The GENIUS Act Passed. Here’s What Banks Actually Need to Do.

The GENIUS Act became law in mid-2025. The FDIC published proposed implementation rules in December. The OCC has conditionally approved digital asset bank charters. For the first time, US banks have a clear legal path to issue payment stablecoins.

I was CTO at a digital asset bank navigating stablecoin compliance before any of this existed. Before there was a framework, before there were guidelines, when every decision was a judgment call against ambiguous regulatory signals. That experience is why I can say with confidence: the gap between regulatory permission and operational readiness is enormous.

Having the legal right to issue a stablecoin and having the infrastructure to actually do it are completely different problems. You need token minting and burning workflows tied to your core banking system. You need real-time reserve attestation. You need wallet infrastructure that meets BSA/AML requirements. You need smart contract audit processes. You need a compliance architecture that maps stablecoin-specific risks to your existing examination framework.

Most banks don’t have any of this. The ones exploring stablecoin issuance are discovering that their technology teams have never built on-chain, their compliance teams have never underwritten token-based products, and their boards don’t have a framework for evaluating the risks.

We built StablecoinRoadmap specifically for this moment. Working templates for wallets, payment gateways, and remittance platforms with sandbox simulation, so banks can validate payment flows before committing capital and regulatory capital to live deployment.

The regulatory door is open. The question is execution.