By: Callum McArthur ’28
Volume XI – Issue I – Fall 2025
I. INTRODUCTION
The rise in the prevalence and legitimacy of Decentralized Finance systems reflects a new era of digitalization and changing legal sphere. Better known as “DeFi” systems, this emerging financial ecosystem is one that allows users to send, purchase, and exchange financial assets without relying on banks, brokerages, or exchanges to do so. In essence, DeFi allows users to side-step the traditional means of financial exchange by operating in a solely online peer-to-peer environment. Here, exchanges are filled out automatically by self-executing code known as smart contracts, and recorded on a public ledger called a blockchain. [1] The assets traded in ecosystems like these are cryptocurrencies, digital tokens or currency that exist only in the decentralized system from which they belong.
Cryptocurrencies such as Ethereum or Bitcoin, the latter boasting a near six-figure market value for a single token, have become popular mediums for individuals to invest and make secure transactions in recent years. However, they have one glaring problem: their value is extremely volatile. This volatility makes them unsuitable for financial functions that require more stability, such as acting as a medium for loans, savings, or even pricing for goods and services. This would severely limit the scope of uses for digital coins if it were not for specialized cryptocurrencies designed to maintain a stable value, typically pegged to fiat currencies like the U.S. dollar, called Stablecoins. These stablecoins are vital elements for an effective DeFi ecosystem, and serve many different purposes, ranging from users lending them to earn yield or borrowing them against other cryptocurrency collateral to yield-generating protocols distributing returns denominated in stablecoins, among many others. While these applications and many more will be explored in more detail to come, the most significant function of stablecoins is to act as a stable medium of exchange, store of value, and to ultimately bridge the gap between DeFi systems and traditional finance.
In this way, stablecoins act as the “cash” of DeFi, and their use has been widely adopted as an asset to stabilize and empower the use of cryptocurrency. Today, stablecoins process trillions in transactions, yet despite their massive scale, they have operated in a legal grey area for years. [2] Often subject to patchwork state licensure, litigated classification battles, and disparate agency enforcement, markets and regulators have been left widely uncertain about the future of cryptocurrency in the United States. The situation only grew more dire after an incident in 2022 when a lack of regulation allowed the stablecoin TerraUSD to collapse from a market price of $120 to practically worthless, wiping out over $50 billion in market capitalization and causing over $400 billion in losses for the broader cryptocurrency markets. [3] This issue was enabled by a lack of restriction regarding what can be traded as a stablecoin, ultimately caused by the coin’s lack of legitimate collateral, which led to its collapse during a fire sale.
Over the years, there have been a multitude of proposed legislative regulations on stablecoins, all of which faced widespread dispute, until the Congress finally decided to enact the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act (Public Law No. 119-27) in July 2025 to create what was seen as a federal stablecoin framework. [4] In essence, the GENIUS Act has a few major functions and problems it aims to address. Mainly, it defines what can and cannot constitute a recognized stablecoin, a question that has been circulating since the 2022 collapse. However, while it succeeded in establishing certainty for what qualifies as a stablecoin in the eyes of the law, it fails to establish who ultimately governs their regulation and usage. In essence, the Act is the US government's first full attempt to regulate and reconcile stablecoins within the larger nationwide banking architecture. However, in doing so, it replaces definitional ambiguity with bureaucratic complexity and uncertainty. By defining what they are and who can issue them, Congress has inadvertently opened Pandora's box and raised a multitude of questions regarding who governs stablecoins, how federal and state systems interact, and whether agency and court interpretations will effectively preserve the Act’s balance between innovation and stability.
