Circle Advocates for a Strong Framework in GENIUS Act Implementation

Lawrence Jengar
Nov 06, 2025 15:49

Circle has submitted a comment letter to the U.S. Treasury on the GENIUS Act, emphasizing a robust framework for U.S. dollar payment stablecoins.

Circle has recently submitted a detailed comment letter to the U.S. Department of the Treasury, addressing the implementation of the GENIUS Act. This initiative follows the Treasury’s Advance Notice of Proposed Rulemaking, which aims to establish a comprehensive framework for U.S. dollar payment stablecoins. Circle’s response underscores the necessity of a uniform and prudentially sound framework that aligns with Congressional intent, according to circle.com.

Key Recommendations and Principles

Circle’s submission emphasizes several fundamental principles for the GENIUS Act’s implementation. These principles include protecting customer funds with clear and robust rules, ensuring interoperability through reciprocity, and maintaining a level playing field for all issuers, whether domestic or international. The company also advocates for strong enforcement mechanisms and the requirement for issuers to maintain “break-glass” plans to protect consumers in case of issuer failure.

The company highlighted that every payment stablecoin should be fully backed with cash and high-quality liquid assets, ensuring transparency and safety for consumers. Circle’s recommendations aim to prevent regulatory arbitrage and ensure that all digital assets designed to maintain stable value adhere to the same rigorous standards.

Ensuring Global Competitiveness

Circle’s letter also stresses the importance of aligning the GENIUS Act’s provisions with international standards to preserve U.S. leadership in digital finance. It suggests that the Treasury should issue guidance on how permitted U.S. stablecoin issuers can operate globally, emphasizing the necessity of interoperability with global financial institutions. This approach is intended to foster strong partnerships between issuers and the broader banking system, enabling seamless cross-border transactions.

Promoting Transparency and Accountability

Transparency and accountability are central to Circle’s recommendations, with calls for monthly independent checks and public reports to verify the safety of stablecoins. Circle also suggests that the Treasury should maintain a public list of approved comparable jurisdictions and recognized foreign issuers to ensure interoperability and market integrity.

Addressing Enforcement and Penalties

Circle further recommends that the GENIUS Act’s enforcement and penalties be clarified to ensure effective supervision of all issuers. This would involve a comparability regime for foreign jurisdictions, ensuring they maintain effective supervisory and enforcement standards. The aim is to protect U.S. consumers and financial markets from illicit finance risks and unforeseen shocks.

Overall, Circle’s comment letter outlines a vision for a comprehensive and transparent regulatory framework that supports innovation while safeguarding consumer interests and maintaining financial stability.

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