The Senate Banking Committee approved the GENIUS Act on March 13, 2025 by an 18-6 vote, advancing a federal framework whose domicile rules will determine which non-US stablecoin issuers can keep serving American customers.

Senator Bill Hagerty (R-TN) and Senator Kirsten Gillibrand (D-NY) reintroduced the bill in January 2025. PYMNTS.com framed the development as turning stablecoin domicile into "a high-stakes regulatory bet" for foreign issuers.

What does the bill require of issuers?

The Act defines a "payment stablecoin" as a digital asset used for payment or settlement and pegged to a fixed value. It bars yield-bearing features on those tokens.

Issuers must hold reserves in cash, short-dated Treasuries, or central-bank deposits, with monthly attestations and an annual audit. Reserve assets backing US-issued tokens must sit in US institutions, segregated from operational accounts.

Federal oversight falls to the Office of the Comptroller of the Currency for any issuer with more than $10 billion in outstanding tokens. State regulators supervise smaller issuers under the same reserve rules.

How does the domicile rule work?

Under Section 4, only issuers domiciled in the United States—or in a foreign jurisdiction that the Treasury Department deems to operate an "equivalent" regulatory regime—can issue payment stablecoins to US persons. Treasury has 180 days from enactment to publish the list of approved foreign jurisdictions.

The bill does not specify a consultation mechanism with foreign supervisors before that list is finalized, a gap that has drawn public criticism from the European Central Bank and the Bank for International Settlements.

What changes for the largest issuers?

Circle, already incorporated in the United States, faces no relocation pressure. Tether's USDT supply exceeded $115 billion across multiple chains by late 2024 per issuer attestations and chain analytics, the largest exposure to the domicile rule among foreign issuers.

USDT still settles more daily transaction volume on Ethereum and Tron than any other stablecoin, concentrating the operational impact on issuers running from outside the United States. A single Treasury determination against Tether's home jurisdiction could remove its tokens from US-facing exchanges overnight.

What enforcement window sits ahead?

The House Financial Services Committee is preparing to mark up the STABLE Act, which carries different licensing and domicile language. Conference negotiations will determine the binding text.

The Senate floor vote has been held in reserve pending alignment with the House package, with banking lobbyists tracking three outstanding items: the Treasury consultation process, the OCC threshold, and the audit cadence for sub-$10 billion issuers.

For foreign issuers, the practical clock starts on enactment day. The Treasury determination window opens immediately, and customer-facing consequences follow once the approved jurisdiction list is published—closing a path that, under current rules, remains open to any issuer regardless of home.