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Jurisdiction · Awaiting implementation

United States

A federal licensing regime for payment stablecoin issuers is law, but every implementing rule was still at the proposed stage when the statute's own rulemaking deadline passed, and the companion market-structure bill has yet to reach a Senate floor vote.

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Regime
GENIUS Act (S.1582, 119th Congress) + CLARITY Act (H.R.3633, pending)
Status
Enacted (July 18, 2025); implementing rulemaking at proposed-rule stage, no final rules as of July 25, 2026
Scope
Payment stablecoins (GENIUS); broader digital asset market structure incl. tokenized assets (CLARITY, pending)

The state of play

The GENIUS Act creates a federal licensing regime for payment stablecoin issuers, with 1:1 high-quality liquid reserves, monthly reserve attestations, redemption rights and parallel federal and state approval pathways. Every implementing rulemaking remained at the proposed stage as the statute's July 18, 2026 rulemaking deadline passed: Treasury has issued an advance notice (September 18, 2025) and proposals on certification of state regimes (April 1, 2026) and illicit finance (April 8, 2026); the OCC proposed its issuer framework on February 25, 2026; the FDIC proposed licensing rules on December 16, 2025 and capital and liquidity rules on April 7, 2026; the NCUA proposed rules on February 11 and May 18, 2026; and FinCEN proposed customer identification requirements on June 18, 2026. The companion CLARITY Act market-structure bill passed the House in 2025 and cleared the Senate Banking Committee 15-9 on May 14, 2026, but a floor vote was still unscheduled in late July 2026. Separately, the OCC conditionally approved five national trust bank charters for digital-asset firms on December 12, 2025, and SEC staff issued a joint statement on tokenized securities on January 28, 2026 confirming that tokenization does not change the securities-law character of an instrument.

Frameworks

FrameworkStatusDateNote
Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act, Public Law 119-27)Enacted 18 July 2025Federal regime for payment stablecoin issuers: 1:1 reserves in cash, short-dated Treasuries and repo, monthly attestations, par redemption, no interest payments to holders, dual federal/state pathways with a $10bn state-regime threshold.
Treasury advance notice of proposed rulemaking on GENIUS Act implementationProposed 18 September 2025Sought comment on the scope of the payment stablecoin definition, foreign issuer comparability and reserve composition ahead of formal proposals.
FDIC notice of proposed rulemaking on stablecoin issuer applicationsProposed 16 December 2025Application and approval procedures for FDIC-supervised subsidiaries seeking to issue payment stablecoins.
NCUA notices of proposed rulemaking on credit union stablecoin issuanceProposed 11 February 2026First proposal February 11, 2026; a second NCUA proposal followed on May 18, 2026. Neither was finalised as of July 2026.
OCC notice of proposed rulemaking for federally qualified payment stablecoin issuersProposed 25 February 2026Application, supervision and capital expectations for national banks and federal branches issuing payment stablecoins.
Treasury notice of proposed rulemaking on certification of state stablecoin regimesProposed 1 April 2026Process by which state regimes are certified as substantially similar to the federal framework.
Treasury notice of proposed rulemaking on illicit finance and AML for stablecoin issuersProposed 8 April 2026Sanctions compliance, blocking and lawful-order capability requirements for permitted payment stablecoin issuers.
FDIC notice of proposed rulemaking on capital, liquidity and risk management for stablecoin issuersProposed 7 April 2026Prudential standards for FDIC-supervised issuing subsidiaries.
FinCEN notice of proposed rulemaking on customer identification programs for stablecoin issuersProposed 18 June 2026Would extend CIP obligations to permitted payment stablecoin issuers.
Digital Asset Market Clarity Act (CLARITY Act, H.R.3633)Pending 14 May 2026Passed the House in 2025; approved by the Senate Banking Committee 15-9 on May 14, 2026 and placed on the Senate Legislative Calendar (No. 423). Revised committee text circulated June 1, 2026; floor consideration unscheduled as of late July 2026.
SEC Division of Corporation Finance and Division of Trading and Markets staff statement on tokenized securitiesGuidance 28 January 2026Confirms that a tokenized security remains a security and that distribution, custody and settlement obligations follow the underlying instrument.
OCC conditional approvals of national trust bank charters for digital-asset firmsIn force 12 December 2025Five conditional approvals: First National Digital Currency Bank (Circle), Ripple National Trust Bank, BitGo Bank and Trust, Fidelity Digital Assets and Paxos Trust Company. Circle received final OCC approval on July 10, 2026.
NYDFS virtual currency regime (BitLicense, 23 NYCRR Part 200) and stablecoin guidanceIn force 8 June 2022State-level licensing and reserve/attestation guidance for USD-backed stablecoins issued from New York.

