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GENIUS Act Enacted, Establishing a Regulatory Framework for Payment Stablecoins Issued or Sold in the United States

By Marina Olman-Pal, Barbara A. Jones, John B. Hutton III, Tracy S. Combs, Robert Mangas, Jera L. Bradshaw & Tiffanie Monplaisir on July 22, 2025
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On July 18, 2025, President Trump signed the GENIUS Act into law. The GENIUS Act, which passed the Senate on June 17, 2025, and the House of Representatives on July 17, 2025, is the first major piece of crypto legislation in the United States.

The GENIUS Act establishes a comprehensive regulatory framework for payment stablecoins, limiting their issuance to “permitted payment stablecoin issuers” (federal or state-qualified entities), that must maintain a 1:1 reserve backing,[1] satisfy public disclosure obligations, and operate under federal or qualifying state regulatory supervision, as described below. The GENIUS Act will take effect on the earlier of (i) Jan. 18, 2027 (18 months after enactment) or (ii) 120 days after the primary federal payment stablecoin regulators issue final rulemaking to implement the GENIUS Act.[2] Once in effect, issuers of payment stablecoins in the United States must abide by the requirements of the GENIUS Act. Digital asset service providers such as cryptocurrency exchanges, custodians and wallet providers, and payment apps will have a three-year transition period to comply with the GENIUS Act. As of July 18, 2028, these providers will be required to restrict their activities to only payment stablecoins that have been issued by an issuer approved under the GENIUS Act.

Link to Click here to read the full GT Alert. Click here to read the full GT Alert.

[1] “One-to-one” backing refers to a situation where each unit of a liability is matched one-to-one by a corresponding asset of equal value held in reserve.

[2] Each primary federal payment stablecoin regulator, the Secretary of the Treasury, and each state payment stablecoin regulator are required to promulgate rulemaking to implement the provisions of the GENIUS Act through a notice-and-comment rulemaking no later than one year after the date of enactment of the GENIUS Act.

Photo of Marina Olman-Pal Marina Olman-Pal

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight…

Marina Olman-Pal is a Co-Chair of the firm’s Financial Regulatory & Compliance Practice. She advises foreign and U.S. financial institutions on a broad range of U.S. federal and state regulatory and compliance matters including licensing/chartering, acquisitions, mergers, divestitures, third-party risk management and oversight issues, BaaS and other bank/fintech-related matters, compliance with Bank Secrecy Act (BSA)/anti-money laundering (AML) laws and regulations, GENIUS Act and fair access law matters.

Marina counsels a wide range of companies in the financial services sector including, domestic and foreign banks, money services businesses including money transmitters, cryptocurrency businesses, Fintech companies, digital payment companies, and non-financial services companies considering new payment or digital wallet models. Throughout her career, Marina has represented clients before U.S. regulators such as the Federal Reserve, OCC, FDIC, FinCEN, OFAC, the Florida Office of Financial Regulation and other state supervisory authorities. Marina also regularly develops anti-money laundering programs for a wide range of financial services businesses and non-financial services businesses including, U.S. and foreign companies active in industries such as real estate, hospitality, automotive and artificial intelligence, among many others.

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Photo of Barbara A. Jones Barbara A. Jones

Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice

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Barbara A. Jones is Co-Managing Shareholder of the firm’s Los Angeles office and a member of the firm’s Global Corporate practice. Barbara serves as Chair of the firm’s interdisciplinary Blockchain & Digital Assets practice. Barbara maintains a diverse corporate and securities law practice across industry groups, emphasizing complex international and domestic transactions, including private and public financings, dual listings, mergers and acquisitions, strategic collaborations and joint ventures, and licensing transactions. She serves as a trusted advisor to public and private company boards of directors on governance matters and complex regulatory reporting and compliance issues. Barbara’s clients include financial institutions, private equity and venture capital groups, and public and private companies in emerging technology, life sciences and biotechnology, defense and security, blockchain and digital assets, telecommunications, information technology, energy (traditional and renewable), mining, media, entertainment and sports. Barbara also represents Olympic and professional athletes and sports-related organizations.

