The U.S. Department of the Treasury has taken a significant step in implementing the GENIUS Act’s stablecoin framework. On April 1, Treasury released a Notice of Proposed Rulemaking (the “Treasury NPRM”) to implement Section 4(c) of the Act, establishing broad‑based principles for determining whether a State‑level stablecoin regulatory regime is “substantially similar” to the federal regulatory framework established by the GENIUS Act. The Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act” or “Act”)…

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