II. LEGISLATIVE AND POLITICAL BACKGROUND
To begin, it may be most helpful to examine the conditions of the US political and legislative environment that necessitated the eventual passage of the GENIUS Act. Before 2025, crypto assets existed within a legally ambiguous and fragmented framework with many different entities claiming overlapping authority. On one hand, the Securities and Exchange Commission often laid claim to the regulation of such digital assets, arguing that due to the reasonable expectation of profit derived from the efforts of others, crypto assets should be classified as securities and thus governed by the Securities Act of 1933, which requires companies to provide investors with detailed information when they offer new securities to the public. [5] In fact, in 2020, the SEC filed a landmark lawsuit against Ripple Labs Inc., which raised over $1.3 billion through unregistered security sales of its own digital asset, XRP. [6]
In a time when blockchain systems existed with little regulation, this lawsuit sent shockwaves through the crypto realm, and the situation was only further complicated when the United States District Court for the Southern District of New York eventually ruled partially for both sides. The District Court stated that crypto assets only counted as securities in certain types of institutional sales, and were instead classified as commodities in other types of exchanges—as stablecoins might be. [7] This ruling not only gives the Commodity Futures Trading Commission (CFTC) partial, although ambiguous, authority over the issuing of crypto assets and stablecoins along with them, but it also opens a power vacuum for others to begin to introduce regulation. It was also around the same time that the Office of the Comptroller of the Currency (OCC) briefly allowed national banks to issue or hold stablecoins as outlined in Interpretive Letter 1172, before being amended by stricter leadership the following year. [8]
All these developments point toward the inherent legal ambiguity of the situation, and Congress’ inability to provide an overarching structure to crypto and stablecoins led to “regulation by enforcement” of sorts. This urgent need is not only apparent in retrospect, but indeed, legislators recognized the necessity for crypto regulation too. In 2023, H.R.4766 - Clarity for Payment Stablecoins Act was introduced to Congress as the first serious bipartisan attempt at solving the issue of stablecoins’ status as legitimate US currency. [9] While the bill was ultimately not signed into law, it set the foundation for many provisions that would eventually make their way into the GENIUS Act, such as definitions of what can and cannot constitute a legitimate stablecoin.
By 2025, both Republicans and Democrats alike saw stablecoin clarity as necessary for avoiding future cryptocurrency collapse, as well as keeping the U.S. competitive with other foreign markets whose transparency on cryptocurrency applications outclassed their own. Namely, the European Union enacted its own “Markets in Crypto-Assets Regulation” in 2024, cementing stablecoin licensing and supervision regimes for issuers, [10] and similarly, China’s government had rolled out legislation on digitized digital yuan in its e-CNY system at scale. [11] It is likely that Congress saw dollar-backed stablecoins as a tool for projecting U.S. monetary power globally; the idea being that, as the world increasingly transacts in digital assets, those assets should remain dollar-denominated and U.S.-regulated. Many of these factors combined to shape and influence the eventual Act passed in July of the following year.
III. CORE PROVISIONS OF THE GENIUS ACT
The GENIUS Act came about in light of the multitude of international, political, and regulatory pressures at the time and, as a result, is quite complex and at times long-winded. At its core, however, the Act breaks down into three major components: (1) reserve and disclosure requirements, (2) licensing and oversight, and (3) compliance. All of the elements work in tandem to produce legislation that is not only the most legally stable of its kind but also promotes a capacity for continued innovation.
To begin the analysis, perhaps the most critical aspect of the GENIUS Act is the definition of what constitutes a stablecoin and who may qualify as a “Permitted Stablecoin Issuer.” Specifically, the Act outlines that permitted stablecoins must “maintain identifiable reserves backing the outstanding payment stablecoins of the permitted payment stablecoin issuer on an at least 1 to 1 basis.” [12] Additionally, the Act clearly states what is permitted as a proper reserve to back such stable coins: allowing virtually only U.S. coins and currency, funds held in demand deposits that may be withdrawn at any time, and short-term US Treasury bills, notes, or bonds with a maturity of 93 days or less. [13]
This second point is particularly significant, and restricting reserves to solely cash assets is instrumental in establishing the needed stablecoin stability. Prior to GENIUS, there was no requirement that stablecoin issuers hold appropriate reserves. Instead, many issuers that were successful early on backed the value of their coins to other cryptocurrencies, or worse, to another cryptocurrency of their making, of which they could increase or decrease supply in order to maintain their stablecoin’s value to ~$1 as prices fluctuated. In fact, the latter is exactly what happened with TerraUSD; its value was tied to another cryptocurrency, Luna. It was during an event in which many investors decided to quickly sell their Luna reserves that caused the TerraUSD collapse, as its algorithmic price adjustments could not handle the mass sale, and it was rendered worthless.
Thus, a clause about acceptable collateral for stablecoins is vital to achieve the much-needed stability in the cryptocurrency realm that the legislature sought to establish. Furthermore, Congress doubled down in the efforts towards transparency and stability by requiring all permitted stablecoin issuers to disclose a monthly report regarding the reserves in place, as well as a monthly certification as to the accuracy of the monthly report by each issuer's CEO and CFO. [14] All of these measures work to ensure that stablecoin remains reliable, as without users trusting them to maintain their value, they will be rendered unsuitable for virtually all transactive purposes.
