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The GENIUS Act’s Vanishing Compliance Window: Will Stablecoin Issuers Have Enough Time to Prepare?

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Baker McKenzie Partner David Zaslowsky recently published an article in Law360 titled, “Tips for Issuers Left in Lurch Without GENIUS Act Final Rules.” The piece examines how delays in enacting the final regulations for the GENIUS Act could leave stablecoin issuers and other market participants with less time to prepare for significant new compliance obligations than was envisioned in the legislation.

David’s key takeaways on what stablecoin issuers should be watching:

  • The missed rulemaking deadline matters, but the shrinking compliance runway may be the bigger issue.
  • If final rules are delayed past approximately Sept. 20, 2026, firms may have less than the 120-day implementation period built into the statute’s structure.
  • Issuers should begin preparing now by assessing readiness, identifying no-regrets compliance steps and securing resources early.

Read the full article here.

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David Zaslowsky is partner in the Litigation Department of Baker McKenzie's New York office. He helps companies solve complex commercial disputes in arbitration and litigation, especially those involving cross-border issues and Section 1782 discovery. David has a degree in computer science and, as a result, has worked on numerous technology-related disputes, including, most recently, those involving blockchain and artificial intelligence. In April 2025, Attorney Intel named David one of the top 25 blockchain lawyers in the country. He is the editor of the Firm's blockchain blog and co-editor of the firm's International Litigation & Arbitration Newsletter. David has been included for a number of years in the Chambers USA Guide and Chambers Global Guide for his expertise in international arbitration. He also sits as an arbitrator and is on the roster of arbitrators for a number of arbitral institutions. David sits on the Board and chairs the governance committee of the New York International Arbitration Center, and is a founding member of the International Arbitration Club of New York. For over 35 years, he has written and spoken often on the subjects of arbitration and international litigation.

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