NYDFS-EBA Stablecoin MOU, HK VATP Rules, and CFTC Perps: What Firms Must Know

Three regulatory developments published in quick succession in late May and early June 2026 confirm what compliance teams have been anticipating: stablecoin oversight is becoming a coordinated, cross-border discipline, not a patchwork of isolated national rules. The New York Department of Financial Services and the European Banking Authority have signed a formal supervisory cooperation agreement. Hong Kong has closed its consultation on virtual asset advisory and management licensing, and issued compliance expectations for stablecoin activity on licensed trading platforms. And the US Commodity Futures Trading Commission has issued its first-ever approvals for crypto perpetual futures available to US customers. Each development carries direct operational consequences for firms managing digital asset compliance and reporting obligations.

NYDFS and EBA: A Memorandum of Understanding on Stablecoin Supervision

What the MOU covers

Signed on 2 June 2026, the memorandum of understanding between the NYDFS and the EBA establishes a formal channel for bilateral information sharing on stablecoin issuers and related market participants. The two authorities have different but complementary mandates. NYDFS regulates stablecoin issuers and other virtual currency businesses in New York state through its BitLicense regime and applicable financial services and banking laws. The EBA, under the EU's Markets in Crypto-Assets regulation, supervises stablecoin issuers classified as "significant" based on size, transaction volume, and systemic connectivity.

The MOU allows both bodies to exchange information covering: the fitness of supervised entities and reasons for any supervisory refusals or licensing status changes; reserve asset holdings, corporate structures, and management arrangements of issuers; and stablecoin trading volume data from exchange platforms in New York and the EU. Beyond data sharing, the agreement enables joint on-site inspections and obliges both parties to notify each other promptly when they identify regulatory breaches among supervised market participants.

Why it matters for cross-border operators

Any stablecoin issuer or VASP operating across the Atlantic should treat the MOU as a material change to the supervisory environment. Information a firm discloses to one regulator can now be shared directly with the other. Firms authorised in New York that are also active in EU markets, or that have subsidiaries licensed under MiCA, should review whether their compliance disclosures to NYDFS and to the EBA are consistent and complete. Divergences, even unintentional ones, carry heightened risk when regulators are sharing data in real time.

The MOU also signals that AML/CFT and sanctions compliance standards will be benchmarked against both regimes simultaneously. Firms using crypto accounting software to manage reserve reporting, transaction volume tracking, or entity-level disclosures across jurisdictions will need to ensure their data architecture supports the granularity both authorities expect. Generic consolidated reporting is unlikely to be sufficient. For a detailed picture of the AML risks associated with illicit stablecoin flows that regulators are actively monitoring, see our coverage of the AML risk implications of illicit stablecoin activity.

Hong Kong: Advisory Licensing Conclusions and VATP Stablecoin Compliance

Consultation conclusions on virtual asset advisory and management services

On 26 May, the Hong Kong Securities and Futures Commission and the Financial Services and the Treasury Bureau published their consultation conclusions on the proposed licensing regime for virtual asset advisory and management services. The consultation, launched in December 2025, attracted 51 submissions and found broad private sector support for the proposed framework.

The new regime maps to the SFC's existing structure for securities advice and asset management, categorised as Type 4 and Type 9 regulated activities under the Anti-Money Laundering and Countering the Financing of Terrorism Ordinance. One significant clarification: there will be no "deeming arrangement." Unlike some transitional regimes in other jurisdictions, existing virtual asset advisors and managers will not be permitted to operate under temporary authorisation while awaiting full licensing. They will need to be licensed before they can legally operate under the new framework.

The actual implementation date will be set through legislative amendments planned for 2026. The SFC and FSTB have encouraged firms that want to be licensed to begin engaging with the SFC now, both to receive early feedback and to reduce the risk of business disruption when the regime goes live.

SFC circular on VATP stablecoin activity

In a separate but related development, the SFC published a circular setting out compliance and risk management expectations for SFC-licensed virtual assets trading platforms engaging in stablecoin-related activities. The Hong Kong Monetary Authority has administered Hong Kong's stablecoin supervisory framework since August 2025, and in April 2026 it approved the first two stablecoins eligible for listing on licensed VATPs.

