Stablecoin regulation

GENIUS Act article flags a potential loophole around synthetic and wrapped stablecoins

What happened

  • Specific facts/numbers: The article argues the GENIUS Act was drafted for “permitted payment stablecoins” and says its wording appears intended to exclude synthetic coins such as Sky’s USDS and Ethena’s USDe that are not primarily backed by cash or Treasuries; Congress.gov materials identify the GENIUS Act as Public Law 119-27, signed in July 2025.
  • Institutions involved: Ledger Insights is analyzing the U.S. GENIUS Act framework; named crypto projects include Sky and Ethena; the official legislative source is Congress.gov and the law applies within the U.S. stablecoin regime.
  • Regulatory/technical context: Congress.gov summaries say the GENIUS Act regulates payment stablecoins redeemable at a fixed amount and requires at least one dollar of permitted reserves for every one dollar issued, with reserves limited to cash-like assets such as coins, currency, insured deposits and short-term Treasuries. The article’s concern is that excluding synthetic stablecoins could also leave room for wrapped or foreign-linked structures to circulate outside those requirements.
  • What to watch next: Watch for whether U.S. regulators or lawmakers issue interpretive guidance, rulemakings, or amendments clarifying how synthetic, wrapped, or foreign-linked stablecoins are treated; no specific next milestone was identified in the materials reviewed.

Why it matters

If the law’s scope is narrower than intended, some stablecoin structures could avoid reserve, licensing, or compliance obligations, creating uneven rules across functionally similar products.

HKMA Relevance

Indirect: U.S. stablecoin perimeter decisions can influence how internationally used dollar-linked tokens and wrapped assets are handled in markets connected to Hong Kong.

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