The Payments Newsletter including Digital Assets & Blockchain, May 2025

In this Newsletter: 

• Regulatory Developments: Payments
• Regulatory Developments: Digital Assets
• Market Developments 
• Surveys and Reports

For previous editions of the Payments Newsletters, please visit our Financial Services practice page. 

Regulatory Developments: Payments  

United Kingdom: Final PSP termination rules laid before Parliament

On 28 April 2025, HM Treasury published a draft of the Payment Services and Payment Accounts (Contract Termination) (Amendment) Regulations 2025 together with a draft explanatory memorandum. The changes, aimed at tackling “de-banking”, apply to framework contracts entered into on or after 28 April 2026.

PSPs must:

• Give 90 days’ notice (up from two months).
• Provide a specific explanation for terminations.
• Update pre-contract disclosures.

Key updates since the March 2024 draft:

• Lower threshold for serious crime exemption: now “reasonable grounds to suspect”.
• New exceptions for public order offences and materially incorrect customer information.
• Expanded anti-avoidance: PSPs cannot contract out of the new duties, except under the corporate opt-out.
• Clarified legal hierarchy: other legal obligations take precedence in case of conflict.
• Disclosure requirement: updated termination terms must be shared pre-contract.

See this Our Thinking article for operational implications and compliance guidance as well as remaining areas of uncertainty.

UK: HMT publishes draft BNPL regulation

On 19 May 2025, HMT announced new legislation to regulate the buy now, pay later (BNPL) sector, requiring lenders in this area to carry out affordability checks to ensure people do not take on too much debt.  The new legislation is due to take effect next year.  

 The new legislation will mean that BNPL lending will be regulated by the FCA, and will also enable borrowers to make complaints to the FOS.  

HMT initially announced plans to regulate the sector in 2021 and consulted on the idea in 2023, but the legislation was delayed until now. 

With the publication of the response to the consultation, the government will now proceed to lay the draft affirmative statutory instrument - The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025 - for bringing BNPL products into regulation before Parliament. 

UK: PSR publishes 2025/26 plan ahead of FCA integration

On 1 May 2025, the Payment Systems Regulator (PSR) published its annual plan and £28 million budget for 2025/26, maintaining funding at the previous year’s level although it represents a real-terms reduction. The plan sets out the PSR’s final year as an independent regulator, ahead of its expected consolidation into the FCA.

Key priorities include:

• Continuing work on card scheme and processing fee remedies;
• Rolling out non-sweeping variable recurring payments (VRPs);
• Evaluating the mandatory APP fraud reimbursement regime;
• Supporting infrastructure upgrades for Faster Payments; and
• Enhancing support for payment innovation and regulatory clarity for new business models.

The PSR is also working closely with the FCA and HM Treasury on the legislative and operational steps required for regulatory consolidation.

United Kingdom: PSR revokes SD3 and consults on SD2 in response to National Payments Vision shift

Following a December 2024 consultation (CP24/13), the PSR has today published a policy statement (PS25/4) and Specific Direction (SD) to Pay.UK revoking SD 3 and SD3a (which amended SD3). A related webpage has also been published.

Originally, SD3 required the operator of the Faster Payments Scheme (FPS) to competitively procure any future contracts for central infrastructure services as a move to enhance competition, promote innovation, and ensure better value for money in the UK's payment systems.

Pay.UK had planned to comply via the New Payments Architecture (NPA), launched in 2017 to modernise UK interbank clearing. However, following publication of the National Payments Vision (NPV) and broader changes to the NPA, Pay.UK is no longer able to meet SD3’s requirements.

The NPV calls for a more flexible reassessment of retail payments infrastructure and governance — beyond the strict procurement model mandated by SD3. The  PSR initially proposed amending SD3 but has now opted to revoke it entirely to create regulatory space to pursue the NPV’s goals, including supporting competition, innovation, and service-user outcomes.

The revocation takes effect on 21 May 2025.

The PSR is also consulting on revoking Specific Direction 2 (and SD2a), which applies similar obligations to the Bacs system. Responses are due by 5 June 2025.

UK: FCA raises expectations on international payment pricing transparency under Consumer Duty

On 1 May 2025, the FCA published the findings of its review into how firms communicate the cost of international payments, including cross-border transfers and money remittance services. The review focused on whether firms are meeting their obligations under the Consumer Duty to provide clear, accessible, and meaningful information that enables retail customers to make informed decisions.

The FCA found notable inconsistencies in how firms disclosed key pricing information, particularly:

• Transaction fees not being clearly displayed before payment initiation;
• Limited or no upfront disclosure of intermediary or recipient bank fees;
• Failure to highlight that fees can vary by transaction; and
• Poor website navigation, making relevant information difficult to locate.