The circular confirms that SFC-licensed VATPs may list those approved stablecoins, and any additional stablecoins the HKMA approves in future. Key obligations include disclosing information to customers about each stablecoin's stabilisation and redemption arrangements; notifying the SFC in writing before any planned stablecoin listing or related activity (though advance SFC approval is not required); and reviewing and updating internal compliance and risk management policies to reflect stablecoin-specific requirements.

Firms operating in Hong Kong should treat this circular as a prompt to audit their current onboarding and product disclosure processes. Digital asset accounting software used to record stablecoin positions will also need to capture issuer-level metadata, since VATP compliance teams will require it to satisfy SFC expectations around customer disclosure and internal policy documentation.

CFTC: First-Ever Approvals for Crypto Perpetual Futures in the US

The two approvals explained

The US CFTC has taken two distinct actions that together constitute its first regulatory approvals for crypto perpetual futures available to US customers.

First, the CFTC approved the listing of a Bitcoin perpetual contract, designated BTCPERP, on Kalshi, which operates as a CFTC-regulated designated contract market. The CFTC determined that the contract complies with the Commodity Exchange Act, the primary US legislation governing domestic derivatives markets.

Second, the CFTC issued guidance to Coinbase, which operates as a CFTC-regulated futures commission merchant, clarifying that it may offer perpetual futures contracts to US customers. These contracts, known as Deribit Perpetuals, are routed through affiliated overseas platforms and qualify as compliant foreign futures under the applicable regulatory framework.

What perpetual futures are and why the approvals matter

Perpetual futures, unlike standard futures contracts, carry no expiration date. A holder can maintain a position indefinitely. Crypto perpetuals reference the spot price of an underlying asset and use a funding rate mechanism to keep the futures price aligned to that spot price, with traders paying a periodic fee to hold their positions. They are widely used for hedging spot exposure and provide leverage and 24/7 market access, features that have made them a dominant product in global crypto derivatives markets.

The CFTC approvals are significant because they bring this product class into the regulated US market for the first time. For accounting and audit teams, perpetual futures introduce specific reporting complexities: positions do not expire and therefore require continuous mark-to-market accounting, funding rate payments must be recognised as periodic income or expense, and the leverage embedded in these instruments affects how notional exposure is reported at a balance sheet level.

Firms whose clients hold or trade perpetual futures will need to assess whether their current crypto bookkeeping software can handle the continuous settlement and funding rate accrual mechanics that these products generate. Standard digital asset accounting software configured for spot trades or expiring futures will not automatically capture the correct economic flows.

Firms managing OFAC and sanctions exposure should also note that the CFTC approvals expand the US-regulated perimeter for crypto derivatives. Any entity offering or brokering these products to US customers must ensure sanctions screening is applied to counterparties. For further detail on sanctions obligations in the crypto context, see our analysis of OFAC SDN cryptocurrency address compliance obligations.

The Broader Pattern: Regulatory Coordination Is Now Structural

Taken together, these three developments reflect a consistent direction of travel. Regulators are not treating digital asset oversight as a domestic problem. The NYDFS-EBA MOU formalises cross-Atlantic supervisory cooperation. Hong Kong's licensing conclusions and VATP circular tighten its framework while maintaining alignment with international AML standards. The CFTC approvals extend regulated access to a product that has until now existed outside the US regulatory perimeter.

For accounting firms, auditors, and CFOs advising or managing digital asset businesses, the practical implication is that compliance gaps which might have been tolerable in a fragmented supervisory environment are no longer defensible. Regulators are sharing data, aligning standards, and expanding the products and entities subject to formal oversight simultaneously across multiple major jurisdictions.

Crypto accounting software that can generate jurisdiction-specific disclosures, track reserve asset compositions, log stablecoin issuer metadata, and handle the accrual mechanics of perpetual funding rates will be increasingly necessary, not optional. Firms should use these developments as a prompt to audit whether their current systems and workflows meet the bar these regulators are collectively setting.

Source: Elliptic