demonstrates internal control and the abandonment of anonymous channels.
An example of a bank refusing to service cryptocurrency occurs when a client makes payments through an unlicensed VASP or does not document sources of funds. In one case COREDO proposed migration to a custodian licensed in the EU, implemented an address whitelist of counterparties and regular EDD reports, and the bank restored service a month after the documents were updated. Correspondent relationships and stablecoins require special attention: the risk of correspondent account revocation when processing stablecoins increases with violations of the Travel Rule and sanctions control.
Banking and tokenization of deposits can be a compromise for those who want to speed up settlements and maintain stable support from a bank. We support projects where a bank offers tokenized deposits for corporate clients in a restricted network with final conversion to fiat – this format reduces compliance concerns and aligns with internal liquidity policies.

COREDO Licensing and Architecture

COREDO assists with the registration of legal entities in the EU, the Czech Republic, Slovakia, Cyprus, Estonia, the United Kingdom, as well as Singapore and Dubai. For projects with stablecoins, EMI/PI licenses in the EU or the equivalent payment institution licenses in the UK are often appropriate, plus VASP registration where the company interacts with crypto assets. In Asia, advice on MAS requirements and local regulators’ requirements for risk management, information security and AML is useful.

In one project, a solution developed at COREDO included a parent company with an EMI license in the EU, an operating company with VASP registration in Estonia and a service center in Singapore for Asian clients. We created an AML/CFT policy, implemented KYC/CDD/EDD procedures, established relationships with a correspondent bank and set up reporting for regulators. This design gave the client a resilient platform for e-money tokens and liquidity management across multiple time zones.

Taxes and accounting

tax implications of using stablecoins in international payments depend on the token’s status and the nature of the transaction. Payments for services and goods require a proper invoice base and fixing the exchange rate on the transaction date, and certain jurisdictions apply VAT/GST in specific scenarios. In accounting it is important to determine whether corporate funds can be held in stablecoins safely from a classification standpoint, as cash equivalents when there is strict redeemability and low risk or as financial assets subject to revaluation.

The COREDO team has set up a hedging policy and the recognition of foreign exchange differences, as well as document flow controls for intercompany settlements. To minimize disputes with tax authorities we recommend keeping blockchain statements, custodian reports, confirmations of the issuer’s auditor attestations and internal approvals for limits.

Stress‑tests and resilience plan

Regulatory stress tests for stablecoins are gaining momentum: the FSB and the Basel Committee emphasize assessing run scenarios, the impact on the money market and interaction with banks. Stress testing stablecoin ecosystems in the corporate context is built around three scenarios – a prolonged depeg, a suspension of redemptions and a custodian failure. We model reaction times, available liquidity corridors, loss limits and the steps to switch providers.

How stablecoins affect banks’ interest rate risk management: during mass redemptions issuers sell short-term paper, which can raise yields and increase pressure on the LCR for holders of that paper. A corporate client benefits if it pre-limits exposure to issuers, uses multiple liquidity providers and documents a playbook: who initiates the unwind, who validates the price, which DvP channels are available.

Implementation of stablecoins in corporations

  • Define objectives: payment speed, reduced fees, DvP or cash management. Assess methods to evaluate the ROI of implementing stablecoins taking into account the TCO of integration and working capital savings.
  • Choose assets and networks: use physically backed (fiat-backed) stablecoins with transparent reserves, avoid experimental algorithmic models.
  • Conduct a legal assessment: consider the European regulatory approach to stablecoins (MiCA), the requirements of the FCA/SEC/MAS/FinCEN, as well as local rules in jurisdictions of operation.
  • Set up compliance: implement KYC/CDD/EDD, the Travel Rule, on-chain monitoring, sanctions screening and forensic tools; describe the risks of stablecoin operations for corporate clients and the processes to control them.
  • Build custody: multisignature, hot/cold separation, segregation of duties, limit policies, cyber-risk insurance and provider SLAs.
  • Reserve transparency: collect attestation/audit reports from issuers, retain proof of reserves, monitor regulatory statuses and disclosures.
  • Integration: link ERP/TMS, support ISO 20022 tags, set up reconciliation and an event log.
  • Banking relationships: prepare a position paper, agree with the bank on acceptable schemes, maintain regular reporting for correspondent banks.
  • Resilience plan: describe triggers for depeg, suspension, custodian failures, failover procedures and loss limits.
  • Review the strategy: take into account regulatory arbitrage and case law, update policy when new requirements from the EBA/ECB/MAS are released.

How COREDO reduces implementation risk

When a client comes to us with a request for stablecoins and cross-border payments, I assemble a cross-functional team: licensing, AML, tax, banking relationships and information security. The COREDO team implemented: registration of a holding in the EU, setup of VASP contours in Estonia, selection of a custodian with a segregated trust model, preparation of an AML package for the bank and building relationships with on-chain monitoring providers. This approach gave the client a fast pilot launch and subsequent scale into Asia through Singapore.

Our experience at COREDO has shown that successful projects are built on discipline. A client who documents a stablecoin policy, imposes limits on issuers regarding reserves and audits, integrates ERP and maintains a transparent dialogue with the bank demonstrates reliability and gains a strategic advantage. I personally ensure that the solution reflects local nuances: from EBA and ECB requirements to MAS requests and correspondent banks’ expectations.

Conclusions

Stablecoins have taken their place in international settlements and corporate treasury. They provide speed and convenience, but at the same time require strict compliance, a thoughtful choice of issuers and mature relationships with banks. EU regulation of stablecoins through MiCA, FATF standards and guidance from Asian regulators create a clear framework in which business can operate predictably.

COREDO helps clients navigate the entire journey: from company registration and obtaining financial licenses to AML‑consulting, custody selection and payment infrastructure setup. We design solutions that preserve banking relationships, consider the impact on LCR/NSFR and minimize the risks of de‑peg and redemption run. If you see the potential of stablecoins for your business and want to realize it without losing resilience, let’s discuss a roadmap and build an architecture that works today and meets tomorrow’s requirements.

COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.

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