Treasury GENIUS Act Proposal Shifts Stablecoin Diligence Burden to Platforms
US platforms must perform due diligence on foreign stablecoin issuers under proposed Treasury rules, with implementation gates in 2027 and 2028.
Treasury proposed rules under the GENIUS Act that require US platforms to conduct reasonable due diligence on foreign stablecoin issuers before offering their tokens. Reliance on an issuer's representation of lawful-order compliance is barred if the platform knows or should know the representation is false.
At minimum, platforms must confirm the issuer is not subject to a public GENIUS Act prohibition. The proposal does not name qualifying tokens or decide the status of any specific stablecoin such as USDT.
Timing and open questions
Two timing gates apply. The general regime takes effect Jan. 18, 2027. A stricter limit begins July 18, 2028, under which covered providers may offer payment stablecoins to US persons only from permitted US issuers or qualifying foreign issuers meeting Section 18 requirements.
Comments close Oct. 19, 2026. Final rule text, issuer-specific decisions, and exact diligence documentation requirements remain pending.