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The GENIUS Act: A Comprehensive Guide to U.S. Stablecoin Regulation

Banner image with a dark purple gradient background featuring the title “The GENIUS Act: A Comprehensive Guide to U.S. Stablecoin Regulation.” The Hola Prime Cryptos logo appears in the top-right corner. The image includes abstract icons of a dollar symbol and a gavel with a document, representing finance and regulation.

Introduction

What Sparked the Need for Stablecoin Regulation?

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Signing of the GENIUS Act: A Historical Turning Point

On July 18, 2025, then-President Donald Trump signed the GENIUS Act into law. It was a landmark day. Not just because the U.S. finally got serious about stablecoin oversight, but because it did so with a rare feat, bipartisan support. The Act immediately became law, with full compliance expected by July 2028. And just like that, the U.S. had a roadmap for one of the most influential digital asset classes of our time.

What Are Stablecoins?

Definition and Basic Characteristics

Stablecoins are digital assets designed to maintain a fixed value, typically pegged 1:1 to fiat currencies like the U.S. dollar. Their goal? To offer the speed and borderless nature of crypto while preserving the predictability of traditional money.

Stablecoins vs. Traditional Cryptocurrencies

Unlike Bitcoin or Ethereum, whose prices can swing wildly in a single day, stablecoins are meant to be stable stores of value. This makes them perfect for:

  • Instant payments
  • Dollar savings in inflation-hit countries
  • On-chain trading settlements
  • DeFi lending and borrowing platforms

The Role of Stablecoins in DeFi and Payments

Stablecoins power the beating heart of decentralized finance (DeFi). Without them, borrowing, lending, staking, and yield farming would lack a reliable medium. On top of that, their role in cross-border transactions is huge. No bank hours. No conversion fees. Just frictionless money movement.

Payment Stablecoins vs. Algorithmic Stablecoins

This distinction is crucial. Payment stablecoins, like USDC or PayPal’s PYUSD, are backed by real-world assets like dollars or Treasury bills. In contrast, algorithmic stablecoins, like the failed TerraUSD, rely on economic incentives or smart contract algorithms and that hasn’t always ended well.

The GENIUS Act zeroes in on payment stablecoins, the kind most commonly used in payments and trading.

Why the U.S. Needed the GENIUS Act

The $232 Billion Question: Market Growth and Systemic Risk

By May 2025, the global stablecoin market had hit $232 billion in capitalization. That’s bigger than many banks. And yet, the legal status of stablecoins was murky. Were they securities? Commodities? Something new?

Regulators needed a clear answer, especially after:

  • Terra’s collapse, which wiped out billions
  • Questions around Tether’s reserve disclosures
  • The rise of institutional use in B2B payments

Learning from Past Failures: Terra (LUNA) and Others

If you blinked in 2022, you might’ve missed the biggest algorithmic stablecoin meltdown in history: TerraUSD. It lost its peg, collapsed alongside LUNA, and took billions in investor funds with it. It proved that the illusion of “peg stability” can be devastating when not backed by real assets.

Gaps in the Regulatory Landscape Before GENIUS

Before the GENIUS Act, stablecoin oversight was a jigsaw puzzle:

  • The SEC claimed jurisdiction over some stablecoins as securities
  • The CFTC focused on derivatives
  • The OCC and Federal Reserve had conflicting views on bank-issued tokens

No unified law meant uncertainty for developers, investors, and consumers.

The GENIUS Act fixes that.

The Legislative Journey of the GENIUS Act

The Creation and Introduction of the GENIUS Act in Congress

The GENIUS Act was introduced February 4, 2025, with significant bipartisan support. Senators Tim Scott (R-SC), Bill Hagerty (R-TN), Cynthia Lummis (R-WY), and Kirsten Gillibrand (D-NY), authored the legislation out of a need to respond to market volatility and pressure for innovation.

Key Supporters and Sponsors

Support came from both sides of the aisle/sectors. Wall Street, fintech startups, and even crypto-prop firms showed their support for the legislation – each seeing a future where clear rules or regulations would lead to more adoption.

The Path Through the Senate

The Senate Banking Committee approved it on March 13, 2025 with an 18-6 vote. The full Senate passed it on June 17, 2025, after a successful cloture motion on May 20 that broke the filibuster. Final vote tally? 68-30.

The House Approval and Presidential Signature

The House followed swiftly, passing the bill on July 17, 2025, with a decisive 308-122 vote. President Trump signed it the next day, calling it “a blueprint for American dominance in digital currency.”

