The United States moved from the most fragmented stablecoin perimeter in the G7 to the most legislated within 18 months. The GENIUS Act in 2025 fixed the federal perimeter for permitted payment stablecoin issuers, the CLARITY Act in late 2025 split market-structure jurisdiction between the SEC and CFTC, and the OCC's interpretive-letter pipeline reopened national-bank custody and stablecoin reserve activity. The regime is simultaneously the deepest in dollar liquidity and the most balkanised across agencies, but the dollar gravity makes it the perimeter every other jurisdiction designs against.
Regulatory posture
Stablecoin policy under GENIUS authorises three issuer routes: subsidiaries of insured depository institutions, federally qualified non-bank issuers supervised by the OCC, and state-qualified issuers below a $10bn outstanding-issuance threshold. Reserves are restricted to cash, short-dated Treasuries, and repo, holder interest is prohibited, and monthly attestation is the minimum cadence. The NYDFS limited-purpose trust charter survives alongside GENIUS, and the first federally qualified issuers entered the perimeter through 2025 and early 2026. Tokenised deposit work runs through bank-led pilots (led by Kinexys, the JPM stack, formerly Onyx) with no Fed-operated bridge layer.
Market structure sits with the SEC and CFTC under CLARITY: secondary trading of digital-asset commodities goes to the CFTC, while tokenised securities, ATS (alternative trading system)-traded instruments, and transfer-agent obligations remain with the SEC. The wrapper still separates a tokenised fund interest from a payment stablecoin via investment-company status. Retail CBDC has been effectively foreclosed by GENIUS.
Regulators
Each agency carries a dedicated page; the one-line remits:
- SEC. Tokenised securities, tokenised funds, ATS rules, and transfer-agent obligations; SAB 122 (January 2025) unblocked bank custody, and BUIDL is the approved-fund worked example.
- CFTC. Digital-asset commodity trading post-CLARITY, plus tokenised-collateral guidance for derivatives venues.
- OCC. Bank-money-on-chain via the interpretive-letter sequence, the trust-bank chartering programme, and non-bank issuer supervision under GENIUS.
- Federal Reserve. Master account access, bank digital-asset supervision, and FedNow; as of April 2026 no OCC trust-charter holder has been granted a master account on the charter alone.
- FDIC, FinCEN, US Treasury. Deposit insurance, the Bank Secrecy Act (BSA) and Travel Rule perimeter, and GENIUS framework ownership plus sanctions via the Office of Foreign Assets Control (OFAC) respectively.
- NYDFS and Wyoming Division of Banking. The state layer: BitLicense and the limited-purpose trust charter in New York, and Wyoming's Special Purpose Depository Institution (SPDI) charter, with the Custodia litigation as the master-account precedent.
Open questions
- How GENIUS preemption interacts with the surviving NYDFS trust route for issuers below the $10bn threshold.
- Whether the Federal Reserve opens master account access to digital-asset-native charter holders, the gate on which the Augustus model and the Custodia precedent both turn.
- Whether GENIUS programmability and freeze powers leave room for AI agents holding payment stablecoins under delegated authority.
Related
- SEC, CFTC, OCC, Federal Reserve for the federal regulatory institutions.
- GENIUS Act, CLARITY Act, OCC trust bank charter, SAB 121 / SAB 122 for the US regulations.
- Stablecoin types, Tokenisation, defined for the framework comparisons and UCC Article 12 plumbing.
- hong kong and japan for the two-agency split and trust-issuance contrasts.