GENIUS Act Compliance Counsel for Stablecoin Issuers
The GENIUS Act put every US payment-stablecoin issuer on a federal compliance clock. Astraea Counsel structures issuers, reserve and attestation programs, and licensing pathways aligned to the new federal framework.
Decisions issuers face now
- You are choosing between the federal pathway and a state-qualified regime
- Your reserve, custody, and monthly attestation program has to be examiner-ready
- You are a foreign issuer deciding how to lawfully serve US customers
- A bank or payments partner is running compliance diligence on your token
- You need a compliance calendar that tracks the effective date and the federal regulators' rulemaking
What we build for issuers
- Pathway analysis: federal charter versus state-qualified issuance, mapped to your size and structure
- Reserve composition, custody, and attestation programs drafted to the Act's requirements
- BSA/AML and sanctions compliance policies sized for a stablecoin issuer's actual risk
- License and registration applications, and responses to regulator questions
- Rulemaking monitoring — when final rules land, we translate them into your concrete obligations and deadlines
Recognition
- Astraea Counsel ranked in Chambers USA: Spotlight 2026 — Fintech (Los Angeles)
- Lawdragon 500 X — The Next Generation: Crypto Regulation, Disputes, Blockchain (2026), Chanté Eliaszadeh
- 2024 Law360 Distinguished Legal Writing Award, The Burton Awards — Chanté Eliaszadeh, co-author (White & Case)
- Best Lawyers: Ones to Watch in America — Commercial Litigation (2026), Brandon Orewyler (recognized during his tenure at Ervin Cohen & Jessup)
- Recognized in The Legal 500 USA — Chanté Eliaszadeh (White & Case LLP, 2023)
- SEC Honors Program, U.S. Securities and Exchange Commission (honors intern, Cyber Unit, 2018)
- Invited speaker: American Bar Association Business Law Section, Korea Blockchain Week (BIF25), ETHDenver, GRR Live, Blockchain Law for Social Good Conference, Art Basel Miami, and Berkeley Law; keynote, Computational Law & Blockchain Festival
Common Questions
When does the GENIUS Act take effect?
Under the statutory formula, the earlier of January 18, 2027, or 120 days after the primary federal regulators finalize implementing rules. Agencies were still mid-rulemaking as of mid-2026, so the date turns on when final rules land — issuers should build to the framework now.
Does the GENIUS Act preempt state stablecoin laws?
Not wholesale. It layers a federal framework over a state-qualified pathway for smaller issuers; which regime governs depends on issuance size, charter type, and the state's certification — the pathway choice is the first legal decision an issuer should make.
We already issue a stablecoin. Are we grandfathered?
No general grandfathering: existing issuers must fit themselves into a permitted-issuer category within the statute's transition windows. The earlier the gap analysis, the cheaper the fix.
Speak With an Attorney
Build your GENIUS Act compliance plan
Schedule a stablecoin regulatory consultation before the effective date sets your deadline for you.
Talk to an Attorney