Stablecoins

4 articles

July 1, 2026

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.

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.

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.

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.

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