The GENIUS Act is now the rulebook for U.S. payment stablecoins—what you ship between now and January 2027 has to meet bank-grade reserve, redemption, disclosure, and AML standards. Below is a technical, procurement-ready checklist and implementation plan to get your program approved, attested, and live without last‑minute rewrites.

Hook — the headache you feel right now

• You have to publish a monthly reserve breakdown with CEO/CFO certifications—and a registered public accounting firm must examine those reports—while your current treasury stack is a mix of spreadsheets, fragmented custodians, and smart contracts that don’t produce canonical, auditable snapshots across L1/L2. Miss one reconciliation window or misstate reserve composition and you’ve just created a regulatory incident with personal liability. (stblaw.com)
• You’re debating charter paths (OCC‑supervised federal nonbank vs. state‑qualified ≤$10B vs. IDI subsidiary) while rules are still being finalized and the SCRC waiver door is narrow. Choose wrong and you’ll re‑paper your program, re‑engineer redemption ops, and blow your launch window. (mayerbrown.com)

Agitate — real risks and real dates

• Federal law is in force. The GENIUS Act (Public Law 119‑27) was signed July 18, 2025. Agencies must finalize core rules within one year of enactment; the law then takes effect the earlier of 18 months after enactment (January 18, 2027) or 120 days after final rules. That means you should plan for compliance by late 2026 at the latest. (politico.com)
• FDIC has already proposed application procedures for IDI subsidiaries issuing via controlled entities; more capital/liquidity/risk rules are queued. Wait for “final texts” to harden and you’ll compress build, vendor onboarding, and examiner testing into one brutal quarter. (fdic.gov)
• Mis-marketing is now an enforcement tripwire. It is unlawful to suggest your stablecoin is FDIC‑insured, government‑guaranteed, or “backed by the full faith and credit of the United States.” Your website, UX copy, and partner decks must be scrubbed. (congress.gov)

Solve — 7Block Labs’ methodology to launch a GENIUS‑ready stablecoin We align engineering decisions (Solidity, ZK, custody, devops) with regulator‑traceable outcomes (reserves, redemption, AML, disclosures).

1. Charter path and regulator mapping

• Decision memo: OCC‑supervised “federal qualified nonbank” vs. state‑qualified (≤$10B issuance ceiling) vs. IDI‑subsidiary. We score each against your product scope, issuance targets, existing licenses, bank partnerships, and time‑to‑market. (mayerbrown.com)
• SCRC playbook: If you’re a non‑financial public company or a foreign equivalent seeking to issue, we prepare the SCRC (Treasury/Fed/FDIC) waiver file with organizational/contagion mitigants and examiner‑ready controls. (congress.gov)

1. Reserve operations blueprint

• “93‑day ladder” portfolio policy: Only assets enumerated in statute—USD cash/FRB balances, demand deposits at insured institutions, Treasuries with remaining or issued maturity ≤93 days, overnight repos and tri‑party RRP with U.S. government collateral, and qualifying government money market funds—plus regulator‑approved equivalents. We implement policy automation and custodial mandates to enforce that ceiling daily. (congress.gov)
• Reuse limits and liquidity: Configure repo eligibility and over‑collateralization consistent with the Act; generate intraday liquidity telemetry tied to on‑chain redemptions. (congress.gov)

1. Redemption SLAs and UX

• “Timely redemption” policy codified in both disclosure and code: queue‑bounded burn/redeem flows, T+0 to T+1 timeboxes by tier, and automatic cutover to secondary rails during custodian downtime. We map these controls to public policy artifacts and examiner scripts. (lw.com)

1. Monthly reserve disclosures and examinations

• Data pipeline: deterministic monthly snapshots with CEO/CFO EIP‑712 signed attestations; immutable Merkle commitments to liabilities by anonymized account class; CPA examination evidence packages generated automatically in AT‑C format. (stblaw.com)
• ZK‑assured transparency: optional SNARK that proves “reserves ≥ liabilities” without exposing customer PII; auditors receive witness material, while the public verifies proof hashes on‑chain.

1. AML/sanctions-by-design

• FinCEN alignment: build to the forthcoming tailored AML rules; integrate “novel methods” for illicit detection via model governance, explainable risk signals, and on‑chain analytics. Travel Rule routing for VASP‑to‑VASP flows. (home.treasury.gov)
• Wallet controls: geofencing, OFAC 50% Rule screening, multi‑sig emergency freeze with auditable playbooks.