Timeline for Implementation and Transition

  • Immediate effect: As of July 18, 2025, the Act is law
  • Regulatory detailing deadline: Within 180 days (early-to-mid 2026)
  • Transition period: 3 years for existing issuers (till July 2028)

Overview of the GENIUS Act’s Key Provisions

The GENIUS Act contains a number of landmark provisions. Together, the provisions establish the framework for a U.S. stablecoin regulatory regime. The provisions are designed to provide transparency, protect consumers, support systemic stability, and promote innovation. This section provides a high-level summary of the Act’s key provisions.

Federal-State Regulatory Framework

Under the GENIUS Act, a two-tiered regulatory system is provided:

  • Federal Oversight: Stablecoin issuers with more than $10 billion in issuance will be regulated by the Federal Reserve and the OCC, which also oversees subsidiaries of insured deposit institutions (banks & credit unions).
  • State Oversight: Smaller issuers may opt to go with state regulation if it can be shown to be “substantially similar” by a new federal Stablecoin Certification Review Committee (members include the Treasury, FRB, and FDIC).

Together, this creates space for innovation and a sufficient bar of protection for institutions that play a systemic role.

Who Can Issue Stablecoins?

The Act limits stablecoin issuance to entities with demonstrated financial strength and compliance capabilities:

  • Subsidiaries of federally insured banks or credit unions
  • Nonbank issuers approved by the OCC as “federal qualified payment stablecoin issuers”
  • State-qualified entities meeting federal standards

This significantly narrows the pool of issuers, raising the bar for participation.

Reserve Requirements for Issuers

The GENIUS Act mandates full reserve backing:

  • 1:1 Reserve Backing: Every stablecoin must be backed by an equivalent in high-quality liquid assets, including:
    • U.S. dollars
    • Treasury bills
    • Insured demand deposits
    • Tokenized equivalents of any of the above
  • Restrictions: Reserves must be segregated and cannot be used for lending or leveraged activity.
  • Transparency: Issuers must publish monthly disclosures, with a CEO’s & CFO’s certification. Instead of monthly disclosures, if the issuer has issued more than $50 billion, they need to conduct an independent annual audit.

Compliance and Transparency Measures

To align with traditional finance, issuers must:

  • Implement AML/CFT programs in accordance with the Bank Secrecy Act
  • Comply with OFAC sanctions
  • Refrain from paying interest or yield on stablecoins to avoid investor confusion and financial instability

Consumer Protections and Priority Rights

  • Insolvency Protections: Stablecoin holders get priority claims over the issuer’s reserves.
  • Clear Naming Rules: Terms like “USG” or any implication of government backing are banned.
  • Enforcement: The CFPB and FTC are given the power to monitor misleading advertising and consumer protection violations.

Guidelines for Foreign Issuers

The Act asserts U.S. jurisdiction over foreign stablecoin issuers operating in American markets:

  • Must comply with U.S. court and agency orders
  • Treasury can ban noncompliant foreign entities from U.S. operations

Rules on Algorithmic Stablecoins

Algorithmic stablecoins (those backed by endogenous collateral or managed via code-based mechanisms) are treated cautiously:

  • No ban is enforced, but a full risk study by the Treasury is mandated within 1 year
  • Contrast: The House’s STABLE Act proposes a 2-year moratorium on these assets

Implementation Deadlines and Transition Phase

  • Immediate Effect: The Act is already law
  • 180 Days: Agencies must issue key rules by mid-2026
  • 3-Year Transition Period: Existing issuers have until July 2028 to comply fully

Federal vs. State Oversight

The GENIUS Act creates a hybrid regulatory framework that clearly separates federal regulation from state regulation, representing a meaningful step away from the current patchwork regulatory environment. While this hybrid regulatory scheme establishes a clear division between federal and state regulation, it provides for an infrastructure to facilitate responsible innovation in a manner that does not jeopardize consumer protection or financial stability.

Threshold-Based Supervision

The law delineates jurisdiction based on the size and systemic impact of the issuer:

  • Federal Oversight is triggered when an issuer’s stablecoin circulation exceeds $10 billion, or when the issuer is a subsidiary of an insured depository institution (IDI).

  • State Oversight applies to smaller nonbank issuers – typically fintech startups – who fall below this threshold but must still meet rigorous requirements.