Barbara practiced U.S. law in London from 1990 through 1997 with Sullivan & Cromwell, LLP, and headed the international capital markets practice of Kirkland & Ellis LLP from 1999 to 2003 before relocating to Boston. From 1997 to 1999, she served as Vice-President, Assistant General Counsel and Regional Counsel for capital markets with J.P. Morgan Securities Ltd. in Europe, the Middle East and Africa. Since returning to the U.S., she has continued to actively represent public and private companies, private equity groups and investment banks in the European, Scandinavian, African and greater Asian markets, including China.

Barbara is a past chair of the ABA’s Subcommittee on International Securities Matters. She is a frequent speaker at conferences relating to cross-border securities matters, strategic alternatives, and digital asset structures. She serves on the Government of Bermuda’s Global FinTech Advisory Board.

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Photo of John B. Hutton III John B. Hutton III

John B. Hutton III is a restructuring advisor and a bankruptcy litigator who has spent his entire career with Greenberg Traurig since joining the firm in 1993. He has wide-ranging experience representing debtors, trustees, secured and unsecured creditors, asset purchasers, indenture trustees and…

John B. Hutton III is a restructuring advisor and a bankruptcy litigator who has spent his entire career with Greenberg Traurig since joining the firm in 1993. He has wide-ranging experience representing debtors, trustees, secured and unsecured creditors, asset purchasers, indenture trustees and bondholders across various industries, with a particular focus on municipal finance/ tax-exempt bonds, real estate, and hospitality. John litigates issues involving cash collateral, adequate protection, valuation, stay relief, feasibility and plan confirmation treatment. In his early years with the firm, John played a key role in the Southeast Banking Corporation bankruptcy case, one of the largest bank holding companies in Florida, which returned over 100 percent to creditors, along with post-petition interest. He has also had multiple Committee representations, including Mission Health, where the recovery for unsecured creditors was increased from a projected 10 percent to 90 percent. The U.S. Trustee called it the “most aggressive” Committee she had seen in her career. John has broad experience in handling indenture trustee and bondholder representations involving tax-exempt community development district bonds and the issues arising in such cases.

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Photo of Tracy S. Combs Tracy S. Combs

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries…

Tracy serves as Co-Managing Shareholder of the Salt Lake City office. A former Regional Director at the U.S. Securities and Exchange Commission, she represents corporations, financial institutions, and individuals in a wide range of federal and state government investigations, litigation, and regulatory inquiries nationwide, including those involving the SEC, the Department of Justice, and state Attorneys General. She also counsels clients in complex business disputes, tort litigation, and cybersecurity matters. As Utah Business Journal’s Legal Elite edition stated in 2025, Tracy can “navigate a wide range of legal situations and…easily handle a crisis for any client.”

Tracy joined GT after an eight-year tenure at the SEC, where she served in a variety of roles in San Francisco and Salt Lake City. Most recently, Tracy served as Director of the SEC’s Salt Lake Regional Office, where she oversaw some of its most high-profile cases. As a former SEC trial and investigative attorney in San Francisco, Tracy brought several groundbreaking enforcement actions, including the SEC’s first public company cybersecurity disclosure case and its first “shadow” insider trading case. Tracy served for three years in the Division of Enforcement’s former Cyber Unit, where she co-led its Cybersecurity & Regulated Entities group. In 2021 to 2022, Tracy served as counsel to the Director of Enforcement, advising on priority matters and coordinating with the SEC’s criminal and civil law enforcement partners nationwide.

Prior to her government service, Tracy was a litigator at a large law firm in Philadelphia and New York, with a focus on high-stakes white collar criminal matters, securities class actions, and complex commercial disputes, and clerked for the Honorable Luis Felipe Restrepo in the U.S. District Court for the Eastern District of Pennsylvania.

