top of page

Stablecoins US Regulations 2025: GENIUS Act Drives Mainstream Adoption and Fee Savings 📰

Updated: Oct 26

Summary: 

  • The GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) was enacted on July 18, 2025[22], creating the first federal regulatory framework for U.S. dollar-backed payment stablecoins

  • The law mandates that these stablecoins be fully backed 1:1 by safe assets (U.S. cash or short-term Treasuries)[23] and subjects issuers to bank-like oversight. On Sept. 18, 2025, the Treasury issued an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comments (deadline Oct. 20)[24].

  • Together, these steps aim to integrate stablecoins into the banking system, promoting consumer protection and driving widespread adoption. Proponents predict corporate users could see over 5% reductions in transaction fees (due to faster, blockchain-based payments) once regulated stablecoins scale in areas like cross-border remittances.


What is the GENIUS Act

The GENIUS Act was introduced in early 2025 and passed by the Senate (6830) on June 17 and by the House (308122) on July 17[25]. President Trump signed it into law on July 18, 2025[26][22]. It takes effect within 18 months unless regulators act sooner. The law defines a payment stablecoin as a digital asset redeemable one-for-one with USD, issued only by chartered U.S. banks or OCC-licensed nonbank firms. In practice, that means companies like Circle (operator of USDC) or Paxos can issue regulated digital dollars only if they meet the new standards.



Under GENIUS, each payment stablecoin must have 100% reserve backing by liquid U.S. assets[27][23]. Eligible reserves include U.S. coins, bank deposits, and short-dated Treasury bills (no corporate debt). These reserves must be held in segregated accounts (unable to be lent out or pledged) with quarterly audits and public disclosure of composition[27][23]. Issuers cannot offer interest or yields on the coins  they function like digital cash.


The Act also extends bank-level regulation to stablecoin issuers. Federally insured banks will be regulated by their usual supervisors; nonbank issuers must be certified by a newly created Stablecoin Certification Review Committee and overseen by the Office of the Comptroller of the Currency (OCC)[28][29]. This means stablecoin issuers will face capital, liquidity and anti-money-laundering requirements akin to banks[30]. Importantly, the law explicitly states that compliant payment stablecoins are not securities or commodities under U.S. law[28], clearing up long-standing legal uncertainty. Smaller issuers (with under $10 billion coin supply) can operate under equivalent state rules if those closely mirror the federal standards[29].


ree

By mid-2025, stablecoin transfers had grown enormously  well over $100 billion worth of transactions were being settled monthly on networks like Ethereum. The GENIUS Act responds to calls for clarity from regulators (including the President’s Working Group) and industry. It aims to reinforce the U.S. dollar’s digital role globally. Key stakeholders include major issuers (Circle/USDC, Paxos/BUSD, etc.), banking giants testing stablecoin pilots (e.g. JPMorgan), and federal agencies seeking to balance innovation with safeguards. The legislation followed earlier presidential support for digital assets (Trump’s 2021 “crypto” executive order) and puts the U.S. on track to lead in stablecoin infrastructure.


Details of the Stablecoin Framework

Reserves and Custody: Payment stablecoins must be backed 1:1 by safe U.S. assets[23]. Practically, that means an issuer holds, for each coin outstanding, an equal amount of cash or short-term Treasury securities in a regulated account. These funds must be held by qualified custodians (banks or trust companies) and cannot be commingled with other assets[23]. The Act requires monthly public reports of reserve holdings, building trust. If an issuer ever fails, holders of the stablecoin are first in line to recover assets[31].


Bank-like Regulation: By law, payment stablecoin issuers are treated as financial institutions under the Bank Secrecy Act[30]. That means full AML/KYC programs. Issuers must also meet capital and operational standards: for example, they cannot offer “yields” on coins and must invest reserves only in government-backed instruments[32]. In the event of bankruptcy, stablecoin holders’ claims have priority over other creditors (a special bankruptcy priority)[31].


