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Experts Discuss What Trump’s USD1 Stablecoin Needs to Survive the EU’s MiCA Regulation ⚖️

Since its launch in late March, World Liberty Financial’s stablecoin USD1 has achieved an impressive market capitalization, reflecting strong investor interest. If the creators want to maximize USD1’s reach by accessing markets abroad, particularly in Europe, they must confront MiCA’s extensive compliance list.

In a BeInCrypto interview, experts from Foresight Ventures, Kaiko, and Brickken stressed the importance of stablecoin issuers having substantial European bank reserves, operational volume caps protecting the euro, and transparent USD1 information to ensure transparency and avoid conflicts of interest.

🔹️USD1’s Search for Dollar Dominance

World Liberty Financial (WLF), a decentralized finance (DeFi) project heavily associated with the Trump family, officially launched USD1 a month ago. Through this stablecoin, WLF aims to promote dollar dominance worldwide.

So far, this initiative has been working well for WLF. According to CoinGecko, USD1 has now surpassed a market capitalization of $128 million and reached a 24-hour trading volume of nearly $41.6 million. The project has already released 100% of its total supply of 127,971,165 tokens.

For WLF to seriously establish dollar dominance across the globe, it will have to move fast and efficiently. This urgency stems from the need to surpass its main competitors, USDT and USDC. These rivals currently hold a massive market share advantage.

Additionally, there’s a need to maintain a competitive advantage against established currencies like the euro.

USD1 needs to access foreign markets and stand out from established competitors to achieve this. Should Europe become a primary target, USD1 must prepare to tackle numerous challenges head-on.

🔹️The EU’s Stringent Compliance Demands

The European Union (EU) became the first jurisdiction in the world to establish a comprehensive regulatory framework for digital assets across its 27 member states. This regulation, known as Markets in Crypto-Assets (MiCA), has been in effect for nearly four months. Through this legislation, the EU has confirmed how seriously it takes compliance with a defined regulatory regime.

“MiCA’s‬‭ main‬‭ requirements‬‭ for‬‭ stablecoins‬‭ are:‬‭ full‬‭ reserve‬‭ backing‬‭ with‬‭ liquid‬‭ assets,‬‭ strict‬‭ reporting‬‭ and‬‭ transparency‬‭ rules,‬‭ a‬‭ cap‬‭ of‬‭ 1‬‭ million‬‭ daily‬‭ transactions‬‭ for‬‭ non-EU‬‭ currency‬‭ stablecoins,‬‭ a‬‭ significant‬‭ part‬‭ of‬‭ reserves‬‭ (30%‬‭ to‬‭ 60%)‬‭ must‬‭ be‬‭ held‬‭ in‬‭ EU-regulated‬‭ banks,” Dessislava Ianeva-Aubert, Senior Research Analyst at Kaiko, told BeInCrypto.

The regulation is detailed and clear, leaving no room for interpretation. If USD1 wants to operate in this crypto market of 31 million users, it must ensure it meets every demand.

🔹️US Senators Flag Risks of Presidential Involvement in USD1

WLF’s announcement of a USD1 stablecoin immediately raised regulatory questions surrounding President Trump’s role in the project. Three days after the announcement, a group of lawmakers led by Senator Elizabeth Warren sent a letter to the Federal Reserve and the Office of the Comptroller of the Currency.

In the letter, the group asked both agencies to clarify how they plan to uphold regulatory integrity following the issuance of USD1.

The Senators cautioned that letting a president personally benefit from a digital currency overseen by federal agencies he has sway over is a big risk to the financial system. They argued that an unprecedented situation like this one could hurt people’s trust in how regulations are made.

“The launch of a stablecoin directly tied to a sitting President who stands to benefit financially from the stablecoin’s success presents unprecedented risks to our financial system,” they argued.

The letter further detailed situations where Trump could directly or indirectly affect decisions regarding USD1.

As things stand, USD1 isn’t well-prepared to follow MiCA’s strict reporting and transparency rules.

🔹️How Do Concerns Over USD1 Impact MiCA Acquisition?

According to Ianeva-Aubert, if USD1 doesn’t clear up doubts over potential conflicts of interest, this would affect its ability to apply for an operating license in the European Union.

