On October 1, 2026, Brazil gained the most objective rule of the cycle. BCB Resolution No. 561 took effect and closed a specific point in the international payments chain: under its Article 50, payments and receipts between the Brazilian provider of electronic international payment or transfer services — eFX — and its counterparty abroad may only take place through a foreign exchange transaction or through a movement in a non-resident account in reais. Virtual assets are barred at that stage.
It is a surgical restriction, not a broad ban. Custody, and buying and selling stablecoins as an investment, remain permitted. Domestic use remains permitted. The other stages of the transaction are not affected. What changed was one link — and it is precisely the link that gave the operation its speed of minutes.
On the same October 1, the BCB opened one door while closing another: BCB Resolution No. 575, issued on June 18, expanded the possibilities for opening and operating foreign currency deposit accounts in Brazil, reaching exporters, companies with foreign debt, companies with foreign shareholders, and non-residents. Conversion into reais, however, still requires a foreign exchange contract.
These are not the only dates. On September 23, the BCB published two other rules that changed the calendar: Resolution 588, which created mandatory reporting to COAF for virtual asset transfers involving self-custodied wallets from US$10,000, also effective October 1; and Resolution 589, which moved to November 6 the prohibition on regulated institutions operating with unauthorized entities. October 30 is the deadline for providers to file their authorization requests. These are four distinct milestones, with distinct addressees — and treating them as one is the most common misreading right now.
In the United States, the contrast is stark. Three weeks after the CLARITY Act's 49–50 defeat, the prevailing assessment among the law firms tracking the issue — and this is Orrick's reading, not a settled legal fact — is that passage during this Congress has become unlikely. Regulation moves ahead, but through agency action, with a public comment period running until October 20.
And in the United Kingdom, the Bank of England closed on September 22 its public consultation on systemic sterling stablecoins, with a design change that deserves attention: per-holder limits are out, and a £40 billion issuance cap per product is in.
Brazil — Four dates, not one: October 1, October 30, November 6, and January 1. Three rules took effect on October 1. Resolution 561 bars the use of virtual assets at one precise point: settlement of the external leg between the regulated electronic FX provider and its counterparty abroad, which now requires a foreign exchange transaction or a movement in a non-resident account in reais. It is not a general ban on stablecoins. Resolution 575 expands foreign currency accounts held in the country. And Resolution 588, published on September 23, created mandatory reporting to the Financial Activities Control Council (COAF) for virtual asset transfers to or from self-custodied wallets from US$10,000. October 30 is the deadline for providers already in operation to file their authorization requests. Separately — and this is the date that changed — following the amendment made by Resolution 589, the prohibition on regulated institutions operating with unauthorized entities takes effect on November 6, 2026. The precautionary hold of up to 24 hours under Resolution 584 applies from January 1, 2027, and already faces a request in Congress to overturn it.
US — Three weeks after the defeat, the bet is entirely on the agencies. In an analysis published on October 2, the law firm Orrick notes that passage of the CLARITY Act during this Congress is now "widely viewed as unlikely," with the Senate calendar shortened by the November elections. Senator Thom Tillis voted no precisely so he could enter a motion to reconsider, preserving a formal path — and seven Democratic senators reaffirmed, after the vote, their commitment to a bipartisan deal. The CFTC has submitted its own proposed rules; the SEC consultation on Regulation Crypto Assets closes on October 20. There is a law for stablecoins (GENIUS Act) and a statutory ban on a Fed retail CBDC until 2030 (P.L. 119-101) — but there is no market structure law.
United Kingdom — The per-holder limit is out. The per-currency cap is in. The Bank of England's consultation on systemic sterling stablecoins closed on September 22. The design drops the per-holder limits previously considered — £20,000 per individual and £10 million per business — and adopts an initial cap of £40 billion per product, declared temporary. Up to 70% of the backing goes into short-term UK government securities and the remaining 30% into unremunerated deposits at the central bank itself. Issuers may not pay interest on balances, but rewards linked to payment use are allowed. The final Code of Practice is expected by the end of 2026.
