INSIGHT

The GENIUS Act advances: What the Senate’s 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, you’re not alone. The uncertainty has left many businesses hesitant to fully embrace these digital payment solutions, despite their growing popularity and utility. On May 20, 2025, the U.S. Senate took a significant step forward by voting 66-32 to advance The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act—the first comprehensive federal framework for stablecoin regulation. 

This legislative milestone 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 aims to address these concerns by providing the regulatory clarity the market has been seeking. 

Key provisions of the GENIUS Act 

While the bill represents 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 proposed framework, only two categories of issuers would be permitted to issue payment stablecoins: 

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

2. 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. 

Reserve requirements and backing 

One of the most critical provisions requires permitted issuers to maintain reserves backing their payment stablecoins on at least a 1:1 basis. Historically this has been considered an industry standard with both USDT and USDC issuing monthly attestations, and this will formalize that work. This requirement aims to address concerns about stablecoin stability and provide confidence to users and regulators alike. 

What this means for your business 

The GENIUS Act’s advancement signals growing regulatory acceptance of stablecoins as legitimate payment instruments. For your organization, this development could translate into several 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. 

Opportunities for adoption 

With clearer regulatory guidelines on the horizon, you may find it easier to justify stablecoin integration in your payment systems. The framework could reduce compliance uncertainty and provide a 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 begin preparing for the new regulatory requirements. The compliance landscape will likely become more structured, with updated policies and procedures, including the 1:1 attestation requirement. 

Vendor and partner evaluation 

As the regulatory framework takes shape, you’ll want to assess whether your current stablecoin partners and service providers will meet the new requirements. This evaluation process should begin early to avoid disruptions to your operations. 

The road ahead 

It’s important to remember that the GENIUS Act still has a lengthy journey before becoming law. The bill is currently open for amendments on the Senate floor, which means provisions could change as lawmakers refine the legislation. This amendment process provides opportunities for industry input and could result in modifications that better serve business needs. 

The extended timeline also gives your organization time to prepare. Rather than waiting for final passage, consider using 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 evolves, your business will face new compliance and reporting requirements. The intersection of traditional financial regulations with emerging digital asset frameworks 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 represents a pivotal moment for stablecoin regulation in the United States. While challenges remain and the legislative process continues, this framework provides a foundation for businesses to build upon as they 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 emerging digital asset requirements can help you make informed decisions and position your business for success. 

Ready to discuss how stablecoin regulations might 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.