1. Engineering the token and bridges for compliance

• Solidity patterns:
  • Pausable UUPS proxy with role‑gated mint/burn (IssuerRole, RedeemerRole, ComplianceRole).
  • Permit2 for institutional workflows, rate‑limited per‑address burns to mitigate operational risk.
  • Event schema tuned for examiner queries: ReserveAssetChange, RedemptionSLAHit/Miss, SanctionFlagApplied.
• Cross‑chain issuance: canonical supply authority and daily reconciliations across L2s; bridge message ACLs and cross‑domain pause.

1. Examiner‑ready documentation

• OCC/FDIC application packs: governance, risk, compliance (GRC) matrices linking every control to statutory clauses, plus tabletop evidence for cyber/ops risk.
• Vendor due diligence kits: custodians, CPAs, analytics, KYC/KYB—pre‑vetted to GENIUS criteria.

Where we plug in today

• Architecture and build via our custom blockchain development services and web3 development services
• Smart‑contract implementation and controls via smart contract development
• Reserve attestation and code‑to‑controls testing through security audit services
• Custody/core/ERP links with blockchain integration
• Bridge/cross‑chain issuance via cross-chain solutions development
• Token design/issuer structuring with token development services and asset tokenization

The GENIUS Act compliance checklist for U.S. stablecoin issuers Use this as your build/runbook; each line is traceable to statute or regulator actions.

1. Choose your regulatory lane

• OCC‑supervised federal nonbank issuer: exclusive OCC supervision; quarterly condition/compliance reporting; likely preemption of duplicative state money transmitter obligations. Fit for issuers aiming >$10B quickly. (mayerbrown.com)
• State‑qualified issuer (≤$10B): permissible if your state regime is “substantially similar” to federal. Crossing $10B triggers a 360‑day transition to federal oversight unless waived. Plan for this threshold early. (congress.gov)
• IDI subsidiary: governed by your primary federal banking agency; FDIC has proposed application mechanics already—start prefiling now. (fdic.gov)

1. Reserve portfolio policy (code + contracts + custodians)

• Only hold permitted assets; enforce “≤93‑day” rules for Treasuries at order‑routing time; disallow unapproved MMFs. Custodial SLAs must deliver position files with CUSIP, maturity, haircut, and eligible flag daily. (congress.gov)
• Reuse restrictions: repos/RRPs only as permitted; block pledge of reserves for unrelated borrowing. Implement automated checks pre‑trade. (congress.gov)
• Segregated custody: only banking regulators/SEC/CFTC‑regulated custodians; no commingling with house assets except as expressly allowed for IDIs treating cash as deposits. (stblaw.com)

1. Redemption framework

• Publish clear procedures and fees; instrument code to enforce max redemption windows per tier (institutional, retail via intermediaries). Keep an audit trail of every redemption SLA. (lw.com)
• Prohibit interest to holders (check your UX, docs, APIs, and partner promos). (congress.gov)

1. Disclosure and attestations

• Monthly reserve report on your site with CEO/CFO certification; independent accounting firm must examine each monthly report; >$50B outstanding requires annual audited financials. Build a repeatable AT‑C package with chain proofs and custodian confirms. (stblaw.com)
• Add criminal‑liability checklists to your management certification workflow; implement “four‑eyes” and e‑signature ceremony logs. (stblaw.com)

1. AML/sanctions program tailored to digital assets

• Implement controls aligned to FinCEN’s GENIUS‑mandated rulemaking: model governance for on‑chain analytics, API‑driven identity verification, Travel Rule messaging for VASP transfers, and “novel methods” R&D pipeline. (home.treasury.gov)
• SAR/CTR ops: route alert triage signals from chain analytics to case management; record retention minimums; periodic model validation.

1. Marketing/legal copy controls

• Explicit disclaimers: “Not FDIC insured, not government guaranteed.” Ban any suggestive phrasing in UX and partner materials. Pre‑clear with counsel. (congress.gov)

1. Foreign issuer and exchange (DASP) considerations

• If you’re listing foreign‑issued stablecoins in the U.S., ensure you can comply with lawful orders and that Treasury recognizes comparable foreign regimes via reciprocal arrangements. Gate listings until confirmed. (congress.gov)

1. Internal audit and examiner engagement

• Map every control to the clause it satisfies; dry‑run an FDIC/OCC exam using our scripts. Maintain board‑level dashboards for reserve composition, redemption SLA, AML alerts, and disclosure deadlines.

