Overview

• The GENIUS Act classifies dollar-backed stablecoins as payment instruments and imposes one-to-one reserve, audit, monthly disclosure and strict AML requirements while banning issuer-paid yield.
• The Office of the Comptroller of the Currency will serve as the primary regulator with 180 days to finalize rules and an 18-month phase-in period before full enforcement, followed by a three-year transition and penalties for unregistered issuance.
• Circulation of regulated stablecoins has topped $263 billion, a 60 percent surge year-over-year, and transaction volumes now exceed those of Visa and Mastercard combined.
• Firms such as Coinbase and PayPal are maintaining 3 percent to 5 percent rewards for stablecoin holders by routing issuance through third parties or non-issuer structures.
• Emerging markets like India are already crafting their own stablecoin regulations to avoid ceding digital finance leadership to the United States.