Stablecoin

Stablecoin issuance has skyrocketed—from $62 billion in 2021 to approaching $250 billion today. Designed to frictionlessly move digital equivalents of fiat currencies on blockchain technology, 99% of stablecoins are currently denominated in US dollars. With the recent passage of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, the United States joins the EU, UK, and other jurisdictions in crafting regulations to promote and manage an anticipated seismic wave of stablecoin growth—pushing vast potential opportunities forward. Our digital asset team stands ready to help clients capitalize on the potential benefits of this technology while navigating emerging risks and global regulatory regimes.

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Genius Act

Implementation Timeline

July 18, 2025
Genius Act signed
Major legislation defining the rules for issuing payment stablecoins to persons in the United States. Each primary federal payment stablecoin regulator, the secretary of the Treasury, and each state payment stablecoin regulator are required to promulgate regulations to carry out the Act through appropriate notice and comment rulemaking within one year of enactment. 1582, § 13(a), 119th Cong. (2025).

More Information
Major legislation defining the rules for issuing payment stablecoins to persons in the United States. Each primary federal payment stablecoin regulator, the secretary of the Treasury, and each state payment stablecoin regulator are required to promulgate regulations to carry out the Act through appropriate notice and comment rulemaking within one year of enactment. 1582, § 13(a), 119th Cong. (2025).

More Information
September 19, 2025

Treasury requested comment on innovative strategies on BSA/AML and GENIUS Act Implementation

Advanced notice of proposed rulemaking seeking broad public input on Treasury’s implementation of the GENIUS Act, including regulatory clarity, BSA/AML and sanctions, state-federal oversight, foreign comparability, and related issues. (Comments closed November 4, 2025)

Advanced notice of proposed rulemaking seeking broad public input on Treasury’s implementation of the GENIUS Act, including regulatory clarity, BSA/AML and sanctions, state-federal oversight, foreign comparability, and related issues. (Comments closed November 4, 2025)
December 19, 2025

FDIC proposed rulemaking to establish GENIUS Act application procedures

For more information, view the Notice of Proposed Rulemaking to Establish GENIUS Act Application Procedures for FDIC-Supervised Institutions Seeking to Issue Payment Stablecoins | FDIC

Proposed rule establishing application procedures for FDIC-supervised institutions seeking approval to issue payment stablecoins through a subsidiary. (Comments closed February 17, 2026)

For more information, view the Notice of Proposed Rulemaking to Establish GENIUS Act Application Procedures for FDIC-Supervised Institutions Seeking to Issue Payment Stablecoins | FDIC

Proposed rule establishing application procedures for FDIC-supervised institutions seeking approval to issue payment stablecoins through a subsidiary. (Comments closed February 17, 2026)
February 12, 2026

NCUA proposed rulemaking for PPSI applications

For more information, view NCUA Proposes Rule for Permitted Payment Stablecoin Issuer Applications | NCUA

Proposed rule covering the payment stablecoin licensing framework and investment rules for federally insured credit unions. (Comments closed April 13, 2026)

For more information, view NCUA Proposes Rule for Permitted Payment Stablecoin Issuer Applications | NCUA

Proposed rule covering the payment stablecoin licensing framework and investment rules for federally insured credit unions. (Comments closed April 13, 2026)
March 2, 2026

OCC proposed rulemaking to implement GENIUS Act

For more information, view GENIUS Act Regulations: Notice of Proposed Rulemaking | OCC

Proposed rule providing a comprehensive framework for all payment stablecoin issuers under OCC jurisdiction, including subsidiaries of national banks, uninsured national trust banks, branches of foreign banks, large state issuers, and non-bank issuers. (Comments will close May 1, 2026)*

For more information, view GENIUS Act Regulations: Notice of Proposed Rulemaking | OCC

Proposed rule providing a comprehensive framework for all payment stablecoin issuers under OCC jurisdiction, including subsidiaries of national banks, uninsured national trust banks, branches of foreign banks, large state issuers, and non-bank issuers. (Comments will close May 1, 2026)*
March 9, 2026

Treasury published report to Congress on innovative BSA/AML proposals

For more information, view the Report to Congress from The Secretary Of The Treasury on Innovative Technologies to Counter Illicit Finance Involving Digital Asset

For more information, view the Report to Congress from The Secretary Of The Treasury on Innovative Technologies to Counter Illicit Finance Involving Digital Asset
April 3, 2026

Treasury Proposed Genius Act Broad-Based Principles

For Determining Whether a State-Level Regulatory Regime Is Substantially Similar to the Federal Regulatory Framework

Proposed rule defining the principles Treasury would use to determine whether a state’s stablecoin regime is substantially similar to the federal framework, as required by the GENIUS Act. (Comments will close June 2, 2026)*

Proposed rule defining the principles Treasury would use to determine whether a state’s stablecoin regime is substantially similar to the federal framework, as required by the GENIUS Act. (Comments will close June 2, 2026)*
April 10, 2026

FDIC Proposed Genius Act Requirements and Standards

For FDIC-Supervised Permitted Payment Stablecoin Issuers and Insured Depository Institutions

Proposed rule providing prudential standards for FDIC-supervised payment stablecoin issuers, including reserve, redemption, capital, risk-management, deposit-insurance, and tokenized-deposit issues. (Comments will close June 9, 2026)*

Proposed rule providing prudential standards for FDIC-supervised payment stablecoin issuers, including reserve, redemption, capital, risk-management, deposit-insurance, and tokenized-deposit issues. (Comments will close June 9, 2026)*
April 10, 2026

Treasury (FinCEN and OFAC) Proposed PPSI Requirements

For the Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program

Joint proposed rule establishing the GENIUS Act AML/CFT and sanctions compliance framework for permitted payment stablecoin issuers. (Comments will close June 9, 2026)*

Joint proposed rule establishing the GENIUS Act AML/CFT and sanctions compliance framework for permitted payment stablecoin issuers. (Comments will close June 9, 2026)*
July 2026

Regulations to be finalized

Required not later than one year after the date of enactment of the Act, each primary federal payment stablecoin regulator, the secretary of the Treasury, and each state payment stablecoin regulator shall promulgate regulations to carry out this Act. S. 1582, § 13(a), 119th Cong. (2025).

