Looking ahead to 2026, three compliance themes stand out for banks and financial institutions operating across emerging markets.

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1. Oversight and accountability for stablecoin issuers

We’re likely to see greater adoption of stablecoins next year, but there’s still no clear precedent for who is ultimately responsible for their oversight and the consequences of failure.

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Will accountability fall to the banks providing deposit or settlement services to stablecoin issuers, or to regulators? And when something inevitably goes wrong, who will suffer financially — the bank, or the issuer itself? This lack of regulatory clarity around stablecoin accountability remains one of the biggest questions facing the industry.

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2. Evolving sanctions and tariff compliance

Sanctions activity is becoming more dynamic, and banks face growing pressure to comply — often with tools and systems that weren’t built for this pace of change. The same goes for tariffs: if a payment facilitates a transaction where the tax or tariff wasn’t properly collected, what is the bank’s exposure? Financial institutions need modern software that can adapt in real time to shifting compliance demands and reduce operational and financial risk in these areas.

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3. Protecting consumers, users, and domestic systems — and defining liability — in real-time cross-border networks.

With more than 70 domestic real-time payment systems, and the move to interconnect these systems — along with central banks’ support for “one-leg-out” transactions — the question is: how do we enable this safely and efficiently, taking into full account counterparty risk, transaction risk, and multi-jurisdictional compliance?

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When dealing with bad actors — whether at the originator or recipient end — committing fraud or exploiting network vulnerabilities, where are the tools to detect, prevent, and mitigate that fraud, and to protect everyone in the system?

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Given the move to interconnect real-time payment systems, defining accountability among originators, intermediaries, and receiving institutions will be essential to maintaining safety, soundness, and trust in the global payment ecosystem.