在稳定币时代引领合规

Implications of the GENIUS Act Stefano BoezioJordan Cole INTRODUCTION The passage of the GENIUS Act marks a pivotal moment for stablecoins in the United States,opening the market to a diverse array of institutions, including banks, technology firms,crypto-native entities, and new market entrants. The establishment of a federal frameworkfor stablecoins also brings significant compliance and risk management implications. Thesepresent both challenges and opportunities for institutions planning to engage in stablecoinissuance and related services. To meet GENIUS Act requirements, institutions need a roadmap so that they can adapttheir existing risk and compliance frameworks. This process begins with the strategicalignment of stablecoin offerings with organizational goals. Next, market players canassess the regulatory landscape and market dynamics and define their risk appetitethrough scenario-based risk assessments. Then, they can critically evaluate and enhancetheir compliance infrastructures. This paper begins by placing stablecoins in the evolving payment landscape and exploringmarket entry options. It then examines the novel and complex risks introduced by stablecoinsand how these translate into specific requirements and expectations for market participants.The work needed to adapt and update an institution’s risk and compliance framework willdepend significantly on its starting position: there will likely be important differences betweenfinancial institutions — already subject to regulation — and new market entrants. Lastly, wesuggest a series of steps for adapting existing frameworks to the challenges and requirementsposed by stablecoins. 1. THE NEW REGULATION After years of false starts and delays, the United States has established its first federal-levelframework for stablecoins through the passing of the GENIUS Act (Guiding and EstablishingNational Innovation for US Stablecoins). The act itself does not contain groundbreakingrules and guidelines compared to recent regulation and guidance in other parts of the world(such as the EU, Singapore, and the United Arab Emirates) and in states (such as New York).Moreover, the Clarity Act to establish a comprehensive market structure framework fordigital assets was still in Congress as of early August 2025. Still, the act represents a large step towards embracing digital assets and a significant winfor the crypto industry. It provides institutions in the United States with a basic regulatoryframework with which to approach businesses related to stablecoins. Now, they will needto decide how to enter the market and then develop detailed plans to manage complianceand risks. The GENIUS Act permits the issuance of dollar-denominated stablecoins, requiringthat licensed stablecoin issuers back these on at least a one-to-one basis. Issuersmust hold reserves in specified high-quality reserves assets, explicitly excluding othercryptocurrencies, and they are not permitted to pay yield or interest to stablecoin holders.The act provides a framework for the federal government to license and regulate issuers,but it also allows states to regulate institutions that issue up to $10 billion of stablecoins,provided the state’s regulatory framework is substantially similar to the federal one. Institutions will have a variety of options to participate in the stablecoin market, includingfacilitating transactions for existing stablecoins, providing access to another firm’sstablecoin, joining an issuing consortium, and issuing their own stablecoin. Each optionwill in turn present various choices: An institution can choose to issue a new stablecoineither by developing the underlying technology and managing the end-to-end operationsor by white-labeling a product from an existing provider. These choices will lead todifferent compliance obligations and risk exposures, and institutions will need to tailortheir compliance frameworks to these. A diverse range of institutions will seek licenses to issue stablecoins in the US, includingbanks, consortia, and payment service providers. Existing regulated financial institutions arewell-positioned to lead. Another natural fit will be crypto-native firms — including existingstablecoin issuers — that may already be regulated by states or other jurisdictions. Newplayers — such as technology companies, asset managers, and retailers — may also beattracted by the potential opportunities. 2. ENTERING THE MARKET With the passing of the GENIUS Act, a raft of firms will look to enter the stablecoin market,due to stablecoins’ potential to make transactions faster and cheaper. We envision fourmain options. FACILITATE OR ACCEPT TRANSACTIONS USING STABLECOINS Stablecoins will represent a new payment method, disrupting services such as paymentapps and card transactions. Market participants will need to choose which stablecoinsto support. They will also need to ensure their services are compliant and that theyfacilitate interoperability. OFFER THIRD