Sagix Apothecary: Complete stablecoin market analysis 2025

The stablecoin ecosystem has evolved into a sophisticated $300 billion market where yield-bearing innovations challenge traditional static models. This transformation has created distinct market segments with different regulatory classifications and technical implementations. The market’s division between regulatory-compliant traditional stablecoins and yield-generating alternatives reflects fundamentally different approaches to stability mechanisms and legal frameworks.

Executive Summary: a market in transition

The stablecoin landscape of 2025 reveals a fundamental shift from passive dollar-pegged tokens to active yield-generating instruments. Yield-bearing stablecoins have captured $13.8 billion in market capitalization, representing 225% growth since November 2024. This evolution mirrors historical monetary innovations where market participants demanded more productive uses for their stable assets.

Three primary forces drive this transformation: regulatory clarification through the GENIUS Act, institutional demand for yield on stable assets, and technological innovations enabling sophisticated on-chain mechanisms. This creates distinct analytical categories for examining how stability mechanisms and legal compliance interact in tokenized assets previously offering only static value storage.

After examining stablecoin fundamentals and historical precedents from Terra's collapse to Brazil's hyperinflation era, we now present a complete market analysis. This report evaluates the major stablecoins of September 2025, their regulatory classifications under the GENIUS Act, and their distinct market positions.

The Ongoing Stablecoin Revolution

who are the players?

Sagix ApothecarySagix

The Druid Deep Dive episode 8: Brazilian hyperinflation: The ultimate portfolio stress test (1980-1994)

Brazil’s hyperinflation (1980-1994) stemmed from decentralized money creation - state banks could print currency. Terra LUNA’s collapse shows how DeFi protocols can trigger similar spirals when multiple mechanism can trigger token creation simultaneously.

Sagix ApothecarySagix

Complete stablecoin market overview

Our comprehensive analysis covers 35 distinct stablecoin implementations across traditional fiat-backed, synthetic, commodity-backed, and emerging yield-bearing categories:

Market summary statistics

Market Dominance

• Total market: ~$290-300 billion across 290+ active tokens
• Yield-bearing market cap: $13.8B (225% growth since Nov 2024)
• Tokenized Treasuries: $5.95B+ total sector, led by BUIDL ($2.1B+) and BENJI ($780M)
• Top 3 traditional stablecoins control 70% of market (USDT, USDC, USDE)
• USDT alone holds 58.79% market share

Regulatory split

• GENIUS Act Compliant: 4-5 tokens (~$243B)
• Non-Compliant: 30+ tokens (~$47B+)
• SEC-Approved: Only YLDS with 3.85% APR
• Institutional-Grade RWA: BUIDL, BENJI dominate $5.95B+ tokenized Treasury sector
• Compliance = U.S. market access under new framework

Key trends

• Institutional Treasury tokenization: BUIDL and BENJI leading $5.95B+ sector
• Yield-bearing expansion: sUSDC, OUSG, USDY, sUSD leading DeFi innovation
• Multi-chain expansion: Solana hosting sUSD, syrupUSDC, YBX; BUIDL on 7+ chains
• RWA integration: Total Treasury holdings >$5.95B across institutional products
• LST-backed models: YBX using JitoSOL/mSOL for Solana staking rewards
• Interest-bearing wraps: aUSDC, sUSDC transforming static stablecoins

Notable winners

• BUIDL: Largest tokenized Treasury at $2.1B+ (41% market share)
• BENJI: Second-largest at $780M with 690+ holders (most in sector)
• USD1: Fastest growth ever (0 to $2.3B in 90 days)
• USDE/sUSDe: 75% growth with 6-19% yields
• Spark Protocol: sUSDC live across 5 networks (4.5-8.75% APY)

Deep Analysis: Yield-bearing innovation clusters

The Spark protocol revolution: making stablecoins productive

sUSDC represents perhaps the most sophisticated yield-bearing stablecoin implementation currently operational. Deployed across Ethereum, Base, Arbitrum, Optimism, and Unichain, sUSDC transforms static USDC into a yield-generating asset earning 4.5-8.75% APY through the Sky Savings Rate mechanism. Unlike rebasing tokens, sUSDC uses an accumulating model where token value increases rather than quantity, maintaining DeFi composability while generating returns.

The technical architecture leverages ERC-4626 tokenized vault standards with $7.9 billion in total protocol TVL supporting the yield mechanism. sUSDT remains in active development under the same framework, promising to extend this innovation to Tether-based strategies. These tokens demonstrate how dollar stability can combine with yield generation, addressing the historical opportunity cost of holding static stablecoins.

BlackRock and Franklin Templeton: Institutional treasury tokenization Leaders

BUIDL represents the institutional gold standard for tokenized Treasury exposure, with $2.1+ billion in assets making it the largest tokenized Treasury fund globally. BlackRock’s USD Institutional Digital Liquidity Fund invests 100% of assets in cash, U.S. Treasury bills, and repo agreements, maintaining a stable $1.00 NAV while paying daily accrued dividends as new tokens monthly. Available across 7+ blockchains including Ethereum, Solana, Arbitrum, and Polygon, BUIDL demonstrates how traditional asset managers can leverage blockchain technology for enhanced settlement and 24/7 access.