This threshold-based approach is designed to focus federal scrutiny where systemic risk is highest, without suffocating innovation at the grassroots level.

Role of the Stablecoin Certification Review Committee

To ensure consistent quality across jurisdictions, the Act creates a Stablecoin Certification Review Committee (SCRC). This committee includes officials from:

  • The Department of the Treasury
  • The Federal Reserve Board
  • The Federal Deposit Insurance Corporation (FDIC)

to determine if the regulatory framework of a state is “substantially similar” to the federal standards established in the GENIUS Act.  If a state’s framework is “substantially similar” stablecoin issuers can legally operate in that state without federal licensure (as long as they comply with the $10 billion threshold).

This structure serves as a regulatory sieve: regulating state-level experimentation within national standards.

State Autonomy, Federal Backbone

States retain their ability to charter and supervise stablecoin entities, but now do so within a harmonized national policy architecture. Unlike earlier proposals that would have federally preempted state oversight entirely, the GENIUS Act adopts a more cooperative stance.

This represents a middle path:

  • It avoids full federal preemption, respecting the U.S. tradition of dual banking systems.
  • It prevents a regulatory race to the bottom by elevating the standard of permissible state regimes.

Coordinated Enforcement

Regulatory agencies operating at both federal and state levels should follow collaborative strategies for enforcement actions, especially when multiple jurisdictions are involved with the same issuer. For instance:  

  • The CFPB and FTC will take the lead on deceptive practices operations at the federal level.
  • State financial regulators will focus on regional supervision of smaller issuers operating under their jurisdictions.

By working together, regulators form a more full-scope net of coverage and catch challenges that might have previously fallen through regulatory gaps.

Why This Matters

Before the GENIUS Act, the stablecoin industry existed in a regulatory gray zone – some firms were regulated under money transmission laws, others claimed exemptions, and many operated in legal limbo. This created:

  • Legal uncertainty for issuers
  • Risk exposure for consumers
  • Inefficiencies for law enforcement and market participants

The federal-state model provides a clear answer to “Who regulates what?”, enabling both innovation and protection to coexist more effectively.

Reserves & Transparency Rules for Stablecoins

The big question everyone asks: Are stablecoins really backed 1:1?

GENIUS tackles this head-on by mandating:

  • 100% reserve backing with high-quality liquid assets like U.S. dollars, Treasuries, or Fed deposits

  • No rehypothecation, meaning issuers can’t lend out or re-use reserves

  • Public monthly disclosures of reserve breakdowns

  • Quarterly audits by independent auditors

This is a direct response to past controversies like TerraUSD and even scrutiny faced by Tether.

If GENIUS passes, it will likely end speculative reserve practices and force all major issuers to maintain true dollar-for-dollar backing. This gives consumers and institutions more confidence and possibly opens doors for more banks and payment processors to integrate stablecoins.

Redemption Rights: The $1-for-$1 Rule

GENIUS doesn’t just focus on the backend reserves; it guarantees the user experience too.

It requires that:

  • Any holder of a regulated stablecoin must be able to redeem it for $1 at any time

  • Redemption must be processed within a reasonable timeframe, often 1–2 business days

  • No excessive fees, delays, or restrictions can be applied

This aims to turn stablecoins into true digital cash, where 1 stablecoin equals 1 dollar, no matter the market conditions.

In a world where some stablecoins have depegged under stress, this provision might be the most consumer-friendly part of the bill.

Consumer Protection Rules Built In

The GENIUS Act inserts a full chapter on consumer safeguards, ensuring:

  • Clear risk disclosures at the time of purchase or onboarding

  • Complaint resolution mechanisms via regulators and independent dispute channels

  • Strict data privacy policies, especially when stablecoins are integrated into retail wallets

  • Cybersecurity and operational standards for technology systems

This is where GENIUS draws inspiration from the traditional banking world – aiming to protect the “little guy” while building stablecoin infrastructure.

In fact, if executed well, these provisions could finally make stablecoins mainstream enough to be trusted by your mom, your grocery store, or your neighborhood lender.

Stablecoin Use in Prop Trading: What Changes?

For prop trading firms and funded traders who use stablecoins to move capital, hedge, or settle trades, GENIUS could reshape backend operations.

Here’s how:

  • You may only be allowed to use federally registered stablecoins for funding accounts or receiving payouts

  • DeFi-native stablecoins like DAI or algorithmic assets may become non-compliant for U.S. entities

  • KYC/AML protocols around stablecoin movements will become stricter, potentially requiring reporting for large transactions

Bottom line? Prop firms may need to re-architect wallets, funding flows, and liquidity strategies around GENIUS-compliant stablecoins.