“MiCA‬‭ requires‬‭ strong‬‭ governance,‬‭ including‬‭ independent‬‭ directors‬‭ and‬‭ clear‬‭ separation‬ between‬‭ owners‬‭ and‬‭ managers.‬‭ Issuers‬‭ must‬‭ have‬‭ clear‬‭ rules‬‭ to‬‭ handle‬‭ conflicts‬‭ of‬ interest. If USD1 has any conflicts, this could make it harder to comply,” she said.

Ianeva-Aubert also highlighted that WLF still hasn’t released enough public information on USD1 to assess the degree of its compliance effectively. In particular, the stablecoin issuer has not disclosed the measures it would take to safeguard against market manipulation.

“‬While‬‭ USD1‬‭ has‬‭ announced‬‭ partnerships‬‭ with‬‭ established‬‭ providers‬‭ like‬‭ BitGo‬‭ for‬‭ custody,‬‭ it‬‭ is‬‭ not‬‭ clear‬‭ if‬‭ it‬‭ currently‬‭ meets‬‭ all‬‭ of‬‭ MiCA’s‬‭ anti-manipulation‬‭ requirements,‬‭ which‬‭ include‬‭ having‬‭ market‬‭ surveillance‬‭ systems‬‭ to‬‭ detect‬‭ suspicious‬‭ trading‬‭ patterns,‬‭ regular‬‭ transaction‬‭ monitoring‬‭ and‬‭ auditing,‬‭ clear‬‭ policies‬‭ for‬‭ preventing‬‭ insider‬‭ trading,‬‭ and other strict controls,” she added.

As of now, USD1 would likely fail MiCA’s transparency tests. However, industry experts pointed out other parts of the framework that might be even larger obstacles for USD1 to operate across the European Union.

🔹️Impact of the EU’s Reserve Mandate on USD1

When asked about the biggest regulatory hurdles USD1 would face in securing a MiCA license, experts’ responses were unanimous. The stablecoin would need to store a large portion of its reserves in a European bank.

This mandate has proven difficult for established stablecoin issuers seeking operations across the region.

“For‬‭ example,‬‭ Circle‬‭ (issuer‬‭ of‬‭ USDC)‬‭ had‬‭ to‬‭ create‬‭ an‬‭ EU‬‭ entity‬‭ and‬‭ keep‬‭ EU-issued‬‭ USDC‬‭ reserves‬‭ with‬‭ EU-authorized‬‭ banks.‬‭ For‬‭ issuers‬‭ meeting‬‭ these‬‭ rules‬‭ could‬‭ require‬‭ some‬‭ level‬‭ of‬‭ restructuring,‬‭ strong‬‭ EU‬‭ bank‬‭ relationships‬‭ and‬‭ more‬‭ complex‬‭ reserve‬‭ management.‬‭ This‬‭ also‬‭ means‬‭ lower‬‭ interest‬‭ revenue,‬‭ since‬‭ EU‬‭ banks usually pay less interest than US or offshore banks,” Ianeva-Aubert said.

This regulation aims to ensure seamless accessibility for European crypto users and traders. For Forest Bai, Co-founder of Foresight Ventures, USD1 could capitalize on this opportunity during the early stages of its development. By doing so, it could avoid some of the obstacles its competitors had to endure.

“‬While‬‭ consolidating‬‭ the‬‭ token’s‬‭ reserves‬‭ in‬‭ EU‬‭ banks‬‭ may‬‭ prove‬‭ difficult,‬‭ USD1’s‬‭ relatively‬‭ small‬‭ market‬‭ size‬‭ could‬‭ work‬‭ in‬‭ its‬‭ favor‬‭ for‬‭ MiCA‬‭ compliance‬‭ at‬‭ this‬‭ stage.‬‭ Unlike‬‭ established‬‭ tokens,‬‭ like‬‭ USDT,‬‭ that‬‭ struggle‬‭ to‬‭ adapt,‬‭ newer‬‭ entrants‬‭ that‬‭ emerged‬‭ from‬‭ Circle‬‭ demonstrate‬‭ compliance‬‭ feasibility,” Bai told BeInCrypto.