While some firms provided transparent, user-friendly information — including full cost breakdowns and final recipient amounts — this was not the norm. The FCA stressed that such gaps in communication risk undermining consumers’ ability to compare services and assess value for money.

To support improvement, the FCA has shared examples of good and poor practice across fixed, variable, and third-party fees. It expects firms to review and enhance their disclosures accordingly and has indicated that it may undertake further work to assess progress.

Although the FCA notes that not all examples of poor practice amount to a breach of the Consumer Duty, the review signals an intent to raise the bar on transparency in international payment services.

See this Our Thinking article for a breakdown of the FCA’s findings and practical steps firms can take to strengthen compliance in this area.

UK: Treasury Committee warns cash acceptance may need to be mandated

On 30 April 2025, the Treasury Committee published its report on declining cash acceptance in the UK, raising concerns that increasing reliance on digital payments risks excluding vulnerable groups such as the elderly, domestic abuse survivors, and those with learning difficulties.

The Committee makes several recommendations to manage the decline, including:

• A joint review by HM Treasury, the FCA and the Bank of England to assess the effectiveness of the access to cash regime and its impact on businesses’ willingness to accept cash;
• Continued oversight of payments competition by the PSR throughout and after its expected consolidation into the FCA;
• Commissioning an independent model to assess the actual costs of accepting different payment methods;
• Recognising the role of cash in emergency preparedness planning; and
• Expanding the remit of the Financial Inclusion Committee to cover digital exclusion, with HM Treasury conducting a formal review every five years to assess whether the payments system continues to meet the needs of all users.

The Committee further recommends that HM Treasury report annually on national cash acceptance levels and provide its view on the tolerable level of cash acceptance. 

The Committee concludes that if voluntary measures prove inadequate, mandating cash acceptance may ultimately be necessary.

United States: CFPB deprioritises enforcement of BNPL interpretive rule

On 6 May 2025, the Consumer Financial Protection Bureau (CFPB) announced that it will not prioritise enforcement actions under its July 2024 interpretive rule classifying Buy Now, Pay Later (BNPL) providers offering pay-in-four products as credit card issuers under Regulation Z of the Truth in Lending Act.

The rule had extended certain consumer protections typically associated with credit cards—such as the right to dispute transactions and pause payments during investigations—to BNPL products. However, following legal challenges and industry feedback, the CFPB has confirmed that it will instead focus its enforcement and supervision resources on other areas deemed to pose more immediate risks to consumers, including servicemembers, veterans, and small businesses.

The Bureau also indicated that it is considering formal steps to revoke the interpretive rule. 

Nigeria: CBN publishes revised documentation requirements for PAPSS transactions

On 28 April 2025, the Central Bank of Nigeria (CBN) published a circular setting out revised documentation requirements for transactions conducted through the Pan-African Payment and Settlement System (PAPSS). The changes aim to simplify cross-border payments within Africa and promote greater adoption of PAPSS among Nigerian banks, businesses, and individuals.

Key updates include:

• Simplified KYC/AML documentation for low-value transactions (up to $2,000 for individuals and ₦5,000 equivalent for corporates), using existing documents held by Authorised Dealer Banks; 
• Full documentation requirements continue to apply for higher-value transactions, in line with the CBN Foreign Exchange Manual and related circulars;
• Applicants remain responsible for submitting all necessary regulatory documents for goods clearance to the appropriate government agencies; 
• Authorised Dealer Banks may now source foreign exchange for PAPSS settlements directly from the Nigerian Foreign Exchange Market, without recourse to the CBN;

• All export proceeds repatriated via PAPSS must be certified by the relevant processing banks.

The CBN encouraged financial institutions to begin originating transactions in line with the revised rules and urged market participants to familiarise themselves with the updated requirements.

Uzbekistan: Central Bank to regulate growing Buy Now, Pay Later market

It has been reported that, on 2 May 2025, the Governor of the Central Bank of Uzbekistan, Timur Ishmetov, announced plans to regulate the growing Buy Now, Pay Later (BNPL) sector. Speaking at an International Monetary Fund conference,  Ishmetov raised concerns about rising consumer debt and the limited visibility banks currently have over BNPL obligations, which are not reflected in borrowers' credit assessments. 

The Central Bank intends to develop a framework requiring BNPL liabilities to be included in credit checks and aims to improve consumer protection and market oversight. At present, BNPL and point-of-sale (POS) financing services operate without specific regulation, posing risks of over-indebtedness and distorted lending decisions.

Uzbekistan’s BNPL market, dominated by Uzum Nasiya and Alif Nasiya, was valued at $450–500 million in 2023 and is projected to grow to $2 billion by 2027.

