Comments from the U.S. Blockchain Association on the Implementation Rules of the GENIUS Act

The U.S. Blockchain Association has submitted comments on the proposed implementation rules for Section 3 of the GENIUS Act by the U.S. Department of the Treasury. The Association recommends clarifying the scope of "digital asset service providers" to exclude infrastructure such as self-custody software and validators, as well as businesses that only trade their own assets. Regarding criminal liability for participating in the illegal issuance of stablecoins, the Association believes that actual knowledge and substantial assistance in coordination with the issuer should be prerequisites. Additionally, the Association suggests that trading platforms assess the compliance of foreign stablecoins based on an official list of issuers and trading bans, and adjust the standards for determining the location of users in unlicensed agreements.

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