The U.S. Treasury has begun implementing the GENIUS Act, inviting comments from the market on the new stablecoin regulations.
The U.S. Department of the Treasury has officially begun the implementation of the GENIUS Act, inviting feedback from market participants within a 60-day window. This marks a significant step in establishing regulatory frameworks for stablecoins.
In an extensive 87-page notice, the Treasury outlines the criteria for assessing whether state-level regulations align with federal standards. Under the GENIUS Act, stablecoin issuers with volumes below $10 billion may choose state regulation, provided they adhere to federal guidelines.
Dual Requirement Framework
The proposed regulations create two categories of requirements for stablecoin issuers:
- Uniform Requirements: These include maintaining reserves and adhering to anti-money laundering and counter-terrorism financing (AML/CFT) regulations.
- State-Calibrated Requirements: Local regulators have the flexibility to set specific capital and risk management standards.
The Office of the Comptroller of the Currency (OCC) will oversee non-bank stablecoin issuers that exceed the $10 billion threshold, as their operations will be subject to federal regulations.
While states can impose stricter regulations than federal standards, they must not conflict with existing laws or hinder comparability.
Disclosure and Branding Regulations
Issuers are mandated to publish monthly reports on their reserve compositions, maintaining the same frequency as federal requirements. Additionally, both state and federal regulations impose naming restrictions on stablecoin branding.
Federal law serves as the foundational standard, meaning that any future Congressional regulations on stablecoin issuers will automatically apply to firms regulated by states unless explicitly stated otherwise.
Legislative Context
Enacted in 2025, the GENIUS Act marked a pivotal moment in U.S. cryptocurrency regulation, establishing the first federal standards for stablecoins, including full reserve backing and mandatory reporting. Concurrently, Congress is considering other legislation, such as the CLARITY Act, which seeks to clarify the roles of the SEC and CFTC in overseeing these assets.
Ongoing discussions around these bills reflect industry concerns, particularly regarding provisions that would prevent firms from earning income based solely on client stablecoin holdings. Recent actions by U.S. authorities have also acknowledged the privacy rights of users of crypto mixers, alongside proposals for reforms in retirement plans, the mining industry, and protections for Bitcoin reserves.
