On July 18, President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (GENIUS Act), the nation’s first major crypto law. This success is a testament to the leadership of the White House and Senator Bill Hagerty, and proof that Washington is finally serious about modernizing the financial system.

The bill erects a clear, first‑of‑its‑kind framework for stablecoins, recognizing the power of dollar‑pegged tokens to make transactions faster and cheaper, and their importance for global dollar dominance. Issuers can now choose between federal or state supervision and get straightforward guardrails on reserves, redemption, audits, and more.

But what matters most isn’t just the bill signing; it's what happens next. GENIUS gives regulators just one year to implement its provisions, and the clock is already ticking.

The next 100 days are pivotal. New OCC chief Jonathan Gould must release joint proposed rules with the other banking agencies, coordinate with state regulators overseeing smaller stablecoin issuers, and prepare for a surge of applications from both new and existing issuers.

Handled well, this rollout will cement American leadership in next‑gen payments; stumble or get mired in governmental infighting, and we risk surrendering the field. And with the U.S. moving with speed and clarity, it won’t just gain a competitive edge – it will help establish the global infrastructure crypto needs to grow, giving builders everywhere a reliable foundation for innovation.

Federal and State Alignment

GENIUS empowers stablecoin issuers to choose between federal or state oversight depending on the value of their tokens in circulation. Issuers with tokens under a $10 billion market cap can opt to be regulated by states, provided that the Stablecoin Certification Review Committee, a new body chaired by the Treasury Secretary, deems the state regime “substantially similar” to the federal framework. Once a state-regulated stablecoin surpasses $10 billion, its issuer must transition to federal oversight unless granted a waiver.

Crypto-native issuers are already applying for federal charters, and the OCC could soon face a backlog, especially given that a quarter of its staff is expected to depart by year end. This alone is a daunting task for the OCC. To avoid delays, the Treasury Department must quickly set the “broad-based principles” GENIUS requires for determining when a state regime is sufficient.

States will also need to align their standards with new requirements under GENIUS, several of which touch on hot button issues that could drive or hinder stablecoin adoption. For example, they’ll need to comply with rules on token-native yield, while protecting popular rewards programs.

Banks will lobby hard against these programs because they often offer better returns than traditional bank deposits. Regulators will have to hold firm against bank arguments that ultimately hurt consumers.

To succeed, federal and state regulators must:

• Develop clear waiver standards for state-regulated issuers exceeding $10 billion;
• Engage in comprehensive information sharing; and
• Align regulatory and supervisory expectations on rewards programs, capital, wind-down plans, and examinations.

Global Coordination

Payment stablecoins are global products designed for fungibility and unrestricted movement across borders. But to ensure their successful implementation without undue burden on issuers, they require coordinated efforts between the United States and foreign governments.

Under GENIUS, the Treasury Department has the power to authorize foreign-registered entities to issue payment stablecoins in the United States so long as those foreign regimes are “comparable” to domestic standards. To do so, the Treasury Secretary must consult with the Stablecoin Certification Review Committee.

To avoid regulatory arbitrage, it’s critical that there are clear, public rules defining how foreign regulatory regimes are assessed. Core standards around reserves and attestations should be identical. Rulemaking must also clarify how issuers can support a single, fully fungible stablecoin that is issued both from the U.S. and foreign jurisdictions.

Specifically, Treasury should:

• Develop clear, rigorous rules for foreign issuers requesting to issue stablecoins within the U.S; and
• Explore reciprocal arrangements with foreign countries for cross-border, fully fungible stablecoins.

Enforcement

GENIUS is explicit: only federally or state-authorized issuers may issue payment stablecoins in the United States.

Enforcement authority spans across Treasury, the OCC, other federal regulators, and the states. Regulators can take action against issuers in violation of the requirements, revoke their authorizations, or subject them to civil or criminal penalties, depending on the type of violation. Treasury, in particular, can impose civil monetary penalties on digital asset service providers using noncompliant foreign issuers.

In order to ensure that enforcement is fair and just, regulators must:

• Have the DOJ establish processes for accepting criminal referrals on unauthorized issuance;
• Revise banking examination and enforcement procedures under GENIUS; and
• Define Treasury’s process for designating noncompliant foreign issuers and enforcing violations by digital asset service providers.

White House Support

Leadership from Crypto & AI Czar David Sacks and White House Crypto Council Executive Director Bo Hines will be a force multiplier in the GENIUS rollout. Active White House involvement will be needed to address interagency squabbles and coordination of resources. Sacks and Hines played an instrumental role in getting GENIUS across the finish line, and now they must keep regulators focused, timelines tight, and innovation top of mind.

Outside of rulemaking, the White House can also monitor whether federal regulators are faithfully implementing the Trump administration’s policy of ensuring that fair access to banking services extends to stablecoin issuers. The Fed has a years-long record of treating crypto firms unfairly and has previously made it nearly impossible for nonbank stablecoin issuers in particular to obtain direct access to Fed services.

With GENIUS passed, the Fed’s discrimination against crypto needs to end. The Fed must now establish even-handed standards for granting master account and payment system access to new classes of stablecoin issuers. If necessary, the White House must use its authority over the Fed’s bank regulatory functions to ensure that it does.

The White House should prioritize:

• Recruiting qualified talent at the OCC to support its rulemaking;
• Coordination between the OCC, Fed, FDIC, and other agencies that need to participate in the rulemaking process; and
• Ensuring that the Fed ceases disproportionate treatment of crypto companies, and clarifying the standards for stablecoin issuer master account access.

Conclusion

The passage of the GENIUS Act is not the finish line. It’s the starting gun. The global race for stablecoin leadership is already underway. If the US government acts decisively in the next 100 days, it can anchor a secure, transparent, and innovation-friendly stablecoin ecosystem, catapulting America ahead of the rest of the world in this transformational upgrade to its financial infrastructure.