Moving to the second key element of the law, another core function of the GENIUS Act is to properly define the appropriate oversight entities regarding stablecoins, and it does so cleverly by building on its aforementioned definitions. By specifying that qualifying stablecoins are both redeemable and designed not to appreciate in value, this means that stablecoins qualify only for exchange purposes, not investment ones, and thus are not governed by the SEC. In fact, the Act actively affirms this, stating that “stablecoins… do include digital assets as defined in section 2 of the Securities Act of 1933 (15 U.S.C. 77b), section 3 of the Securities Exchange Act of 1934 (15 U.S.C. 78c), or section 2 of the Investment Company Act of 1940 (15 U.S.C. 80a-2).” [15]
With this language, GENIUS strategically and unarguably pivots authority away from the SEC and, in doing so, clears the playing field to implement its own unique oversight model. The system in question combines both federal and state capacities for regulation in a manner that ultimately guarantees Federal oversight, but also leaves room for additional state regulation. Specifically, it outlines the process through which entities can apply to become a “federal qualified stablecoin issuer” as a first step to legally distributing stablecoins in the US. [16] This process as a whole consists of a series of complex audits and background checks, which ultimately serve to ensure all companies issuing stablecoins are financially sound to do so. However, the Act goes no further in outlining specific laws beyond constituting what qualifies as a stablecoin and the requirements to become approved to issue them—all else is an authority the GENIUS Act gives to the states. The Act posits, “a State payment stablecoin regulator shall have supervisory, examination, and enforcement authority over all State qualified payment stablecoin issuers of such State.” [17] Thus, the Act crafts a unique dual pathway for regulation: one federally and one on the state level, mirroring the same fundamental dual banking system that has permeated the US financial landscape since the country’s inception. In this way, states are free to regulate stablecoins uniquely, as long as they adhere to minimum federal standards. This provision is key in ensuring that regulation does not stifle the innovative nature of DeFi systems and cryptocurrency, as it allows state experimentation while preserving federal oversight of large, systemically important issuers.
The third and final key element within the GENIUS Act deals with ensuring stablecoin compliance with the wider US financial legal ecosystem. Particularly, it expressly subjects stablecoin issuers and other similar financial service providers to the Bank Secrecy Act (BSA), clarifying that “permitted payment stablecoin issuer shall be treated as a financial institution for purposes of the Bank Secrecy Act, and as such, shall be subject to all Federal laws applicable to a financial institution located in the United States. [18] Among these mandates are requirements to maintain an effective anti-money laundering system, retention of appropriate records, and the use of technology to block or freeze any impermissible or illegal transactions. [19] Provisions such as these may seem obvious or trivial, but are in fact much needed, especially in the context of DeFi, which has no previous obligation to adhere to federal financial laws due to their ambitious nature.
While all these key elements of the GENIUS Act take massive strides towards legitimizing and stabilizing stablecoin within our preexisting central financial framework, its application raises new questions regarding the new legal, financial, and operational uncertainties that may prove equally consequential. In an October 2025 Report, the Andersen Institute for Finance and Economics examined these issues in an overhaul of the cascading effects of the Act. In it, they observed that, “clarity in law does not guarantee stability in practice.” [20] Yes, the Act resolves definitional ambiguity, but simultaneously gives rise to risks that remain untested that may rival the significance of the clarity it begins to begin with.
IV. RISKS AND UNRESOLVED CHALLENGES
The GENIUS Act, while much needed, also brings about significant risks and challenges with its implementation. As previously mentioned, it serves to increase stability by tying stablecoins to cash reserves and US Treasury securities in order to ensure safety. By tying these crypto assets to the most liquid and secure assets, Congress intended to prevent unsafe algorithmic and under-collateralized models that could lead to collapses like that observed by TerraUSD in 2022. However, this link also introduces systematic discrepancies between these digital assets and the more traditional money markets that may prove quite troublesome, as it introduces new forms of fragility that the Act does not yet fully address
To begin, while the Act is quite apt in defining and regulating stablecoins and their issuers, it lacks liquidity insurance and contains no liquidity provisions, undermining the entire stability-based structure and intent of the Act. This lack of liquidity protections means that mass redemptions of stablecoins for cash during a market shock could still trigger liquidity spirals, similar to those seen in money-market funds in both 2008 and 2020. Essentially, during times of economic stress, stablecoin issuers could be forced to dump government debts into an already stressed market in response to facing heavy cash redemptions for the coins they issue, further cascading the negative economic stress.