Yet, even as USD1 scales and its demand grows, other mandatory requirements could restrict its scope of success.

🔹️MiCA’s Transaction Volume Caps to Preserve Euro Dominance

As part of the MiCA regulation, the European Union has taken specific measures to safeguard the euro’s dominance. If a digital currency not denominated in euros were to become extensively adopted for daily payments within Europe, it could present a potential risk to the European Union’s financial sovereignty and the stability of the euro.

To contain this possibility, MiCA places volume caps on transactions used as a means of exchange within the EU.

“‭A‬‭ key‬‭ provision‬‭ of‬‭ MiCA‬‭ that‬‭ is‬‭ often‬‭ overlooked,‬‭ but‬‭ critically‬‭ important,‬‭ relates‬‭ to‬‭ transaction‬‭ volume‬‭ limitations‬‭ for‬‭ EMTs‬‭ denominated‬‭ in‬‭ non-euro‬‭ currencies.‬‭ Where‬‭ the‬‭ daily‬‭ average‬‭ number‬‭ of‬‭ transactions‬‭ used‬‭ for‬‭ payment‬‭ purposes‬‭ exceeds‬‭ 1‬‭ million,‬‭ or‬‭ the‬‭ average‬‭ daily‬‭ transaction‬‭ volume‬‭ surpasses‬‭ €200‬‭ million,‬‭ the‬‭ issuer‬‭ must‬‭ cease‬‭ new‬‭ issuance‬‭ and‬‭ present‬‭ a‬‭ remediation‬‭ plan‬‭ to‬‭ the‬‭ regulator.‬‭ These‬‭ thresholds‬‭ are‬‭ designed‬‭ to‬‭ prevent‬‭ systemic‬‭ reliance‬‭ on‬‭ foreign-denominated‬‭ EMTs‬‭ and‬‭ to‬‭ protect‬‭ the‬‭ euro’s role in the Union’s monetary system,” Elisenda Fabrega, General Council at Brickken, told BeInCrypto.

In other words, MiCA establishes predefined limits on the transactional volume of such currencies. The EU initiates regulatory measures when these limits are exceeded due to widespread payment usage.

“Stablecoins‬‭ such‬‭ as‬‭ TRUMP‬‭ USD1‬‭ must‬‭ implement‬‭ monitoring‬‭ tools‬‭ and‬‭ usage‬‭ controls‬‭ to‬‭ avoid‬‭ breaching‬‭ these‬‭ limits‬‭ unintentionally.‬‭ Issuers‬‭ may‬‭ be‬‭ required‬‭ to‬‭ geo-fence,‬‭ restrict‬‭ retail‬‭ adoption,‬‭ or‬‭ structure‬‭ distribution‬‭ to‬‭ mitigate‬‭ risk‬‭ of‬‭ triggering‬‭ supervisory action,” she added.

Specifically, USD1 issuers must suspend any further digital currency issuance and provide a remediation plan to the relevant regulator, outlining steps to ensure their usage does not negatively impact the euro.

If USD1 wants to work in places where it can experience uninhibited growth, the European market might not be the best fit for this stablecoin. Other parts of MiCA also suggest this could be the case.

🔹️MiCA Limitations to Stablecoins as Investment Vehicles

EU regulators have been clear that stablecoins, or e-money tokens (EMTs), as the regulation refers to them, are payment instruments that should not be confused with investment vehicles. The MiCA framework has a few rules in place to prevent this.

“MiCA‬‭ prohibits‬‭ EMTs‬‭ from‬‭ offering‬‭ any‬‭ form‬‭ of‬‭ interest‬‭ or‬‭ benefit‬‭ to‬‭ holders‬‭ based‬‭ on‬‭ the‬‭ duration‬‭ of‬‭ their‬‭ holdings.‬‭ This‬‭ restriction‬‭ reinforces‬‭ the‬‭ classification‬‭ of‬‭ EMTs‬‭ as‬‭ payment‬‭ instruments,‬‭ not‬‭ investment‬‭ vehicles,‬‭ and‬‭ limits‬‭ their‬‭ use‬‭ in‬‭ structured‬‭ products,‬‭ yield-generating‬‭ services,‬‭ or‬‭ decentralized‬‭ finance‬‭ platforms‬‭ unless‬‭ those platforms are also regulated under EU law,” Fabrega told BeInCrypto.

