GENIUS Act Rules: What Treasury, the OCC and the Fed Have Proposed So Far

• The GENIUS Act takes effect on January 18, 2027. One of its main rules is final; the rest are drafts.

• From that day, a stablecoin issued abroad, such as USDT, stays on US platforms only if its issuer can freeze tokens when authorities order it.

• From July 18, 2028, platforms can offer US users only tokens from approved issuers or qualifying foreign ones.

• Self-custody wallets are largely exempt. The provider behind the Buy button is generally covered, so review your token list with it before January.

The Senate passed it in June 2025, the House followed on July 17, and it was signed the next day. It's the first federal law for payment stablecoins, tokens designed to stay at one dollar and be used for payments. The explainer covers what it asks of issuers.

For anyone offering stablecoins to US users, two dates matter:

• January 18, 2027. Stablecoin issuers need approval to issue in the US, and a stablecoin issued abroad can stay on US platforms only if its issuer can freeze or block tokens when authorities order it.

• July 18, 2028. Platforms can offer US users only stablecoins from approved issuers, or from foreign issuers that meet the law's conditions.

The law names January 18, 2027 as its latest start date, so unfinished rules can't delay it. It could only have started earlier if every main federal regulator had finished its rules in time, and they didn't.

So far only the Office of the Comptroller of the Currency (OCC), which supervises national banks, has finished, and its final rule also starts in January. Roadmaps can treat that date as fixed while the other agencies complete their work.

Nearly all of these rules are about the companies that issue stablecoins. One proposal, from Treasury, is about the businesses that sell them to users, and that's the one platforms need to follow.

Treasury's first proposed rule, from April 2026, is one of the issuer rules. It decides when smaller issuers can opt for state supervision. It deals with how issuers get licensed and leaves a platform's token list untouched.

The two platform dates come from the law itself. Treasury's August proposal adds the detail:

• What it defines: what counts as offering or selling a stablecoin to someone in the US.

• Who it covers: businesses that sell or hold crypto for customers. That generally includes exchanges, custodians and on-ramp providers (services that let people buy crypto with a card or bank transfer) serving US users.

• Where it stands: public comments closed on October 19, and there's no date yet for the final version.

The rules fall into four groups, and only one of them is aimed at platforms.

That top row is a proposal for now, and someone on your team should follow it.

Three open questions matter to platforms, and none has a final text or a set date.

• How Treasury will judge foreign countries. After 2028, a stablecoin issued abroad needs Treasury to agree that its issuer's home country regulates stablecoins as strictly as the US. Treasury hasn't said how it will decide.

• The final offer-and-sale rule. It will settle what counts as offering a stablecoin in the US.

• Approvals for US issuers. From January, issuers need approval to issue in the US, but the OCC hasn't started taking applications, so there's no list of approved tokens yet.

Any plan for January relies on drafts for now, so give each open question an owner who updates the plan when a final text is published.

Tether is behind two dollar tokens on different legal routes. USAT, launched in January 2026, is issued in the US through Anchorage Digital Bank and was designed with the law in mind. It's small so far, with about $183 million in circulation in October.

USDT is issued abroad, so its place on US platforms depends on the route the law sets for foreign issuers.

For a year, lawyers disagreed on whether foreign issuers had to comply in January 2027 or had until 2028. The law and Treasury's proposal settle it in stages.

• From January 2027. USDT can stay on US platforms only if Tether can freeze or block tokens on US orders.

• From July 2028. Tether also needs Treasury to accept its home country's rules and has to register with the OCC, among other conditions. No country has that acceptance yet.

That leaves your team two decisions on USDT. Before January, ask your provider whether it meets the freeze condition. For 2028, set your own date to pick a replacement token and tell users, whatever Tether announces.

For a wallet, the law applies to the Buy button and to the product's copy. Tokens held in users' wallets are largely outside it.

The Act leaves out transfers between two people and transactions through a wallet where users hold their own crypto. Keeping and sending tokens there is generally outside the rules on selling and typically needs no product change.

When someone buys USDC in a wallet, the seller in a typical integration is the provider behind the button, the fiat-to-crypto gateway that takes the payment and delivers the coins. That provider is selling a stablecoin to someone in the US, which is what both dates govern.

Whether the wallet also counts as a seller is a legal question for your counsel, because Treasury's proposal counts advertising a stablecoin to US buyers as one way of offering it.

Calling something a payment stablecoin in US marketing when it wasn't issued under the Act is illegal, with fines of up to $500,000 per violation for anyone who does it knowingly and willfully.

Before January, review screens and campaigns that present a foreign-issued token that way, or suggest it has US approval.

Each question is followed by what a complete answer includes.

You ask: How will you handle stablecoins issued abroad in January?

Listen for: the tokens affected and how the provider checked each issuer.

You ask: How much notice do partners get when a token is removed for US users?

Listen for: a number of days, and whether it happens state by state or across the country.

You ask: What happens to users who already hold a token that's removed?

Listen for: buying stops, and users can generally still keep and send the token from their own wallet. Plan a clear in-app message for them.

Each of the three dollar stablecoins US platforms deal with faces the two dates differently, depending on who issues it.

• USDC is issued by Circle, a US company, so its issuer needs approval like any US issuer, and the OCC hasn't opened applications yet.

• USAT is issued in the US by Anchorage Digital Bank for Tether and faces that same approval.

• USDT is issued outside the US. It faces the freeze condition in January and the foreign-issuer conditions by 2028.

For a catalog, that means the two US-issued tokens depend on approvals, while USDT depends on Tether.

All of this can be prepared before the final rules arrive, with one owner per task.

☐ Roadmap. Put both dates in the plan as fixed. Product.

☐ Catalog. Sort every stablecoin you offer to US users by who issues it. Product.

☐ Provider. Get your on-ramp provider's answers on foreign-issued tokens and notice periods. Partnerships.

☐ Copy. Check screens and campaigns that call a token a payment stablecoin or suggest US approval. Marketing and compliance.

☐ Watchlist. Assign someone to the three open questions. Compliance.

Treasury's final offer-and-sale rule and its process for judging foreign countries are still pending. With this list done, your team will have decided what users see at checkout before those rules arrive.

How each date applies depends on your markets and your token list, and Mercuryo's team can walk you through it on a call. The on-ramp for businesses page lists current coverage and the compliance work Mercuryo takes on for partners.

Did the GENIUS Act pass? Yes. It was signed into law on July 18, 2025, after passing the Senate 68-30 and the House 308-122. Mercuryo's GENIUS Act explainer covers what it asks of issuers.

When does the GENIUS Act take effect? On January 18, 2027. A second date, July 18, 2028, limits which stablecoin platforms can offer to US users, so plan for both.

What does the GENIUS Act do? It sets the first federal rules on who can issue payment stablecoins and which ones US platforms can offer. Mercuryo's gateway guide explains the provider's role.

Can US platforms still offer USDT after January 2027? Yes, if Tether can freeze tokens on US orders. From July 2028, it also needs the Treasury to accept its home country's rules. Mercuryo's team can review your token list on a call.