On August 28, 2026, at the Jackson Hole Economic Symposium hosted by the Federal Reserve Bank of Kansas City, Pablo Hernández de Cos, general manager of the Bank for International Settlements (BIS), delivered a blunt verdict on stablecoins: in his view, they are not a credible means of payment at scale. He set them against tokenized deposits, ordinary bank liabilities simply recorded on a distributed ledger.
Two instruments, one goal: settling in tokens
The core argument rests on singleness of money, the principle that a euro held at a bank is always worth a euro, whatever the underlying rail. A tokenized deposit remains a supervised bank's liability, ultimately settled in central bank money, so that property holds. A stablecoin has no built-in mechanism guaranteeing it always trades at par, and wallet-to-wallet transfers largely sit outside conventional banking oversight.
The second point concerns compliance. Stablecoin balances sit mostly in self-custodied wallets, which complicates enforcement of anti-money-laundering and counter-terrorist-financing rules. Tokenized deposits, because they move across licensed platforms and stay tied to an identified account, make that oversight far easier.
The group-level supervision gap
The same week, the BIS's Financial Stability Institute (FSI) published a separate brief comparing stablecoin issuance regimes across five jurisdictions: the European Union, Hong Kong, Singapore, the United Kingdom and the United States. Its central finding is not about how a stablecoin is defined, but about the scope of the rule that governs it: activity restrictions target the issuing entity, never the wider group it belongs to.
- Lending out the reserves backing the issued tokens
- Staking, or committing those assets to a yield mechanism
- Custody of third-party digital assets, on behalf of outside clients
These three activities are typically off-limits to the issuer itself. Nothing, however, stops a sister company within the same group from carrying them out. A non-bank issuer can strictly comply with the letter of the rule while housing, one affiliate over, exactly what that rule set out to prevent.
| Jurisdiction | Approach for non-bank issuers |
|---|---|
| United States (GENIUS Act) | Restrictive: lending, staking, proprietary trading and third-party crypto custody barred for the issuer |
| Singapore | Restrictive, along lines close to the US regime |
| Hong Kong | Additional activities possible under separate authorization |
| United Kingdom | Additional activities possible under separate authorization |
| European Union (MiCA) | Additional activities possible under separate authorization |
What US practice already confirms
The FSI brief doesn't describe a theoretical risk. In the United States, trust charters granted by the Office of the Comptroller of the Currency (OCC) show that structuring across several entities is already common practice among stablecoin issuers, each one housing a distinct function of the same economic whole. The FSI draws a recommendation from that: consolidated, group-wide supervision, particularly for the largest non-bank issuers, the ones where a materializing risk would be most costly.
For a payment provider weighing whether to build in stablecoin settlement, these two same-day publications sketch a rule of thumb: a token's soundness doesn't show up only in its issuance contract, but in the structure of the group standing behind it. An issuer affiliated with an entity that lends, custodies or otherwise puts the same assets to work elsewhere on the org chart warrants closer due diligence than simply checking the restriction that applies to it alone.