White Collar & Government Investigations Blog

Olshan litigation partner John Moon and counsel Daniel Stone authored an article in Bloomberg Law entitled “GENIUS Act Transition Needs ‘Hyper-Speed’ Progress Given Capital Invested.” In the article, John and Dan discuss the challenges regulatory agents are facing to develop new regulations to implement the GENIUS Act promptly. The law takes effect either on January 18, 2027, or 120 days after regulators adopt final regulations for stablecoins, depending on whichever event occurs first. As John and Dan emphasize, given the “monumental figures” involved in the stablecoin industry—last year transfer volume was approximately $27.6 trillion—"the GENIUS Act’s regulatory framework must be implemented quickly and carefully for the large amounts of capital already circulating within this market space.” John and Dan discuss the need for regulators to work alongside technologists to ensure that the regulatory regime is also technically enabled. “A stablecoin monetary environment enabled by blockchain technology is arriving at an unprecedented speed and scale,” John and Dan said. “That same technology is critical to an effective compliance program implementing the GENIUS Act.”