Circle, a prominent stablecoin issuer, has recently weighed in on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, advocating for "simple, strong rules" to govern the stablecoin market. In a comment letter submitted to the U.S. Treasury Department, Circle outlined its recommendations for a comprehensive regulatory framework designed to ensure consumer protection, market fairness, and global interoperability.

The GENIUS Act, signed into law in July 2025, represents the first major legislative step by the United States to regulate stablecoins. Stablecoins are a type of cryptocurrency designed to maintain a stable value relative to a reference asset, such as the U.S. dollar. The Act establishes a regulatory framework for payment stablecoins, defining them as digital assets that an issuer is obligated to redeem for a fixed value. It mandates that only permitted issuers can issue stablecoins for use by U.S. persons, subject to certain exceptions. These issuers must be subsidiaries of insured depository institutions, federal-qualified nonbank payment stablecoin issuers, or state-qualified payment stablecoin issuers, and are regulated by the appropriate federal or state regulator.

Circle's recommendations to the Treasury Department emphasize several key policy principles:

• Protecting Customer Funds: Circle argues that stablecoins should be fully backed by cash and high-quality liquid assets, kept separate from company funds, and redeemable at par.
• Achieving Interoperability: The company advocates for mutual recognition to facilitate interoperability between different stablecoins.
• Ensuring Uniform Standards: Circle believes that the same rules should apply to the same activities, regardless of the type of issuer. This includes maintaining a level playing field among banks, nonbanks, and stablecoin issuers.
• Maintaining Competitive Balance: Circle stresses the importance of maintaining a competitive balance both domestically and internationally.
• Establishing Clear Consequences: The company calls for clear consequences and contingency plans to address potential issues.

Circle believes that the rulemaking process should reinforce Congressional intent by providing clear and robust rules for all issuers accessing the U.S. market. The company also emphasizes that these rules should be designed to offer Americans transparent and easy-to-understand financial products and services.

Moreover, Circle's letter supports the full implementation of the GENIUS Act to create a consistent national regime for permitted payment stablecoin issuers. The company suggests that a cooperative supervisory approach across federal, state, and reciprocal regimes—grounded in uniform prudential, compliance, and risk management—can deliver national and global parity and preserve effective supervision.

The Treasury Department issued an Advance Notice of Proposed Rulemaking (ANPRM) on September 19, 2025, to solicit public comment on questions related to the implementation of the GENIUS Act. The ANPRM sought feedback on a wide range of potential regulatory issues, including issuance and marketing restrictions, compliance with Bank Secrecy Act (BSA) obligations, anti-money laundering (AML) and sanctions enforcement, coordination between state and federal oversight, foreign regulatory comparability, and tax implications.

The GENIUS Act explicitly subjects stablecoin issuers to the Bank Secrecy Act, obligating them to establish effective anti-money laundering and sanctions compliance programs. All stablecoin issuers must possess the technical capability to seize, freeze, or burn payment stablecoins when legally required and must comply with lawful orders to do so.

Circle's advocacy for "simple, strong rules" reflects a broader industry push for regulatory clarity and a level playing field in the stablecoin market. By providing recommendations to the Treasury Department, Circle aims to contribute to the development of a comprehensive regulatory framework that fosters innovation while protecting consumers and reinforcing the U.S. dollar's role in the digital economy.