What is the GENIUS Act?

What the law requires

• Only a permitted payment stablecoin issuer may issue a payment stablecoin in the U.S., under section 3 of the law.
• Issuers must back coins 100% with liquid assets and publish the reserve mix every month, per the White House fact sheet of July 18, 2025.
• Issuers may not pay holders any form of interest or yield for holding, using or keeping the coin, under section 4(a)(11).
• Stablecoin holders get priority over other creditors if an issuer becomes insolvent, per the fact sheet.
• Issuers fall under the Bank Secrecy Act, must run sanctions compliance programs and must be able to seize, freeze or burn coins when the law requires, per the fact sheet.
• Issuers may not claim a stablecoin is backed by the U.S. government, federally insured or legal tender, per the fact sheet.

Federal or state oversight

Section 4(c) offers a state regime to a state qualified issuer with consolidated outstanding issuance of not more than $10 billion.

The OCC covers uninsured national banks, subsidiaries of insured national banks, federal branches, registered foreign issuers and some nonbank issuers, per WilmerHale's Oct. 27, 2026 summary of the OCC rule.

Key dates

1. July 18, 2025: the President signed S. 1582 into law.
2. Oct. 21, 2026: the OCC issued its final rule for the issuers it supervises, with standards for reserve backing, redemption and risk management. Bank Secrecy Act, anti money laundering and sanctions rules will come in a separate rulemaking with Treasury, per OCC news release 2026-92.
3. Jan. 18, 2027: the Act and the OCC rule take effect. Section 20 sets the effective date as the earlier of 18 months after enactment or 120 days after final regulations. WilmerHale notes that issuance after that date must comply.
4. July 18, 2028: section 3(b) bars digital asset service providers from offering or selling non-permitted payment stablecoins to U.S. persons from 3 years after enactment.

What it means for a crypto company

• Exchanges and wallets that list stablecoins need to know which issuers will be permitted before the July 2028 deadline in section 3(b).
• The yield ban in section 4(a)(11) applies to issuers. The Senate's amended CLARITY Act would also ban passive stablecoin yield paid by third party platforms, per The Block on June 19, 2026. As of Oct. 28, 2026, that bill was not law.
• A company that wants to issue its own payment stablecoin in the U.S. must become a permitted payment stablecoin issuer, under section 3.

Sources

1. Public Law 119-27, GENIUS Act · U.S. Government Publishing Office, July 18, 2025Supports: Statute text for permitted issuers, the yield ban, the $10 billion state option, the 3 year service provider deadline and the effective date.
2. Fact Sheet: President Donald J. Trump Signs GENIUS Act into Law · The White House, July 18, 2025Supports: Signing date and the reserve, disclosure, insolvency, marketing and sanctions requirements.
3. OCC Advances U.S. Digital Asset Leadership with Final Rule to Implement GENIUS Act · Office of the Comptroller of the Currency, Oct. 21, 2026Supports: The OCC final rule, its scope, and the Jan. 18, 2027 effective date of the rule and the Act.
4. OCC Finalizes GENIUS Act Rule for Permitted Payment Stablecoin Issuers · WilmerHale, Oct. 27, 2026Supports: Which issuers the OCC supervises and that issuance after Jan. 18, 2027 must comply.
5. What Is the CLARITY Act? The Crypto Market Structure Bill Explained · The Block, June 19, 2026Supports: The amended CLARITY Act's ban on passive stablecoin yield by issuers and third party platforms.

Related questions

• What is the CLARITY Act?
• Which banks work with crypto companies?
• What is a VASP?

General information, not legal advice.

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