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ASTRAEA COUNSEL

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  1. Home/
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Stablecoins

7 articles

Client Guide

What Happens When a Stablecoin Payment Goes Wrong? The Consumer-Protection Gap in America's New Payment Rails

Stablecoin payments settle in seconds, around the clock, with no chargeback and no error-resolution regime. A crypto payments attorney walks through what actually happens behind a stablecoin payment, where the law protects you, where it doesn't yet, and what businesses should put in place before moving real volume onto the new rails.

August 31, 2026 · 12 min readRead More →
Client Guide

Your Protocol Just Got Hacked: The First 72 Hours — A Legal Playbook for Crypto Incident Response

In the first 72 hours after a crypto hack, the legal decisions — the bounty tweet, the freeze request, the forensics engagement, the public statement — determine whether the protocol ends the incident as a victim with live recovery options or as an OFAC violator and civil defendant. A playbook for founders and GCs.

July 18, 2026 · 30 min readRead More →
Regulatory Alert

When Does the GENIUS Act Actually Take Effect? The 120-Day Trigger and the January 18, 2027 Backstop

Federal regulators arrive at the GENIUS Act's July 18, 2026 rulemaking deadline with eleven proposed rules and zero final ones. That does not delay compliance — it fixes the effective date at January 18, 2027 while compressing the build window issuers have left.

July 18, 2026 · 17 min readRead More →
Thought Leadership

Who Is the BSA Customer When an AI Agent Sends Stablecoins?

The GENIUS Act made stablecoin issuers Bank Secrecy Act institutions, and AI agents are now sending stablecoins on their own. The customer-identification rules assume a person. Corporate law has answered the non-human-person question for two hundred years.

July 1, 2026 · 13 min readRead More →
Thought Leadership

Federal vs. State Stablecoin Regulation: Choosing Your Registration Path

The GENIUS Act sets up a dual-track registration regime for payment stablecoins — a federal path (OCC-supervised) and a state path for issuers at or below $10 billion in a certified state — but it is enacted, not yet effective, with implementing rules still in proposed form as of mid-2026. This guide compares the federal and state pathways, the preemption rules, and the strategic trade-offs once the regime takes effect.

June 19, 2026 · 24 min readRead More →
Client Guide

Stablecoin Reserve Requirements: Attestations, Custody, and Liquidity Management

The GENIUS Act sets a 1:1 reserve mandate for payment stablecoins — cash and short-dated Treasuries, monthly examinations, qualified custody — but it is enacted, not yet effective, with implementing rules still in proposed form as of mid-2026. This guide explains what the statute will require once effective, how today's attestation practice differs, and how to build a compliant reserve program.

June 19, 2026 · 30 min readRead More →
Client Guide

GENIUS Act Stablecoin Compliance: A 2027 Roadmap for Issuers

The GENIUS Act became law in July 2025, but its compliance cliff is January 18, 2027—and the implementing rules are still in proposed form. Here is what stablecoin issuers should be doing now, and the facts the early commentary got wrong.

June 14, 2026 · 12 min readRead More →
View All Articles

Building a Stablecoin or Payments Product?

GENIUS Act compliance, state licensing strategy, and reserve requirements — mapped to your launch timeline.

Discuss Compliance