The decisive month
A law is truly measured when it turns into regulations, and that moment has arrived. The GENIUS Act, signed on 18 July 2025, established the first comprehensive U.S. federal framework for payment stablecoins, and instructed several agencies to issue the regulations that make it operational. According to the tracker by the law firm Chapman and Cutler, most of those rules must be published within one year of enactment, and the law takes effect 120 days after the final rules or, at the latest, on 18 January 2027. With the main comment periods closed on 9 June 2026, the agencies faced a final stretch of a few weeks to reconcile their frameworks before 18 July.
What the law creates
The design is restrictive by construction. The law prohibits anyone other than a permitted payment stablecoin issuer (PPSI) from issuing one of these coins in the United States, and opens three paths: subsidiaries of insured banks, federally licensed OCC issuers and state-qualified issuers. The OCC’s proposal limits reserves to short-duration liquid assets — Treasury bills and bonds with a remaining maturity of 93 days or less, among others — prohibits paying interest or yield to holders, and imposes redemption and capital-adequacy requirements. The text itself clarifies that a compliant stablecoin is considered neither a security nor a commodity, which places it outside the SEC’s primary jurisdiction.
The anti-money-laundering and sanctions twist
Here is the component of greatest interest to a compliance tracker. On 8 April 2026, the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) jointly proposed treating permitted issuers as “financial institutions” under the Bank Secrecy Act, requiring them to maintain anti-money-laundering programs and, for the first time explicitly, a sanctions-compliance program. Among the questions the regulator left open are whether to extend those obligations to foreign issuers and whether to broaden the definition of “account” to include wallet addresses for the purposes of lawful orders. Treasury Secretary Scott Bessent framed the proposal as a way to protect the financial system without slowing U.S. companies in the sector.
The market at stake
The regulation arrives over a market that grew, in large part, outside the banking perimeter. The sector is around 230 billion dollars in outstanding stablecoins, dominated by Tether (USDT) and Circle (USDC). Analysts anticipate pressure on foreign issuers after 18 July — Tether says it is ready to comply, but no offshore issuer has yet filed a formal application under the new rules — and a dilemma for investors between zero-yield regulated coins and decentralized-finance platforms offering between 5 and 8 percent outside the system. The Brookings Institution further warned that rapid growth of these coins could accelerate the outflow of bank deposits and poses operational risks for meeting redemptions around the clock.
The resonance for the region
The matter is not foreign to Latin America, where stablecoins function as a way to access the dollar outside currency controls. In high-inflation countries, USDT is used to save and transfer value, so the rules that define which issuer can operate legally in the United States — and with what reserves and what sanctions obligations — end up shaping the everyday financial tool of millions of people outside that country.
Two readings
The file admits, as almost everything in this field, two narratives. For the administration and the industry, the law brings regulatory clarity, reinforces U.S. leadership in digital payments and anchors stablecoins to the dollar and to Treasury debt. For part of the analysts and the banking sector, the regime leaves open questions: the risk of deposit flight, the yield arbitrage that pushes users toward unregulated platforms, and the doubt over how far the anti-money-laundering obligations will reach the foreign issuers that today concentrate the market. Worth, finally, the basic reminder: what is on the table are proposed rules, not final ones, and the only certainty is the calendar, not yet its final content.