The GENIUS Act’s Signing Triggers Countdown to New Stablecoin Rules
On Friday, President Donald Trump signed the GENIUS Act (S.1582)[1] into law, one day after the U.S. House of Representatives passed the bill by a vote of 308 to 122 and a month after the Senate approved it, 68 to 30. The GENIUS Act establishes a framework for the regulation stablecoins, and it is the first major piece of federal legislation affecting digital assets in the United States.
Policy Tracker
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Sep 19, 2025
Treasury Department solicits public comment on GENIUS Act implementation
United States (Regulatory)
On September 19, 2025, the Treasury Department issued an advance notice of proposed rulemaking (ANPRM) to solicit input on the agency’s forthcoming implemention of the GENIUS Act, the U.S.’s first comprehensive stablecoin law. The ANPRM seeks public comment on how federal agencies should define supervisory thresholds for “permitted payment stablecoin issuers” (PPSIs), design redemption and technical freeze controls, and align issuer reporting with existing frameworks under the Bank Secrecy Act and applicable sanctions regulations. The ANPRM follows Treasury’s August 18 request for information under Section 9(a) of the Act, seeking comment on possible innovative methods for detecting illicit activity involving digital assets.
Together, these measures mark the formal start of the Act’s rulemaking phase and the first coordinated effort to operationalize prudential and compliance mandates on stablecoin issuance at the federal level. Public feedback will guide joint regulations to be issued by the Treasury, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the Federal Reserve, each responsible for delineated oversight authority and supervisory scope. These regulatory actions signal that federal agencies will likely be prepared with final regulations in time for the Act’s stated deadline of January 2027.
Last updated 11/03/2025.
History:
- Sep 19, 2025: The Treasury Department issues an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions relevant to the GENIUS Act’s implementation. 90 Fed. Reg. 45159.
- Aug 18, 2025: The Treasury Department and the Treasury’s Financial Crimes Enforcement Network (FinCEN) issues a request for comment on innovative methods to detect illicit activity involving digital assets (relevant to the requirements of Section 9(a) of the GENIUS Act). 90 Fed. Reg. 40148.
- Jul 18, 2025: President Donald Trump signs the GENIUS Act into law, making it the first major federal statute governing cryptocurrency and establishing a regulatory framework for payment stablecoins. S.1582.
- Jul 17, 2025: The House of Representatives passes the GENIUS Act in a 308–122 vote, clearing the final legislative hurdle and sending the bill to President Trump for signature.
- Jun 17, 2025: The Senate passes the GENIUS Act with bipartisan support in a 68–29 vote, advancing the landmark stablecoin legislation to the House of Representatives for consideration.
- May 01, 2025: Sen. Bill Hagerty (R-Tenn.) introduces a new version of the GENIUS Act to the Senate of the 119th Congress. S.1582.
Aug 22, 2025
CFPB seeks public comment on possible revision to financial information rights rule
United States (Regulatory)
On August 22, 2025, the Consumer Financial Protection Bureau (CFPB) issued an advance notice of proposed rulemaking (ANPR) to reopen and revise Rule 1033, the Bureau’s personal financial data rights rule. The action follows the CFPB’s July 2025 motion to stay proceedings in the Bank Policy Institute’s (BPI) lawsuit challenging the Rule, in which the CFPB told the court it would “comprehensively reexamine” the regime through an accelerated rulemaking process. The CFPB’s new notice seeks comment on potential revisions to the Rule’s scope, data sharing architecture, and implementation timelines. This comes at a time when the Bureau is operating with significantly reduced staff following layoffs and a series of departures among senior rulemaking and enforcement personnel, raising questions about the agency’s near-term capacity to manage complex technical regulations. Fintech firms and consumer advocates generally view the CFPB’s renewed rulemaking efforts as an opportunity to modernize Rule 1033 while preserving the competitive benefits of API-based data portability.
