The GENIUS Act does not remove money-transmission requirements for every business handling payment stablecoins, Michael Handelsman writes in a Kelman.Law opinion article. Exchanges, wallets, payment processors and remittance companies may still need federal registration and state licenses, depending on whether they accept, control, exchange or transmit value for customers. FinCEN registration does not replace state authorization.
Handelsman says the Act’s state-licensing protections apply to qualifying issuers under specified conditions, not automatically to their partners or other activities. The OCC declined to give a general ruling on those boundaries in its October 2026 final rule. The Act and its principal OCC rule take effect on January 18, 2027; as of November 3, 2026, the cited issuer-specific anti-money-laundering, sanctions and customer-identification rules were still proposals.