But there’s a silver lining: greater clarity also means fewer banking lockouts, more mainstream integrations, and lower counterparty risk.

How GENIUS Affects DeFi and Wallets

Though the bill is aimed at issuers, its ripple effects will hit DeFi protocols and wallet providers too.

DeFi protocols might:

  • Get blacklisted if they rely on non-compliant stablecoins

  • Face regulatory enforcement if their stablecoin integrations violate GENIUS provisions

  • Be forced to integrate KYC in order to stay compliant with registered stablecoin providers

Wallet providers (like MetaMask, Coinbase Wallet, or Phantom) may:

  • Need to flag or delist non-compliant stablecoins

  • Add risk disclosures and redemption instructions for users

  • Be held liable for user loss if a wallet misrepresents a stablecoin’s backing

The result? A “compliance layer” may emerge between stablecoins and the DeFi tools built on top of them.

Impact on Foreign Issuers and Offshore Firms

GENIUS doesn’t stop at U.S. shores.

Any foreign firm issuing or promoting stablecoins to U.S. customers will need to:

  • Register with U.S. regulators

  • Appoint a compliance officer within the U.S.

  • Follow all transparency and reserve requirements

This means even offshore exchanges or wallets that integrate stablecoins must take GENIUS seriously – or risk getting blocked, fined, or delisted.

It also means stablecoin markets might bifurcate into:

  • GENIUS-compliant stablecoins (usable in the U.S. and by prop firms)

  • Offshore stablecoins (limited to non-U.S. use, likely higher risk)

For firms with global user bases, the smart move is to begin building GENIUS compliance into their product stack now.

Stablecoin Listing on Exchanges: GENIUS Guidelines

GENIUS indirectly pressures centralized exchanges like Coinbase, Kraken, and Binance.US to:

  • Delist non-compliant stablecoins

  • Provide clear disclosures about each coin’s registration and reserve status

  • Integrate automated redemption pathways into wallets and trading terminals

Expect exchanges to launch GENIUS-compliant labels, just like they did for MiCA-compliant tokens in Europe.

For traders, this could reduce fragmentation and make it easier to filter trusted stablecoins from risky ones.

Will Algorithmic Stablecoins Be Banned?

Short answer? Practically, yes.

GENIUS requires:

  • Full reserve backing with liquid, dollar-denominated assets

  • No reliance on algorithms or secondary tokens to maintain price peg

That bans Terra-like models or entirely crypto-collateralized systems that do not hold reserves in the real economy. 

While it does not literally make these models criminal, it makes sure they can never be legal tender in the U.S., can never be listed on a compliant exchange, and cannot be used with regulated firms.

This kills off a lot of the speculative perception, but it may also hinder some innovative alternative finance.

GENIUS vs. MiCA: The U.S.–EU Stablecoin Divide

Europe’s MiCA law created rules for “e-money tokens” and “asset-referenced tokens,” demanding:

  • Licensing from EU regulators

  • Strict reserve rules

  • Business conduct standards

GENIUS is similar in spirit but narrower:

  • Applies only to USD-pegged stablecoins

  • Grants primary oversight to the Federal Reserve

  • Imposes redemption rights more explicitly

In a way, MiCA is broader, covering more token types. But GENIUS is more surgical – targeting USD coins with extreme precision.

If both succeed, we may see a duopoly emerge: U.S.-compliant vs. EU-compliant stablecoins, with firms needing to support both models.

GENIUS and the Federal Reserve’s Role

One of the most surprising twists of GENIUS is how much power it gives the Fed.

Under the bill:

  • The Fed must approve registrations for state-chartered issuers

  • The Fed can examine operations, issue guidance, and even revoke approval

  • The Fed plays a role in monitoring reserve compliance and disclosures

This positions the Federal Reserve not just as a monetary policy authority, but a de facto digital dollar watchdog.

Some critics argue this blurs the line between central banking and financial regulation. Supporters say it’s necessary to ensure consistency, especially as stablecoins begin to touch payment rails.

How GENIUS May Influence CBDC Development

GENIUS is seen by some as a precursor or alternative to a U.S. CBDC (Central Bank Digital Currency).

