It represents one of the most significant bilateral financial services trading relationships globally, where almost a third of the UK’s financial services exports go to the US with the UK exporting £28.4 billion of financial services trade to the US. The US is therefore a key market for our members, and our members welcome the opportunity to provide respond to the US Treasury’s ANPRM, requesting comment on the implementation of the GENIUS Act.

Key messages

• Apply GENIUS Act determinations to ensure clear supervisory cooperation arrangements that preserve cross-border access and interoperability of different regulated payment and settlement frameworks: The recognition measures for stablecoins under the GENIUS Act via the determination of the UK would increase cross border flows of financial services trade, owing to reduced regulatory barriers between the jurisdictions.
• Clarity on Anti-Money Laundering (AML) and financial crime requirements: The Act outlines the expectation for stablecoin issuers to comply with the Bank Secrecy Act (BSA). Our members believe that it is critical for all public authorities to provide clarity on AML requirements for stablecoins across all use cases. Strong AML requirements are in the best interests of all market participants; however, the boundaries of firms’ responsibilities need to be clearly established, in particular, the question of how far up the chain firms need to look.
• Clear definitions and taxonomy: In the UK, stablecoins are regulated under a number of different regimes that sit under the Financial Services and Markets Act (FSMA) 2023. It is therefore important that definitions and activities are consistent across the multiple sets of requirements to ensure specific cryptoasset firms (issuers, intermediaries, etc) are clear on which requirements they are expected to undertake.