GENIUS Act Stablecoin Rules for US iGaming: USDC In, USDT on a Clock

The GENIUS Act became Public Law 119-27 on July 18, 2025. The date a US-licensed iGaming cashier plans around is July 18, 2028, when the Act starts barring digital asset service providers from selling US persons any payment stablecoin that a Permitted Payment Stablecoin Issuer (PPSI) did not issue. Paysafe's Pay with Crypto, live in regulated US iGaming and daily fantasy sports cashiers since April 8, 2026, takes USDC, the incumbent token with the shortest path to PPSI status.

USDC and USAT have a path to PPSI status by 2028, while USDT has one only if Tether wins the Act's foreign-issuer carve-out. Section 4 also changes how an operator underwrites a stablecoin, because a monthly reserve report, examined by an accounting firm and certified by the issuer's CEO and CFO, replaces brand and trading volume as the input.

GENIUS Act Deadlines for US iGaming Cashiers

Three GENIUS dates matter to a US cashier, and the first was the rulemaking deadline. The Act required the federal payment stablecoin regulators (the OCC, the Federal Reserve, the FDIC and the NCUA), the Treasury Secretary and state regulators to publish implementing regulations within 12 months of enactment, by July 18, 2026. Every rule was still a proposal on that day.

The OCC published its framework proposal in March 2026. On April 8 the FDIC proposed its standards for the issuers it supervises with a 60-day comment period, and FinCEN and OFAC proposed their AML and sanctions program rules, with comments that closed June 9. FinCEN followed with a separate Customer Identification Program proposal on June 22, 2026, and the FDIC took comments on a BSA and sanctions request until August 4. On August 18, 2026, Treasury proposed the rules for Section 3 itself, the ban on issuing, offering and selling non-PPSI stablecoins, and on September 24, 2026, the Federal Reserve put out two proposals for the issuers it supervises, covering reserves, capital, risk management, custody and applications. The OCC is aiming for a final rule in November 2026, with issuer applications to follow in 2027.

The second date is when the Act takes effect. Section 20 sets it at the earlier of 18 months after enactment or 120 days after final rules. The 18-month leg lands on January 18, 2027. A final rule issued after September 20, 2026, puts the 120-day leg past that date, and none had been issued by then, so January 18, 2027, is the effective date to plan against.

The third date is the prohibition itself, which takes effect three years after enactment, on July 18, 2028. Besides the sales ban on digital asset service providers, Section 3 bars anyone other than a PPSI from issuing a payment stablecoin in the US. Treasury's Section 3 proposal is the first rule written for the ban. It covers issuance, offer and sale, so its final text will set how "offer or sell to a US person" applies where a player's wallet meets the cashier. Comments on it close October 19, 2026.

For a US-licensed iGaming operator the planning window therefore runs to July 18, 2028. Until then a digital asset service provider may still sell USDT to US players. After that date no gateway may do so unless Tether qualifies under the Act's foreign-issuer carve-out. The late rules leave issuers less time to win PPSI status before that date.

USDC vs USAT vs USDT Under the GENIUS Act

The three dollar stablecoins that US players bring to a cashier sit on different paths through the GENIUS framework.

USDC sits closest to the Act's requirements. Circle has published monthly Deloitte examinations of its reserves for years, and on August 31, 2026, $73.3 billion USDC was outstanding against $73.4 billion in reserves. Of the reserves, $62.3 billion sat in the Circle Reserve Fund, a money market fund managed by BlackRock and held in custody at BNY Mellon, and $9.6 billion in cash at banks. That mix of cash, overnight Treasury repos and short-dated Treasuries maps onto Section 4(a), which permits cash, insured bank deposits, short-term Treasuries, overnight Treasury repos and reverse repos, and money market funds. Circle holds a NYDFS BitLicense, and its national trust bank, First National Digital Currency Bank, N.A., won conditional OCC approval on December 12, 2025, and final approval in July 2026. It opened as Circle National Trust with digital asset custody for Circle and its affiliates, and managing USDC reserves is a later step.

Tether designed USAT for the GENIUS regime. The token launched on January 27, 2026, and is issued by Anchorage Digital Bank, N.A., the first OCC-chartered federal digital asset bank, with Cantor Fitzgerald holding the collateral. Its structure follows the Act's PPSI requirements from the first token issued. Anchorage publishes a Deloitte reserve examination every month. The first one counted 17.5 million USAT outstanding on January 31, 2026, and was the first Big Four sign-off on a reserve report tied to Tether. By August 31, 2026, the supply had grown to 175.7 million USAT against $176.4 million in cash and overnight Treasury repos. That is 0.24% of the USDC outstanding on the same day. A cashier that adds USAT gets a token built around the Act, with little of USDC's secondary-market depth behind it.

USDT has two problems under the Act, where Tether is domiciled and what backs the token. Tether Limited is domiciled outside the US (originally in the BVI, with parts of its operations since moved to El Salvador and the UAE). The Act's foreign-issuer carve-out requires a Treasury determination that the issuer's home jurisdiction has a "comparable regulatory and supervisory framework," proof that the issuer can comply with US lawful orders including asset freezes and sanctions, and OCC registration with reserves held in the US. Treasury has made no comparable-jurisdiction determination for any country. On June 30, 2026, Tether held $187.75 billion in reserves against $183.64 billion in liabilities. Treasury bills and overnight repos came to $133.59 billion, enough to cover 73% of those liabilities. Term repos added $6.99 billion, though the Act allows repos only at overnight maturity. Gold ($18.84 billion), secured loans ($13.45 billion), bitcoin ($5.80 billion), other investments ($5.24 billion) and public equities ($3.76 billion) made up the rest, and the Act permits none of them.

