Payment Stablecoins: Law, Licensing & Compliance

In this conference opener, panelists will look back at the first 10 months of the GENIUS Act in the U.S., translating reality into lessons on real obligations across reserves, disclosures, certifications, licensing, and AML. You’ll leave knowing how to navigate the future of stablecoin. Topics of discussion include:

• Level-setting expectations and defining success for legal, compliance, risk and product stakeholders
• Framing settled statute v. supervisory signals v. open questions to prevent scope drift
• Treasury RFC and regulatory shift

Choosing a licensing regime is of critical importance from a licensing, timing, supervisory, examination and innovation perspective. In this session, leaders will discuss choice of licensing regime considerations. Topics of discussion include:

• Comparing OCC/federal routes with state money-transmitter and trust company options
• Weighing day-to-day supervision, examination models, and preemption implications
• Deciding bank-subsidiary v. non-bank issuance to align governance and capital strategy

Deficient reserve design and disclosure cadence invite examiner findings and customer confusion. In this session, learn how to architect 1:1 backing, segregations, and monthly attestations that hold up under scrutiny. Topics of discussion include:

• Designing eligible-asset mixes
• Aligning treasury reporting, board metrics, and incident playbooks
• Documenting custody arrangements and segregation mechanics across providers

AML expectations for stablecoins, especially downstream or onchain/peer-to-peer activity, are murky and evolving. In this session, leaders will discuss reasonable baselines, regulatory expectations, integration of Travel Rule and sanctions, and when to expand monitoring. Topics of discussion include:

• Calibrating customer due diligence, ongoing monitoring, and SAR thresholds for tokenized flows
• Implementing Travel Rule obligations and sanctions screening across wallet and exchange rails
• Leveraging on-chain analytics and typologies to detect patterns

Multinational programs risk double work and regulatory drift as regime rules diverge. Topics of discussion include:

• Mapping core obligations across global regimes
• Sequencing compliance artifacts so one policy stack serves multiple jurisdictions
• Interpreting RFC questions to anticipate AML scope, listing constraints, and disclosure refinements

Ambiguity around EFTA/UDAP, prohibited tying, and “rewards vs. interest” can be important considerations in marketing. In this session, panelists will translate boundaries into workable practices and disclosures. Topics of discussion include:

• Determining if/when EFTA error-resolution and disclosure duties attach
• Avoiding prohibited tying and use-restriction constructs in product/marketing
• Structuring rewards, fees, and messaging to preserve compliance and trust
• Governing approvals via cross-functional review and sign-off

• A closer look at the upshot of the Market Structure Bill within the GENIUS Act
• Building a financial services platform to support stablecoin
• Unpacking compliance issues associated with a market strategy
• Examining the pros and cons of different distribution channels