GBBC USA Responds to U.S. Treasury Consultation on GENIUS Act Regulations on Payment Stablecoin Issuance, Offer, and Sale

October 19, 2026: GBBC USA submitted our response to the U.S. Department of the Treasury’s proposed regulations under section 3 of the GENIUS Act.

Our response supports clear, practical rules for payment stablecoin issuance, offer, and sale, and requests additional guidance on:

🔹 Cross-border scope: Clarify the territorial reach of the rules and distinctions between issuance, offers, and sales, including transactions outside the United States.

🔹 Cross-chain transfers and issuer status: Provide examples of when bridging or wrapping a stablecoin constitutes new issuance and when an intermediary should be considered an issuer, taking into account holders’ rights, redemption obligations, custody, and control.

🔹 Customer-location controls: Clarify how customer information, geographic indicators, and transaction monitoring support location assessments, including when issuers may rely on intermediaries’ checks.

🔹 Due diligence and compliance: Clarify responsibilities among issuance participants and the evidence service providers may use to assess foreign issuers’ technological capability and commitment to comply with lawful orders and reciprocal arrangements.

The response draws on principles from the Capital Markets Risk Mitigation Framework (RMF) for Non-Financial Risks of Blockchain Infrastructures, developed by GBBC and Oliver Wyman through a cross-sector working group, to inform practical guidance on controls, due diligence, and responsibilities.

Read GBBC USA’s full response here.