First-mover advantage: The US stablecoin race after the Genius Act
With the first federal law for digital assets on the books, America’s biggest banks, fintechs, and payment giants are racing for the lead in regulated stablecoins.
The passage of the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act in July 2025 marks a seismic shift for digital finance. In a country often defined by its fractured approach to financial regulation, the US now stands poised to issue its first national licences for fully-backed, US dollar stablecoins. As President Trump prepares to sign the bill, a small group of industry leaders — from Wall Street’s largest banks to Silicon Valley’s most ambitious fintechs — are positioning themselves to define the next chapter of money.
The stakes are enormous. Stablecoins, once dismissed as speculative curiosities, now represent more than $260 billion in value. With the legal fog finally lifting, the question for boardrooms and policymakers is not if regulated digital dollars will enter mainstream commerce, but who will control their future.
Meet the frontrunners —
Not every firm can leap immediately into the new regulatory regime. The most likely first-movers are those already living under strict compliance — or those that have made major, public investments in preparing for national scrutiny.
Circle is perhaps the best-known name in US stablecoins, operating the USDC token that accounts for roughly a quarter of the global market. Headquartered in Boston, Circle has spent years cultivating its compliance credentials. It became the first company to receive the New York Department of Financial Services (NYDFS) BitLicense and, as of June 2025, has filed for an OCC national trust charter — an explicit signal that it aims to become the first fully licensed stablecoin bank in the US. Jeremy Allaire, Circle’s CEO, described the move as “a significant milestone in our goal to build an internet financial system that is transparent, efficient and accessible.” The company’s rapid technical development, its relationships with major exchanges, and its vocal support for the Genius Act place it firmly in the pole position.
Coinbase is another household name — though it does not currently issue its own stablecoin, it has deep ties to the sector, holding around $12 billion in USDC through its trading platform and playing a founding role in the Centre consortium that governs USDC. In April, Coinbase confirmed it is “actively considering” a federal bank charter, and has repeatedly hinted at plans to issue a proprietary USD-backed stablecoin as the new regime takes shape. A company spokesperson was direct: “This is something Coinbase is actively considering but has not made any formal decisions yet.” With a powerful consumer brand and extensive money transmitter licences across the US, Coinbase is expected to act quickly once the OCC’s application portal opens.
Paxos may be less of a household name but is a regulatory powerhouse, holding both a New York trust charter and a conditional OCC national trust charter since 2021. The company is already a key behind-the-scenes player: it issues not only its own USDP token but also PYUSD for PayPal, and recently launched USDG in Europe under MiCA rules. Paxos has spent years building a compliance-first culture, and its Head of Strategy, Walter Hessert, recently called the launch of USDG “a testament to our commitment to offering global digital assets that meet the highest standards of consumer protection.” Paxos is well positioned to transition from state-level supervision to a full federal stablecoin licence.
PayPal, for its part, has turned its massive user base and payments infrastructure toward digital assets through the launch of PYUSD, issued by Paxos. In July, the company made headlines by expanding PYUSD to the Arbitrum Layer-2 network, cutting transaction costs and boosting speed for both consumers and developers. “A key to any cryptocurrency’s success is a robust developer ecosystem … developers can now deploy PYUSD-powered applications on the blockchain that best fits their technical requirements,” said May Zabaneh, PayPal’s VP of Product. As both a NYDFS-licensed entity and a national payments leader, PayPal is expected to be an early filer once formal rules drop.
Gemini is another early-mover. Founded by the Winklevoss twins, Gemini holds a New York trust charter and has consistently argued for “smart, targeted regulation.” The company publicly celebrated the House passage of the Genius Act, with co-CEO Tyler Winklevoss stating on X (formerly Twitter), “The GENIUS Act aka the Stablecoin Bill just passed the House and is going to the President’s desk for signature.” With a long track record of regulatory compliance and public support for national licensing, Gemini is likely to move quickly in the new environment.
Banking on something new —
The new legislation has also triggered a rapid pivot among America’s largest banks. In a sector long marked by caution, the Genius Act’s clarity has produced a wave of direct, public statements from senior leaders.
JPMorgan Chase is at the forefront, with CEO Jamie Dimon making it clear that the bank will play in both its proprietary JPMorgan deposit coin and regulated stablecoins. “We’re going to be involved in both JPMorgan deposit coin and stablecoins … to understand it and be good at it,” Dimon said on a July earnings call. The bank is reportedly weighing the creation of a Zelle-style consortium to bring stablecoins to scale across the sector.
Citigroup is following a similar path. CEO Jane Fraser told analysts that Citi is “looking at the issuance of a Citi stablecoin” and is already expanding its Citi Token Services deposit-token platform. She called the shift “a good opportunity for us.”
Bank of America has signalled its intent to participate both in multi-bank networks and in developing its own branded stablecoin, with CEO Brian Moynihan noting, “You need networks to make this all work … We’ll be there, just like we were there when we moved from checks to Zelle.”
