Circle urges OCC to finalize GENIUS Act rules

Circle Internet Group filed comments with the Office of the Comptroller of the Currency on May 1, urging the agency to finalize a national licensing and oversight framework for payment stablecoins. The company disclosed the submission on May 5.

The OCC proposal would place most requirements in a new 12 CFR 15 and set standards for reserve management, redemption policies, risk management, custody, supervision, applications and operational backstops. The proposal covers national banks, federal savings associations, federal branches, foreign issuers and certain state-qualified payment stablecoin issuers within OCC jurisdiction. The OCC said anti-money-laundering and sanctions rules would be addressed separately with the Treasury Department.

Circle asked the OCC to adopt clear and consistently applied rules that reflect the demands on major payment stablecoin issuers. The filing emphasized reliable redemption, operational resilience and uninterrupted availability, and called for regulated payment stablecoins to remain transferable and fungible across customers, platforms and markets.

The company proposed that regulated issuers operate as standalone, ring-fenced entities with sufficient capacity to meet large global demand. Circle argued that similar prudential standards should apply to all issuers regardless of charter or domicile — including banks and nonbanks, state and federal outfits, and domestic and foreign firms — to avoid regulatory arbitrage and competitive disadvantages for firms that follow tighter rules.

Circle identified credit, liquidity, operational and anti-money-laundering risks as areas the final rule should address and requested clear expectations for supervision and remediation. The filing said the rule should support global standards for dollar-backed digital payments while preserving the ability of stablecoins to move and be redeemed across platforms and markets.

In its comments, Circle wrote that the OCC’s approach should require issuers to meet the “highest-level standards of a standalone, ring-fenced entity.” The filing added: “With clear, practical, and consistently applied rules, the United States can protect consumers, build the market of the future, and strengthen the role of trusted digital dollars in the global economy.”

If finalized as proposed, the rule would shape how payment stablecoins handle reserves and redemption, how issuers are supervised and how competition among different issuer types is regulated nationwide. The OCC has not set a date for a final rule; public comments, including Circle’s, will inform its next steps.