These limitations and the volume caps may make Europe an undesirable target for USD1.

“While‬‭ MiCA‬‭ creates‬‭ a‬‭ clear‬‭ pathway‬‭ for‬‭ the‬‭ issuance‬‭ and‬‭ trading‬‭ of‬‭ stablecoins‬‭ within‬‭ the‬‭ EU,‬‭ it‬‭ also‬‭ introduces‬‭ operational‬‭ restrictions‬‭ that‬‭ are‬‭ material‬ and‬‭ enforceable.‬‭ The‬‭ transaction‬‭ volume‬‭ thresholds‬‭ for‬‭ EMTs,‬‭ in‬‭ particular,‬‭ may‬‭ constrain‬‭ market‬‭ expansion‬‭ for‬‭ non-euro-denominated‬‭ tokens‬‭ such‬‭ as‬‭ TRUMP‬‭ USD1,” Fabrega concluded.

Given the circumstances, experts like Bai think WLF might want to focus on countries with better market conditions for stablecoin issuers.

🔹️Should WLF Consider the EU Market for USD1 Operations?

While the European Union has an undeniable crypto market presence, other jurisdictions have an even larger footprint.

‭”The EU’s crypto market remains comparatively small, with just 31‬‭ million users versus Asia’s 263 million and North America’s 38 million users,‬‭ according to a‬‭ report from Euronews‬‭. This limited‬‭ market size may not justify‬‭ MiCA compliance costs for projects, like WLFI,” Bai told BeInCrypto, adding that “Projects‬‭ ultimately‬‭ determine‬‭ their‬‭ own‬‭ growth‬‭ strategy.‬ Given‬ that,‬‭ currently,‬‭ the‬‭ EU‬‭ represents‬‭ a‬‭ secondary‬‭ market‬‭ for‬‭ USD1,‬‭ the‬‭ project’s‬‭ strategic‬‭ priorities‬‭ may‬‭ naturally‬‭ shift‬‭ toward‬‭ regions‬‭ with‬‭ less‬‭ stringent‬‭ stablecoin‬‭ regulations to drive its adoption.”

These circumstances alone may prompt USD1 to reconsider its options.

“Although‬‭ the‬‭ EU‬‭ has‬‭ limited‬‭ competition‬‭ among‬‭ stablecoin‬‭ issuers,‬‭ WLFI‬‭ can‬‭ make‬‭ up‬‭ for‬‭ noncompliance,‬‭ with‬‭ aggressive‬‭ expansion‬‭ in‬‭ regions,‬‭ such‬‭ as‬‭ Asia‬‭ and‬‭ Africa.‬‭ The‬‭ USDT‬‭ precedent‬‭ has‬‭ demonstrated‬‭ that‬‭ dominant‬‭ players‬‭ can‬‭ maintain‬‭ position‬‭ while‬‭ boycotting‬‭ MiCA‬‭ and‬‭ the‬‭ EU‬‭ market.‬‭ For‬‭ USD1,‬‭ MiCA‬‭ compliance‬‭ does‬‭ offer‬‭ EU‬‭ access‬‭ but‬‭ appears‬‭ non-essential‬‭ to‬‭ long-term‬‭ viability,‬ ‭ given alternative growth markets,” Bai added.

In fact, USD1 could start by gaining a competitive edge right at home.

🔹️USD1’s Political Backing at Home

With a crypto-friendly president in office –whose very crypto project officially announced the launch of USD1– the stablecoin has sufficient backing to make its mark.

“The‬‭ bigger‬‭ question‬‭ here,‬‭ however,‬‭ is‬‭ whether‬‭ WLFI‬‭ will‬‭ want‬‭ to‬‭ push‬‭ for‬‭ a‬‭ MiCA‬‭ license‬‭ at‬‭ all,‬‭ given‬‭ it‬‭ has‬‭ the‬‭ right‬‭ set-up‬‭ to‬‭ thrive‬‭ in‬‭ the‬‭ US‬‭ with‬‭ its‬‭ strong‬‭ political‬‭ leaning,” Bai emphasized.

