CertiK warned that newly proposed or implemented US stablecoin rules are fragmenting global liquidity between the United States and Europe, a shift that could affect settlement, market depth, and cross-border flows. The notice frames a divergence in where stablecoin liquidity concentrates and how it may be accessed by market participants.
CertiK’s assessment frames US regulatory action as creating a divergence in where stablecoin liquidity concentrates. Stablecoins are digital tokens designed to maintain a fixed value against a fiat currency, and liquidity refers to the ease with which those tokens can be bought, sold, or used for settlement without large price impact. The firm flagged that regulatory differences may push trading and liquidity provision toward the jurisdiction whose rules are more permissive or clearer, and fragmentation could raise trading costs and settlement latency for cross-border participants.
For market participants, a split in liquidity can widen the premium or discount to net asset value across venues and complicate prime-broker relationships and custody arrangements. Firms that provide on-ramps, custody, or algorithmic market making may face operational and compliance trade-offs when choosing between US-focused activity and European markets.
These shifts could affect tokenization projects, RWA settlement plans, and the design of cross-border payment rails that rely on stablecoin finality and low latency, altering how products are structured and where capital is deployed.
CertiK’s warning and implications for markets
The core assertion in the warning is regulatory divergence between US rules and European frameworks. This creates potential compliance arbitrage, where firms align activity to the regime that best fits business models or capital structures. Immediate compliance risks include fragmented KYC/AML requirements, licensing uncertainty for issuers, and differences in permitted reserve compositions, shaping where liquidity pools concentrate and how quickly settlement can occur across jurisdictions.
CertiK’s warning highlights regulatory fragmentation as a material factor for stablecoin liquidity and cross-border settlement. The practical implication is that firms and policymakers must monitor regulatory alignment or divergence closely, since where rules favor issuance and settlement will influence liquidity distribution.