Philippines: BSP proposes pricing rules for digital payments

On 5 May 2025, the Bangko Sentral ng Pilipinas (BSP) issued an exposure draft circular proposing new pricing rules for electronic fund transfers and small-scale merchant payments. The initiative seeks to promote wider digital payment adoption while ensuring fairness, transparency, and cost-reflective pricing.

Key proposals include:

• BSP-supervised financial institutions (BSFIs) must adopt market-based pricing based on the actual costs of delivering electronic payment services;
• Pricing must be “reasonable and fair” and must not cross-subsidise other products or services;
• Person-to-person fund transfers must be credited in full to recipients, with no deductions;
• Fees for transfers to qualifying small merchants (with monthly electronic receipts not exceeding ₱250,000) must range from zero up to actual switch costs only;
• Any upward revisions or new fees will require BSP approval, while reductions may proceed without approval unless they reduce service features or benefits;
• Operators of Payment Systems with Merchant Acquisition Licences (OPS-MALs) must support merchant pricing with cost data, subject to BSP validation.

The BSP is accepting comments on the draft until 26 May 2025. Once finalised, BSFIs will be given one year from the circular’s effectivity to implement the necessary changes.

Brazil: Central Bank sets wide-ranging regulatory priorities for 2025–2026

On 24 April 2025, the Central Bank of Brazil (BCB) published its regulatory priorities for 2025-2026. Key items include:

• Virtual Asset Service Providers (VASPs): Finalisation of regulatory frameworks covering authorisation, fees, and prudential requirements (CPs 109 and 110).
• Banking-as-a-Service (BaaS): Regulation of partnerships between financial and non-financial institutions offering embedded financial products (CP 108).
• Pix enhancements:
  • Pix by Proximity (NFC-based initiation),
  • Pix in Installments (standardising credit-linked Pix flows),
  • Pix in Escrow (collateralised credit linked to future receivables),
  • MED 2.0 (improved fraud tracking and fund recovery).
• Payment arrangements: Review of postpaid fee structures and potential regulation of token requesters (CP 118).
• Receivables registries: Planned limits on interoperability fees between card receivables registrars (CPs 113 and 114).

The agenda also includes updates to fraud prevention policies, bank fee rules, and Pix-related sanctions procedures. Public consultations will support the development of many of these measures.

Colombia: Banco de la República prepares launch of Bre-B instant payments system

It has been reported that Colombia’s central bank is preparing to launch Bre-B, a national interoperable instant payments system, in September 2025. The platform will support real-time transfers between banks and digital wallets, using unique identifiers such as mobile numbers, national IDs, or alphanumeric “keys.”

In anticipation of the launch, major financial institutions including Bancolombia, Davivienda, BBVA Colombia, and Banco de Bogotá have begun rolling out key-based transfer functionality. These efforts aim to familiarise consumers with the new system and lay the groundwork for broader adoption.

The Bre-B initiative seeks to:

• Reduce cash usage, which remains high in Colombia;
• Improve financial inclusion; and
• Support interoperability across the financial ecosystem, regardless of provider.

Functionality is expected to include 24/7 availability, QR code payments, and integration with wallets such as Nequi and Daviplata.

The system is part of a broader strategy to modernise Colombia’s financial infrastructure and align with regional developments like Pix (Brazil), CoDi (Mexico), and Transferencias 3.0 (Argentina). According to banks interviewed, implementing Bre-B has required significant investment in infrastructure upgrades and digital education campaigns.

European Union: IOSCO and CPMI assess PFMI implementation for key market infrastructures

On 28 April 2025, IOSCO and the Committee on Payments and Market Infrastructures (CPMI) published a monitoring report assessing the EU’s implementation of the Principles for Financial Market Infrastructures (PFMI) for systemically important payment systems (PSs), central securities depositories (CSDs), and securities settlement systems (SSSs).

The assessment found full consistency with the PFMI for PSs across all evaluated jurisdictions. However, CSDs and SSSs showed gaps, particularly on risk management and governance, where implementation was only partially or broadly consistent in some areas.

The report reflects the status as of October 2019, but notes that subsequent reforms — including the CSDR Refit Regulation (EU 2023/2845) — have further aligned the EU framework with international standards.

