GENIUS Act Rules Could Reshape Foreign Stablecoin Access

The Blockchain Association has asked the US Treasury to clarify how the GENIUS Act will apply to digital asset service providers, foreign-issued stablecoins and yield arrangements. In a November 4, 2025 letter, it urged Treasury to keep definitions narrow and tied to the statute, distinguishing customer-facing financial businesses from self-custody software and validators. It also said liability for knowingly facilitating unlawful stablecoin issuance should require actual knowledge and meaningful assistance, and that foreign-stablecoin obligations should rely on information platforms can reasonably access. The Association called for clearer compliance paths for smaller issuers and new entrants. The GENIUS Act sets two timelines for foreign stablecoins: conditions on platforms offering or selling foreign-issued payment stablecoins apply from the Act’s effective date, while a broader restriction on stablecoins from non-permitted issuers is scheduled for July 18, 2028. The effective date could come sooner than 18 months after enactment if primary federal regulators issue final rules, with the Act taking effect 120 days later. The rules could affect a stablecoin market valued at about $301.5 billion on October 20, 2026; USDT represented roughly 60.7%, according to DefiLlama. These are industry recommendations, not adopted rules. Treasury and other agencies’ decisions could shape platform compliance, DeFi infrastructure and access to foreign stablecoins, leaving uncertainty for traders and settlement markets.