The Treasury Department’s comment period on the GENIUS Act has closed.
This date is worth marking: the first U.S. law dedicated specifically to stablecoins is now entering the crucial rulemaking stage.
The Blockchain Association has several key positions in this round of rulemaking that are worth clarifying:
First, KYC obligations must not be extended without limits.
The GENIUS Act requires stablecoin issuers to establish Customer Identification Programs (CIPs). The Blockchain Association’s position is that this obligation should apply only to direct, primary-market relationships between issuers and their customers—not extend downstream to secondary-market transactions or smart contract interactions.
The reasoning is that transactions on the blockchain are executed automatically through smart contracts, without any involvement from issuers. Requiring issuers to bear KYC responsibility for every on-chain transaction they have no part in is technically impossible and exceeds the authority granted by the GENIUS Act.
Second, the definition of stablecoins must be narrow.
The Association wants the Treasury Department to strictly limit the GENIUS Act’s regulatory scope to “payment stablecoins”—rather than allow regulators to use vague definitions to bring all kinds of tokens under the stablecoin framework.
Third, the ban on interest/yield must not be expanded too far.
The GENIUS Act prohibits stablecoin issuers from paying interest directly to holders—a measure intended to distinguish stablecoins from money market funds. But the banking industry has been pushing to extend this ban to platform-level rewards and yield programs. The Association is firmly opposed: the law bans issuers from paying interest, not platforms.
Fourth, advance a “passporting” regime.
Whether a platform approved at the state level can operate nationwide is currently a gray area. The Association is calling for a federal passporting mechanism to prevent states from fragmenting the stablecoin market with their own licensing requirements.
Since the GENIUS Act was signed in July 2025, the debate has moved from legislation to the details of implementation. How the rules are written will determine the true scope of opportunity in the stablecoin sector.
$USDC
#美国区块链协会提交genius法案意见
This date is worth marking: the first U.S. law dedicated specifically to stablecoins is now entering the crucial rulemaking stage.
The Blockchain Association has several key positions in this round of rulemaking that are worth clarifying:
First, KYC obligations must not be extended without limits.
The GENIUS Act requires stablecoin issuers to establish Customer Identification Programs (CIPs). The Blockchain Association’s position is that this obligation should apply only to direct, primary-market relationships between issuers and their customers—not extend downstream to secondary-market transactions or smart contract interactions.
The reasoning is that transactions on the blockchain are executed automatically through smart contracts, without any involvement from issuers. Requiring issuers to bear KYC responsibility for every on-chain transaction they have no part in is technically impossible and exceeds the authority granted by the GENIUS Act.
Second, the definition of stablecoins must be narrow.
The Association wants the Treasury Department to strictly limit the GENIUS Act’s regulatory scope to “payment stablecoins”—rather than allow regulators to use vague definitions to bring all kinds of tokens under the stablecoin framework.
Third, the ban on interest/yield must not be expanded too far.
The GENIUS Act prohibits stablecoin issuers from paying interest directly to holders—a measure intended to distinguish stablecoins from money market funds. But the banking industry has been pushing to extend this ban to platform-level rewards and yield programs. The Association is firmly opposed: the law bans issuers from paying interest, not platforms.
Fourth, advance a “passporting” regime.
Whether a platform approved at the state level can operate nationwide is currently a gray area. The Association is calling for a federal passporting mechanism to prevent states from fragmenting the stablecoin market with their own licensing requirements.
Since the GENIUS Act was signed in July 2025, the debate has moved from legislation to the details of implementation. How the rules are written will determine the true scope of opportunity in the stablecoin sector.
$USDC
#美国区块链协会提交genius法案意见
