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stablecoins
One Step Forward, Two Steps Back? Stablecoins and the Global Dollar System
Since the Second World War, the U.S. dollar has been the dominant global currency for trade, settlement, and reserve purposes. As other countries seek to move away from the dollar system, key U.S. policymakers believe that the rise of dollar …
RoughriderCoin and the Limitations of Stablecoins in Public Banking
The GENIUS Act, enacted in July 2025, provides a federal regulatory framework for stablecoin issuers, including a carveout that, under certain conditions, allows states to oversee issuers of less than $10 billion. After the law went into effect, the …
Davis Polk Discusses SEC’s Application of Securities Laws to Crypto
The SEC has issued a much-anticipated interpretation regarding when the federal securities laws apply to certain types of crypto assets and transactions. It is an important step forward, but reflecting the difficulty in drawing clear lines, critical uncertainties persist. Most …
Simpson Thacher Discusses OCC’s First Comprehensive Federal Rulemaking for Stablecoin Issuers
On February 25, 2026, the Office of the Comptroller of the Currency (the “OCC”) issued a proposal to implement significant portions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act, known as the GENIUS Act (the “Act”), which …
SEC Clarifies the Application of Federal Securities Laws to Crypto Assets
The Securities and Exchange Commission (SEC) on March 17 issued an interpretation clarifying how the federal securities laws apply to certain crypto assets and transactions involving crypto assets. This is a major step in the Commission’s efforts to provide greater …
Closing the Stablecoin Yield Loophole in the Post-GENIUS Era
The enactment of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act established the nation’s first federal prudential framework for “payment stablecoins,” mandating 1:1 reserve backing and explicitly prohibiting issuers from paying interest.[1] This legislative bargain was …
Sidley Discusses the State of Play in Banking and Digital Assets
The environment has never been more favorable for existing banking organizations launching a digital asset business and those Fintech and other nonbank companies considering acquiring or chartering a full-service or limited-purpose bank in order to operate a digital asset business. …
Circle, Coinbase, and the Prohibition on Interest Under the GENIUS Act
The Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act”) establishes the first comprehensive federal framework for “payment stablecoins” in the United States. The bill’s most discussed, and debated, provision is Section 4(a)(11), which provides:
No …
Latham & Watkins Discusses the Road Ahead for Fintech Rulemaking
Key Points:
- The FDIC plans to propose an application process for stablecoin issuance by FDIC-regulated institutions by the end of 2025, and is also collaborating with other banking regulators to develop broader prudential standards for all stablecoin issuers as required
Sidley Discusses “Project Crypto” and the Next Phase of Digital Asset Oversight
On November 12, 2025, SEC Chairman Paul Atkins delivered remarks (the November Remarks) revisiting his announcement of “ Project Crypto,” the Commission-wide initiative launched earlier this year to promote blockchain innovation in U.S. financial markets. Chairman Atkins laid …
Latham & Watkins Discusses Treasury Request for Public Input on GENIUS Act Implementation
On September 19, 2025, the US Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking (ANPRM), seeking public comment related to its implementation of the Guiding and Establishing National Innovation for US Stablecoins Act (the GENIUS Act), …
The GENIUS Act and North Dakota’s Roughrider Coin: State Stablecoins and the Risk of Digital Fragmentation
The Intersection of Cryptocurrency Regulation and Foreign Policy Is Testing Conflict-of-Interest Rules
The convergence of emerging financial technologies and traditional diplomatic relations has created novel challenges for legal frameworks governing digital asset regulation and conflicts of interest in government. Recent developments involving the Trump administration, United Arab Emirates (UAE) investment entities, and …
The GENIUS Act and State-Issued Stablecoins Raise Important Issues of Federalism
The enactment of the GENIUS Act of 2025 marks a watershed moment in American cryptocurrency regulation, establishing the first comprehensive federal framework for payment stablecoins.[1] Yet within this law lies a provision that may fundamentally reshape the balance between …
Skadden Discusses the Trump Administration’s Comprehensive Report on Digital Assets
Executive Summary
- What is new: The Trump administration’s Working Group on Digital Asset Markets released a comprehensive report outlining some 100 policy and legislative recommendations to position the U.S. as a global leader in digital assets and blockchain innovation.
- Why
Cleary Gottlieb Discusses Federal Stablecoin Regulatory Framework
On July 18, 2025, President Trump signed into law the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUSAct” or the “Act”), a first-of-its kind bill that establishes a comprehensive federal regulatory framework …
The CLARITY Act’s Unfinished Business
After nearly two decades of regulatory uncertainty, digital assets stand at a critical juncture in American financial law. On July 18, 2025, President Trump signed the “Guiding and Establishing National Innovation for US Stablecoins Act,” known as the GENIUS Act, …
Shadow SEC Statement No. 6: The Not-So-GENIUS Act
On June 17, 2025, the Senate passed the GENIUS Act, shorthand for the Guiding and Establishing National Innovation for U.S. Stablecoins Act, by a bipartisan vote of 68-30, with 18 Democratic Senators supporting the Bill. The GENIUS Act would amend …
The GENIUS Act: Countering Criticisms and Charting a Path for Stablecoins
Stablecoins have emerged as a central pillar of the digital asset ecosystem, offering a bridge between traditional fiat currencies and decentralized finance. The GENIUS Act, a stablecoin regulation proposal, is advancing with bipartisan support through the U.S. Senate.[1] Given …