Europe — The digital euro got a timeline and merchants. Qivalis, not yet. The European Central Bank selected 36 payment service providers for the digital euro pilot, which runs for 12 months starting in the second half of 2027, and on September 15 opened a call for e-commerce and mobile merchants. Issuance remains conditional on legislation and on a separate decision by the ECB Governing Council. Meanwhile, the euro stablecoin from the Qivalis consortium of 37 banks will be issued on the public Ethereum blockchain — but nothing can be issued before authorization from the Dutch Central Bank, still pending.
🌏 Asia — HSBC's stablecoin has a name. A launch date, no. On September 30, HSBC announced that its Hong Kong dollar stablecoin will be called HSBC RedCoin, distributed through PayMe and the bank's app. The announcement keeps the second half of 2026 as the window, states that the token has not yet been issued, and warns against scams already using the name. The bank has not disclosed which blockchain the token will be issued on. In China, the digital yuan accounted for about 95.3% of the volume settled on mBridge through the end of 2025.
📊 Market — US$300.9 billion, and the quarter's movement was between networks. As of October 1, 2026, the global stablecoin market totaled US$300.9 billion across 195 assets, 152 issuers, and 47 networks, according to a RWA Foundation survey using Token Terminal data. USDT accounts for 61.0% and USDC for 24.8% — 85.9% combined. In the third quarter, Tron gained US$5 billion and Ethereum lost US$4.9 billion, although Ethereum still holds 54.2% of supply.
🌎 Latin America — Argentina at 94%: stablecoins are no longer the exception. It is the highest share of stablecoins in crypto volume among the major currencies tracked by the Artemis platform. Even with the digital dollar premium at around 4% and monthly inflation falling, usage keeps growing — which, in a16z's reading, points to habit, not emergency.
The September 15 outcome has already been covered in this newsletter. What has changed since then is the consolidation of the legal reading of what comes next — and it is less optimistic than the immediate reaction suggested.
On the afternoon of September 15, 2026, the US Senate rejected by 49 votes to 50 the motion that would have allowed debate to advance on the Digital Asset Market Clarity Act (CLARITY Act — the bill that defines who regulates each type of digital asset in the US). Sixty votes were needed to end debate. The tally fell short not only of that threshold, but of a simple majority.
The breaking point was not the division of authority among regulators, the technical heart of the bill, but the ethics language on public officials' holdings in digital assets. Democrats argued that the text did not adequately address the positions of the president and his family; Republicans replied that they had already accepted more than a hundred revisions requested by the other side.
One of the no votes was tactical. In an analysis published on October 2, the law firm Orrick explains that Senator Thom Tillis (R-NC) voted "no" precisely so he could enter a motion to reconsider, preserving a formal path to revive the bill. The bill, therefore, is not legally dead. But the same document is blunt about the odds:
“With the Senate calendar shortened by the November midterm elections, however, passage during this Congress is now widely viewed as unlikely.” — Orrick, analysis published on October 2, 2026
There are, nonetheless, signals in the opposite direction. After the vote, seven Democratic senators — among them Ruben Gallego, Kirsten Gillibrand, and Mark Warner — publicly reaffirmed their commitment to a bipartisan deal. The realistic window would be the lame-duck session, between the November 3 election and early January. An analysis published on September 6 by Crypto Briefing had already mapped the structural obstacles of that window: the bill needs floor time, a process to reconcile the House and Senate texts, and enough votes to overcome procedural hurdles — and any reopening of debate tends to generate new amendment demands on consumer protection and illicit finance. No new date has been set.
