U.S. OCC Releases Proposed Implementation Framework for the "GENIUS Act," Tightening Regulatory Gaps on Interest-Bearing Stablecoins

The Office of the Comptroller of the Currency (OCC) recently published a 376-page proposed rulemaking aimed at establishing a concrete implementation framework for the "GENIUS Act" and publicly solicited feedback from the community.

The "GENIUS Act" was officially signed into law by U.S. President Trump on July 18, 2025, and aims to create a unified federal regulatory standard for the United States' payment stablecoin activities.

The proposed rules clarify the responsibilities of various stablecoin issuers under OCC jurisdiction, including subsidiaries of national banks and federal and state-qualified issuers, and set compliance standards for reserve assets, liquidity, custody, risk management, and audits.

Notably, anti-money laundering (AML), OFAC sanctions, and the Bank Secrecy Act are not included in this proposal and will be addressed separately by the Treasury Department, reflecting a clear division of regulatory responsibilities.

In response to market concerns about stablecoin yields, the OCC's approach is to close regulatory loopholes that allow indirect interest payments. Although the "GENIUS Act" prohibits compliant issuers from directly paying interest to stablecoin holders, banks remain concerned about the risk of indirect interest payments.

To address this, the OCC explicitly states in the proposed rules that if an issuer enters into agreements with related parties or third parties to indirectly pay holders profits related to holding or using the tokens, it will be considered a violation. This aims to prevent circumvention of the ban through third-party agreements.

However, the OCC also lists exceptions, stating that independent consumer discounts offered by merchants and profit-sharing arrangements between issuers and non-related parties under "white-label partnerships" are not subject to these restrictions.

In summary, the proposed rules from the OCC refine enforcement standards but also reveal deep concerns within regulators about balancing innovation with preventing stablecoins from morphing into "shadow banks" that absorb deposits.

This indicates that the true regulatory intent is not to stifle the industry but to firmly position stablecoins as "payment tools" and strictly prohibit their transformation into vehicles for "financial deposit-taking" profits.

But can a framework that only allows transfers and cannot generate interest—namely, a #Stablecoin—satisfy the ever-expanding appetite of Wall Street giants? Clearly, this "yield" battle has only just begun.

#OCC