Looking past the immediate future, Bai underlined that if the US doesn’t keep developing supportive crypto regulations, USD1’s growth in the country could be held back following a government shift.

“For‬‭ USD1,‬‭ policy‬‭ longevity‬‭ is‬‭ worth‬‭ watching,‬‭ as‬‭ its‬‭ post-Trump‬‭ viability‬‭ faces‬‭ uncertainty,‬‭ given‬‭ potential‬‭ US‬‭ political‬‭ shifts‬‭ in‬‭ the‬‭ coming‬‭ years.‬‭ Even‬‭ if‬‭ WLFI‬‭ strives‬‭ to‬‭ comply‬‭ with‬‭ MiCA‬‭ now,‬‭ the‬‭ question‬‭ is‬‭ what‬‭ about‬‭ the‬‭ years‬‭ succeeding Trump’s tenure,” he said.

Nonetheless, failure to comply with a comprehensive framework like MiCA would be a blow to USD1.

🔹️USD1’s Path Amid Growing Appeal of Regulated Stablecoins

Based on Kaiko’s research, users are growing in preference for regulated stablecoins.

‭“MiCA-compliant‬‭ stablecoins‬‭ have‬‭ shown‬‭ robust‬‭ growth‬‭ during‬‭ recent‬‭ market‬‭ turbulence,‬‭ according‬‭ to‬‭ Kaiko‬‭ data‬‭ (as‬‭ opposed‬‭ to‬‭ non-compliant options), showing that users increasingly prefer regulated options,” Ianeva-Aubert revealed.

Given this reality, USD1’s failure to comply with the EU’s regulations, should it ever even consider applying for a MiCA license in the first place, could have negative consequences for the project’s long-term viability.

“If‬‭ USD1‬‭ can’t‬‭ meet‬‭ MiCA’s‬‭ rules,‬‭ it‬‭ would‬‭ likely‬‭ be‬‭ blocked‬‭ from‬‭ the‬‭ EU‬‭ market,‬‭ just‬‭ like‬‭ USDT‬‭ was‬‭ for‬‭ most‬‭ European‬‭ users.‬‭ This‬‭ would‬‭ limit‬‭ its‬‭ growth‬‭ and‬‭ potentially‬‭ impact‬‭ its‬‭ credibility‬‭ amongst‬‭ institutional‬‭ users,” Ianeva-Aubert concluded.

Regardless of the markets WLF evaluates in its efforts to increase the reach of USD1, compliance with general stipulations concerning transparency, legal architecture, and real-time transaction oversight could be conducive to its eventual success.

https://beincrypto.com/experts-discuss-trump-usd1-stablecoin-eu/

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Since launch, the Soroban Security Audit Bank has successfully conducted over 40 essential audits, deploying over $3 million to support security of the smart contracts on Stellar. Check it out!

 

Ecosystem Success Stories: How the Soroban Audit Bank Drives Security Forward

By making automated formal verification available to developers, in addition to allocating significant budget for securing many of the top DeFi protocols built on top of Stellar, SDF has established a new security standard in the Web3 ecosystem. Mooly Sagiv, Co-Founder of Certora
SDF has been a strong partner as we’ve worked with teams across the Stellar ecosystem. SDF’s Audit Bank initiative allows for a smooth and streamlined review process, and is a clear reflection of the Stellar ecosystem’s enhanced commitment to security. Robert Chen, CEO of OtterSec
 

Leading projects within the Soroban ecosystem have highlighted the impact of the Audit Bank

Finding a good auditor is difficult, expensive, and high-stakes. The Audit Bank streamlines the process and supports ecosystem projects with security review at critical growth milestones. Markus Paulson, Co-Founder of Script3
The audit firms we worked with deeply understood the full ecosystem and the underlying protocols used. Their expertise and the tools from the Audit Bank strengthened our security and supported user and investor trust. Esteban Iglesias Manríquez, Co-Founder of Palta.Labs

What's New in 2025: Enhanced Audit Support for Soroban Builders

Teams building financial protocols, high-dependency data services, high-traction dApps funded by the Stellar Community Fund are able to request an audit and will typically be matched with a reputable audit firm within two weeks. We recently restructured the program for this year to enhance audit efficiency and incentivize accountability, and rapid and complete vulnerability remediation:

