The GENIUS Act requires regulators to issue detailed rules that clarify which stablecoin issuers can legally operate within the United States by July 18, 2026. This deadline marks the end of a one-year rulemaking period during which the Treasury, the Office of the Comptroller of the Currency (OCC), and state regulators must transform the law into a formal framework for stablecoin access and compliance.
At the heart of the GENIUS Act is the definition of “permitted payment stablecoin issuers.” Only these entities will be allowed to issue payment stablecoins legally, while others—including foreign or state-qualified issuers—must meet specific criteria to qualify. The law prohibits unauthorized issuers from operating in the U.S., making issuer status the key determinant of market access.
The Act establishes separate but interrelated oversight for various categories of issuers. The OCC’s recent proposal covers national bank subsidiaries, federal savings association subsidiaries, foreign payment stablecoin issuers, and nonbank entities seeking federal qualification, as well as state-qualified issuers under OCC supervision. This proposal addresses application and registration processes, supervisory responsibilities, reserve requirements, redemption protocols, custody safeguards, revocation procedures, and capital adequacy standards under a unified regulatory framework.
Compliance with anti-money-laundering (AML) and sanctions laws is a critical component. The Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) have proposed applying Bank Secrecy Act (BSA) standards to permitted issuers. The OCC followed suit with its own proposal outlining AML and counter-terrorism financing (CFT) supervisory processes, including information sharing to support enforcement or supervisory actions.
Until regulators issue final guidance, questions remain around how equivalency with state regulations and foreign registration will be handled for applicants. Additionally, the GENIUS Act’s effective date depends on whether it takes effect 18 months after its enactment or 120 days after the implementing rules are finalized—whichever occurs first. Importantly, this timeline applies strictly to rulemaking and does not impose an immediate market cutoff for existing users or issuers.