Tether reports its reserves quarterly, while a PPSI has to report monthly. In August 2026 KPMG completed the first full audit of Tether's 2025 financial statements, with the gold bars physically counted, though an annual audit leaves the reserve mix where it was. Tether has until July 18, 2028, to rebuild that mix, win a comparable-jurisdiction determination or move US-facing volume to a US-domiciled issuer. USAT, issued by Anchorage, already gives Tether that route, so the likely outcome is USAT carrying Tether's US volume while USDT serves players outside the US.

Paysafe Pay with Crypto Under the GENIUS Act

Paysafe launched Pay with Crypto on April 8, 2026, for regulated US iGaming and daily fantasy sports operators. MoonPay supplies the conversion through its Commerce Checkouts product, and Paysafe runs the merchant side and the cashier integration on a platform that processed $167 billion in payments in 2025.

Pay with Crypto takes USDC only. A player at a US-licensed cashier picks it, pays from a self-custody or custodial wallet or by scanning a QR code, and MoonPay converts the USDC into dollars on the spot. The dollars fund the player's account, so the operator never holds a stablecoin. On the operator side the MID works like a card MID, and MoonPay sits between the player's wallet and the operator's bank as the digital asset service provider of record. The January 18, 2027, effective date changes nothing for the rail, because the sales ban that reaches it starts on July 18, 2028.

Two consequences follow for an operator that takes the rail. First, the operator receives dollars, and MoonPay carries the token risk during the conversion. Section 3 does not reach the operator on this flow, because the operator sells no stablecoin to the US person and takes a dollar deposit from a digital asset service provider that converted on the player's behalf.

Second, the gateway sits inside Section 3. After July 18, 2028, a digital asset service provider such as MoonPay may not offer a US person a stablecoin unless a PPSI or a qualifying foreign issuer stands behind it. Pay with Crypto runs on USDC, so its token line holds after that date only if Circle is a PPSI by then. A cashier that takes USDT from US players through another conversion gateway loses that line on the same date unless Tether qualifies under the carve-out first, and USAT is the Tether-designed token that can replace it.

The launch matters for planning because the flow already runs in regulated US cashiers before the rules are final. An operator that integrates now builds against the date that decides its token list, July 18, 2028.

GENIUS Act Reserve Disclosure and Stablecoin Counterparty Risk

Without mandatory reserve reports, operators underwrite a stablecoin on brand and liquidity. The big token has the deep secondary market that holds its peg, and a smaller token has thinner liquidity and takes a haircut. That model produces policies like "USDT for breadth, USDC for compliance" and treats reserve composition as something an issuer publishes when it chooses to.

Section 4 replaces that input. PPSIs must publish monthly reports of reserve composition on their websites, examined by a registered public accounting firm, and the CEO and CFO must certify the reports to regulators and face perjury liability for misstatements. Issuers with more than $50 billion in outstanding stablecoins must also publish annual audited financial statements. Only custodians under federal or state banking supervision may hold reserves, and issuers may not pay holders yield or interest.

For USDC the reporting rhythm stays the same, because Circle already reports monthly. The Act makes that report mandatory, fixes the reserve perimeter it covers and puts the CEO and CFO on the hook for a false certification. For USDT both the rhythm and the reserve mix would have to change.

Once PPSIs exist, an operator's risk team can weigh its exposure to each stablecoin against that issuer's certified monthly reserve report. Drift in reserve composition from one report to the next becomes a leading indicator the team can act on, and a late report becomes a trigger to restrict acceptance. Comparing every accepted token against the operator's own thresholds then becomes routine treasury work.

What US iGaming Operators Should Do Before July 18, 2028

1. Build a stablecoin acceptance policy with three tiers. PPSI-eligible covers USDC, USAT and any other US-domiciled candidate. Foreign-issuer-pending covers USDT until Treasury makes a comparable-jurisdiction determination or Tether restructures. Excluded covers everything else. Review the tiers quarterly as final rules ship.
2. Make your cashier integration record the source token at deposit time, even when the gateway settles in fiat. Without that field your treasury team cannot measure stablecoin concentration once monthly PPSI reports arrive.
3. Use Paysafe's Pay with Crypto as the reference design, since it already runs on USDC with fiat settlement. The USDT risk sits on other gateways. If one of yours takes USDT from US players, plan for that line to close by July 18, 2028, and prepare player messaging and retention offers for the move to USDC or USAT.
4. Add reserve-composition changes to the counterparty-risk dashboard you already run for card acquirers. Send any monthly drift of more than five percentage points on a covered token, and any late report, to treasury for review.
5. Ask your state regulator (NJ DGE, PA PGCB, MI MGCB or equivalent) whether it wants prior approval of stablecoin acceptance or only after-the-fact reporting. State positions vary, and the GENIUS framework does not preempt state cashier rules.

An operator that waits for the rules to settle before doing any of this faces an emergency cashier rebuild in 2028. The B2B side of the question, which acquirers and PSPs pay an operator in stablecoins instead of only taking them from players, is covered in the stablecoin settlement guide for gambling operators.