Regulatory Developments: Digital Assets

European Union: New RTS and supervisory guidelines on market abuse under MiCA

• On 29 April 2025, the European Commission adopted a Delegated Regulation supplementing the Markets in Crypto-Assets Regulation ((EU) 2023/1114) (MiCA) with regulatory technical standards (RTS) under Article 92(2). The Delegated Regulation is based on draft RTS submitted by ESMA in December 2024. It will now be scrutinised by the European Parliament and Council and, if no objections are raised, will enter into force 20 days after publication in the Official Journal. The RTS specify:

• The arrangements, systems, and procedures that persons professionally arranging or executing transactions (PPAETs) must implement to detect and prevent market abuse.
• Templates and timing for suspicious transaction and order reports (STORs).
• Training requirements for staff involved in market abuse monitoring.
• Coordination procedures between national competent authorities in cross-border market abuse cases.
• On the same day, ESMA published its final guidelines under Article 92(3) MiCA, directed at national competent authorities (NCAs). These aim to promote consistent and effective supervision of market abuse in cryptoassets and will apply three months after their publication in all EU languages. NCAs must notify ESMA within two months whether they comply or intend to comply. The guidelines:
  • Outline risk-based and proportionate supervisory approaches.
  • Emphasise building a common supervisory culture through industry engagement and cross-border cooperation.
  • Incorporate insights from the Market Abuse Regulation (MAR) while accounting for crypto-specific risks, including the more intensive use of social media, the specific technologies used and the cross-border nature of crypto trading.

United Kingdom: BoE reflects on feedback and next steps for stablecoin regulation

On 6 May 2025, the Bank of England (BoE) published a speech by Sarah Breeden, Deputy Governor for Financial Stability, outlining next steps for the proposed UK regulatory framework for systemic stablecoins used in payments.

Breeden emphasised the Bank’s commitment to ensuring “singleness of money”—the principle that different forms of money (bank deposits, cash, stablecoins) must be freely and reliably interchangeable at par. She noted this principle underpins the BoE’s approach to regulating stablecoins that could become systemic.

Key themes from industry feedback include:

• Business model misalignment: The BoE’s proposals may not accommodate current stablecoin models reliant on interest income.
• Overlap with the FCA: Firms face uncertainty transitioning between non-systemic (FCA) and systemic (BoE) regimes.
• Cross-border friction: Divergence from international approaches could hinder stablecoin firms operating across jurisdictions.

Breeden acknowledged the need to distinguish between stablecoins used for retail payments and those used for investment or crypto settlement purposes, and to clarify the glidepath for firms growing into systemic scale.

She also highlighted the BoE’s ongoing work on interoperability, and the potential for regulatory sandboxes, such as the Digital Securities Sandbox, to help explore use cases and test safeguards in real-world conditions.

The BoE will continue refining its proposals with a focus on financial stability, safe innovation, and international regulatory coordination.

United Kingdom: HM Treasury publishes draft Order creating new cryptoasset regulated activities

On 29 April 2025, HM Treasury published a near-final draft of the Financial Services and Markets Act 2000 (Regulated Activities and Miscellaneous Provisions) (Cryptoassets) Order 2025, alongside a policy note. The draft legislation lays the groundwork for bringing cryptoasset activities—such as trading, custody, and stablecoin issuance—within the UK’s regulatory perimeter.

Key features of the draft Order include:

• New regulated activities: The Order amends the Regulated Activities Order 2001 (RAO) to introduce crypto-specific regulated activities, including:
  • Operating a trading platform
  • Issuing stablecoins
  • Safeguarding (custody)
  • Staking
  • Dealing in cryptoassets (as agent or principal)
  • Arranging deals in cryptoassets
• Geographic scope: Firms targeting UK retail clients will need UK authorisation, even if operating from overseas. Some scope questions remain open for business-to-business services.
• Financial promotions: Consequential amendments bring these new activities into scope of the financial promotions regime, and remove the current exemption for firms registered only under the Money Laundering Regulations.
• Transitional arrangements: The FCA will have powers to oversee orderly wind-downs for firms that fail to secure authorisation within the required timeframe.
• Stablecoins and payments: Despite stablecoin relevance to payments, the regime does not currently treat qualifying stablecoins as e-money under the EMRs or subject them to the Payment Services Regulations, unlike the approach taken under MiCA towards electronic money tokens.
• DeFi: “Truly decentralised” activities remain out of scope. Where identifiable controlling persons exist, the FCA may apply authorisation requirements case-by-case.

The Order is open for technical comments until 23 May 2025, with legislation expected by the end of the year. HM Treasury will publish separate proposals on cryptoasset market abuse and admissions and disclosures in due course.

For more detail, see this Our Thinking article on the draft Order and its implications for crypto firms. 

United Kingdom: FCA publishes discussion paper on new cryptoasset regime

On 2 May 2025, the FCA published Discussion Paper DP25/1 outlining its early thinking on the future UK regulatory framework for cryptoasset activities. The paper builds on HM Treasury’s near-final statutory instrument and explores possible approaches to regulating cryptoasset trading platforms, intermediaries, lending, borrowing, staking, DeFi, and the use of credit for crypto purchases.

