Circle Responds to the Bermuda Monetary Authority’s Proposed Framework for Payment Services Providers

Circle recently submitted a response to the Bermuda Monetary Authority (BMA) regarding its proposed regulatory framework for payment services providers (PSPs). Circle welcomes the BMA’s initiative to create a modern, technology-neutral, and risk-proportionate regime that aligns with international standards while fostering innovation.

Circle strongly supports the BMA’s efforts to provide legal clarity for a rapidly evolving payments landscape, particularly as digital wallet services and embedded financial tools become more commonplace. In its feedback, Circle emphasized the importance of clear definitions and regulatory treatment across three categories of PSPs: digital wallet providers (DWPs), payment-handling providers (PHPs), and payment technology providers (PTPs). In particular, Circle encouraged the BMA to distinguish between custodial and non-custodial wallet solutions, ensure that self-to-self transfers for interoperability are excluded from regulatory scope, and maintain a technology-neutral stance when evaluating infrastructure providers like card networks and blockchain-based payment enablers.

Circle continues to see Bermuda as a beacon for global standard-setting around emerging financial technology, and the BMA’s innovative, tiered approach to licensing has long served as a laboratory for a risk-based approach to fostering responsible financial innovation.  

Bermuda’s initiative reflects a forward-looking approach to balancing responsible innovation with robust regulatory oversight. Circle appreciates the opportunity to contribute to developing a comprehensive framework that could position Bermuda as a leader in regulating modern payment services. We look forward to continuing our collaboration with the BMA and supporting global policy efforts that enable safe, open, and inclusive digital finance.