
Bryce S. Robins
Associate
212-784-6929 brobins@sh-law.comFirm Insights
Author: Bryce S. Robins
Date: November 25, 2025

Associate
212-784-6929 brobins@sh-law.com
Stablecoins were supposed to be the “boring” part of crypto: digital dollars that just work. Yet for years they have lived in a regulatory no-man’s-land, classified one day as securities, the next as commodities, and sometimes as something regulators had not even named yet. That uncertainty is finally starting to clear in the United States, and the rest of the world is moving fast too.
Here in the U.S., 2025 delivered the breakthrough most of the industry had been waiting for. In July, President Trump signed the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act into law, the country’s first comprehensive federal framework built specifically for payment stablecoins. After years of speeches, white papers, and enforcement actions, Congress finally drew a line in the sand: if a stablecoin is redeemable 1:1 for dollars and used mainly for payments or settlement, it now has a clear, tailored rulebook instead of being shoehorned into 1930s securities laws.
The new law is already reshaping the landscape. Issuance now sits at roughly $303 billion and climbing, more than quadruple what it was just four years ago. Stablecoins have become the on-ramp, the trading pair, the settlement layer, and in many cases the lifeline for cross-border payments. Clear rules matter, and the market is responding.
So, what does the GENIUS Act actually do? It limits issuance to tightly supervised entities: bank subsidiaries, federally chartered non-banks, or state-approved players that meet strict standards. Every token has to be backed one-for-one with cash, short-term Treasuries, or other ultra-safe, liquid assets. No rehypothecation games, no corporate bonds, no funny business. Large issuers publish monthly attestations and submit to annual independent audits. Holders get first claim on reserves if something goes wrong, and no one is allowed to slap “FDIC-insured” or “U.S. government-backed” on marketing materials. Interest payments are off the table too; these are payment tools, not savings accounts.
Perhaps most importantly, the law treats issuers like the financial institutions they are. That means full Bank Secrecy Act compliance, KYC, transaction monitoring, and the ability to freeze tokens when law enforcement comes knocking. Foreign issuers wanting U.S. customers have to play by the same rules. Core pieces of the regime kick in by early 2027, with exchanges and wallets getting until mid-2028 to phase out anything that doesn’t comply.
But the U.S. is only one piece of the puzzle. In Europe, MiCA has been fully in force for over a year. Tether and others have already been delisted from major EU exchanges that want to stay on the right side of the law. A consortium of nine European banks just launched a MiCA-compliant euro stablecoin because no one wants the entire bloc reliant on dollar-pegged tokens forever.
Singapore continues to set the gold standard in Asia: 100% high-quality reserves, held locally, redeemable in five business days or less, and issuers restricted to stablecoin business only, no lending or staking on the side. The UAE, Hong Kong, Japan, and the UK have all rolled out or tightened their own frameworks in the last 18 months. The big requirements (licensing, full reserves, transparency, redemption rights) are converging quickly, but the details still differ enough to keep compliance teams very busy.
The bottom line? The era of regulatory ambiguity for fiat-backed stablecoins is ending. The companies that treat compliance as a competitive advantage rather than a cost center are the ones that will capture the next wave of institutional adoption.
The evolution of stablecoin regulation marks a significant turning point for the digital asset ecosystem. With the GENIUS Act establishing a national framework in the United States and global jurisdictions converging on similar standards, regulatory clarity is accelerating institutional adoption. Market participants that understand these requirements and prepare proactively will be best positioned to operate confidently and competitively as this new era of compliance takes shape.
If your business issues, custodies, integrates, or relies on stablecoins, now is the time to assess your exposure to the new regulatory frameworks taking shape in the United States and abroad. Companies should begin evaluating reserve practices, licensing requirements, cross-border activity, and vendor relationships to ensure alignment with both the GENIUS Act and emerging global standards. Early planning is likely to become a significant competitive advantage as institutions and service providers adjust to a more supervised environment.
The attorneys in Scarinci Hollenbeck’s Blockchain Offerings, Cryptocurrency Defense and Investigations Practice counsel clients on the full spectrum of digital asset compliance issues. Our team advises on GENIUS Act implementation, MiCA authorization, licensing applications, reserve structures, audits, and risk-management strategies for issuers and service providers. With experience across U.S. and international regulatory regimes, we help clients navigate complex obligations and maintain compliance as standards continue to evolve. For assistance with stablecoin compliance or to speak with an attorney about your specific regulatory needs, contact us.
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