Traditionally, the federal government can help to mitigate this and keep firms and individuals confident even during times of economic downturn via FDIC insurance and agreements with the Federal Reserve to establish an explicit emergency liquidity backstop. Programs such as the Money Market Mutual Fund Liquidity Facility (MMLF), a Federal Reserve program introduced in 2020 to provide aid and relief via loans to eligible institutions to purchase assets from money market mutual funds, are perfect examples of a federal safeguards that could be implemented in the case of stablecoin issuers. However, mentions of emergency measures are completely absent in the GENIUS Act. [21] This glaring hole in the stability of stablecoins could, paradoxically, amplify the financial fragility within the very system meant to stabilize them; because while monthly disclosures and regulations enhance visibility, transparency does not necessarily translate directly to liquidity or stability, and even a well-backed stablecoin could experience runs if market confidence falters, especially without federal safeguards.
It is increasingly clear that the GENIUS Act shores the dimension of risk presented by unregulated insurance while introducing another in the form of this systematic linkage. The Act chooses to circumnavigate the issue of federal backstops, and while an argument can be made that, in doing it, the Act preserves the inherently decentralized and independent nature of DeFi systems, the risks presented are nonetheless threatening. In addition to these inherent risks, the GENIUS Act still creates significant jurisdictional tensions amongst different authorities, and while the federal-state dual system may have been established with the intent to define oversight systems, it remains unclear if Congress actually achieves this. In creating not a single defined regulator, but rather a layered, coherent federal umbrella, the GENIUS Act emerges as a battleground for one of the oldest tensions in American financial law: the uneasy coexistence of federal and state authority over money, banking, and innovation.
The tension permeates the entirety of the Act’s legislation. For example, issuers seeking registration can either seek federal licensure via the US Treasury, or continue operating under State authority, so long as they meet minimum standards set by the federal government. [22] At first glance, this provision may seem to empower stablecoin accessibility while maintaining appropriate regulations, and while it does achieve this to a degree, many argue that it simply increases the capacity for jurisdiction inefficiencies and divergent supervisory expectations. For example, a California-based stablecoin trust licensed by the US Treasury and Texas–regulated limited-purpose trust could, in theory, issue functionally identical products that are governed by wildly different statutes.
This ambiguity risks undermining the stability that the GENIUS Act was passed to ensure in the first place. Historically, coordination failures between the Federal bodies like the OCC and state banking departments have been significant and often led to litigation, such as that of Watters v. Wachovia Bank (2007), in which a struggle between the OCC and state regulators in Michigan led to the Supreme Court reaffirming limits on federal preemption over state banking powers. [23] The GENIUS Act could see conflicts arising in similar gray areas when federal, state, and even local authorities begin to apply for overlapping jurisdictions over issuers.
Furthermore, although the GENIUS Act seems to restrict the jurisdiction of federal agencies, in practice, it may be difficult to ensure proper enforcement of these new boundaries, and entities like the SEC and CFTC may very well contest these provisions. For one, while the Act specifies that stablecoins are not treated as securities, the SEC still retains authority over all yield-bearing crypto assets that are designed to generate a return. These assets are fundamentally tied to stablecoin usage, as they rely on them to make transactions, pay dividends, and facilitate exchanges. Thus, while the SEC does not have jurisdiction over stablecoins outright, it still retains large influence over stablecoin usage and ecosystem through this indirect influence. In this way, the SEC still plays a large role in stablecoin regulations, and while the commission has recognized its withdrawal of official authority, Chairman Paul Atkins has made clear their mission to continue to make decisions with its influence on the stablecoin market in mind. [24]
Additionally, examining administrative law further compounds the uncertainty about the oversight system laid out by the GENIUS Act. The Act grants the US Treasury broad interpretive authority to define “operational resilience” and “qualified reserve assets” when granting permits to stablecoin regulators. This ambiguity invites a plethora of questions regarding authoritative overreach, especially when considering the landmark decision of the Supreme Court in West Virginia v EPA (2022), in which the Court ruled that federal agencies must have clear Congressional authority when making decisions of significant economic or political importance. [25] This presents a major uncertainty for future US Treasury rulings, as it may have to implement new standards as technology improves, legislative roadblocks and precedents like these may present a sizable problem and lead to further complications. In fact, the Andersen Institute recognizes these challenges too, quoting that jurisdictional competition and disagreement among agencies, if unresolved, could replicate the fragmentation that complicated derivatives oversight before the 2008 financial run. [26] Thus, in clarifying these inter-agency roles, the Act has inadvertently planted the seeds for future jurisdictional and even constitutional litigation and disagreement if the law cannot evolve as technology inevitably will.
