The Treasury Department published a notice of proposed rulemaking that extends GENIUS Act liability beyond stablecoin issuers to exchanges facilitating stablecoin transactions, while also introducing unresolved compliance questions for foreign-issued stablecoins operating in US markets. The NPRM marks a significant broadening of the compliance perimeter compared to the original GENIUS Act language and signals Treasury intends aggressive implementation of the statute.
Armada's crypto desk accepts tokenized T-Bills as eligible collateral, and several tokenized T-Bill products are distributed or settled via stablecoin infrastructure that may involve foreign-issued stablecoins or exchange intermediaries now captured by the NPRM. If those rails are deemed non-compliant, collateral eligibility and settlement mechanics for those instruments could be materially affected. Legal review of custody and settlement chains is warranted before the comment period closes.