Stablecoin issuer / redeemer in United States

Under the GENIUS Act (P.L. 119-27) only a permitted payment stablecoin issuer may issue a payment stablecoin in the United States (§3(a)). A permitted issuer must be formed in the United States and be a subsidiary of an insured depository institution approved by its federal banking agency (or by the NCUA for credit unions), a Federal qualified issuer approved by the OCC (including nonbanks), or a State qualified issuer regulated by a state (§§2(23), 2(25)).

Under GENIUS Act §4(c) (P.L. 119-27), a State qualified payment stablecoin issuer with not more than USD 10 billion outstanding may opt for a state regime that is substantially similar to the federal framework; the state regulator certifies this to the Stablecoin Certification Review Committee (Treasury Secretary as chair; the Federal Reserve Chair or Vice Chair for Supervision and the FDIC Chair as members) and recertifies annually. An issuer that exceeds USD 10 billion must transition to federal oversight within 360 days or stop issuing new stablecoins, unless its federal regulator grants a waiver (§4(d)). Treasury proposed the substantial-similarity principles on 3 April 2026 (91 FR 16844) and adopted interim SCRC procedures effective 30 September 2026 (91 FR 61688).

Pre-GENIUS, states like New York DFS required a BitLicense for stablecoin activities.

The GENIUS Act (P.L. 119-27, S. 1582), signed 18 July 2025, is the federal payment stablecoin law. Section 13 required implementing regulations within one year (by 18 July 2026); that deadline passed with only one final rule, Treasury's procedural interim final rule for the Stablecoin Certification Review Committee (30 September 2026). Under section 20 the Act takes effect on the earlier of 18 January 2027 or 120 days after the primary federal regulators issue final implementing regulations.

On 3 April 2026 Treasury proposed rules under GENIUS Act §4(c) setting broad-based principles for deciding whether a state payment stablecoin regime is substantially similar to the federal framework, the test that lets state qualified issuers with no more than USD 10 billion outstanding stay under state regulation (91 FR 16844; comments closed 2 June 2026). The rule is still proposed.

Pre-GENIUS state rules: NYDFS Guidance (2022) on reserves, attestations, redemption.

FinCEN — Treasury bureau (31 U.S.C. 310) that administers the Bank Secrecy Act: MSB registration on Form 107 within 180 days of establishment and every two years (31 CFR 1022.380), and the funds-transfer recordkeeping and travel rule for transmittals of $3,000 or more (31 CFR 1010.410(e)-(f)).

OCC — charters and supervises national banks and federal savings associations, which may provide crypto-asset custody, certain stablecoin activities and node participation without prior supervisory non-objection (Interpretive Letter 1183, 7 March 2025); conditionally approved five national trust bank charters for digital-asset firms on 12 December 2025; and is the primary federal payment stablecoin regulator for Federal qualified issuers under the GENIUS Act.

SEC — regulates crypto assets that are securities and transactions in them, including broker-dealer and exchange registration under the Exchange Act. Its 17 March 2026 interpretation (Rel. 33-11412, 91 FR 13714) sets a token taxonomy of digital commodities, digital collectibles, digital tools, stablecoins and digital securities, and applies the Howey test to determine when a non-security crypto asset is subject to an investment contract.

OFAC — administers U.S. economic sanctions, which apply to virtual currency transactions; on 15 October 2021 it published 'Sanctions Compliance Guidance for the Virtual Currency Industry'.

DOJ — prosecutes federal crimes involving crypto assets, including money laundering (18 U.S.C. 1956) and operating an unlicensed money transmitting business (18 U.S.C. 1960), as well as fraud and sanctions-evasion offences.

Bank Secrecy Act (Public Law 91-508, 1970; codified at 31 U.S.C. 5311 et seq.) is the federal AML/CFT statute. It requires reports and records useful in criminal, tax and regulatory investigations and requires money transmitting businesses to register with Treasury (31 U.S.C. 5330), implemented by FinCEN Form 107 within 180 days of establishment and renewal every two years (31 CFR 1022.380).

New York BitLicense (23 NYCRR Part 200) (2015) — NY-specific virtual currency business licensing

California DFAL (2025) — Digital Financial Assets Law — state crypto licensing

VASP: FinCEN MSB registration (immediate, Form 107) + state Money Transmitter Licenses in 49 states + DC (18-36 months for full coverage, $2M-$10M+ in bonds/fees). Montana is sole exemption.

Financial Crimes Enforcement Network (FinCEN): administers the Bank Secrecy Act AML/CFT regime. Under FIN-2013-G001 (18 March 2013) an administrator or exchanger of convertible virtual currency is a money transmitter and therefore a money services business; FIN-2019-G001 (9 May 2019) consolidates that guidance and applies it to further CVC business models. Each MSB must register with FinCEN on Form 107 within 180 days of establishment and renew every two years (31 CFR 1022.380).

State regulators: Examples include California's DFPI (Digital Financial Assets Law effective July 1, 2026, requiring licenses with $100k/day penalties); New Jersey Department of Banking and Insurance; New York's NYDFS (BitLicense regime); Connecticut (money transmitter laws).

Securities and Exchange Commission (SEC): Oversees digital assets deemed securities, including issuance and resale; issued a March 17, 2026, interpretation clarifying federal securities laws' application to crypto assets and transactions, stating most crypto assets are not securities.

Evidence fact us.tax not found (may have been renamed).