Gregory Strong, Sarah Chen, and Jonathan Galea Publish “Beyond the Perimeter: Non-Qualifying Payment Stablecoins Under U.S. and EU Law” in GLI’s Blockchain & Cryptocurrency Regulation 2027
October 29, 2026
Cahill partners Gregory Strong, Sarah Chen, and Jonathan Galea authored the “Beyond the Perimeter: Non-Qualifying Payment Stablecoins Under U.S. and EU Law” chapter in Global Legal Insights’ Blockchain & Cryptocurrency Regulation 2027 guide.
Much of the commentary on the GENIUS Act has focused on the stablecoins and issuers the Act covers; this chapter examines stablecoins that do not qualify under the Act and the U.S. and EU legal regimes that continue to govern them. The chapter compares the U.S. framework with the EU’s Markets in Crypto-Assets Regulation (MiCA), which both impose restrictions on intermediaries such as exchanges, but leave the holding and transfer of non-qualifying stablecoins through self-custody wallets and decentralized finance applications unrestricted. It also offers practical considerations for issuers, exchanges, and institutional holders.
The GLI Blockchain & Cryptocurrency Regulation 2027 guide explores blockchain and cryptocurrency laws and regulations across 26 jurisdictions.
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