Senator Cynthia Lummis, the bill's lead author, had anticipated the outcome to reporters on the day of the vote, conditioning her assessment on the motion failing:
“I think we're done. It's over. (…) Because we've been working on this bill for over a year, and we've given them over 120 of their requests. That's enough.” — Senator Cynthia Lummis, to reporters, September 15, 2026
The regulators' response was swift and documented. On September 16, the chairman of the Commodity Futures Trading Commission (CFTC — the derivatives regulator), Michael Selig, called the result regrettable and said the commission is ready to publish its rules using the legal authorities it already has. The same day, the chairman of the Securities and Exchange Commission (SEC — the securities regulator), Paul Atkins, said he would act "with or without legislation." On September 17, an official SEC statement explicitly linked the Senate defeat to the agency's action:
“Earlier this week, Congress was unsuccessful in advancing the CLARITY Act despite the tireless efforts of many. So today, the Securities and Exchange Commission is taking a significant step forward, within its statutory authority, to bring America's capital markets into the digital age.” — Paul Atkins, SEC Chairman, official statement of September 17, 2026
That step was the so-called Innovation Exemption. Under the SEC's own press release 2026-90, published on September 17, the agency granted temporary and conditional five-year exemptions: platforms classified as Tokenized Securities Venues are exempted from the definition of "exchange" under the Securities Exchange Act of 1934, and may trade tokenized versions of listed US stocks through automated market makers and restricted-access liquidity pools; and certain liquidity providers are exempted from the definition of "dealer."
The conditions are in the order itself. Tokens must give holders "the same rights and privileges" as traditional shares of the equivalent class, including dividends and voting. Purely synthetic tokens are excluded. There are symbol and volume limits. Smart contracts must be auditable and public. Trading halts must mirror those of the primary exchange. Platforms must notify issuers before listing third-party tokenizations — and issuers may object to trading in their shares.
For those operating in the US market, a deadline is running. The SEC is holding a public consultation, until October 20, 2026, on Regulation Crypto Assets — its proposal for crypto asset offerings. Orrick's analysis explicitly recommends that affected companies submit comments before that date. It is the window in which the industry can still shape the design of the rule that will, in practice, replace the law that did not pass.
The problem with this route is acknowledged by the regulators themselves. When the bill still had a chance, in August, Selig had said he preferred the legislative route precisely because it makes the framework harder for future administrations to reverse. Forbes recorded the same acknowledgment from the other side:
“Agency action, however, does not carry the same permanence as legislation.” Atkins acknowledged that limitation in August, calling legislation “indispensable” to creating rules that a future regulator cannot easily reverse. — Forbes, September 16, 2026
The US map looks like this. There is a law for payment stablecoins: the GENIUS Act, of July 2025. There is a statutory ban on a Federal Reserve retail digital currency: Title XI of the 21st Century ROAD to Housing Act, which became Public Law 119-101 on July 11, 2026 without the president's signature, provides that the Fed may not issue a retail CBDC, directly or indirectly, until December 31, 2030. But there is no market structure law.
One day after the defeat, the House tax committee (Ways and Means) approved by 38 to 5 the Digital Asset Tax Certainty Act, which creates specific tax treatment for qualified dollar-backed stablecoins, exempts network fees of up to US$10 from tax, and extends to crypto assets rules already applied to traditional markets — revenue recognition, transfers, wash sales, mining, staking, and broker obligations. According to CoinDesk, about five weeks of scheduled legislative work remain before the January session, which makes the timeline tight for further progress this year, even though the move lays groundwork for the next.
The practical takeaway for those operating in the US: the rules will come, but through instruments that can change with every change of administration. That favors those who build compliance robust enough to survive revisions — not just to meet the rule of the moment.
This is the most technically interesting item of the cycle, and it passed with relatively little noise. On September 22, 2026, the public consultation period closed on the Bank of England's policy statement and draft Code of Practice for systemic sterling-denominated stablecoins.
The design change is the point. Earlier proposals contemplated per-holder limits — in the order of £20,000 per individual and £10 million per business. Those limits are gone: users will face no restriction on how much they can hold. In their place came an aggregate issuance cap of £40 billion per systemic stablecoin product, which the central bank itself describes as temporary, with no set end date, to be reviewed once it is satisfied that the risks to credit supply have been mitigated.
It is worth understanding why this matters, and here comes my own reading, not a finding of the consultation. A per-holder limit is intrusive and hard to enforce: it requires knowing who holds how much, in every wallet, all the time. An issuance cap is verifiable on the issuer's balance sheet. In my synthesis, the Bank of England traded a control over the user for a control over the issuer — and, in doing so, preserved the instrument's usefulness for corporate treasuries, which would be the first to hit a £10 million limit.
