The European Securities and Markets Authority (ESMA) published an opinion on October 8 requiring national regulators to mandate remediation of non-compliant stablecoin exposures within three months, or approximately January 8, 2027. Firms not yet in compliance may provide strictly limited services needed for an orderly wind-down, including liquidation, conversion, withdrawal, transfer or safekeeping of existing holdings. These exit services must be time-limited, clearly communicated to clients and closely supervised, and must not enable new acquisitions or active distribution. The opinion cites Article 66(1) of MiCA, which requires providers to act in clients’ best interests, and only concerns access through regulated EU firms without imposing a worldwide ban on holding assets such as USDT.
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