Required not later than one year after the date of enactment of the Act, each primary federal payment stablecoin regulator, the secretary of the Treasury, and each state payment stablecoin regulator shall promulgate regulations to carry out this Act. S. 1582, § 13(a), 119th Cong. (2025).
January 18, 2027
(no later than)

Expected Effective Date

Payment stablecoins may be issued only by PPSIs pursuant to the Act

The Act and its amendments will take effect on the earlier of two dates: (1) 18 months after enactment or (2) 120 days after the primary federal payment stablecoin regulators issue any final regulations implementing the Act. S. 1582, § 20, 119th Cong. (2025).

The Act and its amendments will take effect on the earlier of two dates: (1) 18 months after enactment or (2) 120 days after the primary federal payment stablecoin regulators issue any final regulations implementing the Act. S. 1582, § 20, 119th Cong. (2025).
July 2028
Restrictions Take Effect

For Custodians and other Digital Asset Service Providers
Custodians and other digital asset service providers can sell or deal only in payment stablecoins issued by PPSIs
- Three years after enactment, it will be unlawful for a digital asset service provider to offer or sell a payment stablecoin to a person in the United States unless the payment stablecoin is issued by a permitted payment stablecoin issuer. S. 1582, § 3(b)(1), 119th Cong. (2025).
FinCEN issues guidance and rulemaking on innovative AML
- Within three years of enactment, the Financial Crimes Enforcement Network shall issue public guidance and notice-and-comment rulemaking based on required research and risk assessments under Section 9(d). S. 1582, § 9(d), 119th Cong. (2025).
Federal regulators submit report to Congress on insolvency proceedings
- Within three years of enactment, primary federal payment stablecoin regulators shall submit to Congress a report containing findings on potential insolvency proceedings of permitted payment stablecoin issuers, including any legislative recommendations. S. 1582, § 11(h)(2), 119th Cong. (2025).
Custodians and other digital asset service providers can sell or deal only in payment stablecoins issued by PPSIs
- Three years after enactment, it will be unlawful for a digital asset service provider to offer or sell a payment stablecoin to a person in the United States unless the payment stablecoin is issued by a permitted payment stablecoin issuer. S. 1582, § 3(b)(1), 119th Cong. (2025).
FinCEN issues guidance and rulemaking on innovative AML
- Within three years of enactment, the Financial Crimes Enforcement Network shall issue public guidance and notice-and-comment rulemaking based on required research and risk assessments under Section 9(d). S. 1582, § 9(d), 119th Cong. (2025).
Federal regulators submit report to Congress on insolvency proceedings
- Within three years of enactment, primary federal payment stablecoin regulators shall submit to Congress a report containing findings on potential insolvency proceedings of permitted payment stablecoin issuers, including any legislative recommendations. S. 1582, § 11(h)(2), 119th Cong. (2025).

Potential Benefits & Use Cases

With stablecoins, businesses and consumers can transact in dollars at the speed of light. Transactions may become cheaper and faster, with less counterparty and foreign exchange risk. Stablecoins offer a host of potential benefits including:

Cross-border payments and remittances
Faster settlement
Cheaper transactions
Operational and compliance efficiencies
Financial inclusion
Decentralization
Smart contract integration
Hedging against inflation
Ease of integration
Blockchain ecosystem growth

How We Can Help

Our lawyers are well versed on the US GENIUS Act and similar regulations in the EU, UK, and other jurisdictions and have deep experience helping companies across the digital asset arena. We understand the significant opportunities for our clients—both digital asset natives and new entrants.

Issuers

Our experience includes working closely with stablecoin issuers for nearly a decade. With US regulatory clarity now an imminent reality, the number of issuers globally will continue to soar. Incumbents and new entrants will face heightened competition, which in turn will drive further innovation and bespoke solutions. Global commerce requires a global law firm. Our team helps issuers to seize opportunities while seamlessly managing regulatory complexities worldwide. We assist clients with:

Navigating evolving regulation across agencies and geographies
Establishing new entities and attaining regulatory authorization where required
Managing custody arrangements

Innovators

Technological innovation drives the digital asset industry. Crypto wallets and exchanges (centralized and decentralized) have pushed the industry forward, and payment abstraction solutions and other advancements will continue to catalyze growth and global stablecoin adoption. We guide innovators in this space through the shifting regulatory landscape as financial services infrastructure continues to transition to the digital age. We help innovator clients with:

Regulatory compliance
Data privacy
Intellectual property issues
Mergers and acquisitions
Tax considerations
Competition law issues

Adopters

Stablecoins are the most widely held use case for digital assets today and may offer significant benefits for business-to-business cross-border transactions and remittances—allowing users to transact in their preferred currency with near-instant settlement and reduced costs and counterparty risk. As use grows rapidly and infrastructure advances, stablecoins supported by blockchain may become a payment option for potentially every consumer globally. Our lawyers help businesses around the world to consider how they can incorporate stablecoins into their operations while navigating the applicable regulatory, tax, and legal issues.

Insights

Our perspectives on the evolving developments in stablecoins.