원화 스테이블코인의 입법방향

초록

This study analyzes the current state of the global stablecoin market and conducts a comparative review of regulatory frameworks in the United States, the European Union, and Japan to examine the regulatory gaps in South Korea. Despite the collapse of Terra, Korea continues to face significant capital outflows and regulatory arbitrage due to the absence of a dedicated legal framework for stablecoins. Korean investors actively use foreign-issued stablecoins, particularly Tether (USDT), resulting in increasing overseas capital transfers. In contrast, major jurisdictions have implemented stringent regulatory regimes, including licensing requirements for issuers, full reserve backing, mandatory disclosures, and restrictions on the distribution of foreign-issued stablecoins. This paper pays special attention to the key provisions of the U.S. GENIUS Act and the recent amendments to Japan’s Payment Services Act, both of which provide comprehensive regulatory responses to stablecoin risks. Drawing upon these international cases, this study proposes several policy recommendations for Korea: introducing a licensing regime for stablecoin issuers, strengthening reserve and disclosure requirements, managing the circulation of foreign-issued stablecoins, promoting the issuance of Korean won-denominated stablecoins, and establishing an integrated, cross-agency regulatory governance structure. The findings suggest that without regulatory reform, Korea risks lagging behind global standards and exacerbating financial stability vulnerabilities associated with the rapid expansion of the stablecoin market.

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