Rule 1033, authorized by Section 1033 of the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010, establishes consumer rights to access and share their transaction-level financial data. The Rule, finalized in 2024 after years of development and industry consultation, obligates covered banks and card issuers to provide such data (without charge) directly to the consumer or to any third party the consumer designates. Banking trade groups maintain that the Rule exceeds the Bureau’s statutory authority and would impose uncompensated infrastructure and cybersecurity burdens. Stakeholders may present their positions during the public comment period, closing October 21, 2025.
Last updated 11/03/2025.
History:
- Aug 22, 2025: The CFPB issues an advance notice of proposed rulemaking to reopen and revise Rule 1033, soliciting comments through October 21, 2025. 90 Fed. Reg. 40986.
- Jul 29, 2025: The CFPB announced its intent to revise Rule 1033 in its motion to stay proceedings in the Bank Policy Institute’s lawsuit challenging the Rule. Forcht Bank, NA v. CFPB, Doc. 80 (CFPB Motion to Stay).
- Nov 18, 2024: The CFPB publishes the final version of Rule 1033. 89 Fed. Reg. 90838.
- Oct 31, 2025: The CFPB publishes its Notice of Proposed Rulemaking for Rule 1033.88 FR 74796.
- Jul 21, 2010: President Barack Obama signs the Dodd–Frank Wall Street Reform and Consumer Protection Act, directing the CFPB to write rules giving consumers on‑demand access to their account data. Pub. L. No. 111‑203, 124 Stat. 1376 (2010).
Jul 22, 2025
Senate refers modified illicit finance bill targeting crypto and fintech to Committee on Banking, Housing, and Urban Affairs
United States (Legislative)
The Financial Technology Protection Act of 2025 (H.R. 2384) is currently pending in the Senate Committee on Banking, Housing, and Urban Affairs. The legislation seeks to counter the growing threat of digital assets being used for terrorism financing and other illicit activities by establishing an Independent Financial Technology Working Group to Combat Terrorism and Illicit Financing. If enacted, the group would be led by the Treasury Department’s Under Secretary for Terrorism and Financial Crimes and include senior officials from the DOJ, FBI, IRS, DHS, DEA, and other agencies. Private-sector representatives from financial technology firms, blockchain intelligence companies, financial institutions, academic institutions, and privacy and civil liberties groups would also participate.
The Working Group would research the illicit use of digital assets, recommend legislative and regulatory actions to strengthen anti-money laundering and counter-terrorism financing frameworks, and produce annual reports to Congress. The bill also requires a final report before its four-year sunset and the release of a public strategy to prevent sanctioned or terrorist entities from exploiting digital assets. Originally introduced in 2023 as H.R. 2969, the bill has been reintroduced in 2025 with the same core objective of addressing the misuse of emerging financial technologies.
Last updated 07/22/2025.
History:
- Jul 22, 2025: The Senate received the proposed bill and referred it to the Senate Committee on Banking, Housing, and Urban Affairs.
- Jul 21, 2025: After consideration and debate, the House passed a motion to reconsider without objection
- May 06, 2025: The House Committee on Financial Services amends the proposed bill and places it on the Union Calendar.
- Mar 26, 2025: Rep. Zachary Nunn (R-Iowa) reintroduces the Financial Technology Protection Act to the House of Representatives of the 119th Congress. H.R. 2384.
- Jul 23, 2024: The Senate receives the House bill and refers it to the Committee on Banking, Housing, and Urban Affairs, and the Senate failed to take up the legislation before the close of the 118th Congress.
- Jul 22, 2024: The House of Representatives of the 118th Congress passes a bill to establish the Financial Technology Protection Act (which was first introduced in 2023) with overwhelming support from both parties. H.R. 2969.
Jul 18, 2025
House passes CLARITY crypto market structure bill
United States (Legislative)
On July 17, 2025, the House of Representatives passed the Digital Asset Market Clarity Act of 2025 (“CLARITY Act”) by a vote of 294–134, advancing the most comprehensive federal digital asset market structure bill to date. The legislation now heads to the Senate. The final House version preserves language establishing a new “tradable asset” category, which covers digital assets that are neither “digital commodities” nor “restricted digital securities”, and assigns oversight of those assets to the Commodity Futures Trading Commission (CFTC). It also imposes new insolvency disclosure obligations on broker-dealers, and exempts developers and decentralized protocols from money transmission licensing requirements when they lack control over consumer funds.