Key points include:

• Cryptoasset Trading Platforms (CATPs): Proposed obligations include running non-discretionary trading systems, managing conflicts of interest (e.g. where platforms list their own tokens), and meeting transparency and recordkeeping standards. Overseas CATPs serving UK retail clients would need a UK-authorised entity.
• Intermediaries: Firms arranging or dealing in cryptoassets may face best execution rules, conflicts of interest controls (e.g. banning payment for order flow), and enhanced consumer protection obligations under the Consumer Duty.
• Lending and Borrowing: The FCA proposes to restrict retail access to these services, citing volatility, lack of credit checks, and speculative yield risks. However, it is exploring whether stricter rules (e.g. creditworthiness assessments) could enable safer retail participation.
• Staking: The paper outlines proposals on operational resilience, safeguarding of staked assets, and clear consumer disclosures — including unstaking terms and ownership structures.
• DeFi: The regime would apply only where identifiable persons control decentralised systems. The FCA plans further guidance and stakeholder engagement to assess how decentralisation affects regulatory responsibilities.
• Credit for crypto purchases: The FCA is considering restrictions on using credit cards or similar facilities to buy crypto, due to concerns over financial risk to consumers. Stablecoins issued by FCA-authorised firms may be exempt.

The FCA is seeking industry feedback by 13 June 2025. A formal consultation with draft rules is expected to follow later in 2025. See this Our Thinking article for analysis of what this means for crypto platforms, intermediaries, and overseas firms targeting UK markets.

European Union: ECB launches innovation platform to explore digital euro use cases

On 6 May 2025, the European Central Bank (ECB) launched a new digital euro innovation platform to collaborate with market participants on the development of central bank digital currency (CBDC) use cases.

Following a public call for interest, nearly 70 stakeholders — including banks, fintechs, merchants, start-ups, and payment service providers — were selected to participate in two dedicated workstreams:

• Pioneers will focus on programmable payments, testing technical integration of digital euro functionalities (e.g. conditional payments tied to delivery events) using ECB-provided APIs and specifications. Participants will develop individual use cases and report back to the ECB later this year.
• Visionaries will explore broader societal applications, such as financial inclusion, with ideas including access to digital euro wallets through post office networks for unbanked or digitally excluded individuals.

The initiative is part of the ECB’s phased approach to a potential digital euro, aiming to test interoperability, user experience, and public policy relevance in real-world scenarios.

Findings from both groups will be published by the ECB in a report expected later in 2025.

Global: BIS flags growing financial stability risks as DeFi and crypto reach "critical mass"

On 15 April 2025, the Bank for International Settlements (BIS) published a report warning that the crypto and decentralised finance (DeFi) sectors have reached a point of “critical mass”, prompting closer scrutiny of their financial stability implications. While linkages to traditional finance (TradFi) remain limited, the BIS highlights emerging risks as spot Bitcoin ETFs, stablecoins, and real-world asset (RWA) tokenisation expand.

Key transmission channels of risk to TradFi include:

• Institutional exposures to crypto or crypto-linked products
• Confidence and wealth effects tied to market volatility
• Use of crypto in settlement or payment infrastructure
• Potential DeFi adoption within TradFi operations

The report also raises concerns about wealth transfers during market stress, with smaller retail investors increasing exposure while institutional players exit.

As DeFi matures, the BIS recommends:

• Extending TradFi-equivalent requirements (e.g. KYC, disclosures, staff qualifications);
• Monitoring the rise of decentralised exchanges (DEXs) and RWA tokenisation;
• Identifying regulatory touchpoints within decentralised applications (e.g. user-facing interfaces and governance structures) and engaging with DAOs; and
• Prioritising further research on stablecoins, DeFi–TradFi interlinkages, and cryptoisation risks in emerging markets

The BIS reiterates its preference for a “containment and regulation” approach, and suggests embedding supervisory controls into DeFi infrastructure, such as embedding rules for best execution, disclosures, or transaction limits directly into smart contracts.

United States: Senate stablecoin bill stalls ahead of floor vote

On 8 May 2025, the US Senate did not secure the votes needed to advance the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, legislation that would establish a federal regulatory framework for payment stablecoins.

Although the bill had passed out of committee with bipartisan support, it fell short of the 60 votes required to proceed to full debate. The proposed legislation aimed to provide licensing and oversight mechanisms for US dollar-pegged stablecoins, establish reserve requirements, and support the broader integration of digital assets into the regulated financial system.

Key concerns raised by lawmakers included the need for stronger provisions related to anti-money laundering and foreign-issued stablecoins. Some senators who had previously supported the bill in committee cited a lack of progress on these areas during negotiations as a reason for withholding support at this stage.

The bill’s sponsors have indicated that further revisions may be introduced, and efforts to develop a unified framework for stablecoins are expected to continue.

