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Blockchain Association Urges Treasury to Clarify Stablecoin Rules Under GENIUS Act

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The U.S. Blockchain Association has submitted feedback on proposed Department of the Treasury regulations implementing Section 3 of the GENIUS Act. The industry group is seeking clearer operational boundaries for businesses operating in the stablecoin sector.

Among its recommendations, the association urged regulators to narrow the definition of digital asset service providers so that self-custody software, network validators, general infrastructure, and firms trading only their own assets are excluded. It also stated that criminal liability for illegal stablecoin issuance should require proven knowledge and direct assistance. Additionally, the group advised using official lists and trading bans to evaluate foreign stablecoins, alongside updated methods for identifying user locations on permissionless networks.

Market participants will be watching how Treasury responds to these comments as it finalizes the enforcement rules for the GENIUS Act, which could establish major legal precedents for digital asset liability and infrastructure compliance.

Key points

  • The U.S. Blockchain Association filed comments on proposed Treasury rules for Section 3 of the GENIUS Act.
  • The group asked to exclude self-custody software, network validators, and proprietary traders from being classified as digital asset service providers.
  • It recommended that criminal liability for illegal stablecoin issuance require actual knowledge and coordinated assistance.
  • Recommendations included using official lists to check foreign stablecoin compliance and updating user location metrics for permissionless protocols.

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Questions and answers

What did the Blockchain Association ask Treasury regarding the GENIUS Act?

The group submitted comments requesting clearer boundaries for stablecoin businesses, including narrower definitions for service providers and specific rules for criminal liability and foreign compliance.

Who should be excluded from digital asset service provider rules under the proposal?

The association recommended excluding self-custody software, network validators, general infrastructure providers, and entities that transact exclusively in their own assets.

What conditions did the association suggest for stablecoin criminal liability?

The association stated that criminal liability for participating in unlawful stablecoin issuance should require actual knowledge and substantial assistance coordinated with the issuer.