Here’s why:

  • It creates a network of private stablecoins, fully backed and Fed-approved

  • It gives regulators control without requiring direct issuance from the Fed

  • It allows innovation while retaining guardrails

Rather than launching a CBDC, the U.S. might let regulated stablecoins act as proxies – achieving many of the same policy goals (financial inclusion, cross-border payments, digital finance adoption) without needing a full government-run coin.

That’s the genius of GENIUS.

How GENIUS May Affect Crypto Wallet KYC

With tighter rules around issuance, redemption, and exchange use, GENIUS will likely push KYC deeper into wallets.

  • Non-custodial wallets might need to add KYC when connecting to regulated stablecoin providers

  • Wallets may require identity checks for redemption access

  • APIs could emerge to link wallet addresses to compliance registries

This creates friction but also builds the bridge to institutional adoption, where verified digital wallets could replace traditional bank accounts.

What Happens to Non-Compliant Stablecoins?

GENIUS doesn’t send them to crypto jail, but it excludes them from regulated finance:

  • They can’t be listed on exchanges

  • They can’t be used in U.S. financial products

  • They can’t be used by registered firms or wallets

Over time, these coins may:

  • Move offshore

  • Lose liquidity

  • Be forced to rebrand as experimental or speculative assets

This is similar to what happened with non-SEC compliant ICOs – still around, but pushed into the shadows.

Enforcement: What Happens If Firms Don’t Comply?

GENIUS has teeth.

  • Heavy civil penalties for unregistered issuance (up to millions in fines)

  • Criminal charges for fraudulent misrepresentation of reserves

  • Authority for regulators to freeze redemptions or shut down operations

This isn’t just a set of recommendations – it’s enforceable law. Prop firms, wallet providers, and exchanges would be smart to build legal teams now.

Timeline: When Will the GENIUS Act Go Live?

The bill is currently in the 2025 legislative cycle, with bipartisan backing. If passed, GENIUS allows:

  • 2 years for issuers to comply

  • 6 months for regulators to create rules

This means the earliest full implementation could be late 2027, though parts (like registration or disclosures) may go live sooner.

For now, it’s not law – but it’s one of the most developed stablecoin proposals to date. And if you operate in crypto, you need to be preparing for it.

Final Thoughts: GENIUS Act’s Place in the Future of Finance

The GENIUS Act marks a turning point. For the first time, the U.S. isn’t just reacting to stablecoins – it’s shaping their future.

By tightening oversight, guaranteeing redemptions, and building trust, GENIUS opens the door to:

  • Stablecoins being used in payroll, remittance, and lending

  • Banks and fintechs integrating stablecoins into their apps

  • DeFi evolving into “ReFi” – Regulated Finance

Sure, some parts of the crypto world may feel boxed in. But for those who play by the rules, GENIUS offers legitimacy, access, and long-term survival.

This bill might just be the first real foundation for a digital-dollar economy.

Stay ahead. Stay informed. And if you’re a firm building with stablecoins, now’s the time to get GENIUS-ready.

Frequently Asked Questions (FAQs)

1. What is the GENIUS Act and why was it passed?

The GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) is the first federal legislation, passed in July 2025, to regulate payment stablecoins. It came on the heels of significant use of stablecoins and multiple crises, like the TerraUSD collapse, where major deficiencies in reserve transparency, regulatory clarity, and consumer protection were made plainly visible.

2. When will the GENIUS Act be fully implemented?

The GENIUS Act was signed into law on July 18, 2025. Although federal agencies have up to 180 days (early in 2026) to issue final rules, existing issuers will get a 3-year transition period, spending until July 2028 to become fully compliant.

3. Who is allowed to issue stablecoins under the GENIUS Act?

Only entities that are financially strong and have a compliance infrastructure can issue regulated stablecoins, specifically:

  • Federally insured banks or credit unions

  • OCC-approved nonbank payment stablecoin issuers

  • State-regulated firms certified by the new Stablecoin Certification Review Committee

4. What are the reserve requirements under the GENIUS Act?

Stablecoins must be backed 1:1 with high-quality liquid assets such as U.S. dollars, Treasury bills, or insured demand deposits. Reserves must be segregated, not leveraged or lent, and disclosed monthly. Issuers above $50 billion in circulation require annual independent audits.

5. Does the GENIUS Act ban algorithmic stablecoins?

Not directly. But it makes their use in regulated markets extremely difficult by requiring full dollar-backed reserves and banning endogenous collateral. A Treasury-led risk review on algorithmic stablecoins is also mandated within a year.

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