The composition of the backing also changed, in the direction of issuer profitability: up to 70% in short-term UK government securities, with maturities of up to six months — up from the 60% previously proposed — and the remaining 30% in unremunerated deposits at the Bank of England itself, down from the original 40%. Issuers remain prohibited from paying interest on balances, but rewards linked to payment activity, such as cashback and loyalty programs, are expressly permitted.
The final Code of Practice is expected by the end of 2026. Practical application, however, depends on an earlier trigger: no stablecoin becomes subject to this regime before being designated as systemic by HM Treasury. The operational horizon, therefore, is 2027.
The takeaway: the United Kingdom is designing a regime in which a sterling stablecoin can scale up to a known limit, with mostly interest-bearing backing and without competing with bank deposits through interest. It is a third way between the American model — permissive law, no issuance cap — and the European one, which combines a CBDC with regulated stablecoins.
On the public side, the project has moved beyond intentions. On July 14, the European Central Bank (ECB) selected 36 payment service providers to take part in the digital euro pilot, scheduled to start in the second half of 2027 and run for 12 months. On September 15, the ECB opened a call for e-commerce and mobile merchants to sign up — a step that points to real acceptance testing, not just interbank infrastructure. The pilot will bring together the ECB, the 19 national central banks of the euro area, and the selected merchants, testing person-to-person transfers, in-store payments, online purchases, and mobile payments.
Precision matters here: a pilot is not issuance. The version used in the test will be a beta that looks like the digital euro but will not be legal tender. The ECB is working with 2029 as a possible issuance date — and the central bank itself describes that horizon as conditional on European legislation and on a separate decision by its Governing Council. Any date cited is a horizon, not a commitment.
On the private side, Qivalis — a consortium of 37 banks from 15 European countries, including ING, UniCredit, BNP Paribas, BBVA, ABN Amro, Rabobank, Intesa Sanpaolo, Nordea, and CaixaBank — still has no license. On September 8, 2026, Ethereum Institutional reported that the consortium's euro stablecoin will be issued on the public Ethereum blockchain, rather than on a permissioned network restricted to banks. The token is designed to be fully backed, one to one, by euros held in bank deposits and high-quality liquid assets. The exact split between these two reserve classes does not appear in a primary communication from the consortium and is therefore not detailed here.
The choice is a meaningful signal. Europe's largest banks decided to bring regulated money onto the same infrastructure where dollar stablecoins already circulate, instead of building a closed circuit. It is a bet on interoperability and liquidity.
The obstacle is regulatory. The consortium itself states that it is not authorized and does not issue electronic money, with its electronic money institution license application still pending at the Dutch Central Bank (DNB — De Nederlandsche Bank). The process began in December 2025. For comparison, the French authorization of SG Forge's EURCV stablecoin took about 18 months; the Maltese authorization of StablR's EURR, about 12. The consortium publicly maintains its second-half 2026 target; an analysis published by BitcoinMarket on August 4 clarifies that this window corresponds to an interbank pilot, and estimates the first half of 2027 as a realistic date for retail access on exchanges.
The second test is liquidity, and market figures explain the scale of the challenge. As of October 1, 2026, according to a RWA Foundation survey using Token Terminal data, the global stablecoin market totaled US$300.9 billion, spread across 195 assets, 152 issuers, and 47 networks. Tether USD (USDT) accounted for 61.0% of supply and USD Coin (USDC) for 24.8% — 85.9% combined, both in dollars. The quarter's movement was between networks, not between issuers: Tron gained US$5 billion, reaching US$93.9 billion, while Ethereum lost US$4.9 billion, still holding 54.2% of total supply.
Thirty-seven sponsoring banks do not, on their own, generate trading volume. Qivalis's challenge is to shift a habit: traders price pairs in dollars, and collateral markets in decentralized finance follow that liquidity.
