2025: The Year of Stablecoins – What Core Strategies Should Companies Prepare as Institutionalization Draws Near? [Anjin Close-Up]

[Hankyung CFO Insight]

Dongi Lee, Blockchain & Digital Assets Group Leader, Deloitte Consulting Korea

In May 2025, the U.S. Senate passed the stablecoin regulatory bill, 'GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins of 2025 Act),' with a 66-to-32 vote. The swift reintroduction and approval of a bill that had previously been rejected is seen as a reflection of the new Trump administration’s pro-crypto policy stance and active private sector support for stablecoin adoption.

The GENIUS Act establishes a comprehensive regulatory framework ranging from the definition of dollar-based payment stablecoins (Payment Stablecoin, hereafter PSC), issuance requirements, reserve composition, to consumer protection. Issuers must hold 100% liquid assets, such as cash or government bonds, as reserves redeemable 1:1, with monthly external audits and CEO certification required. PSC holders must be able to redeem their PSC for legal tender at any time, and these rights must be assured by law.

The core of these provisions is to recognize stablecoins not merely as 'digital assets' but as reliable 'digital payment instruments,' with the aim of integrating them into the existing financial order and payment infrastructure. As capital and payment systems around the globe rapidly digitalize, swift regulatory measures by the U.S. are expected to have a significant ripple effect on the currency sovereignty and financial systems of other nations.

Stablecoins first emerged in 2014 with BitUSD, quickly followed by fiat-collateralized Tether (USDT) gaining market dominance. Due to their accessibility without customer identity verification (KYC), they grew to become key assets within the crypto ecosystem. However, concerns over reserve transparency led institutional investors to focus on USDC since around 2018. USDC distinguished itself with monthly external audits, winning the trust of institutions and regulators, and rapidly gaining presence in the DeFi sector. Amid continued innovation, the 2022 collapse of the algorithmic stablecoin TerraUSD (UST) precipitated a major bank run and market cap collapse, heightening awareness throughout the market of the need for stablecoin stability and clear regulation. Accordingly, regulators in the U.S., EU, Japan, and other major economies are now closing regulatory gaps to manage risks and foster industry growth for enhanced global competitiveness.

Domestically, there is still no clear legal definition or framework for stablecoins. Nonetheless, voluntary use cases are already emerging in the market. Notably, Hong Kong-based virtual asset payment company RedotPay launched a stablecoin-backed check card, offering real-time settlement at Visa-affiliated stores at home and abroad. Linked with Apple Pay and quick to issue for foreign residents in Korea, this card drew attention as an innovative payment instrument until issuance was halted in late May due to local regulatory considerations.

Furthermore, some production workplaces in Korea reportedly see foreign workers receiving wages in stablecoins rather than won and remitting home via stablecoins. Practical benefits include lower transfer fees, mitigating FX volatility, faster remittance, and the ability to send funds without bank visits. Yet, the proliferation of dollar-based stablecoins raises concerns over weakened monetary sovereignty and foreign exchange management in Korea. For these reasons, there are growing calls to actively review the introduction of won-based stablecoins to address regulatory gaps.

Currently, over 99% of the global stablecoin market is based on the U.S. dollar, whereas the won accounts for less than 1% of international settlements via SWIFT. Although the use of won remains limited even in the digital economy era, Korea already has digital ecosystems based on the won—such as in gaming, content, and e-commerce—providing sufficient grounds for designing domestic payment stablecoins. Won-based PSCs can be expanded in various ways, including real-time settlements between domestic companies, cross-border consumer payments, and the digitalization of local currencies.

Deloitte, the world’s largest accounting and consulting firm, outlines eight key areas for stablecoin issuers to consider in its '2025 Year of Stablecoins' report: ▲Business strategy, ▲Risk management, ▲Reserve management, ▲Accounting & tax, ▲Financial consumer protection, ▲Technology infrastructure, ▲External partnership management, and ▲Supervisory response. These are expected to provide clear direction for growing a domestic stablecoin ecosystem and addressing stakeholders’ concerns.

From a business strategy perspective, clarifying issuance objectives, establishing operating models, and building financial forecasting systems are important. In risk management, identifying and evaluating risks such as liquidity, AML/KYC compliance, and blockchain technology risk—as well as developing integrated management systems with contingency plans—are necessary. Reserves should be managed through policies focused on highly liquid assets, and preparations must be made for external audits. In accounting and tax, the starting point is to establish classification criteria for stablecoins (intangible asset, cash equivalent, liability, etc.).

For consumer protection, requirements include asset segregation, monthly information disclosure, external audits, and clearly defined redemption structures. Technology infrastructure must cover node operation, key management, smart contract security, and the establishment of at least annual information security audits. Due diligence and contract management with external partners such as custodians, and setting up reporting and certification systems with each supervisory authority, are also essential.

These eight areas go beyond mere regulatory compliance and represent sophisticated system designs for stablecoins to be implemented as real payment infrastructure. Issuers must inspect these areas at the group level and prepare internal control processes in advance for timely regulatory response.

Stablecoins are real-time payment instruments issued by 'financial institutions of the digital era.' Technical capability and platform scalability alone are not enough; careful design encompassing public benefit, transparency, and stability is essential. Whereas central bank digital currencies (CBDC) form digital currency infrastructure for the public sector, stablecoins represent a private infrastructure model where traditional financial institutions and non-bank digital asset firms can cooperate.

2025 is likely to mark a pivotal turning point: with the passing of the GENIUS Act, the U.S. has integrated stablecoins into institutional finance, and other countries are moving to implement their own PSCs. To avoid falling behind, domestic authorities must urgently review legal definitions, issuance standards, audit and reserve frameworks for stablecoins. At the same time, companies and financial institutions should proactively build issuance simulations, technology validation, and internal controls for stablecoins.

Ultimately, a 'won-based stablecoin' offers not just a new opportunity for financial and payment innovation, but also a key to elevating Korea's financial competitiveness in the digital economy era. For Korea’s low-growth economy to generate new revenue through digital transformation, now is the golden time. To ensure that 2025 is recorded as 'The Year of Stablecoins,' fast and precise action from both industry and government is anticipated.

Market Insight (insight@hankyung.com)