The US Treasury Department has recently taken a substantive step towards implementing the Guidance and Establishing a National Innovation for Stablecoins Act (GENIUS Act). The Treasury officially issued an Advance Notice of Proposed Rulemaking (ANPRM), broadly soliciting opinions from the industry, investors, and the public. This move indicates that the future compliance framework for stablecoins in the United States is gradually taking shape.
This consultation covers almost all core aspects of the stablecoin ecosystem: including issuer eligibility criteria, reserve disclosure standards, cross-border circulation arrangements, anti-money laundering requirements, marketing restrictions, and tax gaps. The Treasury hopes to use the feedback as a reference and foundation for formal regulations. According to EY survey data, once the GENIUS Act is fully implemented, the adoption rate of stablecoins is expected to increase rapidly, with cross-border transaction volume potentially reaching $4 trillion. Already, 13% of businesses have begun using stablecoins for cross-border payments, and over half of the businesses not currently using them anticipate adopting them within the next year.
Addressing the core question of "who can issue stablecoins in the US," the GENIUS Act clearly states that only licensed Payment Stablecoin Issuers (PPSI) are eligible. The Treasury also raised questions about whether additional definitions and safe harbor provisions are needed, aiming to balance innovation and risk. Against this backdrop, Tether, the issuer of the world's largest stablecoin USDT, has garnered significant attention. In the future, Tether must either strictly comply with the new regulations, exit the US market, or launch new compliant products. In fact, Tether has already announced plans to issue USAT, a compliant stablecoin targeting the US market, to proactively address the challenge.
The GENIUS Act also sets conditions for foreign issuers, allowing them to provide services in the US only if their home country's regulatory framework is deemed compatible with that of the US. The Treasury is currently seeking input to determine which jurisdictions meet the requirements and to understand potential frictions arising from differences in cross-border regulatory systems.
Reserve asset transparency is another key regulatory focus. The Act requires issuers to disclose reserve details monthly, including composition, maturity timelines, custody locations, and liquidity arrangements. However, regulators are still considering whether further clarification on reserve custody standards is necessary. Furthermore, the GENIUS Act possesses certain extraterritorial reach, requiring foreign institutions providing stablecoin services to US users to also comply with relevant standards. This has sparked broad discussion regarding international regulatory coordination and sanction mechanisms.
However, gaps remain in the bill's tax treatment, as it does not clearly define payment stablecoins within the federal tax system, leaving room for interpretation by the Internal Revenue Service (IRS). Meanwhile, the controversy over "interest payments" is particularly intense. The Act prohibits issuers from directly paying interest but does not restrict exchanges or other service providers from attracting users through "rewards." This clause has raised concerns in the banking industry, which fears that crypto exchanges might leverage this to compete with traditional deposit-taking businesses.
It can be said that the GENIUS Act has entered a critical pre-implementation phase, and its final direction will profoundly impact the stablecoin landscape in the US and even globally. From compliance thresholds to cross-border arrangements, and from reserve transparency to tax definitions, every aspect is undergoing public scrutiny. The stablecoin industry is facing a major "test" that concerns its future destiny.