On September 30, 2026, HSBC announced that its Hong Kong dollar (HKD) stablecoin will be called HSBC RedCoin. The bank says the token will be distributed through PayMe and the HSBC Hong Kong mobile app at launch, keeping the second half of 2026 as the window, based on the issuer license granted by the Hong Kong Monetary Authority (HKMA) on April 10, 2026. Maggie Ng, the bank's chief executive in Hong Kong, explained that "Red" refers to HSBC's long-standing visual identity in the region.
Three points in the announcement deserve a close reading. The first is that the token has not yet been issued, and the bank itself says further updates will be shared in due course — in other words, there is no confirmed launch date. The second is the fraud warning: HSBC states that it has no connection with fraudulent stablecoins claiming to be associated with the bank and urges customers to be wary of investment scams. The name spawned imitations before the product even existed. The third is what was not said: the bank has not disclosed which blockchain the token will be issued on, nor how external wallets will be able to interact with it — a detail that determines whether RedCoin will be an interoperable instrument or an internal HSBC rail.
The announcement came with a line worth noting for its restraint:
“HSBC RedCoin isn't a leap into the unknown—it's a natural next step.” — HSBC announcement, September 30, 2026
Hong Kong's second licensee follows a different strategy. Anchorpoint Financial — a joint venture led by Standard Chartered, with participation from Animoca Brands — has a model geared to authorized distributors, cross-border payments, settlement of tokenized assets, and supply chain finance. The two do not compete head-on from the start: one targets retail and merchants, the other, wholesale and corporate.
The most distinctive feature of the Hong Kong model remains identity control — but it is worth delimiting exactly how far it goes. The HKMA's anti-money laundering guidelines require licensed issuers to identify and verify the wallets used by customers at issuance and redemption, with risk-based monitoring at those two points to identify and report suspicious transactions, including screening of wallets linked to suspicious activity or designated persons. In addition, the travel rule on originator and beneficiary information applies to covered transfers, with a threshold of HK$8,000 (about US$1,000).
What the available sources do not establish is a universal ban on any secondary transfer to an unidentified wallet. According to CoinDesk, in practice Hong Kong dollar stablecoins will "likely" embed compliance checks in the smart contracts themselves, restricting transfers to whitelisted wallets. That is a plausible technical consequence of the regulatory architecture — and may well be the path issuers choose — but it is not an express requirement of the rule, and should not be read as such. Even so, within its proven scope, this is a stablecoin structurally different from USDT or USDC, whose issuance and redemption points do not operate under this degree of verification.
In Japan, the three largest banks — MUFG, SMBC, and Mizuho — are developing a yen stablecoin through the Progmat platform. The Financial Services Agency (FSA) decided to support a proof-of-concept test in November 2025, and it is important to note what that is and is not: support for an experiment is not regulatory approval of issuance. The Japanese framework restricts issuance to licensed banks, trust companies, and licensed funds transfer service providers.
In South Korea, the legal design for stablecoin issuers remains openly contested, and no structure has been decided. The Bank of Korea proposed that issuance rest with bank-led consortia, with banks jointly holding more than 50% of the shares — technology companies could be the largest single shareholder, as long as they stay below the banks' combined total. The Financial Services Commission came to support that proposal, but lawmakers from the ruling party and other members of the National Assembly oppose it, and the financial authority itself said that the shareholding structure and any mandatory role for banks had not yet been defined. The country remains the only major Asian jurisdiction without a specific stablecoin law.
China is advancing along a different path. According to the Atlantic Council, mBridge — the cross-border settlement platform that brings together the central banks of China, Hong Kong, Thailand, the United Arab Emirates, and Saudi Arabia — had processed, through January 2026, more than 4,000 cross-border transactions, with a cumulative value of about US$55.49 billion. The digital yuan (e-CNY) accounted for approximately 95.3% of settlement volume. The Bank for International Settlements (BIS), which ran the initial pilots in 2022, stepped back from direct involvement in October 2024, handing governance entirely to the participating central banks. The concentration in yuan raises the question of whether the platform is a neutral multilateral infrastructure or an extension of China's digital currency.