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Photo of Robert Mangas Robert Mangas

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in multiple policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial services, information…

Rob is a shareholder in the firm’s Federal Government Law & Policy group. He has represented clients before Congress and federal agencies from a variety of industries and in multiple policy areas, including trade, energy, environment, health care, biotechnology, transportation, financial services, information technology, artificial intelligence, manufacturing, tax, education, pensions, defense, and foreign relations. Rob has a depth of understanding of the rules of the U.S. Senate and House of Representatives, and he has deep experience in legislative drafting. He previously served as chief of staff to U.S. Senator Wendell Ford, the former Senate Majority Whip.

Rob is a member of the firm’s Tariff Task Force, a multidisciplinary initiative that draws on the firm’s global platform to guide our clients through what comes next in regards to tariffs, including tariff refund matters, tax, litigation, and M&A activity spurred by these global shifts.

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Photo of Jera L. Bradshaw Jera L. Bradshaw

Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory

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Jera L. Bradshaw is a former state and federal regulator who advises community, regional, and national banks on all aspects of financial regulatory compliance and enforcement, with an emphasis on state and federal enforcement actions; corporate and board governance matters related to regulatory compliance, bank-fintech partnerships, regulatory applications, enterprise risk; and “troubled” banks.

Jera regularly assists financial institutions of all sizes with examinations, applications, and enforcement matters; has an extensive background advising banks on compliance and remediation programs; and is experienced appearing before the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (FRB), the Consumer Financial Protection Bureau (CFPB), and multiple state bank regulatory authorities.

Before joining private practice, Jera served ten years as bank regulatory counsel to the FDIC and the Tennessee Department of Financial Institutions (“TDFI”) where she conducted legal review of regulatory filings such as branch applications, golden parachute payments, mergers, brokered deposit waivers, changes in bank control, and retirement of capital; supported regulatory examinations; oversaw enforcement actions; and advised on legislation, laws, and policies affecting financial institutions.

More recently, she acted as senior counsel of regulatory affairs for a large regional bank advising on intricate legal issues affecting the enterprise including implementation of enhanced prudential standards, affiliate transactions, dividend restrictions, Community Reinvestment Act strategy, and consumer compliance management systems (“CMS”).

Jera leverages her deep bank regulatory experience to deliver practical legal advice on a range of financial regulatory topics including affiliate transactions, deposit products, BSA/AML compliance, lending limits, insider transactions, capital and liquidity risk management, and the Community Reinvestment Act. She counsels clients on regulatory aspects of new product development, including bank partnership models, BaaS relationships, payment systems, fintech deposit platforms and third-party oversight. She also advises bank acquirers and sellers on regulatory approvals for M&A transactions, noncontrolling investments, nonbank activities, and other complex issues.

Jera is chair of the American Bar Association’s Regional and Community Banks Subcommittee, a faculty member of Fundamentals of Banking Law, and a guest lecturer at the SMU Dedman School of Law. In addition to speaking on regulatory issues affecting insured depository institutions, Jera is routinely called upon to train bank boards and management on a wide range of legal and risk management topics.

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Photo of Tiffanie Monplaisir Tiffanie Monplaisir

Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal

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Tiffanie Monplaisir is a member of the Corporate Practice in Greenberg Traurig’s Miami office. She focuses her practice on financial services provider regulation and compliance. Tiffanie counsels U.S. and international financial institutions, non-financial services businesses, and other entities in navigating the complex federal and state regulatory landscape governing payments, lending, licensing, and consumer financial services. Tiffanie’s practice includes advising banks, FinTech and digital payment companies, money services businesses, payment processors, cryptocurrency businesses, and digital asset companies on a wide range of regulatory matters including licensing, crafting innovative solutions for Bank Secrecy Act/Anti-Money Laundering (BSA/AML) and Office of Foreign Assets Control (OFAC) compliance programs and related policies and procedures. Tiffanie also works on nationwide state money transmitter, lending, servicing, and other license acquisition projects.

Read more about Tiffanie MonplaisirEmailTiffanie's Linkedin Profile
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  • Posted in:
    Banking, Finance and Securities, Technology and AI
  • Blog:
    Financial Services Observer
  • Organization:
    Greenberg Traurig, LLP
  • Article: View Original Source

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