Issuers & Oversight: Qualified issuers fall into three categories: (1) banks and credit unions, (2) OCC-chartered nonbank issuers that receive federal approval, and (3) state-chartered issuers under “substantially similar” laws[29][33]. Nonbank companies (like fintechs) must be certified by a federal committee before issuance[29]. Overall supervision will primarily involve the Federal Reserve, Treasury and OCC, whereas traditional SEC/CFTC authority is preempted (stablecoins cease to be treated as securities or commodities)[28].


Efficiency & Cost Savings: By formalizing 1:1 stablecoins, the Act is expected to greatly streamline transactions. For example, big corporations that often pay tens of millions in cross-border fees may use stablecoins to transact directly, bypassing multiple correspondent banks. Early pilots (e.g. JPMorgan’s stablecoin tests) have shown cost savings of 5070% on remittances. Industry analysts estimate that corporate treasury departments could cut global payments costs by 510% once stablecoins are broadly integrated into banking networks. These savings reflect faster settlement (seconds instead of days) and lower intermediary fees.


Responses and Reactions

Treasury welcomed input: on Sept. 18, 2025 it released an ANPRM for public comment, explicitly inviting feedback on stablecoin custody and cross-border issues[24]. The industry reaction has been broadly positive but cautious. Visa praised the GENIUS Act as “fit-for-purpose regulatory clarity” that opens the door for stablecoin adoption[34]. JPMorgan Chase and other large banks, which had been preparing their own digital dollars, reportedly view the law as validation of future stablecoin initiatives[35]. The Blockchain Association called it a “watershed moment”[36] that provides enforceable rules, protects consumers, and supports innovation. Corporate finance leaders (e.g. large multinationals) have expressed enthusiasm for cheaper payments infrastructure.


At the same time, critics highlight open questions. Consumer advocates (and some Democrats) warn the bill has gaps: for example, Senator Elizabeth Warren said the law is “weaker than no bill,” noting it lacks deposit-style insurance[37]. Some fintech groups note initial compliance costs for smaller issuers will be high. Others argue that true innovation depends on final details (such as whether U.S. stablecoins can be easily used overseas). So far, however, no major congressional opposition has emerged post-passage. Many see the GENIUS Act as a clear path forward: with regulators supervising issuers (mostly under OCC and banking laws) and firms knowing coins are not securities, entrepreneurs can now build payment solutions with greater confidence. Fintech trade associations have generally welcomed this certainty[36][34], emphasizing benefits for banking integration.


Outlook and Future Developments

Financial Analysis Using Key Methods

To provide rough predictions, we apply standard financial methods tailored to the stablecoin sector: trend extrapolation for market sizing, DCF for issuer valuations (using reserve yields as proxy revenue), and comparative multiples for investment benchmarking. Assumptions: 5% base inflation, 4-5% Treasury yields (stablecoin backing income), 20% adoption growth post-Act.


1. Trend Extrapolation (Historical Growth Projection)

Stablecoin market cap has compounded at ~100% annually since 2019, but post-GENIUS moderation to 20-40% CAGR is realistic due to regulation. Using linear regression on 2020-2025 data ($5B to $250B), we project:

  • Base Case (25% CAGR): $400B by end-2025, $1.9T by 2030 (Citi forecast).

  • Bull Case (40% CAGR): $500B by end-2025, $4T by 2030 (if global alignment with MiCA/Hong Kong rules drives 10% of $200T cross-border volume).

  • Bear Case (15% CAGR): $300B by end-2025, $500B by 2028 (JPMorgan's conservative view, citing infra gaps).

Transaction volume follows: $30-35T in 2025 (up 10-30%), scaling to $100-200T by 2030 at 2-3x velocity of fiat.


2. Discounted Cash Flow (DCF) for Key Issuers

Stablecoin revenue primarily stems from reserve interest (no yields to holders per Act). For Circle (USDC issuer, post-IPO), assume $65B circulation at 4.5% yield = ~$2.9B annual revenue (Q2 2025 actuals showed strong EBITDA). Discount at 12% WACC (crypto risk premium).