Brazil closes this cycle with something the debate lacked: dates. A set of Central Bank of Brazil (BCB) rules organizes the calendar — 519, 520, 561, 575, 584, 588, and 589 — and some of them are already in effect. They are worth separating carefully, because obligations with different legal bases have different timelines, and one of the dates changed on September 23, within this coverage window.
BCB Resolution No. 561, of April 30, 2026, took effect on October 1. It updates the rules for eFX — the electronic international payment or transfer service — and, in its Article 50, requires that payments and receipts between the Brazilian provider and its counterparty abroad take place through a foreign exchange transaction or a movement in a non-resident account in reais, barring the use of virtual assets at that stage.
Precision matters here, because the rule has been read more broadly than it is. What Article 50 establishes is the scope of a specific prohibition: settlement of the external leg between the regulated electronic FX provider and its partner abroad. It does not reach custody, the buying or selling of stablecoins as an investment, or use within Brazil's borders. It is not, therefore, a general ban on stablecoins in cross-border settlement. A necessary caveat, however: this does not justify concluding that every other transaction setup is outside the reach of the other FX and regulatory rules — 561 closes one link; it does not license the others.
The practical effect, however, is concrete for those who had built operations on that link. Legal analyses from the industry point to three immediate consequences: loss of speed, with settlements that took minutes reverting to the days-long timeframe of the traditional banking system; higher costs, with the return of correspondent bank fees at each intermediate step; and a disproportionate impact on mid-sized exporters with multiple buyers abroad, who benefited from direct settlement.
On the same October 1, the BCB offered an alternative through the traditional route. BCB Resolution No. 575, issued on June 18, 2026, amended BCB Resolutions No. 277 and 278, of 2022, to expand the possibilities for opening and operating foreign currency deposit accounts in Brazil. The list of eligible holders, previously restricted to financial institutions, embassies, and insurers, now includes exporting companies, companies with foreign debt, companies with foreign shareholders, and non-resident entities that carry out external credit or direct investment operations. Foreign currency transfers between these accounts are exempt from a separate FX transaction, which reduces costs; cash deposits and withdrawals, however, are prohibited, and conversion into reais still requires a foreign exchange contract.
The design is coherent: the regulator is not denying the demand for settlement in foreign currency; it is insisting on channeling it through authorized institutions and FX instruments.
The third rule that took effect on October 1 is the least publicized and perhaps the most operational. BCB Resolution No. 588, published on September 23, 2026, amended Article 49 of Circular No. 3,978, of 2020, to create mandatory reporting to the Financial Activities Control Council (COAF) of virtual asset transfers to or from self-custodied wallets of US$10,000 or more. The trigger is per transaction, without the daily aggregate language that Resolution 584 adopts for the same wallets — an asymmetry that industry legal analysis has already flagged as a structuring loophole.
October 30, 2026 marks the end of the 270-day transition period counted from the entry into force of BCB Resolutions No. 519, 520, and 521, of 2025, on February 2, 2026. The core obligation for that date is one: virtual asset service providers (SPSAVs) that were already operating must have filed their authorization request with the BCB. The consequence of non-compliance is explicit — a provider that does not file on time must cease providing services within 30 days after October 30. It is not a fine; it is a halt to the activity.
Two other obligations converge on the same date, with different legal bases and best kept separate from the first: notification of pre-existing activity or transfer of the operation to eligible Brazilian entities; and implementation, by providers, of the recording of data and information on indications or attempts of fraud. Each has its own provision, and treating them as a single deadline is the reading that has caused the most confusion in the market.
Here is the most relevant correction to the calendar, and it is recent. Until September, the prevailing understanding was that the prohibition in Article 91 of BCB Resolution No. 520 — which bars regulated institutions from carrying out or facilitating transactions with entities not authorized to provide virtual asset services — would follow the October deadline. BCB Resolution No. 589, published on September 23, 2026, amended that provision and moved its effects to November 6, 2026.
