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Circle, the issuer of one of the largest US dollar-backed stablecoins, has urged US regulators to establish a level playing field across banks, non-banks, and foreign issuers as the GENIUS Act takes shape. The firm filed comments in response to the US Department of the Treasury’s notice of proposed rule-making and stressed that uniform standards must apply across all participants in the digital asset ecosystem. It advocated for strong enforcement mechanisms and called for consistency in supervision to preserve consumer protection and market integrity.
Circle supported the core GENIUS Act principle that payment stablecoins must be fully backed by cash and high-quality liquid assets. It said every issuer - bank, non-bank, or foreign - should follow the same rules so that consumers do not bear risks from regulatory shortcuts. The submission explained that clear requirements for US market access, along with shared supervision with trusted foreign regimes, will promote competition and curb offshore regulatory arbitrage.
In detailing its position, Circle emphasised that digital tokens which “walk and talk like a dollar” should bear the same obligations as payment stablecoins under the Act. It underlined that labels or marketing alone should not allow any issuer to dodge safeguards. The firm also called for recognition of foreign regulatory regimes that meet GENIUS standards and maintain effective supervision - not just light-touch registration.
Moreover, Circle said that rule-making should avoid unnecessary constraints that impair liquidity management, cross-border payments, or interoperability with regulated infrastructure. The document made clear that implementation must close evasion pathways so any issuer leveraging the US dollar’s trust cannot sidestep the regime Congress intended.
Circle recommended that strong enforcement mechanisms must accompany the regulatory framework. It called for clear consequences for non-compliance to sustain public confidence in stablecoin markets and stop regulatory loopholes from undermining consumer protections. Circle also urged that payment stablecoins remain fully backed, that backing assets be separated from company funds, and that monthly independent checks and plain-English public reports give users verifiable assurance of safety and redemption at par.
In addition, the submission stressed that issuers must maintain tested wind-down playbooks so customers can receive their funds quickly and fairly, including across borders, if something goes wrong. Penalties should be predictable for non-compliant actors, while good-faith efforts could qualify for narrowly scoped safe-harbor protections. By blending transparency, accountability, and operational readiness, Circle argued the framework can uphold strong oversight without stifling innovation.
Furthermore, Circle aligned this strategy with its longstanding advocacy for responsible innovation in digital payments. The firm asserted that a cooperative supervisory approach across federal, state, and reciprocal regimes - grounded in uniform prudential, compliance, and risk-management standards - can deliver both national and global parity in supervision.
The call made by Circle puts forth an important question for the Treasury of the U.S.: would the Genius Act be in a position to generate consumer protection, innovation, and global competitiveness that is balanced? Issuers of payment stablecoins may wind up with less slack and more operational demands imposed on them by regulators as rule-making continues.
One of the biggest challenges for the regulators will be ensuring that the different types of issuers have the same obligations applied to them across the board, a case that includes banks, non-banks, and foreign companies, while making sure that the stability-seeking tokens indeed meet the standards set.
The market players should be ready for the transformation that involves increased transparency and equally implemented supervision. In the meantime, the international issuers will probably have to rework their business models in order to meet the U.S. access to the market and corresponding regulatory cooperation conditions.
Some say that a uniform regime could make the whole dollar-pegged stablecoin market in the United States more credible and it would reduce the arbitrage opportunities for the offshore players. Accordingly, Circle’s suggestions may become a determining factor in both the regulatory framework and the competitive dynamics of the stablecoin ecosystem.
Circle’s resonance with the GENIUS Act reveals the company’s readiness to put up equal regulatory barriers for all privacy coin issuers. The firm requests that the Treasury impose such reforms that would generate a positive impact not only on consumers but also on the whole industry through setting a clear competition amongst innovators. It is convinced that a unified framework will guarantee the integrity of the market and the uniformity of the stablecoin supervision across the globe.
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