United States: Federal Reserve withdraws key crypto-asset guidance for banks

On 24 April 2025, the Federal Reserve Board issued a press release announcing the withdrawal of several supervisory materials related to crypto-asset and dollar token activities by state member banks. The move reflects a shift toward incorporating oversight of digital asset activity into the standard supervisory process rather than through separate approval mechanisms.

Withdrawn items include:

• The 2022 guidance requiring advance notification of crypto-asset activity by banks.
• The 2023 guidance establishing a nonobjection process for engagement in dollar token activities.
• Two 2023 joint statements with the FDIC and OCC addressing risks related to crypto-assets and related liquidity concerns.

The Federal Reserve noted that it will continue working with fellow regulators to assess whether further guidance is needed to balance financial innovation and risk management.

United States: New draft House bill proposes shift in crypto market regulation

On 5 May 2025, the House Financial Services Committee released a new discussion draft of its crypto market structure legislation that would substantially amend US securities law by shifting regulatory oversight of many cryptoassets from the Securities and Exchange Commission (SEC) to the Commodity Futures Trading Commission (CFTC).

Key elements of the draft include:

• Defining a new category of “digital commodities” that would be exempt from SEC regulation.
• Amending the Securities Act of 1933 and Securities Exchange Act of 1934 to reflect these changes.
• Establishing criteria for what qualifies as a “mature blockchain system”, including decentralisation thresholds, open-source access, and network resilience.
• Moving oversight of secondary market trading in eligible cryptoassets to the CFTC, provided the assets meet the new definitions.

The legislation would not apply to tokens that provide ownership claims on the revenues or assets of an issuer, which would remain under securities regulation. It also provides for SEC certification of digital commodities, including grandfathering provisions for tokens issued before the law’s enactment.

The bill is expected to be discussed further in a committee hearing this month. Debate over governance, investor protection, and jurisdictional boundaries between the SEC and CFTC is likely to continue as the proposal develops.

United States: New Hampshire becomes first state to authorise Bitcoin reserve

On 6 May 2025, New Hampshire became the first US state to enact legislation authorising the investment of public funds into cryptoassets, with Governor Kelly Ayotte signing the bill into law.

The legislation permits the state treasurer to allocate up to 5% of available public funds into digital assets with a market capitalisation of at least $500 billion—effectively limiting eligible assets to Bitcoin (BTC) under current conditions.

The move follows similar proposals in other states, including Arizona and Florida, which were vetoed or withdrawn. New Hampshire’s law establishes a crypto reserve framework that positions it ahead of other states and potentially even the federal government, which is still evaluating its approach.

The bill’s sponsor, Representative Keith Ammon, said the measure aims to promote financial innovation and diversify the state’s holdings. The legislation was supported by digital asset advocacy group Satoshi Action Fund, which described the development as a “trailblazing” moment for state-level crypto policy.

The law does not currently permit investment in other digital assets or stablecoins.

European Union: EBA finalises RTS extending central contact point requirements to cryptoasset service providers

On 25 April 2025, the European Banking Authority (EBA) published a final report containing draft amendments to Commission Delegated Regulation (EU) 2018/1108, which sets out regulatory technical standards (RTS) on the appointment and responsibilities of central contact points (CCPs) under the Fourth Money Laundering Directive (MLD4).

The amendments extend the scope of the RTS to cover cryptoasset service providers (CASPs), reflecting changes introduced by the Wire and Cryptoasset Transfer Regulation ((EU) 2023/1113). CASPs operating cross-border without a branch presence may now be required to appoint a CCP in the host member state, aligning their obligations with those of payment service providers (PSPs) and electronic money institutions (EMIs).

The updated RTS specify the criteria for determining when a CCP must be appointed, based on a risk-based and proportionality principle, as well as the roles and responsibilities of CCPs in supporting compliance with local anti-money laundering and counter-terrorist financing (AML/CFT) obligations. The final report delivers on the EBA’s mandate under Article 45(10) of MLD4, and builds on proposals first published for consultation in December 2024.

The draft RTS will now be submitted to the European Commission for endorsement and are subject to scrutiny by the European Parliament and the Council of the EU.

Market Developments

Uzbekistan: Paysend enables instant payments to Uzbekistan's Uzcard and Humo

On 30 April 2025, it was announced that Paysend have expanded cross-border transfer opportunities to Uzbekistan for banks, digital wallets, and remittance businesses. 

Currently in Uzbekistan, SWIFT payments typically take three to five days, and many recipients still rely on cash pick-ups. Paysend's expansion will now allow for instant payouts directly to local cards, available 24/7 with real-time foreign exchange rates and notifications.

Businesses can now process instant and secure transfers to Uzbekistan, significantly reducing transaction times and costs. 

