Jurisdiction · United States
United States
After the GENIUS Act, deposit tokens carry a lighter relative burden than non-bank stablecoin issuance. The fourth network.
Facts
- Regime
- The GENIUS Act (July 2025) sets a federal framework for payment stablecoins — full reserves, monthly disclosures — that applies to non-bank issuers; bank deposit tokens remain deposits under banking supervision
- Currency and leg
- US dollar; settlement through a designated settlement bank with a Federal Reserve master account, or a pooled account where the Federal Reserve's policy allows
- Identity attestation
- Reliance on another institution's customer identification program — counsel opinion required; reliance provisions exist under the Bank Secrecy Act framework
- Market
- Incumbents are moving: DTCC's tokenization pilot and token-settled trading at Nasdaq create demand for a cash leg in bank money
Status
Planned as the fourth network in year four; deposit-token conversations with US banks under way.
Regulatory description is our reading of the GENIUS Act and public regulatory statements as of September 2026.
What a launch here requires.
A jurisdiction pack, a settlement leg with the central bank or a designated settlement bank, a Member Council, a local operating team. Nothing above the ledger changes.
Year 3
Counsel and regulator
OCC and state conversations; opinion on deposit-token status and on the operator's designation
Year 4
Network launched
USD pack; settlement bank binding; Member Council
Year 4
Asset legs
A transfer agent or tokenization platform as the first asset leg; DvP for tokenized securities
Year 4+
Cross-border
Dollar–sterling and dollar–euro payment-versus-payment
Join the launch group here.
Issuers, participants and the central bank each have a seat in the first phase. Ask which are open.