The Blockchain Association has submitted comments to the U.S. Department of the Treasury regarding Section 3 of the GENIUS Act, calling for clear rules on stablecoin issuance.

The Blockchain Association posted on X, stating that it has submitted a comment letter to the U.S. Treasury (@USTreasury) regarding the proposed implementing regulations for Section 3 of the GENIUS Act. Section 3 addresses who may issue, offer, and sell payment stablecoins in the United States. The association expressed appreciation for the Treasury's implementation efforts but emphasized its hope that the final rules will remain consistent with the original intent of congressional legislation. The association put forth the following key recommendations: 1. Definition of "Digital Asset Service Provider": This definition should apply to client-facing businesses, exclude core infrastructure such as self-custody software and validator nodes, and should not encompass entities that merely trade their own assets. 2. Criminal Liability Standard: Under the proposed rules, routine market-making activities for "newly issued" stablecoins could be construed as "knowing participation" in an illegal issuance. The association recommends restricting liability to cases involving "actual knowledge" and providing "substantial assistance" in coordination with the issuer. 3. Foreign-Issued Stablecoins: The proposed rules require open-ended due diligence on foreign issuers, despite many exchanges having no business relationship with them. The association recommends allowing firms to rely on publicly available lists of registered issuers and trading restrictions already established by Congress. 4. Determination of User Location: On permissionless protocols, companies typically only see wallet addresses. The association proposes replacing the "reasonable belief" standard with "actual knowledge supplemented by information gathered in the ordinary course of business." 5. Other Recommendations: Eliminate open-ended "functional equivalence" tests regarding monetary value, reassess cost estimates, and align the effective date with the GENIUS Act