#美国区块链协会提交genius法案意见

【The U.S. wants to regulate stablecoins; the industry is drawing a line for regulators】

In its comments on the implementation rules for the GENIUS Act, the Blockchain Association’s main point is simple: regulating stablecoin issuers is fine, but don’t use that as an excuse to bring the entire on-chain world under your jurisdiction.

The association wants self-custody software, validator nodes, and businesses that trade only their own assets to avoid being casually classified as digital asset service providers. It also says criminal liability should require that the party actually knew about the conduct and provided substantial assistance.

What’s at stake in this debate is who bears the cost of compliance. Draw the boundaries too broadly, and developers and infrastructure providers may be saddled with obligations that aren’t suited to them; draw them too narrowly, and regulatory gaps may remain. The industry naturally wants fewer restrictions, but regulators can’t simply let the industry set the rules for itself.

These are only comments submitted for consideration; they don’t mean the Treasury Department has accepted them. There’s no direct upside for any particular token at this point. The real question is whether the final rules limit responsibility to parties actually involved in issuing stablecoins and providing related services. If regulators ultimately extend the obligations to more on-chain participants, this submission may prove to be little more than wishful thinking on the industry’s part.