INSIGHT

GENIUS Act passes Senate: What this historic stablecoin framework means for your business 

Javier Salinas, Michelle Choy • June 17, 2025

Industries: Blockchain & Digital Assets

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If you’ve been waiting for clearer regulatory guidance on stablecoins, the wait is nearly over. The uncertainty that has left many businesses hesitant to fully embrace these digital payment solutions is finally being addressed. On June 17, 2025, the U.S. Senate made history by passing The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act in a strong 68-30 bipartisan vote—marking the first-ever federal regulatory framework for stablecoins to clear the Senate. 

This legislative breakthrough could reshape how your organization approaches digital payments and opens new opportunities for businesses operating in the $250 billion stablecoin market, which is projected to grow to more than a trillion dollars in coming years. Let’s break down what this means for you and how to prepare for the changes ahead. 

Understanding the current stablecoin landscape 

The numbers tell a compelling story. Today’s stablecoin market sits at approximately $250 billion, with the two dominant U.S. stablecoins—USDT and USDC—representing $214 billion of that total market capitalization. These digital assets have gained traction as reliable payment and settlement tools, offering faster transaction speeds and lower costs compared to traditional payment methods. 

However, the lack of clear regulatory framework has created challenges for businesses looking to integrate stablecoins into their operations. The GENIUS Act addresses these concerns by providing the regulatory clarity the market has been seeking. 

Key provisions of the GENIUS Act 

While the bill represents historic progress for the crypto industry, it’s important to understand its specific scope. The GENIUS Act focuses exclusively on payment stablecoins—not all digital assets. The legislation defines payment stablecoins as digital assets designed for payment or settlement purposes, where issuers maintain obligation to preserve stable value relative to a fixed monetary amount. 

What payment stablecoins are not 

The bill makes clear distinctions about what payment stablecoins don’t represent: 

• They are not considered national currency 

• They don’t qualify as securities or commodities under the Investment Company Act of 1940 

Who can issue payment stablecoins 

Under the framework, only two categories of issuers are permitted to issue payment stablecoins: 

Subsidiaries of insured depository institutions – These entities would operate under existing banking regulations, providing additional consumer protection through established oversight mechanisms. 

Federal qualified nonbank payment stablecoin issuers – These organizations would require approval from the Comptroller of the Currency, creating a new regulatory pathway for non-bank entities to participate in the stablecoin market. 

Enhanced reserve requirements and oversight 

The legislation includes several critical provisions that strengthen stablecoin stability and oversight: 

1:1 Reserve Requirement – Permitted issuers must maintain reserves backing their payment stablecoins on at least a 1:1 basis, backed by cash or Treasury securities. While this has been considered an industry standard with both USDT and USDC issuing monthly attestations, this requirement now formalizes that practice into law. 

Mandated Independent Audits – Issuers above $50 billion must undergo independent audits, ensuring greater transparency and accountability for the largest stablecoin operators. 

Anti-Money Laundering and Sanctions Compliance – The framework includes robust AML requirements and sanctions compliance measures, along with national security guardrails to protect the financial system. 

Limits on Big Tech and Foreign Issuance – The legislation places stricter oversight on entities like Tether and includes provisions limiting Big Tech companies and foreign entities from issuing stablecoins without proper oversight. 

What this means for your business 

The GENIUS Act’s passage signals definitive regulatory acceptance of stablecoins as legitimate payment instruments. For your organization, this development translates into several immediate opportunities and considerations:

Conducting a comprehensive audit 

Before the new regulations take effect, consider conducting a thorough audit of your current digital asset activities. This assessment should examine your stablecoin transactions, custody arrangements, accounting treatment, and internal controls. 

An audit can help identify potential compliance gaps and provide a baseline for measuring your organization’s readiness for the new regulatory environment. Additionally, having documented audit findings will demonstrate proactive compliance efforts to regulators and stakeholders.  

Clear opportunities for adoption 

With definitive regulatory guidelines now established, you can confidently justify stablecoin integration in your payment systems. The framework reduces compliance uncertainty and provides a clear roadmap for incorporating these digital assets into your treasury management or customer payment options.

Planning for compliance 

If your business already uses stablecoins or plans to in the future, now is the time to prepare for the new regulatory requirements. The compliance landscape will become more structured, requiring updated policies and procedures that align with the 1:1 reserve requirements, audit mandates, and AML provisions. 

Vendor and partner evaluation 

As the regulatory framework takes shape, assess whether your current stablecoin partners and service providers will meet the new requirements. This evaluation process should begin immediately to avoid disruptions to your operations, particularly given the enhanced oversight on certain issuers like Tether. 

The road ahead 

While the GENIUS Act has successfully passed the Senate, the legislative journey continues. The bill now moves to the House of Representatives, where lawmakers may advance their own version (such as the STABLE Act) or merge it with broader crypto legislation like the CLARITY Act. 

Target Timeline – President Trump has indicated his intention to sign comprehensive stablecoin legislation into law by the August 2025 recess, creating urgency for House action. 

Potential Consolidation – Lawmakers may link stablecoin rules with wider crypto market reforms, potentially combining the GENIUS Act with the House’s Clarity or STABLE Acts for a more comprehensive digital asset framework. 

This timeline gives your organization a clear window to prepare. Rather than waiting for final passage, use this period to: 

• Assess your current stablecoin usage and future needs 

• Review existing compliance frameworks and identify gaps 

• Engage with legal, tax, and accounting professionals to understand implications 

• Monitor legislative developments and industry best practices 

Navigating regulatory complexity 

As stablecoin regulation moves toward final implementation, your business will face new compliance and reporting requirements. The intersection of traditional financial regulations with the newly established digital asset framework creates complexity that requires careful navigation. 

Understanding how these requirements apply to your specific situation—whether you’re a potential issuer, custodian, or user of stablecoins—will be crucial for maintaining compliant operations and capitalizing on new opportunities. 

Moving forward with confidence 

The GENIUS Act’s Senate passage represents a pivotal moment for stablecoin regulation in the United States. With bipartisan support and a clear path toward becoming law, this framework provides the foundation businesses have been waiting for to confidently integrate digital payment solutions. 

Your organization doesn’t have to navigate this evolving landscape alone. Having knowledgeable advisors who understand both traditional financial regulations and the emerging digital asset requirements can help you make informed decisions and position your business for success in this new regulatory environment. 

Ready to discuss how the new stablecoin regulations will impact your business? Our blockchain and digital assets team stays current with regulatory developments and can help you understand the implications for your specific situation. Contact BPM today to explore how we can support your digital asset strategy and compliance planning as we move toward final implementation.