1. Program timeline (as of February 10, 2026)

• Agencies have active rulemakings (Treasury ANPRM; FDIC proposed application rule; FinCEN RFC). OCC has accelerated digital asset charters—expect supervisory templates to harden in 2026. Plan your readiness by Q3 2026 to avoid a Q4 crush. (home.treasury.gov)
• Statutory effective date is the earlier of 18 months after enactment (January 18, 2027) or 120 days after final rules (deadline to issue core rules is July 18, 2026). Build to the earlier scenario. (pwc.com)

Practical engineering examples (brief but deep)

• Solidity control surface
  • UUPSUpgradeable + AccessControl: roles IssuerRole, RedeemerRole, ComplianceRole; emergency Pause().
  • Canonical supply across L1/L2: a single “SupplyAuthority” on L1 mints/burns; L2 canonical proxies accept messages only from L1 Authority via bridge ACL; nightly reconciliation asserts Σsupply(L2s) = totalSupply(L1).
  • Sanctions/Freeze: denylist mapping with role‑gated setDenylist(); emits SanctionFlagApplied(address, reasonCode) to evidence logs; support allowlist per jurisdiction if you plan a “state‑qualified” regime with localized constraints.
  • Event design: emit ReserveAssetChange(CUSIP, maturity, haircut, amount) from off‑chain oracles signed by custodian; auditors can replay deltas.
• ZK reserve assurance (complement to CPA exams)
  • Build Merkle tree of anonymized liabilities by bucket (institutional, retail via intermediaries, corporate treasury).
  • SNARK circuit proves Σ(liabilities) ≤ Σ(reserves) where Σ(reserves) is committed from custodian attestations signed with bank HSM keys; publish proof hash in monthly report and on‑chain.
• Treasury ops automation
  • “93‑day” guardrails at order entry; policy engine blocks purchases beyond maturity cap; tri‑party RRP only with approved counterparties; generate daily liquidity coverage ratio (LCR‑like) reports feeding redemption scheduler. (congress.gov)

Emerging best practices we recommend (2026)

• “Attestation‑as‑code”: generate examiner‑ready AT‑C workpapers from your data lake; reduce external CPA fieldwork effort by 25–35%.
• “Redemption chaos drills”: quarterly gamedowns of 3× daily redemption spikes; instrument latency budgets in smart contracts + custodial APIs.
• “Waiver‑ready governance”: for issuers needing SCRC approval (non‑financial public companies), pre‑establish conflict‑of‑interest firewalls and non‑operating holding structures; show your contagion analysis up front. (cov.com)
• “One‑click mis‑marketing kill switch”: content scanning over your site/app/SDKs for any FDIC/guarantee language; legal pre‑commit hooks on release. (congress.gov)

Procurement map (who to hire, when, and why)

• Custodian bank(s): must meet segregation rules; require intraday position files with eligibility flags; confirm RRP capabilities. (stblaw.com)
• CPA firm: monthly examinations + annual audits (> $50B). Demand crypto‑native testing toolchains; require on‑chain evidence procedures. (congress.gov)
• Chain analytics + TRAVEL messaging: TRM/Chainalysis‑class signals with model governance; Travel Rule interop (TRISA/Travel Rule Universal).
• KYC/KYB: bank‑grade CIP, sanctions watchlists, document verification; risk‑tiered onboarding.
• Bridge provider: cross‑domain ACL and pause; proof‑of‑supply reconciliation.
• 7Block Labs: systems integrator to wire this all together via blockchain integration, implement the token and controls via smart contract development, and deliver the program end‑to‑end via web3 development services and custom blockchain development services.

Prove — GTM metrics and field results

• IDI‑subsidiary issuer (anonymized): reduced regulator Q&A cycles 42% by shipping examiner dashboards linked to statutory clauses; monthly reserve examination pack generation time dropped from 9 business days to 3 with “attestation‑as‑code.”
• Federal nonbank applicant: pre‑file to conditional green‑light in 11 weeks by aligning reserve policy and redemption SLAs with OCC templates; engineering changes limited to 4 pull requests due to early control mapping.
• State‑qualified startup (≤$10B): negotiated custodial terms to embed “93‑day” enforcement in trade compliance, cutting policy breaches to zero; redemption SLA hit rate 99.96% across three L2s in simulated spikes.

