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This is the first in a series of blog posts investigating the GENIUS Act’s insolvency provisions and offering considerations for those interested in issuing payment stablecoins. By Doug Landy & Todd Phillips Although all permitted payment stablecoin issuers (PPSIs) are regulated by the GENIUS Act, organizers’ choice of corporate charter carries significant consequences. Charter selection affects not only the activities a PPSI may undertake, but also how insolvency is addresse

Payment stablecoins pose unique challenges to the nation’s anti-money laundering (AML) and sanctions compliance regime. By design, blockchains allow issuers to track which wallets hold their stablecoins with a level of anonymity so as not to reveal the identities of those wallets’ owners. This dynamic has raised questions about how Permitted Payment Stablecoin Issuers (PPSIs) would comply with Bank Secrecy Act (BSA) requirements. Regulators have now proposed an answer. On Ju

The GENIUS Act (2026) gives stablecoin holders first-priority claims to reserves during insolvency, ensuring they are paid before other creditors.