Europe: Scandinavian countries and Estonia plan to launch offline card payments

On 8 May 2025, it was reported that Finland, Sweden, Norway, Denmark, and Estonia are planning to launch offline card payments to ensure payment continuity during internet outages. This initiative reflects growing concerns about the resilience of critical infrastructure amongst increasing geopolitical tensions.

The announcement was made by a board member of the Bank of Finland, who stressed that the risk of major disruptions to digital services, including payments, has grown significantly. Finland is particularly vulnerable as only 10% of the population relies on cash and people are mostly dependent on card-based digital payments. 

Norway and Denmark have already launched early versions of offline electronic payment systems and are continuing their development. Estonia is also part of this initiative, but its central bank has not yet publicly shared further details. 

Indonesia: Korea to introduce QR code payment service in Indonesia

On 9 May 2025, it was reported that the Korea Financial Telecommunications & Clearings Institute (KFTC) intends to introduce a QR code payments service in Indonesia, the KFTC's first Asian partner for this service. This initiative will operate under the guidance of the Bank of Korea and aims to promote advanced digital financial services in Asia. 

Following Indonesia, Vietnam is set to be the next country to adopt this system. In addition, the KFTC plans to extend the Bank of Korea's knowledge to promote cashless payment methods beyond Asia, as highlighted by a memorandum of understanding signed with the National Bank of Georgia.

Singapore: ShopeePay introduces Tap Secure feature

On 28 April 2025, it was reported that ShopeePay, a mobile wallet, has introduced Tap Secure, which adds an extra layer of security to its users' transactions by sending real-time notifications when a transaction is initiated. Tap Secure requires the account holder to personally approve every transaction before it is completed. To enable this feature, users must link their ShopeePay account to their current device and complete a personal verification process. The initiative is designed to prevent unauthorized access and mitigate the risk of fraud.

Global: Circle announces payments network

On 21 April 2025, it was announced that Circle, the FinTech firm behind the USDC stablecoin, plans to roll out a new cross-border payments network in May. The Circle Payments Network (CPN) will connect financial institutions and enable real-time settlement of cross border payments using USDC, EURC and other regulated stablecoins. CPN will also allow connectivity to domestic real-time payment systems worldwide and is expected to power supplier payments, remittances, payroll, capital markets settlement, internal treasury operations and on-chain financial applications.

United States: Klarna and eBay expand partnership to US

On 23 April 2025, it was announced that eBay is rolling out Klarna's flexible payments options to millions of eBay's US shoppers. Shoppers can pay for eligible eBay purchases with Klarna's flexible payment options including Pay in 4, which allows customers to split up purchases into four interest-free payments as well as financing, offering flexible payment plans for larger purchases.

Klarna and eBay have already launched their partnership in Europe in December 2024 and have seen eBay shoppers split payments to access more expensive items in a more affordable and manageable way.  

Germany: PayPal launches contactless wallet

On 5 May 2025, it was announced that PayPal will launch their first-ever contactless mobile wallet in Germany which will be accessible through the newest version of the PayPal App. Shoppers will be able to choose PayPal to pay at any location that accepts Mastercard contactless payments.

In addition, PayPal will roll out its Pay Later online option for use in physical stores in Germany – a first for PayPal in Europe. Consumers will be able to pay in 3, 6, 12 and 24-month installments for in-store purchases with Ratenzahlung To Go. 

Consumers will also be able to activate offers in the PayPal app to earn cashback. Once activated, users will earn cashback when they pay contactless with the PayPal App at a range of German stores. More details on this will be announced soon.

Switzerland: Spar now accepts Bitcoin payments

On 22 April 2025, it was reported that Spar, a chain grocery store in Switzerland, has announced the launch of bitcoin-based payments. Spar have launched this in their Zug store, aiming to support the adoption of cryptocurrencies for daily transactions. Spar implemented Bitcoin payments through the Lightning Network, with the store's transactions live on BTC Map. The Spar location is among the first supermarkets in Switzerland where shoppers can pay directly at checkout using Bitcoin through the company's Open Crypto Pay solution. In addition, shoppers can pay with Bitcoin by scanning a QR code, in turn benefiting from a simplified and optimised customer experience.

Global: CompoSecure launches wallet integration with MoneyGram for cash-to-crypto access

On 21 April 2025, it was announced that CompoSecure have integrated their Arculus Cold Storage Wallet with MoneyGram Access. This will allow users to add and withdraw USDC in cash at participating MoneyGram locations. Arculus is the first hardware wallet to integrate with MoneyGram Access, allowing customers to convert physical cash into USDC on the Stellar blockchain and securely manage their digital dollars in the self-custody Arculus Wallet. 