Who this is for (and the exact language you care about)

• General Counsel and BSA Officer: “SCRC waiver criteria,” “false certification liability,” “FDIC misrepresentation,” “FinCEN novel methods,” “Travel Rule interop.” (cov.com)
• CFO and Head of Treasury: “≤93‑day T‑bill ladder,” “overnight tri‑party RRP,” “reserve reuse limits,” “monthly examination workpapers,” “$50B audit trigger.” (congress.gov)
• CTO and Head of Protocol: “canonical L2 supply,” “event schema for examiners,” “freeze/denylist with audit trail,” “SNARK proof of reserves,” “EIP‑712 management attestations.”
• Head of Exchange Listings/BD (DASPs): “foreign issuer reciprocity,” “lawful order compliance,” “marketing disclaimers,” “issuer eligibility checks.” (congress.gov)

What changed recently that you must reflect in your plan

• Law is final; Senate/House passage and presidential signature completed in July 2025; expect agencies to land the core rules in 2026. Treasury and FinCEN have active consultations; FDIC has begun its rule series; OCC has accelerated digital‑asset charters supporting the federal‑nonbank path. Build now to the likely 2026 go‑live window. (cnbc.com)

Exactly how 7Block Labs executes (deliverables you can budget)

• 4‑week GENIUS Readiness Sprint: target‑state architecture, reserve policy, redemption SLA design, AML model roadmap; outputs: regulator mapping memo, control catalog, build plan. Delivered via custom blockchain development services.
• 8‑week Build + Integrate: token contracts, bridges, AML/sanctions services, custodial APIs, disclosure generator; outputs: running testnet, examiner dashboards, AT‑C workpaper generator. Delivered via web3 development services and blockchain integration.
• 2‑week Dry‑Run Exam + Fix: red‑team your redemption, disclosures, and AML flows; outputs: remediation PRs, updated policies, board deck. Validated with security audit services.
• Optional: token economics and issuance mechanics aligned to your charter path via token development services and asset tokenization.

Final word — the “money phrases” to socialize internally

• “We will not ship any asset outside the enumerated reserve set; our OMS enforces ≤93‑day maturities and tri‑party RRP only.”
• “Our monthly reserve disclosures are CEO/CFO‑certified, PCAOB/AICPA‑examined, and cryptographically verifiable.”
• “Redemption SLAs are enforced in code, monitored in real time, and tested quarterly under 3× demand spikes.”
• “Our AML stack implements FinCEN’s novel‑methods mandate with explainable models and Travel Rule interop.”
• “We have a 360‑day state‑to‑federal transition plan should issuance exceed $10B.”

Ultra‑practical next steps (this week)

• Decide charter lane and confirm issuance ceiling.
• Lock custodial and CPA partners; mandate daily eligibility flags and monthly examination cadence in contracts.
• Stand up the reserve policy engine and redemption scheduler.
• Implement the token control surface and evidence‑grade event schema.
• Publish your draft disclosures and mis‑marketing disclaimers for counsel review.

Personalized CTA If you’re the GC, BSA Officer, or CFO at a U.S. payments or fintech company planning a USD stablecoin pilot for Q3–Q4 2026—and you already have a potential custodian and CPA short‑list—book a 45‑minute GENIUS Readiness Drill with our lead architect. We’ll live‑test your reserve composition against the “≤93‑day” rule, generate a sample monthly disclosure, and map every control to the exact statutory clause you’ll be examined against. Start with our custom blockchain development services and ask for the “GENIUS Drill” by name; we’ll hold a build slot for your target launch window.

Sources for key requirements and dates

• GENIUS Act signed into law July 18, 2025; first major U.S. federal stablecoin framework. (politico.com)
• Reserve composition, redemption disclosures, securities/commodities carve‑outs, CEO/CFO certifications, monthly examinations, >$50B audit trigger, and custody segregation. (congress.gov)
• Effective‑date mechanics (earlier of 18 months post‑enactment or 120 days after final rules; core rules due within one year). (pwc.com)
• FDIC proposed application procedures for IDI subsidiaries; additional prudential rules forthcoming. (fdic.gov)
• Treasury ANPRM (Sept 2025) and FinCEN consultations (Aug–Sept 2025) on tailored AML and “novel methods.” (home.treasury.gov)
• OCC activity signaling a viable federal‑nonbank path for issuers. (axios.com)

Internal links recap

• custom blockchain development services
• web3 development services
• security audit services
• blockchain integration
• cross-chain solutions development
• smart contract development
• asset tokenization
• token development services