The GENIUS Act turns one year old on July 18, but federal regulators tasked with writing the implementing rules for US stablecoin issuers remain months behind the institutions already building on the framework.

Signed by President Donald Trump on July 18, 2025, the legislation required stablecoin issuers to back tokens one-to-one with cash or other liquid assets and set baseline standards for risk management and financial-crime controls. It left the heavier lifting—capital and liquidity requirements, anti-money-laundering rules, sanctions compliance and customer identification—to the Treasury, Federal Reserve, FDIC and Office of the Comptroller of the Currency.

What enforcement deadline applies?

The law takes effect on the earlier of two dates: January 18, 2027, or 120 days after regulators publish final rules. Three comment windows remain open through the summer.

• OCC comment period on AML and sanctions standards closes July 24.
• FDIC window for bank-secrecy and sanctions standards closes August 4.
• Customer-identification comment window at Treasury and FinCEN closes August 21.

"While the GENIUS Act clarifies much, financial regulators must now write rules," Nellie Liang, a senior fellow at Brookings, said in October.

Which institutions have moved fastest?

The industry waited for neither the statute nor the rulemaking. SoFi opened SoFiUSD to nearly 15 million customers in May, the first stablecoin issued by a US national bank to reach a banking platform. MoneyGram followed in June with MGUSD, a token built to move dollars across its global payments network.

Mastercard began clearing settlement in USDC and SoFiUSD on its network. Visa and Mastercard are among more than 140 companies backing Open USD, a consortium stablecoin designed to integrate with existing payment rails rather than compete against them. BNY, the custodian bank, is also part of the consortium.

"This shift opens the door for banks, networks and platforms to participate with confidence," Visa CEO Ryan McInerney wrote in the company's 2025 annual report.

How does this reshape the incumbents?

Circle and Tether have dominated the market through USDC and USDT, generating billions of dollars in revenue from reserve management. The new framework threatens that position. In July, Circle won approval to establish a national trust bank, placing the new entity under federal oversight and giving Circle a regulated channel for managing USDC reserves.

"The GENIUS Act [...] sets consistent standards for reserve backing, transparency, and consumer protections, paving the way for [...] innovation in the digital asset space," Circle wrote in a June 2025 blog post.

Open USD poses a different kind of challenge. Its 140-plus backers include Visa, Mastercard and Coinbase, giving it distribution into card networks and exchanges that Tether and Circle must reach through partnerships.

"A stablecoin with neutral governance and shared economics is a unique combination," BNY Chief Product and Innovation Officer Carolyn Weinberg told Reuters.

What remains unresolved?

The yield question is the most consequential open fight. The act bars stablecoin issuers from paying yield directly to holders, but it does not address whether exchanges or other third parties can offer rewards programs.

Banks argue that yield-bearing products could pull deposits from the traditional system. The crypto industry has resisted broader restrictions.

If exchanges remain free to reward holders, USDC and USDT gain an early advantage, given their existing exchange distribution. If regulators restrict rewards, banks and payment networks launching their own tokens may capture more of the next leg of growth.

"The next phase of stablecoin adoption is about real-world utility," Mastercard Executive Vice President for Blockchain and Digital Assets Raj Dhamodharan said in June.

The market is shifting from issuance to distribution, and the winners will be the tokens that penetrate deepest into payment flows. With comment windows closing through August 21 and a statutory implementation deadline of January 18, 2027, the shape of that competition will be set within months rather than years.