Three months after the landmark U.S. stablecoin legislation known as the GENIUS Act was signed into law on July 18, 2025, the bill remains in a public comment period, delaying its implementation. The crypto industry had initially celebrated the legislation as a significant advancement for federal regulation of stablecoins in the U.S. However, as it stands, no stablecoin or stablecoin issuer is currently regulated under this new framework, despite anticipation from both established entities and newcomers in the market seeking to align with the forthcoming regulations.
One of the early frontrunners in this evolving landscape is Anchorage Digital Bank, notable for holding a charter from the Office of the Comptroller of the Currency (OCC), which permits it to operate as a crypto-focused bank. Recently, Anchorage announced plans to issue “America’s first federally regulated stablecoin,” named USDtb, in collaboration with Ethena Labs, famous for creating the synthetic dollar asset USDe. Initially launched by Ethena Labs in December 2024, USDtb is primarily backed by BlackRock’s tokenized U.S. Treasury fund, BUIDL, which reportedly manages over $2.8 billion in assets. Previously, USDtb was issued outside of the United States, with Ethena Labs overseeing its minting and redemptions.
In an announcement made via a post on X on October 13, Ethena Labs confirmed its cooperation with Anchorage Digital in transitioning the USDtb smart contract, describing this move as a “monumental onshoring,” thereby branding USDtb as the first federally regulated stablecoin issued in compliance with the GENIUS Act. However, industry experts caution that such claims may be prematurely optimistic, emphasizing that it remains too early to accurately label USDtb as federally regulated. Critics argue that the current status of the legislation means that no one is regulated by GENIUS as its provisions have not yet come into effect.
Commentators including Facundo Werning, head of LATAM at stablecoin startup Agora, highlight the distinction between “onshoring” USDtb through a regulated institution and actual statutory approval. Nicole Dyskant, co-founder of RegDoor, noted that the U.S. Treasury has published an Advance Notice of Proposed Rulemaking to solicit public feedback on the implementation of the act. This public comment period is set to close on November 4, 2025, after which final regulations will be drafted and published. The GENIUS Act will come into force either 120 days after these final rules are released or 18 months post-enactment, whichever occurs first, meaning the act is currently a framework awaiting activation.
Legal analyses from several U.S. law firms have clarified that only an approved “permitted payment stablecoin issuer” (PPSI) can issue or market a payment stablecoin in the U.S., and such approvals cannot be secured until the rulemaking process is complete. This raises the question of how entities claim compliance when the regulatory framework is not yet in effect. Zach Rosenberg, general counsel at Ethena Labs, acknowledged the restrictions inherent in the situation, affirming that while Ethena is structuring USDtb in accordance with the forthcoming law, the GENIUS Act does not currently regulate anyone.
Dyskant suggests that language used by firms like Ethena Labs and Anchorage should be interpreted as indicative of their goals rather than strict legal claims, stating that terms like “GENIUS-ready” imply adherence to anticipated standards rather than formal certification.
The competitive landscape is also evolving, with major players like Circle and Tether eyeing compliance with the GENIUS Act. Circle’s USDC, the largest U.S.-issued stablecoin, has been recognized for its caution and transparency, with regular reserve attestations and banking relationships reinforcing its claim to compliance. However, as of now, Circle has not provided further commentary on its preparations.
Tether, known for the world’s largest stablecoin, USDT, has announced plans to issue a new U.S.-approved stablecoin, USAT, tailored to be compliant with the GENIUS framework, with Anchorage Digital also overseeing this issuance. No further details from Tether on its compliance efforts have been made available at this time.
Reflecting on the current regulatory landscape, Dyskant concluded that it is crucial to recognize that no stablecoin can be considered fully compliant under GENIUS at this stage, as the regulatory requirements defining compliance remain in the process of being finalized and are not yet enforceable.
