The Blockchain Association filed a 26-page comment letter on October 19, 2026, urging the U.S. Treasury Department to narrow and clarify its proposed GENIUS Act rules for payment stablecoins. The framework is set to take full effect on January 18, 2027; Treasury has not issued a final rule.
The association argued that firms trading their own assets, validators and self-custody software should not be treated as Digital Asset Service Providers. It warned that the proposed “knowing participation” standard could expose ordinary secondary-market trading or market-making to criminal penalties, and asked Treasury to require actual knowledge and substantial assistance in coordination with an issuer. For foreign issuers, it proposed allowing firms to rely on regulators’ public prohibition lists rather than conduct open-ended due diligence, noting that many service providers have no direct relationship with those issuers.