The distinction is practical, not bureaucratic. On October 30, what is at stake is the provider's own status: whether or not it filed the request. On November 6, what is at stake is the status of its counterparties: banks, payment institutions, and authorized providers become barred from dealing with anyone who is not authorized. These are two different risks, with different owners — and presenting October 30 as the single date that decides who keeps operating underestimates the second.
BCB Resolution No. 584, published on August 7, 2026, amends BCB Resolution No. 142, of 2021, and extends to virtual asset service providers — including those still in the regulatory transition phase — the anti-fraud procedures that already apply to banks and payment institutions. It takes effect on January 1, 2027.
The core of the rule is the precautionary hold. Virtual asset transfers bound for abroad or for self-custodied wallets become subject to a precautionary period of up to 24 hours, counted from receipt of the funds. The rule covers transactions above the equivalent of US$10,000, in a single transaction or in the customer's daily aggregate. Stablecoins are included. Early release is possible, at the institution's discretion, based on a documented risk analysis that considers the customer's profile, the type of transaction, the counterparty's data, and the destination jurisdiction.
The official rationale is fraud prevention: according to the BCB, the growing use of virtual assets, including stablecoins, makes it possible to quickly move proceeds from scams abroad or to self-custodied wallets, where recovery becomes difficult.
The industry's reaction was immediate and divided. Market associations argued that the hold may push activity into unregulated markets and that it can be circumvented by splitting transactions below the threshold. Regina Pedroso, a director at ABToken, and the Instituto Livre Mercado are among the voices that have publicly opposed the rule's design.
The challenge reached Congress in August, when federal deputy Júlia Zanatta (PL-SC) introduced Legislative Decree Bill (PDL) No. 926/2026 to overturn the resolution in full. The existence, authorship, and purpose of the bill are confirmed; the filing date is recorded as August 10 by Cointelegraph Brasil, but an aggregated record indicates August 8, and the Chamber's official record was not accessible for automated reading by the time this edition closed. To take effect, the bill must be approved by both the Chamber of Deputies and the Senate. The text's central argument is the absence of procedural safeguards: the resolution provides neither a duty to give the customer a reasoned notice nor a specific challenge procedure when a transaction is rejected after the hold period.
Crypto asset purchases by Brazilians reached US$14.68 billion in the first half of 2026 — up 135% from US$6.24 billion in the same period of 2025. In May 2026 alone, Brazilians bought about US$2.632 billion in stablecoins, 158% more than in May 2025. The International Monetary Fund (IMF) signaled that existing frameworks remain insufficient on critical points — customer protection and asset segregation — and called for attention to cross-border flows driven by stablecoins.
Official data provide the historical scale. According to a survey released by Brazil's Federal Revenue Service on July 23, 2026, from August 2019 to December 2025, R$1.58 trillion in crypto asset transactions were declared in Brazil, of which R$1.13 trillion — 71.7% — were in stablecoins. The share reached an annual peak of 91.5% in 2023, with a monthly high of 94.3% in July of that year, and settled in the 76% to 80% range in 2024 and 2025. The absolute monthly record was R$39.7 billion in November 2025. Among declared stablecoins, USDT accounts for 88.7% of volume, followed by USDC with 7.1% and BRZ with 3.4%.
That last figure deserves a pause. More than nine-tenths of declared stablecoin volume in Brazil is in dollars, and only 3.4% in a real-backed token. It is the portrait of a domestic demand for digital foreign currency that the regulated system does not yet serve — and it explains, better than any legal argument, why the BCB's calendar became so tight.
In the Drex tests, we noticed something that applies to this moment: regulatory friction rarely shows up in the technology. It shows up in the design of the flow — who settles with whom, in which currency, under which authorization. The Brazilian calendar has become objective: October 1 has passed, October 30 is the filing deadline, November 6 closes the door on unauthorized counterparties, January 1 brings the precautionary hold. Anyone who has not yet remapped settlement, counterparties, and anti-fraud controls has a deadline — and it is short.
An a16z crypto report published on August 30, 2026 showed that 94% of crypto volume traded in Argentine pesos goes to stablecoins. Based on data from the analytics platform Artemis, it is the highest share among the major currencies tracked. About one in five Argentines uses crypto assets today. In the United States and Europe, Bitcoin, Ethereum, and speculative tokens still dominate volume. In Argentina, stablecoins are not a part of the crypto market — they are the market.
