U.S. prosecutors are increasingly asking stablecoin issuers to freeze wallet addresses voluntarily — bypassing the judicial authorisation normally required for asset seizures. Unlike traditional forfeiture, which demands a demonstrated link to criminal activity and court approval, these issuer-initiated freezes can lock out holders who acquired funds through entirely legitimate means, with little notice and limited recourse.
The GENIUS Act reinforces this dynamic by requiring stablecoin issuers to maintain the technical capability to freeze, burn, or restrict tokens on law enforcement request. Because issuers typically defer to the requesting agency without knowing the underlying basis, affected holders must engage government directly — often facing an informal burden-of-proof reversal that demands contemporaneous documentation of every transaction in the chain.
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