GENIUS Act Compliance Guide
Complete implementation checklist for stablecoin issuers preparing for GENIUS Act requirements
Table of Contents
Executive Summary
The Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act establishes a comprehensive regulatory framework for payment stablecoin issuers in the United States.
Key Deadline
Compliance Required By: 18 months from enactment
All existing stablecoin issuers must submit initial registration applications within this timeframe.
Key Requirements
1. Registration & Licensing
Federal registration with OCC or state banking regulator
Minimum capital requirements based on outstanding stablecoins
Board-approved written policies and procedures
2. Reserve Requirements
100% backing with high-quality liquid assets
Segregated custodial accounts for reserve assets
Monthly independent audits and attestations
3. Consumer Protection
Clear redemption rights and processes
Disclosure requirements for risks and terms
Cybersecurity and operational resilience standards
Implementation Checklist
Phase 1: Preparation (Months 1-6)
- ☐ Gap analysis of current practices vs. GENIUS requirements
- ☐ Engage legal counsel and compliance advisors
- ☐ Develop implementation project plan and budget
- ☐ Establish compliance committee and governance structure
Phase 2: Infrastructure (Months 7-12)
- ☐ Implement reserve management and custody systems
- ☐ Develop audit and attestation processes
- ☐ Build compliance monitoring infrastructure
- ☐ Create consumer disclosure documentation
Phase 3: Registration (Months 13-18)
- ☐ Prepare and submit registration application
- ☐ Respond to regulator inquiries and requests
- ☐ Complete first independent audit and attestation
- ☐ Finalize all policies, procedures, and disclosures
How Veria Simplifies GENIUS Compliance
Automated Reserve Monitoring
Real-time verification of reserve assets with blockchain attestation and automated compliance reporting.
Audit-Ready Reporting
Generate monthly attestation reports automatically with audit trails and evidence documentation.
Consumer Protection Tools
Pre-built disclosure templates and redemption tracking to meet consumer protection requirements.
Regulatory Intelligence
Stay updated on GENIUS Act guidance, interpretations, and regulatory developments.
Ready to Implement GENIUS Compliance?
Schedule a consultation with our compliance experts to develop your custom implementation roadmap.