The origin is structural: monthly inflation that peaked at 25.5% and years of restricted access to physical dollars. But recent data complicate that reading. The digital dollar premium over the official rate narrowed to about 4% at the end of August 2026, and monthly inflation fell to 2.1%. Even so, downloads of Lemon, one of the country's largest crypto wallets, grew in every quarter analyzed. a16z suggests that stablecoins may be ceasing to function as a hedge against inflation and becoming part of everyday habit. It is a hypothesis of the report, stated with that caution, and worth preserving as such: the correlation with falling inflation does not, on its own, prove causation, and saying it "became a habit" would be too categorical for what the data show.
The regional picture is advancing at different speeds. Mexico’s 2018 Fintech Law remains one of the first formal recognitions of virtual assets in the world. Peru recorded 50% growth in crypto app downloads in 2025, with 2.9 million installs. And in the Chainalysis 2025 Global Crypto Adoption Index, the sixth edition of the index, published on September 2, 2025, three countries in the region are in the top 20: Brazil (5th), Venezuela (18th), and Argentina (20th).
The Chilean case deserves a more precise description than what circulates in the market. Law No. 21,521 did not create a specific license for stablecoin issuers. It regulates services related to financial instruments and crypto assets — alternative trading systems, order routing, intermediation, and custody — requiring registration in the registry of financial service providers and compliance with the rules of the Financial Market Commission (CMF). And its definition of crypto asset expressly excludes money in national or foreign currency. Currency-backed stablecoins are treated as equivalent to foreign currency, and the law amended the constitutional organic law of the Central Bank of Chile to cover crypto assets used as a means of payment — that is, they depend on the central bank's regulation of payment means and systems, not on an issuer license created by the Fintech Law. The distinction matters for anyone assessing a corporate structure in the country.
In August, the Financial Infrastructure Forum Latam, held at the Museu do Amanhã in Rio de Janeiro from August 11 to 13 as part of Blockchain.RIO, brought together representatives of the Central Bank of Uruguay, the Central Reserve Bank of Peru, El Salvador's Digital Assets Commission, Fenasbac, and ANBIMA. The shared assessment was that digital asset supervision in the region has left the experimental phase. Rodrigo Henriques, of Fenasbac, summed it up: the market is living under stricter regulation, but that marks the transition from exploration to real use cases. Érika Lacreta, of ANBIMA, added that infrastructure used to be the means and is now the end of the process.
The period between July 28 and October 7, 2026 produced a contrast that became clear in the first week of October.
The world's largest crypto market failed to pass its market structure law and came to depend on agency rules, with a public comment period running until October 20. Brazil, with a smaller market, did the opposite: it published rules, set dates, put three into effect on October 1, has the authorization filing deadline on October 30 and the prohibition on unauthorized counterparties on November 6 — and already faces a challenge in Congress. The United Kingdom redesigned the control, swapping a per-holder limit for an issuance cap. Europe gave the digital euro a timeline and is still waiting for its private consortium's license. Asia named the product before having a date. And Argentina showed how far demand for the digital dollar goes when the local currency loses credibility.
There is no single winning model. There is a set of national bets, and each defines three things: who can issue, in which currency, and under which controls. The difference between the countries that advance and those that stall is not in technological ambition — it is in the clarity of dates. By that criterion, and this is my reading, Brazil pulled ahead of the United States in this cycle.
Correction. In Issue #8, we reported that the statutory ban on a Federal Reserve CBDC had become law on June 28, 2026. The correct date is July 11, 2026: the 21st Century ROAD to Housing Act was presented to the White House on June 29 and became Public Law 119-101 without the president's signature, after the ten-day period provided for in Article I, Section 7, of the US Constitution elapsed. The ban is in Title XI and covers the issuance of a retail CBDC — directly or through an intermediary — until December 31, 2030.
— André Carneiro, CEO, BBChain
Sources for this edition:
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