Written by: Xiao Za Legal Team

Friends in the crypto circle should still remember that in July 2025, Trump signed the "GENIUS Act." Not long after, the U.S. Department of the Treasury launched an ANPRM for public comment, sparking heated discussions in the community.

I believe everyone is eager to learn about the latest developments. The Xiao Za team’s article will follow the usual format, first taking you through the history of stablecoin development in the U.S., and then breaking down the core focuses of the "GENIUS Act" and the ANPRM.

01 History of U.S. Stablecoins — Centered Around the "GENIUS Act"

Old friends know that early U.S. crypto regulation was a "multi-headed battle": the SEC claimed cryptocurrencies were "securities," the CFTC said they were "commodities," and regulations varied by state. New York's BitLicense was so strict that it discouraged businesses, while Wyoming rolled out the red carpet for crypto companies. In 2025, the situation began to change, with the introduction of the "GENIUS Act" and the "STABLE Act," marking the entry of U.S. stablecoin regulation into the "Gemini" era. Therefore, if you want to understand the current state of U.S. stablecoins and the role of the public comments on the "GENIUS Act," these two acts need to be discussed together.

These two acts can be considered the "Gemini" of U.S. stablecoin legislation, with similar paths.

First, let's look at the "GENIUS Act" (full name: "2025 Guidance and Establishment of a National Innovation Act for U.S. Stablecoins"), proposed by senators in February 2025, which is primarily tailored to develop a path for "payment stablecoins." Its key contents can be summarized as follows:

Next, we examine the "STABLE Act" (full name: "2025 Stablecoin Transparency and Accountability Better Ledger Economy Act"), which shares the core logic of the "GENIUS Act" but differs in details. First, the focus of positioning is different. While both define payment stablecoins, the "STABLE Act" particularly emphasizes that "issuers must commit to redeeming or repurchasing at a fixed currency," highlighting the capital preservation attribute; second, the core rules are the same: both require a 1:1 holding of high-quality liquid assets, regular audit disclosures, and licensed issuance, but differ in requirements for international issuers and state regulatory authority limits.

Overall, these two acts do not have substantial conflicts; they are more like "complementary partners": the "GENIUS Act" sets the framework, clarifying the regulatory jurisdiction and development direction for stablecoins; the "STABLE Act" completes the details on transparency and accountability, focusing on user fund safety.

02 Six Major Topics of the ANPRM and Public Opinion Focus

After understanding the history of U.S. stablecoins, friends can shift their focus to the recent ANPRM released by the U.S. Department of the Treasury regarding the formal advancement of the "GENIUS Act." This public comment request covers almost all aspects of the stablecoin ecosystem, focusing on six major topics: first, the qualification definition of issuers (including the "equivalent regulation" recognition for foreign issuers); second, the rules for holding and disclosing reserve assets; third, the scope of extraterritorial applicability (compliance requirements for foreign institutions serving the U.S.); fourth, anti-money laundering and marketing restrictions; fifth, federal income tax characterization; and sixth, the prohibition of interest payments (including disputes over indirect payments). Currently, opinions are still being collected, and while conclusions are difficult to form, there are several core topics that I would like to discuss with everyone.

First, who is qualified to issue stablecoins? This is the key issue determining whether USDT can remain in the U.S. market. The "GENIUS Act" stipulates that only officially licensed "payment stablecoin issuing institutions" can issue coins in the U.S. Therefore, a core topic in the Treasury's inquiry is "who can issue payment stablecoins in the U.S." According to the GENIUS Act, only licensed payment stablecoin issuers (PPSI) can issue such stablecoins in the U.S. The ANPRM also asks for public feedback on whether additional definitions are needed and whether to open a "green channel" for small transactions.

For Tether, the company issuing USDT, if it does not meet these new requirements, it may only have three options: either comply with the new regulations, exit the U.S. market, or launch a new coin that meets the regulations. Tether announced the launch of USAT, specifically designed for the U.S., which is essentially an attempt to meet regulatory conditions through "business segmentation." The regulatory standards for foreign issuing institutions have far-reaching implications; by questioning whether other countries' regulatory systems meet standards and the compliance capabilities of institutions, the U.S. is actually competing for the authority to set global stablecoin rules. In the future, foreign stablecoins that do not meet U.S. standards may find it very difficult to enter the U.S. market.

Second, can stablecoins provide users with returns? This issue has also sparked intense debate. Although the act prohibits issuers from directly providing interest to users, it has not stopped platforms like exchanges from offering indirect rewards. For example, the Coinbase platform offers users a 4% reward for holding stablecoins, which has drawn criticism from banks, accusing it of secretly attracting deposits and lobbying the government to change the rules. Regulatory authorities are inquiring whether "indirect interest counts as a violation," which reflects the competition between traditional finance and the crypto industry for market share.

In Conclusion

Ultimately, the "GENIUS Act" and the ANPRM are fundamentally about the U.S. wanting to incorporate stablecoins into the dollar hegemony system. The act aims to secure the advantage of dollar stablecoins by tying them to U.S. Treasury bonds and establishing a framework, but claiming "hegemony realization" is overly optimistic. The crypto market is inherently decentralized, global regulation is competitive, and with the rise of Hong Kong and the promotion of offshore RMB stablecoins, I believe the U.S. cannot dominate alone.

Finally, I offer some practical advice to friends: first, keep a close eye on the feedback results of the ANPRM, especially regarding reserve custody and interest payment rules, as these directly affect the costs and liquidity of USDT and USDC; second, pay attention to the Hong Kong market, where offshore RMB stablecoins have valuation gaps, and early positioning may present opportunities. The ongoing battle between regulation and innovation means that understanding the rules and choosing the right track is essential to avoid capsizing in the wave of stablecoins.

免责声明：本文章仅代表作者个人观点，不代表本平台的立场和观点。本文章仅供信息分享，不构成对任何人的任何投资建议。用户与作者之间的任何争议，与本平台无关。如网页中刊载的文章或图片涉及侵权，请提供相关的权利证明和身份证明发送邮件到support@aicoin.com，本平台相关工作人员将会进行核查。