BNY Mellon is acting as the primary custodian for Ripple USD (RLUSD), offering Wall Street-grade reserve management and transaction banking to a new class of enterprise stablecoins. Emily Portney, the bank’s Head of Asset Servicing, explained: “We’re excited to support the growth and adoption of RLUSD by facilitating the seamless movement of reserve assets and cash for conversions.”
U.S. Bank has also gone public, with CEO Gunjan Kedia stating, “We are quite ready to pilot our own stablecoin, with the first focus being interoperability within the banking system.” This signals that mid-tier banks may not wait for megabank standards, but will look to launch their own stablecoins as soon as licensing rules allow.
The integration race —
Beyond the banking giants, the Genius Act has triggered immediate moves from major fintechs and payment networks, each seeking a first-mover advantage.
Mastercard is rapidly scaling its Multi-Token Network, aiming to let banks, wallets, and acquirers settle both consumer and B2B payments in regulated, USD-backed stablecoins. The firm is working with partners such as Nuvei, OKX, and Paxos, and expects to apply as a “qualified payment stablecoin service provider” when the Federal Reserve and OCC issue application guidelines.
Jorn Lambert, Chief Product Officer, said, “While the tech behind stablecoins holds tremendous promise… utility plus interoperability will decide who wins.” Raj Seshadri, Chief Commercial Payments Officer, added, “What stablecoins bring is another choice for businesses and consumers in how they pay and want to be paid.”
Stripe has also moved swiftly, acquiring the wallet infrastructure startup Privy in July to enable “turn-key, self-custody” wallets for users, and partnering with Shopify and Coinbase to enable seamless USDC checkouts. Neetika Bansal, Stripe’s Head of Money-as-a-Service, highlighted the reach: “The end card-holder can spend at 150 million-plus Visa merchants seamlessly… the more stablecoins, the better.”
PayPal’s expansion of PYUSD on new blockchain networks is another sign that scale and technical sophistication will be crucial for early compliance and rapid adoption.
What comes next —
A key determinant for early movers will be their ability to demonstrate existing compliance with banking-grade standards. Firms such as Paxos, Circle, Gemini, and PayPal have long operated under NYDFS trust charters or have already filed for OCC approval, meeting many of the requirements now codified in the Genius Act. JPMorgan, Citi, Bank of America, BNY Mellon, and U.S. Bank, as national banks, have robust anti-money laundering and audit programmes that will smooth the path to federal approval. Custodia Bank, operating under Wyoming’s SPDI charter, and Coinbase, with its extensive state licensing, round out the compliance front-runners.
Public statements in the wake of the Act show these firms are not starting from scratch; instead, they are aligning their existing regulatory programmes with the Genius Act’s final rule-set, giving them a significant head start over less-established challengers.
The weeks since Congress passed the Genius Act have also seen a flurry of strategic deals — each signalling a different facet of the stablecoin market’s future.
Stripe’s acquisition of Privy, for instance, positions it as a leader in wallet infrastructure, integrating secure, self-custody options for mainstream users. Ripple’s decision to partner with BNY Mellon as the custodian for RLUSD reserves is a strong vote of confidence in Wall Street’s ability to provide trusted infrastructure. Circle’s partnership with OKX, bringing 1:1 USDC conversions to 60 million exchange users, is an explicit play for on/off-ramp liquidity ahead of federal licensing.
Meanwhile, Mastercard’s collaboration with MoonPay to develop card-linked wallets points to a future where regulated stablecoins are seamlessly integrated with traditional payment rails. The acquisition of Coin Metrics by Talos, a trading and portfolio management platform, is yet another signal that data, risk analytics, and compliance monitoring will become standard in the digital asset world. PayPal’s deployment of PYUSD on Arbitrum Layer-2, with near-instant, sub-cent transactions, shows a clear focus on scalability and developer adoption.
The Genius Act sets hard deadlines: regulators must publish implementing rules within 12 months, by July 2026. Once applications open, agencies have 45 days to confirm completeness and 120 days to approve or deny — with automatic approval if deadlines are missed. Most prohibitions and requirements are set to take effect no later than January 2027, or as soon as 120 days after final rules are published.
Agency leaders have been direct. OCC Acting Comptroller Rodney Hood has said the application portal will open “well before the Act’s one-year deadline.” The Federal Reserve’s Vice-Chair Michelle Bowman has committed that the Fed “stands ready to review stable-coin applications the moment the joint rules drop, which we expect in the first half of 2026.” The CFTC is launching a “digital-asset markets pilot programme” in early 2026, offering a sandbox for early applicants.
Circle is so far the only issuer to publicly declare it will file immediately. Dante Disparte, Circle’s Chief Strategy Officer, called the House vote “a defining moment,” with the company confirming its GENIUS licence application is “substantially ready.” Other likely early filers — including Paxos, PayPal, Gemini, and Coinbase — are keeping their cards close for now.
The bottom line —
For US business leaders, the signal is unmistakable: regulated digital money is moving from concept to commercial reality. The Genius Act has transformed a fragmented landscape into a true race — with compliance, technical scale, partnerships, and speed of execution as the key competitive differentiators.
Those with a head start in licensing and regulatory readiness will shape the next decade of digital finance. The winners in this new contest are already emerging. For the rest, the clock is ticking.