Products issued under this regime

  • USDC (Circle)
  • USDT (Tether)
  • PYUSD (Paxos for PayPal)
  • RLUSD (Ripple)
  • USAT (Tether US-regulated token issued by Anchorage Digital Bank, launched January 27, 2026, with Cantor Fitzgerald as reserve custodian)
  • BUIDL (BlackRock USD Institutional Digital Liquidity Fund, on Securitize)
  • BENJI (Franklin Templeton OnChain U.S. Government Money Fund)
  • JPMD (JPMorgan deposit token)

Market participants

On the record

Every development we have evidenced under United States, newest first.

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Third Circuit holds federal commodities law preempts state gaming law for sports event contracts

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Regulatory United States US Court of Appeals for the Third Circuit: KalshiEX LLC v. Flaherty, No. 25-1922 ↗

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Regulatory United States Equities Federal Register: Order Approving a Proposed Rule Change To Enable the Trading of Securities on the Exchange in Tokenized Form (Release 34-105047) ↗

OCC proposes rules implementing the GENIUS Act

The Office of the Comptroller of the Currency published a proposed rule implementing the GENIUS Act, codifying most requirements in a new 12 CFR Part 15 and amending Parts 3, 6, 8 and 19. The proposal covers permitted activities, reserve assets, redemption, risk management, audits, reports and supervision for permitted payment stablecoin issuers, and applies to national banks, federal savings associations, federal branches and agencies, foreign issuers and non-bank applicants for federal issuer approval.

Regulatory United States Stablecoins OCC Bulletin 2026-3: GENIUS Act: Notice of Proposed Rulemaking ↗

SEC staff grant no-action relief for DTC's tokenization service

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Regulatory United States Equities US Securities and Exchange Commission: no-action letter to The Depository Trust Company ↗

US Treasury opens GENIUS Act implementation rulemaking

The Department of the Treasury issued an advance notice of proposed rulemaking on implementing the GENIUS Act, with comments due by 20 October 2025. It sought input on issuance, reserve and marketing rules for stablecoin issuers and service providers, illicit finance controls, the treatment of foreign payment stablecoin issuers, taxation, insurance and cost and benefit estimates.

Regulatory United States Stablecoins Federal Register: GENIUS Act Implementation (Department of the Treasury) ↗

BNY and Goldman Sachs launch mirrored tokenization of money market fund shares

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Circle prices initial public offering ahead of New York Stock Exchange listing

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Market United States Stablecoins Circle: Circle Announces Pricing of Upsized Initial Public Offering ↗

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Regulatory United States Office of the Comptroller of the Currency: News Release 2025-42 ↗

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Regulatory United States Other asset classes US Securities and Exchange Commission, Release No. 34-100224 ↗

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Product launch United States Tokenized funds BlackRock and Securitize press release (Business Wire) ↗

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Regulatory United States Other asset classes US Securities and Exchange Commission, Statement on the Approval of Spot Bitcoin Exchange-Traded Products ↗

SEC charges Terraform Labs and Do Kwon over the collapse of TerraUSD

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Regulatory United States Stablecoins US Securities and Exchange Commission press release 2023-32 ↗

US President's Working Group recommends stablecoin legislation

The President's Working Group on Financial Markets, with the FDIC and the OCC, recommended that Congress require stablecoin issuers to be insured depository institutions, subject custodial wallet providers to federal oversight, limit issuers' affiliation with commercial entities and promote interoperability between stablecoins. Treasury Secretary Janet Yellen said existing oversight was inconsistent and fragmented, and agencies committed to acting within current authority while legislation was pending.

Research United States Stablecoins US Department of the Treasury: President's Working Group on Financial Markets releases report and recommendations on stablecoins ↗

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