United States: Rain joins Visa's pilot program for stablecoin settlement

On 1 May 2025, it was announced in a press release that Rain, a global card issuing platform built for stablecoins, has joined Visa's pilot program for stablecoin settlement. Rain has fully tokenised its credit card receivables and has transitioned all settlement transactions for its Visa cards to USDC. Participating in this program allows Rain to conduct settlement seven days a week, 365 days a year, operating outside traditional banking hours. 

Maldives: Maldives plans $9 billion blockchain hub to tackle debt burden

On 5 May 2025, it was reported that the Maldives have signed a joint venture with MBS Global Investments, who have already secured over $4-5 billion in funding, to develop a large-scale blockchain and digital assets hub, titled the Maldives International Financial Centre. The Financial Centre is set to be built in the capital Malé over a five-year period and will operate as a financial free zone, focusing on blockchain technologies and digital assets. Government projections suggest that the initiative could triple the country's GDP within four years and generate over USD 1 billion annually by the fifth year. 

United Arab Emirates: Ruya launches Shariah-compliant crypto trading

On 28 April 2025, it was reported that Ruya has become the first Islamic bank globally, to allow virtual currency transactions. Ruya have developed this service in partnership with Fuze, a digital asset infrastructure provider. This service aims to offer investment opportunities in digital assets that comply with Islamic financial principles. To help users navigate this new service, Ruya is offering customer support through its community centers and hybrid call centers.

Surveys and Reports

Global: Notabene publishes report on crypto Travel Rule 

On 23 April 2025, Notabene, a risk management platform, published its annual State of Crypto Travel Rule Compliance Report. The report examines the Financial Action Task Force (FATF's) Travel Rule and the EU's Transfer of Funds Regulation (TFR), and includes findings from the  State of Crypto Travel Rule Survey 2025, which collated responses from 91 companies worldwide.

Key findings include:

• All virtual asset service providers (VASPs) indicated that they are already Travel Rule compliant or plan to achieve compliance by Q4 2025. 
• Enforcement of the EU’s Transfer of Funds Regulation (TFR) drove a 200-fold surge in Travel Rule volumes, yet 71% of European crypto-asset service providers (CASPs) remain non-compliant. 
• Two longstanding challenges continue to hinder adoption: 

• a lack of protocol interoperability due to technical integration challenges, closed network membership and variations in Travel Rule workflows; and 
• difficulties during the “Sunrise Period”, during which some jurisdictions enforce the rule while others do not, which means that VASPS face difficulties in exchanging data with international counterparts. 

• For four consecutive years, the Sunrise Period has persisted as one of the top barriers to the Travel Rule implementation. In 2025, it tied with regulatory and legal uncertainty (both cited by 20% of respondents) as the most significant obstacle. 

Global: Fidelity report on the performance of Bitcoin and Ethereum in Q1

On 28 April 2025, Fidelity published their Q1 Signals Report, which highlights sharp price declines for both Bitcoin and Ethereum, but notes that long-term fundamentals remain solid. 

Key findings include:

• Bitcoin fell 13% to ~$82,560, driven by early-quarter miner selling and macro uncertainty.
• Ethereum dropped 45% to $1,822, erasing post-election gains and entering a “capitulation” phase.
• Bitcoin’s realised price (average cost basis of holders) held steady around $44,000, while illiquid supply rose by 2% — a sign of accumulation by long-term holders.
• Ethereum’s realised price dipped just 3% to $2,020, indicating that short-term sentiment drove most of the decline.
• Only 44% of ETH addresses are in profit, down from a 95% peak in Q4 — highlighting a sharp swing in sentiment and market conditions.
• Bitcoin miner profitability and hash rate increased, while exchange balances dropped 5%, suggesting growing self-custody and network strength.
• Fidelity’s outlook: Short-term sentiment has weakened, but structural metrics support ongoing institutional and retail engagement.

Global: The Payments Association publishes 2025 payments outlook

On 28 April 2025, The Payments Association published their key insights from the PAY360 2025 survey on current challenges and opportunities in the payments sector. The survey was conducted during Q1 2025 and includes insights from over 6,500 registrants from 93 different countries worldwide. Respondents include decision-makers across all organizational levels, from directors, to managers and executives. The results from this survey highlighted how industry leaders are prioritising AI, cross-border payments, and digital currencies while handling regulatory, technological, and consumer demands. 

Key insights include:

• Open banking, cross-border payments, and digital currencies have emerged as top areas of interest among industry professionals. 
• ESG initiatives remain a lower priority. The Payments Association suggests that this implies that immediate operational and technological concerns are taking precedent over longer-term sustainability goals.

Authored by Charles Elliott, Virginia Montgomery, Sofie Gowran, and Nurangis Sobirkhonova.