바레인의 스테이블코인 발행·제공 모듈(Module SIO)과 우리나라의 스테이블코인 법제에 대한 시사점

In July 2025, the Central Bank of Bahrain (CBB) enacted a stablecoin-specific framework, the Stablecoin Issuance and Offering Module (Module SIO) under Volume 6 (Capital Markets) of its Rulebook, distinct from the existing general virtual asset regulatory framework, the Crypto-Asset Module (Module CRA). Module SIO permits only single fiat–currency–backed stablecoins and mandates the maintenance of reserve assets equal to at least 100 percent of the outstanding par value, the composition of reserve assets in high-quality and highly liquid instruments, segregation and third-party custody of reserve assets, prohibition of encumbrances, monthly independent verification of reserve assets, annual audited financial statements, periodic reporting of circulation and use as a medium of exchange, a permanent right of redemption at par value, and issuer recovery and redemption plans. Module SIO adopts an ex ante regulatory approach to mitigate the risks inherent in stablecoin payments, recognizing that the failure of a stablecoin issuer may propagate systemic liquidity stress throughout the macro-financial system. Global legislative developments—the United States’ Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), the European Union’s Markets in Crypto-Assets Regulation (MiCA), and Hong Kong’s Stablecoins Ordinance—reflect the global convergence toward a stablecoin-specific framework. Given the cross-border and technologically decentralized nature of blockchain-based stablecoins, regulatory coherence and international interoperability are critical. The general virtual asset regulatory framework is insufficient to address stablecoin-specific risks, particularly those relating to issuer accountability, reserve asset integrity, redemption rights, and macro-financial stability. In this regard, Korea should enact a stablecoin-specific framework that incorporates mandatory 100 percent reserve backing, a permanent right of redemption at par value, independent external verification, and periodic disclosure of transactions and use as a medium of exchange. Furthermore, an institutional framework allocating licensing and prudential supervision to the Financial Services Commission, while entrusting the Bank of Korea with oversight of monetary policy and payment system stability, would facilitate a coordinated governance structure appropriate to the quasi-monetary characteristics of stablecoins. To promote the constitutional principle of legality and constrain administrative discretion, the core elements of the licensing and supervisory regime should be codified in statute to ensure transparency, predictability, and democratic legitimacy.