Europe's stablecoin framework ties crypto to banks without the crisis backstop the US used to contain the 2023 SVB collapse, UniCredit's deputy vice chair warned.
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UniCredit warns EU's €100K deposit cap can't contain crypto-bank crisis
Elena Carletti, UniCredit's deputy vice chair and head of the board's risk committee, said European authorities may be unable to replicate the US response to the 2023 banking crisis because the region's deposit guarantee system caps protection at €100,000 ($116,500) per depositor — far below the sums stablecoin issuers would need to safeguard during a bank run.
"The same decision cannot be easily taken in Europe," Carletti said at a banking conference hosted by Madrid's IESE Business School on Thursday, referring to the US decision to invoke a systemic risk exception that guaranteed all deposits at Silicon Valley Bank and Signature Bank, including funds held by crypto firms.
The warning centers on the European Union's Markets in Crypto-Assets regulation, which requires stablecoin issuers classified as electronic money token providers to hold reserves in bank deposits or similar low-risk liquid assets. That structure ties crypto markets directly to the banking system — a link exposed during the March 2023 collapse of SVB, when Circle revealed $3.3 billion of USDC's cash reserves were trapped at the failed lender. USDC briefly lost its dollar peg before US regulators stepped in with blanket deposit guarantees that stabilized the token.
"That means that we are forcing a certain alliance of stablecoin and crypto providers with the banking sector without the possibility of extending insurance in the same way, and that to me is a double form of weakness," Carletti said.
The gap leaves Europe's stablecoin framework with a structural vulnerability. MiCA can define reserve standards and issuer obligations, but it cannot guarantee that those reserves remain accessible during a banking crisis. Unlike the US, where the Federal Deposit Insurance Corp. can invoke a systemic risk exception with Treasury and Fed approval, Europe's deposit guarantee directive offers no equivalent mechanism for emergency coverage of large corporate accounts tied to crypto firms.
The concern extends beyond stablecoin issuers to the banks that hold their reserves. A lender serving multiple stablecoin clients could face sudden deposit outflows if token holders redeem aggressively during market stress, creating a feedback loop between crypto market volatility and traditional bank liquidity. European banks already face heightened scrutiny on cybersecurity and AI-related risks, with ECB outgoing Vice President Luis de Guindos saying this week that lenders need to invest more in defenses against new large language models that can find flaws in software.
For institutional investors considering euro-denominated stablecoin products, the regulatory gap introduces counterparty risk that MiCA compliance alone does not address. Asset managers evaluating stablecoin exposure in Europe will need to assess not only whether an issuer meets reserve requirements, but whether those reserves would remain stable during the kind of bank stress that turned a crypto problem into a financial-sector problem in 2023.
This article is for informational purposes only and does not constitute investment advice.
[1] UniCredit warns Europe may struggle to contain crypto-bank crisis under MiCA rules[2] Europe less able than US to contain crypto-bank shocks, UniCredit director says[3] ECB tells banks to invest more to get a grip on AI security risk[4] May 2026 Global Regulatory Brief: Digital finance (Prediction markets, digital collateral and cryptoasset capital rules)[5] Europe May Struggle to Contain Crypto-Bank Shock, UniCredit Official Says - FinanceFeeds
