Stablecoins: the Blockchain Association seeks more precise US rules

Comments on a proposed rule

On 19 October 2026, the Blockchain Association published a comment letter on the US Treasury's proposal implementing Section 3 of the GENIUS Act. The organisation, which represents industry businesses, supports the objective of a framework for payment stablecoins while seeking more precise wording. Its response addresses covered participants, unlawful issuance and foreign tokens, among other matters. The letter expresses the position that a trade organisation has put forward as part of a consultation process; publication of that position does not amount to the regulator making a new decision.

The proposal concerns the conditions under which payment stablecoins may be issued, offered or sold in the United States. The work of preparing the regulation must be distinguished from the law that provides the legal foundation for that work. A consultation gathers arguments and proposals before a final version is drafted. Changes requested by a participant do not become applicable simply because they are submitted. Their effect will depend on the authority's response and the final text, including its own timetable provisions.

Defining who actually provides a service

A central issue concerns the definition of digital asset service providers. The Blockchain Association asks for a distinction between a business acting for clients and an entity trading only its own assets. It also wants exclusions for certain infrastructure, self-custody interfaces and validation functions to be explicit in the regulation. The issue is how obligations attach to an activity: owning or using a stablecoin does not necessarily describe the same role as holding or exchanging it for other people.

The organisation also seeks a narrower definition of knowing participation in unlawful issuance. Under its proposal, this would require actual knowledge of the facts and substantial assistance coordinated with the issuer. It considers that ordinary secondary-market trading should not automatically be equated with participation in issuance. This request must remain attributed to the association. It establishes neither a general exemption from liability nor the status of a particular operation without examining the applicable texts.

Foreign issuers raise additional difficulties

The letter criticises certain verification expectations concerning foreign issuers. The association notes that a platform may offer a token without having a contractual relationship with its issuer, limiting the information it can obtain directly. It proposes relying more on authorities' public lists and registers unless there is knowledge of contrary evidence. The debate for that reason concerns how compliance should be documented and responsibilities divided among participants, rather than the absence of all controls over the tokens concerned.

In open environments, a wallet address does not always provide a verified identity or location. This difference between available technical data and required information explains the importance of regulatory definitions. It does not mean that all decentralised activities fall outside the law. The decisive elements for following the consultation will be the final definition of covered services, treatment of exceptions and verification arrangements adopted. The 19 October letter makes specific requests on these points; whether they are adopted remains a matter for the Treasury.