CoinDesk
The GENIUS Act, the U.S. stablecoin law President Trump signed one year ago, triggered a two-year compliance countdown on Saturday for foreign issuers like Tether, whose USDT is the world's most-traded stablecoin. Tether has roughly until July 2028 to meet U.S. standards, though some lawyers read the law as forcing compliance for foreign issuers within months of the statute going live, likely by January 2027. As much as a quarter of USDT's reserves remain parked in assets the law is unlikely to bless, including precious metals, lending and Bitcoin, according to Tether's most recent disclosures.
Federal financial regulators, meanwhile, have not yet finalized the rules foreign issuers would have to follow. The OCC, the Treasury, the Fed and others have proposals in motion, but none have landed, leaving companies without a defined rulebook even as the first requirements approach. The longer-range demands include OCC registration, Treasury certification of a foreign issuer's home regulator as comparable to the U.S. regime, and custody of reserves at U.S. institutions. Lawyers at Davis Polk call the OCC registration requirement alone a significant undertaking.
Why it matters
The compliance question is structural, not cosmetic. Tether's rival Circle, U.S.-based and already operating under U.S. oversight, has moved further along the pre-compliance path, while Tether has so far declined to update its stance publicly. CEO Paolo Ardoino told CoinDesk at the White House last year that USDT would be managed to meet the foreign-issuer standard and that a separate U.S.-specific token was also planned. That token, USAT, launched through Anchorage Digital this year but remains at low usage. Tether did not respond to recent requests for an update. Anchorage's head of policy Kevin Wysocki said he expects institutional users to migrate to compliant, bank-issued digital dollars well ahead of the 2028 deadline, not at the deadline.
Market impact
Smaller U.S. venues with thinner legal teams are likely to delist non-compliant foreign stablecoins first, while larger exchanges are expected to fight for the volumes. Trevor Tanifum of consulting firm FS Vector expects major platforms to spend on lawyers and lobbyists rather than voluntarily give up the liquidity that USDT brings. Coinbase, the largest U.S. exchange, declined to discuss its listing plans.
Frequently asked questions
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How long does Tether have to comply with the GENIUS Act?
Most lawyers read the law as giving foreign issuers until July 18, 2028, to meet the full slate of U.S. stablecoin standards. Some interpret the statute as forcing foreign issuers to comply sooner, roughly six months after GENIUS officially goes live, likely by January 2027.
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What parts of USDT's reserves are at risk of falling short?
Tether's most recent disclosures show as much as a quarter of USDT reserves in assets the law is unlikely to bless, including precious metals, lending, and Bitcoin. The longer-range GENIUS requirements include OCC registration, Treasury certification of a comparable home regulator, and U.S.-based reserve custody.
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Has Tether said how it will meet the requirements?
CEO Paolo Ardoino told CoinDesk at the White House last year that USDT would be managed to meet the foreign-issuer standard and that a separate U.S.-specific token was planned. That token, USAT, launched through Anchorage Digital this year but remains at low usage. Tether did not respond to recent requests for an…
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What happens to USDT on U.S. exchanges if Tether misses the deadline?
Smaller U.S. venues with thin legal teams are likely to delist non-compliant foreign stablecoins first. Larger platforms are expected to fight for the volumes, spending on lawyers and lobbyists before voluntarily giving up USDT liquidity. Coinbase, the largest U.S. exchange, declined to discuss its listing plans.
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How are regulators doing on writing the GENIUS Act rules?
Federal regulators have proposals in motion but have not finalized the rules foreign issuers would have to follow. The OCC, Treasury, and Fed are all in various stages of rulemaking, leaving companies without a defined rulebook even as the first requirements approach. The companion Digital Asset Market Clarity Act is…
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