Points of Focus 

• OCC’s GENIUS Act proposal requires foreign stablecoin issuers to register as Foreign Payment Stablecoin Issuers (FPSI) to serve US users.  
• Mandates comparable foreign regulation, US-based dollar reserves, and no yield arrangements, potentially barring Tether.  
• 2028 deadline bars US platforms from offering non-compliant stablecoins; rules also push real-time freeze/seize compliance.

The Office of the Comptroller of the Currency (OCC) has released a sweeping 376-page GENIUS Act rulemaking proposal that would impose stringent registration and operational requirements on non-US stablecoin issuers seeking to serve American users. 

OCC Stablecoin Guidance – TETHER and Non-US Issuers. There is also a monumental impact for non-US "Foreign Payment Stablecoin Issuer (FPSI)".
1) any non-US entity wishing to have their stablecoin offered to US citizens must register with the OCC as a Foreign Payment Stablecoin…

— Tom Noyes (@noyesclt) February 26, 2026

Under the proposal, foreign entities must: 

• Register as Foreign Payment Stablecoin Issuers (FPSI) with the OCC 
• Demonstrate they are subject to a foreign regulatory regime deemed “comparable” to the GENIUS Act by the US Treasury
• Hold US dollar reserves exclusively in US-regulated financial institutions, and face a blanket prohibition on any arrangement, direct or indirect, that pays yield or interest to holders. 

Observers have described the language used in the announcement as deliberately broad, presuming a violation of any contract, agreement, or third-party arrangement provides payments tied to holding or using the stablecoin.

The OCC’s proposal marks a decisive step toward full US regulatory control over stablecoin access, effectively forcing non-US issuers to choose between strict compliance i.e US reserves, no yield, real-time freeze/seize, or exit the American market.

Who could be affected?

Consequently, it has been suggested that it could be targeted at issuers like Tether (USDT), the world’s largest stablecoin by market cap, which currently operates outside US jurisdiction and offers yield-linked programs in certain markets. 

The proposal also requires foreign issuers to demonstrate technological capability for real-time compliance with US lawful orders, including OFAC sanctions and court-ordered freezes, moving beyond Tether’s current manual processes toward auditable, national-bank-level standards.

Regardless, a hard deadline looms. By July 18, 2028, it will be illegal for any US-based exchange or wallet provider to offer or sell a stablecoin unless the issuer is OCC-permitted or registered as an FPSI. Non-compliance would force platforms to delist affected tokens, potentially disrupting US access to major stablecoins like USDT and DAI if they fail to meet the new regulations.

At variance with GENIUS Act framework

This seems to be in contrast with the GENIUS Act’s domestic framework, which already bans interest on regulated stablecoins, but allows issuance by licensed entities. For entities like Tether, the requirements could prove prohibitive. US reserve mandates conflict with its offshore model, and the yield ban closes off programs that have driven adoption. 

Stablecoins represent a legally permissible new payment tool. The OCC invites comments on a proposed regulatory framework for payment stablecoins pursuant to the GENIUS Act. More info at https://t.co/fbADAxqP2N. pic.twitter.com/gfwt6AtN7u

— OCC (@USOCC) February 25, 2026

For the short-term, US platforms face delisting risk by 2028. In the long-term, however, this could speed up fragmentation i.e. the US-compliant stablecoins vs. global alternatives, or push foreign issuers toward registration. Will the US actions aimed at exerting tighter control and improving consumer protection come at the cost of reduced competition and innovation? Only time will tell.