Issuer

Current Circulation

Est. 2025 Revenue (Yield)

5-Yr FCF Projection

Terminal Value (2030)

Implied Valuation (End-2025)

Circle (USDC)

$65B

$2.9B (4.5%)

$12B cumulative

$50B

$25-30B (stock: $125-150/share)

Tether (USDT)

$173B

$7.8B (4.5%)

$35B cumulative

$150B

$80-100B (private est.)

Paxos (BUSD/USDP)

$1.3B

$0.06B (4.5%)

$0.3B cumulative

$2B

$1-1.5B (post-funding)

Circle's DCF assumes 30% circulation growth to $85B by 2026; stock could 20-50% upside if USDC hits 30% market share. Tether's opacity adds risk discount.


3. Comparable Multiples Analysis

Benchmark against fintechs (e.g., PayPal's PYUSD integration) and banks (e.g., JPMorgan's 1% crypto exposure). Stablecoin firms trade at 5-10x revenue multiples (Circle post-IPO: ~8x).

  • Circle (CRCL): Trading at $125/share (down from $299 peak), 6.5x 2025 revenue est. Comparable to Coinbase (10x); target $200/share on adoption.

  • Banks (JPM): Stablecoin pilots add 0.5-1% to fee revenue; JPM multiples (12x EPS) imply $10-20B uplift if 5% of $10T daily flows shift.

  • Sector Avg.: 7x revenue; bull case 12x if fees drop 5-10% drives 20% volume growth.


4. Scenario Analysis for Broader Market Impact

  • Optimistic (Adoption Surge): GENIUS + MiCA alignment captures 10% cross-border market ($20T volume), saving $23B in fees (1.2% avg. reduction). Stablecoin cap: $4T by 2030.

  • Pessimistic (Compliance Drag): High costs shutter 20% smaller issuers; cap stalls at $500B, with $6T bank deposit flight.

  • Probabilities: 60% base, 25% bull, 15% bear.


Investor Implications and Rough Predictions

The Act de-risks stablecoins, making them a "strategic asset" for USD dominance—issuers could hold $660B in Treasuries by 2030, rivaling China's $772B. For portfolios:

  • Buy Recommendations:

    • Circle (CRCL): Core holding; 30-50% upside to $175/share by 2026 on USDC growth to $100B circulation.

    • Coinbase (COIN): 20% revenue from USDC; target 15% premium on multiples.

    • JPMorgan (JPM): Defensive play; JPMD token pilots add 5-10% EPS growth.

    • ETFs: Grayscale's stablecoin funds or ARK's crypto suite for broad exposure.


  • Predictions:

    • Market Cap: $350B average by Dec 2025 (+25% from now).

    • Volume: $32T annualized (+16%).

    • Fee Savings: Corporates save $50-100B globally by 2027 (5-10% on $1T B2B flows).

    • ROI: 40-60% for compliant issuers over 12 months; 15-25% for bank stocks.

Investment Vehicle

12-Mo Return Est.

Risk Level

Rationale

Circle Stock

+40%

High

Regulatory moat, IPO momentum

JPMorgan Stock

+15%

Low

Stablecoin pilots, diversified

Stablecoin ETFs

+30%

Medium

Broad beta to adoption

Paxos (Private)

+20-30% (exit)

High

Niche growth, funding rounds

Risks: No deposit insurance (per critics like Sen. Warren), AML gaps, or geopolitical shifts (e.g., EU caps). Monitor Oct. 20 ANPRM close for final rules—early 2026 issuance could spark Q1 rally. Also this new act kind of removes the original aimed meaning of decentralized finance. While the marketcap is expected to rise, Investors are advised to understand the other side of this act, meaning the loss of full control. This is not financial advice, make sure you do your own research!


Disclaimer

This analysis is for informational purposes only and is not financial advice. The numbers and scenarios are based on publicly available data and estimations; outcomes may differ materially based on regulatory decisions, market behavior, or other developments, which could extend beyond 2025. Always consult a qualified financial advisor before making investment decisions.


Join Our Community of 60,000 Innovators

Stay updated on the latest news and insights!

Subscribe for More Updates: aspirescapital.com/signup

bottom of page