Here’s the moment people in this space always ask for and rarely get: a real window to influence the rulebook before it’s written.
On 19 September 2025, the U.S. Department of the Treasury opened an Advance Notice of Proposed Rulemaking (ANPRM) to gather public input on how to implement the Guiding and Establishing National Innovation for U.S. Stablecoins GENIUS Act.
It’s the start of turning statute into day-to-day rules – and Treasury is asking for help, on the record, by 20 October 2025. (Separately, its earlier 18 August Request for Comment on detecting illicit activity in digital assets is still open until 17 October 2025.)
From Law to Rulebook
The GENIUS Act is already on the books.
It tasks Treasury with designing regulations that support payment-stablecoin innovation while balancing illicit-finance risk, consumer protection, and financial stability.
The ANPRM is the first formal step in that implementation.
Treasury signals exactly what it wants to hear about: regulatory clarity, AML and sanctions obligations, tax treatment, the state–federal balance, and other foundational issues that will decide how “permitted payment stablecoins” operate in practice.
What “Permitted” Means in Plain English
Under the framework, only permitted payment stablecoin issuers (PPSIs) are allowed to issue payment stablecoins in the United States, with limited exceptions for certain foreign issuers that meet criteria set by U.S. standards.
The Act contemplates reserve requirements, marketing restrictions, and penalties for non-compliance.
Treasury’s job is to specify the details, including how to prevent illicit finance in this market and how issuers and service providers should meet Bank Secrecy Act and sanctions expectations.
The Questions on Treasury’s Desk
Treasury groups its request for input into six headings: issuers and service providers, illicit finance, foreign payment-stablecoin regimes, taxation, insurance, and economic data. Within those, it poses targeted prompts. A sample of what it’s asking:
- How should regulations execute Section 3(a) – which makes it unlawful for any person other than a PPSI to issue a payment stablecoin in the U.S., and should safe harbours exist?
- What clarifications are needed around Section 4(a) on reserves and the requirement to publish reserve composition?
- Is the statutory definition of “payment stablecoin” sufficiently clear, or does it need sharpening?
- How should payment stablecoins not issued by a PPSI be treated for accounting under Section 3(g)(1)?
- What should Treasury require under Section 4(a)(5) for AML/sanctions programmes, from suspicious-activity monitoring to customer identification and due diligence?
- Which factors should determine whether a foreign jurisdiction’s regime is comparable to U.S. requirements—and what should disqualify a jurisdiction from being deemed comparable?
Each of these asks is straight from the ANPRM: Treasury is opening the door for concrete, line-by-line feedback on how the Act should work in the wild.
Foreign Issuers and the Comparability Test
One of the more consequential choices ahead concerns foreign-issued payment stablecoins.
The GENIUS Act allows for the possibility that certain foreign issuers could operate in the U.S. if their home regimes are comparable to the U.S. framework. Treasury is therefore seeking input on the criteria for that judgment.
The stakes are obvious: the comparability test will influence which tokens can be offered to U.S. users, how cross-border distribution is supervised, and how firms structure their compliance footprints.
What This Means if You Build, Bank, or Buy
If you issue or service stablecoins, the ANPRM is effectively a checklist of the obligations that will define your operating model: reserves and disclosures, programme governance, sanctions screening, reporting, customer diligence, and the treatment of non-PPSI instruments.
If you are a financial institution, these rules will shape counterparty standards, product approvals, and risk assessments.
If you are a user or merchant, the comment process is where questions about transparency, redemption mechanics, and consumer protection can be surfaced with the regulator that’s drafting the rules.
Dates That Matter
Two clocks are running.
Comments on Treasury’s illicit-finance Request for Comment (the broader digital-asset piece) are due 17 October 2025.
Comments on the GENIUS Act ANPRM – the stablecoin-specific implementation are due 20 October 2025.
Miss those dates and the first, formative round of input becomes history.
The Policy Pulse
GENIUS moved from theory to practice the moment Treasury opened this ANPRM.
The agency is asking pointed questions about who may issue, what reserves must look like, how transparency should work, how AML/sanctions controls must be structured, how taxes and insurance should be treated, and which foreign regimes can qualify as “comparable.”
If you care about the design of U.S. payment-stablecoin markets, this is the window.
The law sets the destination, this process decides the route.
