GENIUS Act
GENIUS Act readiness checklist.
A working checklist of what payment stablecoin issuers should have in place before enforcement begins, drawn from our GENIUS Act guide.
01
Timeline & scope
- Plan against the deadline: GENIUS Act enforcement begins by January 2027, possibly as soon as late 2026.
- Start your infrastructure assessment now. Most stablecoin issuers already have.
- Confirm your obligations as a payment stablecoin issuer, including classification under the Bank Secrecy Act.
02
Verifiable data & reserves
- Be ready to prove every transaction: “our data provider handles that” is not an answer regulators accept.
- Provide data your examiner can independently reproduce.
- Support audited reserve disclosures with verifiable onchain data.
03
Lineage & traceability
- Trace every token from issuance to redemption with cryptographic proof.
- Maintain auditability and transaction traceability end to end.
- Be able to freeze, block, or burn tokens under lawful orders.
04
AML/CFT & risk
- Meet AML/CFT program requirements, including treasury screening.
- Be ready for SAR-filing obligations with supporting data infrastructure.
- Put operational risk management standards in place.
Gaps in the checklist? A Compliance Architecture Assessment walks through every item against your current stack, before your examiner does.
Based on the Edge & Node GENIUS Act guide (edgeandnode.com/articles/genius-act). Informational only, not legal advice.