Originally introduced by Financial Services Committee Chair French Hill (R-AR) on May 29, the bipartisan bill divides jurisdiction over digital assets between the CFTC and the Securities and Exchange Commission (SEC). The SEC would retain authority at the initial distribution phase for certain token projects, whereas the CFTC would regulate most secondary market trading. The Act creates a CFTC-led registration framework for exchanges and intermediaries, requires asset segregation and disclosures, and prohibits staking as a condition of access. The bill also aligns with the GENIUS Act, the new stablecoin law signed into law in July, signaling growing bicameral momentum for a unified digital asset regulatory framework.
Last updated 07/18/2025.
History:
- Jul 17, 2025: The House of Representatives passes the CLARITY Act by a vote of 294–134, advancing the bill to the Senate.
- Jun 10, 2025: The House Financial Services and Agriculture Committees advance key amendments to the CLARITY Act bill before moving it to the floor of the House of Representatives for a vote.
- May 29, 2025: House Financial Services Committee Chair French Hill (R-Ark.) introduces the bipartisan CLARITY Act, a bill that would allocate digital asset oversight between the SEC and CFTC and establish a maturity framework for when cryptocurrency projects would shift between the two agencies.
Court Tracker
Consider DLx Law a source for updates on recent legal outcomes and ongoing cases that are shaping the landscape of blockchain and the financial services industry. With our Court Tracker, you can closely monitor other legal developments that are noteworthy for many of our clients and the industry as a whole. Check back in from time to time to stay informed about some recent regulatory enforcement actions and notable court cases.
Importantly, we make no representation whatsoever that the Court Tracker is up to date, comprehensive, or accurate, and it should not be relied on as legal or regulatory advice. Read our full disclaimer.
Notable Decisions
SEC v. Terraform Labs PTE Ltd. & Do Hyeong Kwon
S.D.N.Y. (Fed. Trial Ct.)
Filed: Feb 16, 2023
Description: The SEC charged Terraform Labs PTE Ltd and Do Hyeong Kwon with a multibillion-dollar crypto asset securities fraud. The SEC alleged that from April 2018 to May 2022, Terraform and Kwon raised billions of dollars from investors by offering and selling digital asset securities, including an algorithmic stablecoin called Terra USD (UST) and other crypto asset securities, many in unregistered transactions. In its complaint, the SEC alleged the following digital assets are unregistered securities: UST, LUNA, MIR.
Judgment entered
(Jun 12, 2024 )
Summary: The defendants entered a settlement agreement with the SEC, and the judge entered the consent order on June 12, 2024, with civil penalties, including just under $4.5 million in total monetary remedies against Terraform Labs, to be allocated under the organization’s Chapter 11 plan in U.S. Bankruptcy Court.
SEC v. Beaxy Digital, Ltd., et al.
N.D. Ill. (Fed. Trial Ct.)
Filed: Dec 25, 2023
Description: The SEC charged Beaxy (a digital asset trading platform) and its executives and founders with (1) raising $8 million in an unregistered securities offering (BXY tokens), misappropriating $900,000 of it for personal use, and (2) failing to register as a national securities exchange, broker, and clearing agency when facilitating the purchase and sale of digital assets as securities. The SEC alleged in its complaint that BXY tokens are securities.
Judgment entered
(Feb 13, 2024 )
Summary: The court entered default judgment against the defendants after they failed to make an appearance or respond to the SEC’s complaint.
In re: Coinbase Inc.
3d Cir. (Fed. Appeals Ct.)
Filed: Apr 24, 2023
Description: In spring of 2023, Coinbase filed an appellate-level petition seeking a writ of mandamus to compel the SEC to act on Coinbase’s pending rulemaking petition to provide clarity for the crypto industry.
Judgment entered
(Dec 18, 2023 )
Summary: Considered to be in large part the result of Coinbase’s mandamus petition seeking to compel a decision, the SEC on December 15, 2023, finally issued a formal decision denying Coinbase’s petition to have the SEC engage in rulemaking to clarify its interpretation of how securities laws can be applicable to business activities involving cryptocurrencies. As a result, the judge denied Coinbase’s mandamus petition as moot. Although it is not the outcome Coinbase sought, it now has a judicially reviewable decision to move forward with.
