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Circle submitted a comment letter to the US Treasury on how to implement the GENIUS Act stablecoin law. The firm called for uniform rules for banks, nonbanks, and foreign issuers that offer dollar-linked payment stablecoins in US markets.
Circle argued that clear, consistent requirements can protect users and support competition in digital payments. It described the rulemaking as a chance to move payment stablecoins into a single national framework anchored in the US dollar.
In its filing, Circle urged Treasury to require that payment stablecoins hold full backing in cash and high-quality liquid assets. The company said issuers should keep reserves separate from operating funds and offer par-value redemption on demand.
Circle also recommended independent monthly checks and plain-language public reports on reserve assets. Those disclosures, it said, would help users and supervisors verify that backing remains available, including during stress events.
The letter promoted a “same activity, same rules” standard for tokens that function like dollars in payments. Circle warned that issuers should not bypass GENIUS Act obligations by changing labels or limiting formal redemption rights.
The firm supported clear penalties for violations, together with safe-harbor protections for good-faith compliance with lawful orders. It also backed advanced wind-down plans that return customer funds in an orderly way if an issuer fails.
Circle asked the Treasury to base implementation on a standalone issuer model that applies to banks and nonbanks. Under that approach, the issuing entity would hold the staff, systems, and risk controls needed to meet GENIUS standards.
The company also proposed a reciprocal path for foreign stablecoin regimes that match US prudential and compliance requirements. It urged the Treasury and the Office of the Comptroller of the Currency to publish a list of comparable jurisdictions and recognized foreign issuers.
Circle said transparent criteria for that list could support interoperability and reduce regulatory arbitrage across borders. Strong and coordinated supervision, it added, would help ensure that offshore issuers do not gain an advantage by facing looser oversight.
Circle asked the Treasury to clarify how permitted US payment stablecoin issuers can operate globally under the GENIUS framework. The firm linked that guidance to practical conversion between tokens and fiat currency for businesses that settle across time zones.
It said that rules should support liquidity management and interoperability with banks, brokers, and regulated exchanges. Without that support, payment flows could fragment as transactions move between traditional financial rails and digital asset platforms.
Circle also urged regulators to support guidance that treats permitted payment stablecoins as cash and cash equivalents for accounting and tax purposes. Such treatment, it said, would align financial reporting with fully reserved structures and give treasurers and auditors clearer standards.
Through these recommendations, Circle presented the GENIUS Act rollout as a chance to raise transparency and reduce risk in core payment functions. The company maintained that clear definitions, risk-sensitive prudential rules, and firm enforcement can guide demand toward transparent, fully reserved payment stablecoins.
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