Circle Submits Comment Letter on Proposed GENIUS Licensing Regime

On May 1, Circle submitted comments to the Office of the Comptroller of the Currency (OCC) on its proposed rule implementing the landmark GENIUS Act (the “Act”) which establishes a first-of-its-kind digital payments regime in the United States for payment stablecoins.

The OCC’s proposed framework—which lays out standards for everything from reserve management to information security—represents a major regulatory milestone in the development of the payment sector, establishing the intensive risk management, significant operational resourcing, and dedicated and seamless 24/7/365 functionality that an institution-grade digital financial services entity needs. It builds on the foundational requirements Congress established in the GENIUS Act: strong reserves, reliable redemption, sound risk management, effective supervision, and high standards for compliance.

Why this matters: payment stablecoins are becoming part of the global financial system. To be useful at scale, they need to be safe, transparent, redeemable, and trusted by consumers, businesses, financial institutions, and regulators. The OCC’s rulemaking turns the GENIUS Act into a durable framework that works in practice, requiring issuers to meet highest-level standards of a standalone, ring-fenced entity with all of the capacity to meet the large demands placed on global issuers.

Circle’s submission highlights a number of technical areas of feedback and is rooted on the following core principles:

• U.S. standards should lead globally. The GENIUS Act is designed to extend the benefits of U.S. regulation, the rule of law, and secure digital money around the world. This matters because strong U.S. rules can help set the global benchmark for trusted digital dollars.
• Regulated payment stablecoins must work as one instrument. The value of a payment stablecoin comes from being transferable, fungible, and usable across customers, platforms, and markets. That matters because fragmentation can add risk to the global payment system while making digital money less liquid and harder to redeem.
• Consumer protection must remain central. Payment stablecoin issuers must be able to redeem stablecoins reliably for holders wherever they are. This matters because confidence in a stablecoin ultimately depends on a simple promise: holders should be able to get their money back when they need it, where they need it.
• Strong rules should create a strong market. Tokens should not be able to market themselves as “stable” without meeting robust standards. This matters because consumers and businesses should not have to read the fine print to know whether a dollar-backed digital instrument is actually subject to meaningful oversight. This was Congress’ vision with the Act. 
• All issuers should compete on an even playing field. Whether bank or nonbank, state or federal, and domestic or foreign, all issuers should operate within a common prudential perimeter. This matters because regulatory arbitrage can weaken trust and put compliant issuers at a disadvantage.
• Risk management must match the role stablecoins play. Regulated payment stablecoins require strong frameworks for credit, liquidity, concentration, operational, and anti-money laundering risks. This matters because stablecoins are not just technology products; they are payment and settlement instruments that depend on resilient financial and operational controls.
• Payment stablecoins should not be confused with tokenized deposits. Stablecoins and tokenized deposits serve different purposes and should not be treated as interchangeable payments and settlement assets. Congress explicitly carved tokenized deposits out of the Act because payment stablecoins are built for broad transferability and settlement, while tokenized deposits are meant to be digital representations of bank liabilities. Tokenized deposits raise different questions that require their own regulatory framework.

The GENIUS Act marked a turning point for dollar-backed digital money. The OCC’s proposed rule is an important step toward making that framework real. With clear, practical, and consistently applied rules, the United States can protect consumers, build the market of the future, and strengthen the role of trusted digital dollars in the global economy.