At its core, the GENIUS Act’s architecture, from its dual federal-state authority to its reserve and disclosure requirements, is indeed politically elegant but operationally complex. Most saliently, it distributes oversight across a multitude of agencies in a way that helps to clarify authority and legitimacy, but also may lead to discrepancies and fragmentation in enforcement. As such, it is both fair to question the legitimacy of its authoritative designation and financial provisions of the GENIUS Act, and recognize that while it represents a much-needed step towards coherent stablecoin and crypto regulation, it is far from perfect.
V. CONCLUSION AND AFTERTHOUGHTS
There is no denying the significance of Congress’s decision to pass the GENIUS Act, both in the realm of cryptocurrency and the American socio-political landscape. It serves as a necessary and historic first step toward a coherent federal framework for stablecoins and digital assets; however, its unique architecture sheds light on the inherent tensions between innovation, stability, and authority. In prioritizing clarity and the definition of roles in its legislation, Congress has simultaneously defined conflict and the ground on which it will inevitably emerge, and the operational and jurisdictional ambiguities may prove just as troublesome as the definitional unknown that spurred its enactment.
It is evident that its clarity in definition does not extend to clarity in application, and uncertainty around who derives authority from the Act makes agency discretion a legal minefield, and any future implementation would likely rely on Congressional or Judicial interpretation of its ambiguities. Furthermore, the GENIUS Act’s promise of stability is undermined by its lack of centralized safeguards for approved issuers and users. Insurance mirroring those provided by the Federal Reserve or FDIC being absent presents a significant risk and uncertainty about how well this new system will actually perform in practice, especially in today's wildly volatile economy.
This may seem like a blatant oversight from Congress, and—while it very well may prove to be so—this issue points to a larger theme that the GENIUS Act plays a part in striking a balance between technological innovation and systematic safety. While it can be argued that requirements like anti-money laundering compliance and US Treasury oversight reinforce a safer cryptocurrency ecosystem, it risks entrenching it in a dependence on traditional finance systems. This is exactly the system that decentralized finance was created to circumvent, and in fact, the entirety of the GENIUS Act undermines the values of the cryptocurrency system it is designed to fit into.
In a similar vein, valid questions regarding the adaptability of the established framework as technological evolution progresses can be raised. The GENIUS Act’s efficacy at the time of its passing is moderate at best, and riddled with inconsistencies and grounds for significant legal and jurisdictional disputes. One can only imagine how it will struggle to keep up with the implementation of emerging technology like new blockchain-ledgers or even AI-integrated financial technology. U.S. legislation often has a tendency to lag behind technological and even financial reforms, and the consequences of the GENIUS Act’s inability to adapt to the ever-changing world could prove significant.
The struggle to define and legitimize digital money in the eyes of the law has been longculminating, and the Act is both a definitive declaration of the acceptance of the growing digital dimension to the legal financing system. The future will remain ever-uncertain, and whether GENIUS will prove to be the foundations of a stable digital financial system, or merely the latest futile iteration of a law chasing innovation, will depend on how the coming generation of legal scholars build upon it.
Endnotes
[1] Alex Lipton and Stuart Levi et al., “An Introduction to Smart Contracts and Their Potential and Inherent Limitations,” The Harvard Law School Forum on Corporate Governance, May 26, 2018, https://corpgov.law.harvard.edu/2018/05/26/an-introduction-to-smart-contracts-and-their-potential-and-inherentlimitations/.
