GENIUS Act: What the New Federal Stablecoin Framework Means for Users and Issuers

GENIUS Act: What the New Federal Stablecoin Framework Means for Users and Issuers

December 6, 2025 posted by Tamara Nijburg

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GENIUS Act Reserve Requirements

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The GENIUS Act is the first time the U.S. government has laid down clear, binding rules for stablecoins - digital tokens meant to act like cash, backed one-to-one by U.S. dollars or other safe assets. Signed into law on July 18, 2025, this isn’t just another regulatory footnote. It’s a full rewrite of how stablecoins can operate in America. If you’re using or issuing a stablecoin, this law changes everything - and it starts affecting you on January 18, 2027.

Who Can Issue Stablecoins Now?

Before the GENIUS Act, anyone with a website and a bank account could launch a stablecoin. That’s over. Now, only specific financial institutions are allowed to issue payment stablecoins. That means banks, credit unions, and certain nonbank financial firms that get approval from the Federal Reserve. No more anonymous startups, no more offshore entities hiding behind smart contracts. If you want to issue a stablecoin in the U.S., you need a banking license or a special federal nod.

This isn’t about stopping innovation. It’s about stopping risk. Remember when some stablecoins lost their peg in 2022? The GENIUS Act makes sure that can’t happen again - by limiting who can even get in the game.

Reserves Are No Longer a Guess

One of the biggest fears about stablecoins has always been: Are they really backed? The GENIUS Act answers that with a hard rule: every stablecoin in circulation must be backed 1:1 by real assets. And those assets can’t be just anything.

Issuers must hold reserves in:

  • Physical U.S. cash
  • U.S. Treasury bills
  • Repurchase agreements (repos) backed by Treasuries
  • Other low-risk assets approved by regulators

That’s it. No corporate bonds. No crypto. No commercial paper. No risky investments. Just the safest, most liquid assets the U.S. financial system offers. And they have to prove it - every quarter. Issuers must submit detailed reserve reports and get audited by certified public accounting firms. No more vague claims. No more “we’re fully backed” without proof.

Anti-Money Laundering Is Now Mandatory

Stablecoins were once seen as a way to move money quietly. Not anymore. The GENIUS Act forces issuers to follow the Bank Secrecy Act - the same rules banks have to follow to fight money laundering and terrorist financing.

That means:

  • Know Your Customer (KYC) checks on every user
  • Monitoring transactions for suspicious patterns
  • Reporting large or unusual transfers to FinCEN

It’s not just about compliance - it’s about trust. If people can’t be sure stablecoins aren’t being used for crime, adoption will stall. This law makes that impossible.

A transparent digital wallet containing only U.S. cash and Treasury bills, symbolizing regulated stablecoin backing.

What Issuers Can’t Do

The GENIUS Act doesn’t just set rules - it draws hard lines. Issuers are only allowed to do three things:

  • Issue and redeem stablecoins
  • Manage the reserve assets
  • Provide custody services for stablecoins or private keys

That’s it. No lending. No investing. No using your reserves to fund other projects. No rehypothecation - except for one narrow exception. Issuers can use Treasury bill reserves as collateral in short-term repurchase agreements, but only if they’re cleared through approved central counterparties or get prior regulator approval. This keeps the system liquid without risking the backing of the stablecoin.

And here’s a big one: reserves must be kept separate from the issuer’s own money. No commingling. Ever. If the issuer goes bankrupt, your stablecoin isn’t part of the bankruptcy estate. Your money stays protected.

Custody Rules: Who Holds Your Keys?

If you’re using a wallet that holds your private keys, the GENIUS Act says the company managing those keys must be regulated. That means only banks, credit unions, or federally approved custodians can hold your stablecoins or private keys. No more random crypto exchanges or unlicensed platforms.

But here’s the twist: if you’re using a hardware wallet or a self-custody app - like MetaMask or Ledger - the law doesn’t touch you. The act specifically excludes software or hardware providers that help you manage your own keys. That’s a win for users who want control without giving up security.

The Stablecoin Certification Review Committee

One of the most powerful parts of the law is the Stablecoin Certification Review Committee (SCRC). It’s chaired by the Treasury Secretary and includes the Federal Reserve Chair and the FDIC Chair. This committee doesn’t just oversee federal rules - it can decide whether a state’s stablecoin rules are “substantially similar” to the federal standard.

Why does that matter? Because before the GENIUS Act, states like Wyoming and New York had their own rules. Some were stricter, some looser. Now, if a state’s rules aren’t close enough to the federal standard, the SCRC can effectively block stablecoin issuers from operating there - unless they comply with federal rules. This is meant to prevent a patchwork of conflicting laws.

But will it work? Experts are divided. Some states may resist federal control. Others may see it as a chance to attract business by aligning with national standards. The real test comes in 2027, when the first state-level stablecoin issuer tries to operate under its own rules.

A balanced scale with U.S. reserves and a stablecoin, overseen by a regulatory committee under federal authority.

Why This Matters for the U.S. Dollar

The White House called the GENIUS Act a move to “strengthen the U.S. dollar’s reserve currency status.” That sounds like jargon, but it’s critical. Right now, China, the EU, and even Saudi Arabia are testing digital currencies. If the U.S. doesn’t lead in digital money, the dollar could lose ground.

The GENIUS Act says: we’re not banning stablecoins - we’re owning them. By making U.S.-backed stablecoins the safest, most transparent option in the world, the U.S. can dominate global payments. Imagine a foreign business paying for goods in a U.S. dollar stablecoin - backed by Treasuries, audited daily, regulated by the Fed. That’s more trustworthy than a crypto-backed stablecoin from an unknown issuer.

This isn’t just about finance. It’s about power. The country that controls the digital dollar controls the future of global trade.

What Happens After January 18, 2027?

The law gives issuers 18 months to comply - or 120 days after final regulations are published, whichever comes first. That’s enough time to build systems, hire compliance teams, and get approved. But it’s not a free pass. The clock starts ticking the day the law was signed. Issuers who waited until the last minute are already behind.

By mid-2027, you’ll see a big shift. Unregulated stablecoins will vanish from major exchanges. Wallets will stop supporting them. Banks will only integrate compliant ones. If you’re holding a stablecoin that’s not on the approved list, you’ll have to move it - or risk losing access.

For users, this means more safety. For issuers, it means more cost. But for the system as a whole, it means stability.

What This Means for You

If you’re a regular user: your stablecoins will be safer. You’ll know exactly what backs them. You’ll know who’s holding your keys. You won’t wake up to a 30% drop because the issuer took a gamble.

If you’re a business using stablecoins for payments: you’ll have legal certainty. You can now treat them like electronic cash, not a gamble.

If you’re a developer or startup: the door is still open - but only if you play by the rules. You can build wallets, payment tools, and DeFi apps - but you can’t issue stablecoins unless you’re a regulated financial institution.

The GENIUS Act doesn’t kill innovation. It channels it. It turns a wild west into a regulated marketplace - and that’s exactly what’s needed for mass adoption.