Ongoing Cases
U.S. v. Iurii Gugnin
E.D.N.Y. (Fed. Trial Ct.)
Filed: Jun 9, 2025
On June 9, 2025, the Department of Justice (DOJ) unsealed a 22-count indictment against crypto executive Iurii Gugnin, charging him with laundering over $500 million through cryptocurrency exchanges and U.S. banks. Prosecutors allege that Gugnin primarily acted on behalf of sanctioned Russian financial institutions, using his company, Evita, to facilitate transactions for various sanctioned entities worldwide. The DOJ also charged Gugnin with wire fraud, conspiracy to defraud the United States, and operating an unlicensed money transmitter business. Although Evita held a money transmitter license in Florida, the DOJ asserts that Gugnin secured it through fraudulent representations. If convicted, Gugnin faces a potential life sentence. Prosecutors claim Gugnin used Evita to facilitate purchases for foreign clients, including U.S. electronics and components (including those subject to export controls) for Rosatom, Russia’s state-owned nuclear technology company. Gugnin allegedly knew authorities were investigating him; the DOJ states he searched the web for “how to know if there is an investigation against you” and “evita investments inc. criminal records search.”
Status: DOJ prosecutors unsealed the 22-count indictment against Iurii Gugnin on June 9, 2025, and Gugnin was immediately arrested and now awaits trial. Updated 06/11/2025.
SEC v. Consensys Software Inc.
E.D.N.Y. (Fed. Trial Ct.)
Filed: Jun 28, 2024
Description: The SEC charged Consensys Software Inc., the development company behind MetaMask, for allegedly conducting unregistered offers and sales of securities by facilitating investments by MetaMask users into certain cryptocurrency staking protocols, namely, Lido and Rocket Pool. According to the SEC’s complaint, Consensys failed to register as a broker and did not meet the legal requirements for offering staking services while it collected more than $250 million in fees. The SEC’s complaint comes shortly after Consensys sued the SEC in April following its receipt of a Wells notice from the agency, challenging its attempts to classify ETH tokens and related staking service protocols as being unregistered securities.
Status: In anticipation of forthcoming guidance from the SEC’s Crypto Task Force, the SEC and Consensys jointly agreed to dismiss the case with prejudice. The move signals a strategic retreat in the agency’s approach to crypto infrastructure. It marks a win for firms that provide foundational services such as wallets and developer tools, rather than issuing or promoting tokens, and suggests that future enforcement may be reshaped by evolving internal policy. Updated 03/27/2025
U.S. v. Roman Storm et. al.
S.D.N.Y (Fed. Trial Ct.)
Filed: Aug 21, 2023
The U.S. government filed criminal charges against Tornado Cash developer Roman Storm on August 21, 2023, alleging that he conspired to operate an unlicensed money-transmitting business, violated U.S. sanctions law, and engaged in money laundering in connection with his role in developing the Tornado Cash protocol. Storm faces up to 45 years in prison if convicted. The case is viewed as a major test of developer liability in decentralized finance and the legal treatment of smart contracts and dApps. Storm’s defense argues that Tornado Cash’s smart contracts are immutable and self-executing, and that Storm did not actively facilitate money laundering. Counsel maintains the protocol was designed to enhance privacy in the transparent crypto ecosystem and that Storm’s code contributions are protected speech under the First Amendment. Prosecutors responded that Tornado Cash was repeatedly used to launder illicit funds, including by the Lazarus Group, a North Korean state-backed hacking organization under U.S. sanctions.
Status: On August 6, 2025, a federal jury convicted Roman Storm of operating an unlicensed money transmission business, following four days of deliberation. The jury acquitted Storm on related counts of money laundering and sanctions evasion, which carried potential 20-year prison terms. Storm now faces a maximum sentence of five years. He remains free on bail and is expected to appeal the conviction. Updated 08/11/2025.
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