[2] Matt Higginson and Garry Spanz, “The Stable Door Opens: How Tokenized Cash Enables Next-Gen Payment,” McKinsey & Company, accessed November 18, 2025, https://www.mckinsey.com/industries/financial-services/ourinsights/the-stable-door-opens-how-tokenized-cash-enables-next-gen-payments
[3] Andrew Loo, “What Happened to Terra?,” Corporate Finance Institute, n.d., accessed November 18, 2025, https://corporatefinanceinstitute.com/resources/cryptocurrency/what-happened-to-terra/.
[4] S.1582 - 119th Congress (2025-2026): Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS). July 18, 2025. https://www.congress.gov/bill/119th-congress/senate-bill/1582/text.
[5] Securities Act of 1933, Pub. L. No. 73-22, 48 Stat. 74 (1933)
[6] SEC v. Ripple Labs, Inc., 682 F. Supp. 3d 308 (S.D.N.Y. 2023)
[7] SEC v. Ripple Labs, Inc., 682 F. Supp. 3d 308 (S.D.N.Y. 2023Congress’s)
[8] Office of the Comptroller of the Currency, Interpretive Letter #1172: OCC Chief Counsel's Interpretation on National Bank and Federal Savings Association Authority to Hold Stablecoin Reserves (Sept. 21, 2020), https://www.occ.gov/topics/charters-and-licensing/interpretations-and-actions/2020/int1172.pdf
[9] Patrick T. [R-NC-10] Rep. McHenry, “H.R.4766 - 118th Congress (2023-2024): Clarity for Payment Stablecoins Act of 2023,” legislation, May 7, 2024, 2023-07-20, https://www.congress.gov/bill/118th-congress/house-bill/4766.
[10] Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on Markets in CryptoAssets, and Amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (Text with EEA Relevance), 150 OJ L (2023), http://data.europa.eu/eli/reg/2023/1114/oj . https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica
[11] Zongyuan Zoe Liu, “Why China Is Spooked by Dollar Stablecoins and How It Will Respond | Council on Foreign Relations,” accessed November 18, 2025, https://www.cfr.org/article/why-china-spooked-dollar-stablecoins-andhow-it-will-respond.
[12] Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, Pub. L. No. 119-27, § 4(a)(1), 139 Stat. 419 (2025)
[13] GENIUS Act, Pub. L. No. 119-27, § 4(a)(1)(A)(i)–(iii), 139 Stat. 425–26 (2025)
[14] GENIUS Act, Pub. L. No. 119-27, § 4(a)(1)(C), § 4(a)(3)(A)–(B), 139 Stat. 426–27 (2025)
[15] GENIUS Act, Pub. L. No. 119-27, § 2(22)(B)(iii), 139 Stat. 422 (2025)
[16] GENIUS Act, Pub. L. No. 119-27, § 5(a)–(c), 139 Stat. 439–40 (2025)
[17] GENIUS Act, Pub. L. No. 119-27, § 6(c)(1), 139 Stat. 442 (2025)
[18] GENIUS Act, Pub. L. No. 119-27, § 12(a)(5), 139 Stat. 449 (2025)
[19] GENIUS Act, Pub. L. No. 119-27, § 12(a)(1)(A)–(C), 139 Stat. 449 (2025)
[20] AIadmin, “Stablecoins: A Revolutionary Payment Technology with Financial Risks,” Andersen Institute, October 2, 2025, https://anderseninstitute.org/stablecoins-whitepaper/.
[21] “Money Market Mutual Fund Liquidity Facility,” Board of Governors of the Federal Reserve System, accessed November 18, 2025, https://www.federalreserve.gov/monetarypolicy/mmlf.htm.
[22] GENIUS Act, Pub. L. No. 119-27, § 4(c)(1), 139 Stat. 435 (2025)
[23] Watters v. Wachovia Bank, N.A., 550 U.S. 1 (2007).
[24] Paul S. Atkins, “SEC.Gov | Statement on Passage of the GENIUS Act by the House of Representatives,” U.S. Securities and Exchange Commission, accessed November 18, 2025, https://www.sec.gov/newsroom/speechesstatements/atkins-statement-genius-act-071725
[25] West Virginia v. EPA, 142 S. Ct. 2587 (2022)
[26] AIadmin, “Stablecoins: A Revolutionary Payment Technology with Financial Risks,” Andersen Institute, October 2, 2025, https://anderseninstitute.org/stablecoins-whitepaper/.