On 8 September 2025, the Wolfsberg Group published guidance on the provision of banking services to fiat-backed stablecoin issuers.

The Wolfsberg Group is an association of 12 global banks which aims to develop frameworks and guidance for the management of financial crime risks. The Wolfsberg Group notes that the increased adoption of fiat-backed stablecoins represents a new financial crime risk management challenge to financial institutions.

The Wolfsberg Group is of the view that most of the same financial crime risk management principles apply in developing and monitoring a relationship with any type of bank or non-bank financial institution, which is reinforced in the guidance. The guidance also explores the unique financial crime risks associated with the provision of banking services to a fiat-backed stablecoin issuer operating in a regulated jurisdiction and establishes a framework for financial institutions to manage these relationships appropriately.

Conceptual approach

A key message in the guidance is that the conceptual approach to banking a stablecoin issuer is similar to any customer relationship. An FI should understand the risks associated with the customer and the relationship, as well as how that customer manages those risks. The FI then should determine if it is comfortable both with the risk exposure and risk management strategy offered by the issuer. The FI should also develop a reasonable risk management framework that allows the FI to determine if the customer’s behaviour stays within that appetite and take corrective action as necessary.

Topics

The guidance:

  • Introduces the relevant terminology used by the Wolfsberg Group on stablecoins. While definitions may differ across the industry, a shared understanding of the basic terms introduced and explained in the guidance will be relevant for developing the overarching risk management framework.
  • Describes the typical fiat-based services that an FI may provide to a stablecoin issuer, emphasising how existing financial crime-related controls may require tailoring to respond to the unique risks presented by the relationship.
  • Describes the level to which an FI, in following a risk-based approach, may monitor the compliance obligations of the issuer on the blockchain.