원화 스테이블코인 도입을 위한 규제체계 설계: 미국 지니어스법, EU MiCA, 일본 자금결제법 비교를 중심으로

초록

This study proposes a regulatory and governance framework for the introduction of a Korean won–denominated stablecoin in an environment where competition among global payment systems is intensifying due to the rapid expansion of stablecoins. It conducts a comparative analysis of the U.S. GENIUS Act, the European Union’s Markets in Crypto-Assets Regulation (MiCA), and amendments to Japan’s Payment Services Act, focusing on international standards for issuer authorization, reserve asset management and redemption, consumer protection, AML/CFT compliance and Travel Rule requirements, and supervisory frameworks. The analysis identifies key policy alternatives, including a qualified fintech issuer licensing regime that moves beyond the binary choice between bank-only issuance and unrestricted private issuance, technological and business-model innovation under full-reserve and mandatory redemption requirements, and a phased adoption strategy centered on interoperability and standards. By presenting a policy package that incorporates an implementation roadmap and key performance indicators (KPI), this study contributes to both the academic literature and policy discussions on enhancing the global competitiveness of a Korean won–denominated stablecoin.

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