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