BLOCKRIVER AG RECEIVES SRO MEMBERSHIP: VIEW INFO
Whtie Papers
Explore in-depth research and position papers.

The Death of Omnibus Risk in OTC Markets

Omnibus risk structures were effective in an environment of limited scale and homogeneous counterparties. As institutional OTC markets have expanded, those same structures have become sources of hidden concentration and balance-sheet fragility.

Segregation represents a structural response to this shift. By localising exposure and enforcing attribution, it transforms systemic risk into manageable, unit-level risk. The decline of omnibus risk is therefore not a regulatory artefact, but a consequence of how institutional markets now operate.

The implication is clear: resilience in modern OTC markets depends less on monitoring pooled exposure and more on designing systems where exposure cannot silently aggregate in the first place.

Banks Are Building Their Own Stablecoin Rails: EMIs Face a Structural Reckoning

Twelve major European banks, including BBVA, BNP Paribas, and UniCredit, are building shared stablecoin infrastructure through Qivalis, bypassing the EMI intermediaries that once served as their on-ramps to digital payments. For licensed EMIs serving institutional clients, this isn't competition from fintechs. It's your traditional banking partners becoming direct rivals in the settlement layer you cannot legally access.

When BBVA joined the Qivalis consortium this week, it brought the membership to twelve of Europe's largest banks, a roster that reads like a who's who of correspondent banking. The consortium now includes Banca Sella, BNP Paribas, CaixaBank, Danske Bank, DekaBank, DZ BANK, ING, KBC, Raiffeisen Bank International, SEB, and UniCredit. These are not speculative crypto ventures. These are the institutions that move euros between corporates, process treasury payments, and anchor cross-border trade finance.

The consortium has set up a joint venture headquartered in Amsterdam, operating under MiCA's solvency, governance, and customer protection standards. Qivalis is currently awaiting authorization as an electronic money institution from the Dutch central bank. The regulatory approach is deliberate: by structuring Qivalis as an EMI, the consortium can issue a MiCA-compliant euro stablecoin while preserving the trust architecture that institutional clients expect from regulated banks.

The euro-denominated stablecoin will enable 24/7 access to efficient cross-border payments, programmable payments, and improvements in supply chain management and digital asset settlements, from tokenized assets to cryptocurrencies. For a corporate treasurer managing liquidity across multiple jurisdictions, that's a material operational upgrade, near-instant settlement, reduced counterparty risk, and integration with on-chain asset markets.

The timing matters. MiCA's provisions for stablecoins, including Asset-Referenced Tokens and E-Money Tokens, became applicable on June 30, 2024. Full CASP authorization requirements entered into force on December 30, 2024. European banks now have a clear regulatory path to issue stablecoins, and they're taking it together rather than individually. The consortium model spreads development costs, pools regulatory expertise, and creates immediate network effects across multiple domestic markets.

This is where the structural disadvantage for EMIs becomes acute. Under MiCA, E-money tokens can only be offered in the EU by credit institutions and electronic money institutions authorized in the EU that have submitted a white paper to the competent supervisory authority. On paper, EMIs can issue stablecoins. In practice, the capital requirements, reserve management obligations, and technical infrastructure demands favour institutions with balance sheets measured in hundreds of billions.

Unlike ARTs, firms wishing to issue and offer EMTs must be authorized either as a CRR credit institution or an electronic money institution under the E-Money Directive. No possibility to become authorized under MiCA alone is foreseen in this respect. EMIs can play, but only if they're already licensed under existing e-money frameworks, and only if they can meet the incremental requirements MiCA layers on top. The regulatory bar isn't impossibly high, but it favours incumbents with existing compliance infrastructure and access to low-cost liquidity.

The competitive dynamic is straightforward. Banks like BBVA aren't building stablecoin rails because they want to compete in crypto markets. They're building them because industry participants view the consortium's work as part of a broader effort to upgrade euro digital payment rails for a tokenized economy. A widely adopted bank-issued coin could support securities settlement, cross-border trade, and treasury operations conducted in near real time.

This is where institutional client expectations become the forcing function. Fireblocks' 2025 survey indicates banks are twice as likely to prioritize cross-border payments via stablecoins compared to other use cases, with speed outpacing cost savings as the top motivator. When corporate treasury teams evaluate their payment infrastructure, settlement velocity increasingly determines provider selection. A fiat-only EMI competing against a bank-backed stablecoin offering faces the same asymmetry as a fax machine competing against email: technically functional, but structurally outclassed.

The broader institutional infrastructure is moving in the same direction. Project Agorá brings together seven central banks. Bank of France representing the Eurosystem, Bank of Japan, Bank of Korea, Bank of Mexico, Swiss National Bank, Bank of England, and the Federal Reserve Bank of New York, to explore how tokenization of wholesale central bank money and commercial bank deposits on programmable platforms can improve the monetary system. BBVA is a participant. So are dozens of other regulated financial institutions. The direction of travel is unambiguous: settlement infrastructure is moving on-chain, and the institutions building it are the same ones that EMIs have historically relied on for correspondent banking relationships.

Visa announced the launch of USDC settlement in the United States in December 2025, marking a major milestone in the company's stablecoin settlement pilot program and strategy to modernize its settlement layer underpinning global commerce. When payment networks and universal banks converge on the same infrastructure thesis, it stops being experimental and starts being table stakes.

For EMIs serving institutional clients, the calculus is uncomfortable. Your fiat rails remain essential for regulatory compliance and local payment schemes. But your institutional clients, the trading firms, corporate treasuries, and cross-border platforms, increasingly need settlement options you cannot legally provide without additional licensing, capital, and technical capabilities. The banks that used to sit upstream from you in the correspondent chain are now building parallel infrastructure that routes around you entirely.

Qivalis is working towards obtaining its regulatory approval and planning to launch the euro-denominated stablecoin in the second half of 2026. Qivalis has set a launch target for the second half of 2026. That's eighteen months away. For an EMI head of product or chief commercial officer, the question isn't whether stablecoin settlement will become commercially relevant, it's whether your institution can build or acquire the capabilities to participate before your banking partners become your direct competitors.

The regulatory framework doesn't preclude EMIs from this market. But it doesn't level the playing field either. Banks can leverage existing credit institution licenses, balance sheet strength, and correspondent relationships to build stablecoin infrastructure at scale. EMIs face the same licensing pathways but without the structural advantages that make execution practical. The result isn't a regulatory barrier, it's a competitive one.

Sitting still is a choice. But so is watching your institutional client base migrate toward providers who can offer what you cannot. The banks building Qivalis aren't asking permission from their EMI partners. They're building the future of euro settlement infrastructure and inviting their corporate clients to come along.

References

[1] BBVA joins banking consortium to issue European stablecoin

[2] Qivalis, joint venture of a European banking consortium, to launch euro stablecoin in the second half of 2026, KBC Newsroom

[3] Project Agorá: central banks and banking sector embark on major project to explore tokenisation of cross-border payments, Bank for International Settlements

[4] Markets in Crypto-Assets Regulation (MiCA), European Securities and Markets Authority

[5] Visa Launches Stablecoin Settlement in the United States

Stay informed.
<NEWSLETTER REGISTRATION CONFIRMED>
<ERROR>