The US Treasury has proposed comprehensive gatekeeping rules for the GENIUS Act that establish clear pathways for foreign stablecoin issuers to access the US market. According to the latest Treasury proposal, beginning July 18, 2028, digital asset service providers (DASPs) will generally be able to offer payment stablecoins to US customers only if the stablecoins are issued by a Payment-Permitted Stablecoin Issuer (PPSI) or a qualifying Foreign Payment Stablecoin Issuer (FPSI). This represents a significant shift from the original legislation, which placed immediate restrictions on foreign-issued stablecoins. The proposal acknowledges practical difficulties in applying the provision, noting that DASPs may lack full insight into an FPSI's technological capability and cannot know with certainty whether the FPSI will comply in the future. Treasury proposes that DASPs may rely on an FPSI's representation that the issuer has the technological capability to comply with lawful orders and reciprocal arrangements, provided the DASP conducts reasonable due diligence. However, DASPs cannot rely on such representations if they know, have reason to know, or should know that the representation is false, that the FPSI lacks the required technological capability, or that the FPSI will not comply with a lawful order or reciprocal arrangement.
The Treasury Department has outlined specific criteria that foreign payment stablecoin issuers must meet to access the US market. According to the latest proposal, an FPSI must be subject to regulation and supervision by a foreign payment stablecoin regulator that the Treasury Secretary determines, upon the recommendation of each other member of the Stablecoin Certification Review Committee, has a payment stablecoin regulatory and supervisory regime 'comparable' to the regime applicable to PPSIs. The FPSI must also be registered with the OCC and hold reserves in a US financial institution sufficient to meet liquidity demands of US customers, except as otherwise permitted under a reciprocal agreement entered into by the Treasury Secretary. Additionally, the foreign country in which the FPSI is domiciled and regulated must not be subject to comprehensive US sanctions or designated as a jurisdiction of primary money laundering concern. This comprehensive framework ensures that foreign issuers meet equivalent regulatory standards while maintaining US market access.
The stablecoin market is witnessing a fundamental shift as traditional payment schemes position themselves as the operating system for programmable money. Visa's new Stablecoin Platform, revealed in July and initially available in beta, represents the clearest recent example of this transformation. The platform provides banks, fintechs and crypto businesses with a Visa-managed environment where they can mint, redeem, hold and transfer stablecoins, including wallet infrastructure, approval policies, audit logs, passkeys and transfer allow-lists. This development comes as stablecoins begin to move from crypto trading infrastructure into regulated institutional payments, with banks under growing pressure to offer tokenised services without taking on uncontrolled technology or compliance risk. The response from traditional payment schemes has not been to sullenly defend the old model from the sidelines - instead, both groups are trying to make themselves indispensable to the next generation of programmable money by embedding themselves within the infrastructure of stablecoin payments.
A managed stablecoin payment operates through four operational layers that fundamentally change how business value moves across borders. The blockchain network records the transfer and provides transaction finality according to network rules, with CFOs evaluating reliability, settlement characteristics, network costs, and operational resilience. The stablecoin issuer maintains the asset and its redemption mechanism, with reserve quality, transparency, liquidity, and issuer risk being material treasury considerations. Wallet and key management controls who can authorize transactions, with businesses managing this directly or delegating custody to regulated providers. The payments infrastructure connects the digital settlement rail to recipient onboarding, compliance controls, fiat funding, currency conversion, local payout rails, payment status, and reconciliation data. This infrastructure includes wallets, controls, interoperability, security and settlement services that institutions need before programmable money can operate at scale.
The GENIUS Act adds separate regulatory tests for issuers seeking US market access, with Treasury's proposed implementation framework restricting payment stablecoin issuance after January 18, 2027. According to crypto.news, the law places conditions on foreign-issued stablecoins and includes a further restriction beginning July 18, 2028, when digital asset service providers generally would no longer be permitted to offer payment stablecoins to US customers unless licensed issuers provide them. For institutions choosing among eligible stablecoins, Sham said formal authorization will be only the starting point, with firms examining issuer redemption terms, reserve quality and concentration, asset segregation, and independent reporting capabilities. The law places conditions on foreign-issued stablecoins and includes restrictions on digital asset service providers offering payment stablecoins to US customers.
