Access Restricted for EU Residents
You are attempting to access a website operated by an entity not regulated in the EU. Products and services on this website do not comply with EU laws or ESMA investor-protection standards.
As an EU resident, you cannot proceed to the offshore website.
Please continue on the EU-regulated website to ensure full regulatory protection.
Monday Dec 1 2025 14:00
4 min
The Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act, signed into law on July 18, is being touted as the statute that finally pulls dollar-pegged tokens out of the regulatory gray area into a supervised, payments-first framework. Supporters claim it offers legal clarity, consumer protections, and a pathway for programmable money. Critics, however, raise a fundamental question: If issuers are strictly guided to hold cash and short-term Treasuries, will this effectively make them structural buyers of US debt? This argument is presented by author and ideologist Shanaka Anslem Perera, who argues that under GENIUS, "Every digital dollar minted becomes a legislated purchase of US sovereign debt."
The GENIUS Act defines "payment stablecoins" as fiat-referenced tokens primarily used for payments and settlement. Only permitted payment stablecoin issuers can serve US users at scale, and these issuers must back their tokens at a 1:1 ratio with a narrow pool of high-quality assets. These assets include US coins and currency, Federal Reserve balances, insured bank deposits, short-maturity Treasuries, qualifying government money market funds, and tightly constrained overnight repos backed by Treasuries, all held in segregated accounts.
Issuers are required to redeem at par, publish regular reserve disclosures, and provide audited financials above certain size thresholds, while adhering to a limited set of activities related to issuing and redeeming stablecoins, rather than broader lending or trading. Foreign issuers seeking access to US customers via domestic platforms must either comply with this framework or demonstrate to the Treasury that their home country's regime is "comparable."
Yet, GENIUS might be more of a preliminary step. Analysts at Brookings recently discussed potential issues for regulators as they implement the act. These concerns centered on uninsured bank deposits, the role that large non-financial, publicly listed firms may play in issuing stablecoins, how "comparable" foreign regulation may deviate from US standards, and whether issuers actually possess the technological and procedural capacity to meet AML/CFT sanctions and monitoring obligations.
Perera’s "forensic analysis" takes this several steps further. He interprets GENIUS as transforming payment stablecoin issuers into narrow banks whose primary economic role is to convert global demand for digital dollars into structural demand for short-term US sovereign debt. He contends:
"The United States Treasury has executed a structural transformation of American monetary architecture that bypasses the Federal Reserve, conscripts the private sector as a forced buyer of government debt, and may have solved – temporarily – the terminal problem of deficit financing."
Because reserves are channeled into central bank balances, short-dated Treasuries, government money market funds, and fixed short-term secured loans, and because issuers cannot lend broadly, rehypothecate freely, or pay yields to users, the natural outcome is balance sheets filled with T-bills.
In this sense, Circle, Tether, and their GENIUS-compliant counterparts become pipelines. Emerging-market savers fleeing inflation or capital controls are buying digital dollars. Issuers park those inflows in short-term US paper. The Treasury benefits from cheaper funding. Repeat the process.
The same design that creates a steady bid for bills also creates what Perera calls "redemption asymmetry" on the way down. While the Federal Reserve’s current stance on central bank digital currencies (CBDCs) is clear (i.e., not pursuing one without Congressional authorization), Perera told Cointelegraph, "that’s a peacetime policy." He points to research by the Bank for International Settlements that found stablecoin outflows raise Treasury yields two to three times more than inflows lower them. Should a trillion-dollar stablecoin market suffer a 40% drawdown, hundreds of billions of short-dated Treasuries could be dumped into the market in weeks.
He warns:
"That’s when the CBDC conversation resurfaces. A stablecoin crisis becomes the catalyzing event that shifts political calculus. The argument becomes: Why subsidize private stablecoin risk when a Fed-issued digital dollar eliminates counterparty concerns entirely?"
At that point, the Fed’s "no digital dollar without Congress" stance would run headfirst into its financial-stability mandate. The tools are already in place; using them to stabilize a GENIUS-era shock would underscore that private stablecoins now sit on top of a de facto central bank backstop.
On paper, GENIUS can still deliver its promise: fully reserved dollar tokens under clear federal standards, faster and cheaper payments, and a way to connect on-chain settlement to the core of the dollar system. If Treasury Secretary Scott Bessent’s ambitions materialize, that market could reach into the trillions and become a lasting source of Treasury demand.
But that also means US fiscal strategy, global demand for digital dollars, and the next chapter of central bank money are now intertwined. GENIUS might prove to be a smart way to harness stablecoins, or the opening roll of the dice in a game that ends with a crisis-driven digital dollar and a much more explicit debate over who really controls the money pipeline.
Risk Warning: this article represents only the author’s views and is for reference only. It does not constitute investment advice or financial guidance, nor does it represent the stance of the Markets.com platform.When considering shares, indices, forex (foreign exchange) and commodities for trading and price predictions, remember that trading CFDs involves a significant degree of risk and could result in capital loss.Past performance is not indicative of any future results. This information is provided for informative purposes only and should not be construed to be investment advice. Trading cryptocurrency CFDs and spread bets is restricted for all UK retail clients.