Jason Gottlieb, Will Roth and Vani Upadhyaya Discuss GENIUS Act in Washington Lawyer

Partner Jason Gottlieb, Counsel William Roth and Associate Vani Upadhyaya authored an article in Washington Lawyer titled “GENIUS Act: A Regulatory First Step, Not the Final Word,” offering insight into the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The Act, signed into law on July 18, 2025, introduces “a comprehensive federal framework for regulating payment stablecoins while seeking to balance innovation, market integrity and consumer protection,” the authors explain.

The framework seeks to strike a balance by:

• Requiring third-party service providers to offer only compliant payment stablecoins in the U.S.
• Assigning oversight authority to both federal and state regulators
• Creating a new Stablecoin Certification Review Committee to serve as a regulatory gatekeeper

However, the authors point out certain ambiguities that remain. For example, states may take differing approaches in establishing their own stablecoin regulatory systems that must be “substantially similar” to the federal framework. Additionally, there are challenges for foreign issuers and the digital asset service providers that seek to make foreign stablecoins available domestically. 

Further, the authors note that “the Act’s restrictions on noncompliant stablecoins raise significant questions about enforcement for decentralized exchanges or other DeFi protocols that operate without centralized control and may unintentionally make available noncompliant stablecoins.”

The authors conclude that despite the significant uncertainties that remain, “the Act marks a step toward integrating stablecoins into the ever-evolving financial system.”

Read the full article here