Circle Submits Comment Letter on Implementation of the GENIUS Act

Circle Internet Financial has responded to the U.S. Department of the Treasury's Advance Notice of Proposed Rulemaking on the GENIUS Act, advocating for a uniform framework for U.S. dollar payment stablecoins. Circle emphasizes the need for full implementation of the GENIUS Act to establish a consistent national regime that supports comprehensive compliance by all stablecoin issuers interacting with U.S. markets. The company's recommendations include ensuring customer funds are protected with strong rules, promoting interoperability through recognition of foreign regimes, and maintaining a level playing field for all issuers, regardless of their origin or type. Circle also highlights the importance of clear regulatory requirements for accessing U.S. markets, the necessity of "break-glass" plans for noncompliance, and the establishment of insolvency and resolution structures to support international reciprocity. By setting clear definitions and risk-sensitive requirements, Circle believes the Treasury can foster a competitive market that prioritizes transparency and compliance, reinforcing U.S. leadership in digital finance.