Yesterday, the U.S. Department of the Treasury released the proposed rules for implementing the GENIUS Act.
Many are only focusing on “stablecoin regulation finally落地,” but what truly matters is that the U.S. is now beginning to decide who will be allowed to issue U.S. dollar-backed stablecoins—and who will be shut out. (U.S. Department of the Treasury)
After the GENIUS Act passed last year, two critical questions remained unresolved:
What does it mean to “issue” a stablecoin in the United States?
What does it mean to “offer or sell” to persons in the United States?
These seemingly dry legal definitions actually determine the lifeline of the entire market.
Who needs a license?
Who can keep selling?
Which stablecoins will be delisted from exchanges?
All of these questions ultimately hinge on these two definitions.
Now, with the Treasury’s release of proposed rules and the opening of a public comment period, stablecoin regulation has moved from “written into law” to “how to enforce.” (U.S. Department of the Treasury)
The timeline is also clear:
Starting January 18, 2027, payment stablecoins issued in the United States must hold a federal or state license.
Starting July 18, 2028, exchanges and service providers may only offer stablecoins to U.S. users if those stablecoins are issued by compliant issuers.
In other words, the industry’s true shakeout may not begin now—but will unfold gradually over the next 18 months.
Within this regulatory restructuring, winners and losers are becoming increasingly clear.
USDC is likely the biggest beneficiary.
It is domestically issued, has mature regulatory relationships, and a well-established compliance framework.
What was once seen as costly compliance overhead may soon become its greatest moat.
The stricter the rules, the higher the barriers to entry for newcomers—and Circle’s advantages become even more pronounced.
The greatest pressure may fall on USDT.
The GENIUS Act’s compliance requirements for foreign issuers directly target the biggest weakness of offshore stablecoins: how to prove sustained adherence to U.S. regulatory standards.
Tether’s longstanding issues around reserve transparency and regulatory relationships will now come under renewed scrutiny under the new rules.
Exchanges cannot remain unaffected either.
The 2028 deadline means that future decisions on “which stablecoins to support” will no longer be purely business choices—but potentially compliance mandates.
Two developments to watch closely:
First, during the 60-day comment period, how will the U.S. Treasury define “persons in the United States”?
Will it rely on user location?
KYC information?
Or transaction behavior?
The breadth of this definition will directly determine the scope of regulatory impact.
Second, will Tether accelerate efforts to establish a compliant U.S.-based presence?
If USDT wishes to remain part of the U.S. market, this may be its most critical next move.
The real regulatory showdown in the stablecoin war may have only just begun.
