Stablecoin

¹ 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 not later than 1 year after the date of enactment of the Act. S. 1582, § 13(a), 119th Cong. (2025).

² 30 days after the date of enactment, and for a period of 60 days thereafter, the Secretary of the Treasury shall seek public comment to identify innovative or novel methods, techniques, or strategies that regulated financial institutions use, or have the potential to use, to detect illicit activity, such as money laundering, involving digital assets. S. 1582, § 9(a), 119th Cong. (2025).

³ The Secretary of the Treasury is required to submit a report on non-payment stablecoins within 180 days after the enactment of the Act. S. 1582, § 9(e)(1), 119th Cong. (2025).

⁴ Not later than 1 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).

⁵ The Act and its amendments will take effect on the earlier of two dates: 18 months after the date of enactment of the Act, or 120 days after the primary Federal payment stablecoin regulators issue any final regulations implementing the Act. S. 1582, § 20, 119th Cong. (2025).

⁶ 3 years after the date of enactment of the Act, it shall 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).

⁷ Not later than 3 years after the date of enactment of the Act, the Financial Crimes Enforcement Network shall issue public guidance and notice and comment rulemaking, based on the results of the research and risk assessments required under Section 9(d). S. 1582, § 9(d), 119th Cong. (2025).

⁸ Not later than 3 years after the date of enactment of the Act, the primary Federal payment stablecoin regulators shall submit to Congress a report that contains all findings of the study of the potential insolvency proceedings of permitted payment stablecoin issuers, including any legislative recommendations. S. 1582, § 11(h)(2), 119th Cong. (2025).

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

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.

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If you have any questions or need assistance, please reach out to any of the lawyers pictured below or your regular Morgan Lewis contact.