Next Steps for GENIUS Payment Stablecoins

Core Thesis

The GENIUS Act (enacted July 2025, PL 119-27) establishes the first federal framework for payment stablecoins, but four implementation issues remain unresolved and will determine whether stablecoins become trusted payment instruments or stay confined to crypto trading: (1) interest payments, (2) maintaining the singleness/par of money, (3) illicit-finance prevention, (4) operational resilience.

Key Claims

• USD stablecoin supply grew to ~$280B at year-end 2025 from ~$25B in 2020. Evidence: moderate
• Treasury Secretary Bessent projected stablecoins could reach $3 trillion by 2030. Evidence: weak (official projection)
• EY survey: only 13% of firms currently use stablecoins, but >50% of non-users expect to adopt within 6–12 months.
• EY estimate: stablecoins could be 5–10% of cross-border payments by 2030 ($2.1–4.2T).

Regulatory Requirements (GENIUS)

• 1:1 reserve backing; permissible assets: US coin/currency, T-bills ≤93 days, uninsured bank deposits, repo.
• Subject to Bank Secrecy Act AML/CFT; FinCEN to issue rules within 3 years.
• Issuers must disclose redemption policy and offer timely redemption; periodic exams for operational continuity.
• OCC conditionally granted national trust bank charters to Circle, Paxos + 3 others (Dec 2025).

Entities

• Authors/regulators framing: Brookings (Liang, Dudley); OCC, Federal Reserve, Treasury, FDIC, FinCEN.
• Issuers named: Circle, Paxos, Coinbase, PayPal, JPMorgan Chase, BNY, Tether (largest, ~6 arbitrageurs/month redeeming).

Source: Next Steps for GENIUS Payment Stablecoins — Liang & Dudley, Brookings, 2026-03-03. Full-text fetched.