  • Complimentary Initial Audit: Projects will need to contribute 5% of the audit cost upfront, but this co-payment amount is eligible for a full refund, provided that critical, high, and medium vulnerabilities identified are swiftly remediated within 20 business days of receiving the initial audit report (learn more).
  • Incentivized Security at Key Traction Milestones: Complimentary, extensive follow-up audits are available as projects achieve critical traction milestones (e.g., $10M and $100M TVL). These audits include deeper assessments such as formal verification or competitive audits, significantly boosting project security at pivotal stages.
  • Advanced Security Tooling: Projects can enhance their security self-serve through complimentary or discounted access to specialized tooling, which provide vulnerability detection and formal verification capabilities (see full list of available tooling). These tools are encouraged to capture ‘easy-to-spot’ issues prior to audit as well as a final check post-audit to increase the effectiveness and thoroughness of audits.
  • Enhanced Audit Readiness Support: Projects receive structured preparation support, including the implementation of best practices and security standards based on the STRIDE threat modeling framework. This ensures project teams are thoroughly prepared, optimizing audit efficiency and minimizing delays.

Get Started Today

If you're already funded through the Stellar Community Fund, meet the criteria and ready to secure your smart contracts, check your email for an invitation to submit an audit request–if you haven’t received one, contact [email protected].

If you haven't built on Stellar yet, we encourage you to start your journey with the Stellar Community Fund to become eligible for future security audits and ecosystem support. For any broader questions on the program, contact [email protected].

Also, we’re organizing an exciting series of workshops–join us for the kick-off on Soroban Security Best Practices on Friday, May 30, 2025 at 2 PM ET on @StellarOrg. Together, we're shaping a secure and resilient future for smart contracts on Stellar.

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Santander mulls stablecoin, crypto offering

Bloomberg reported that Banco Santander is mulling introducing euro and dollar stablecoins, or potentially making a third party coin available to clients, citing sources. This move aligns with broader crypto ambitions, as its digital bank, Openbank, has reportedly applied for a European cryptocurrency license under the Mica Regulations and may enable retail access to digital assets.

Systemically important banks embrace stablecoins?

Major banks are now moving from observers to participants in this expanding market. Should Santander confirm plans to launch a stablecoin, it will be the fourth global systemically important bank (G-SIB) to do so. Societe Generale’s FORGE subsidiary launched the EURCV euro coin in 2023. Deutsche Bank is a partner in ALLUnity, another stablecoin initiative with plans to launch this year, subject to regulatory approval. And Standard Chartered is part of a joint venture in Hong Kong that intends to introduce a stablecoin.

Santander’s involvement could extend beyond an individual initiative. The bank is a shareholder in The Clearing House, where the Wall Street Journal reported that US banks are exploring the potential to create a joint stablecoin. If a US initiative took that route it could involve nine more G-SIBs including Bank of America, Barclays, BMO, BNY Mellon, Citi, HSBC, JP Morgan, TD Bank and Wells Fargo.

Apart from these initiatives, our research shows that more than 20 other banks have been involved in stablecoin projects.

Until recently stablecoins were mainly used to settle cryptocurrency transactions and by residents in countries with volatile domestic currencies. During the last year stablecoin infrastructure has been expanding, especially for mainstream cross border payments. Plus, President Trump issued an executive order prioritizing stablecoins. One of the administration’s motivations is this increases demand for US Treasuries, lowering the interest rate the government pays on the Treasury bills.

Santander as an early digital assets mover

Santander’s stablecoin consideration builds on years of blockchain experience. The bank was an early Ripple investor and previously used Ripple’s permissioned network for payments (not XRP), while also embracing permissionless blockchain activities including issuing a digital bond on Ethereum in 2019. This dual approach led to collaborations with other major players – alongside Societe Generale FORGE and Goldman Sachs, Santander participated in the European Investment Bank’s first digital bond, also on Ethereum. Currently, the bank’s most significant digital money initiative involves Fnality, the wholesale blockchain-based settlement network, where Santander ranks among 20 institutional backers and is part of the early adopter group alongside Lloyds Bank and UBS.

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