Franklin Templeton’s BENJI/FOBXX represents the second-largest tokenized Treasury implementation at $780 million, with the distinction of having 690+ holders—more than any competing tokenized Treasury product. The Franklin OnChain U.S. Government Money Fund (FOBXX) was pioneering as the first U.S.-registered mutual fund to use public blockchain as its system of record. Each BENJI token represents one share of the regulated money market fund, targeting $1.00 value while investing 99.5% of assets in U.S. government securities and cash equivalents.

These institutional-grade offerings create a new tier in the tokenized asset hierarchy, sitting above smaller RWA implementations like Ondo’s OUSG and USDY. BUIDL and BENJI demonstrate how regulatory credibility and scale operate in institutional contexts, though their qualification requirements limit retail accessibility compared to DeFi-native yield-bearing alternatives.

Ondo Finance: Bridging traditional finance and DeFi

OUSG and USDY represent institutional-grade tokenization of U.S. Treasury exposure. OUSG has accumulated $500+ million through direct investment in BlackRock’s BUIDL fund, providing 5% yields from short-term Treasury securities with 24/7 liquidity. USDY offers similar exposure through a retail-accessible structure, maintaining $630 million in assets while delivering 4-5% returns.

These implementations demonstrate successful real-world asset (RWA) integration, converting traditional Treasury investments into programmable, composable tokens. The regulatory uncertainty surrounding these products in the U.S. has created varied market responses, as regulatory clarity could dramatically expand their addressable market while regulatory restrictions could limit growth.

Solana’s Emerging Yield ecosystem

The Solana network hosts an increasingly sophisticated array of yield-bearing stablecoin experiments. Solayer’s sUSD represents the first native yield-bearing stablecoin on Solana, backed by U.S. Treasury Bills and offering 4-5% yields through OpenEden’s platform integration. The implementation uses Solana’s token-2022 interest-bearing extension, automatically adjusting token multipliers to reflect accumulated interest.

Maple Finance’s syrupUSDC deployment via Chainlink’s CCIP brings cross-chain yield-bearing capabilities to Solana, while marginfi’s upcoming YBX promises to combine Solana liquid staking rewards with stablecoin stability. These developments position Solana as a major innovation hub for yield-bearing stablecoin development, though liquidity fragmentation across multiple tokens remains a concern.

Aave’s Interest-Bearing infrastructure

aUSDC exemplifies the DeFi-native approach to yield-bearing stablecoins through lending protocol integration. With $35 million in market capitalization, aUSDC automatically generates yield from Aave’s lending activities, with rates fluctuating based on borrowing demand. The model’s simplicity—deposit USDC, receive yield-bearing aUSDC—demonstrates how established DeFi protocols can transform static assets into productive instruments.

The broader Aave ecosystem supports multiple interest-bearing tokens, creating a foundation for sophisticated yield strategies. For market analysis purposes, aUSDC offers variable yields that respond to market conditions, providing higher returns during periods of increased borrowing demand while maintaining the underlying USDC stability.

Risk assessment framework for market analysis

Regulatory Compliance Considerations

The GENIUS Act’s implementation creates a clear regulatory divide in the stablecoin market. Compliant tokens like USDC, PYUSD, and potentially USD1 operate within clear regulatory frameworks with institutional adoption pathways. Non-compliant yield-bearing alternatives face legal restrictions under the Act’s provisions.

YLDS represents the only SEC-approved yield-bearing option, though its 3.85% APR falls below DeFi alternatives. The regulatory landscape continues evolving as implementation rules develop through 2026-2027.

Technology and counterparty risks

Yield-bearing stablecoins introduce additional risk vectors beyond traditional stablecoin considerations. Smart contract risks in protocols like Spark, Aave, and Ethena create potential failure points not present in simple fiat-backed stablecoins. Cross-chain bridge risks affect tokens like syrupUSDC that operate across multiple networks.

Counterparty risks vary significantly across implementations: RWA-backed tokens like OUSG and USDY face traditional finance counterparty risks, while DeFi-native options face protocol governance and smart contract risks. Different implementation approaches create varying risk profiles across the market.

Liquidity and market structure analysis

Many yield-bearing stablecoins trade with limited liquidity compared to established alternatives like USDC and USDT. This creates different operational characteristics across the market. Understanding liquidity differences helps evaluate implementation feasibility for different use cases.

Tokens like sUSDC with multi-chain deployment demonstrate different liquidity profiles than single-chain alternatives, while established protocols like Aave maintain deeper liquidity pools for interest-bearing tokens.

Understanding the stablecoin quality spectrum

For educational analysis, we examine stablecoins across three quality categories based on institutional backing and regulatory clarity. These categories help understand the current market structure: U.S. Treasury-backed tokens, commodity-backed alternatives, and yield-bearing vehicles derived from compliant base assets. Each category presents different regulatory status, technical implementations, and risk characteristics that market participants evaluate differently.

Category 1: GENIUS Act compliant fiat-backed stablecoins

USDC (USD Coin) - The Foundation
Circle’s USDC represents the gold standard for regulatory-compliant stablecoins with $67.7 billion in market capitalization. 1:1 backing by U.S. dollars through cash and short-term U.S. Treasury bonds, managed by BlackRock with custody at BNY Mellon, provides institutional-grade security. Monthly attestations by Grant Thornton and explicit GENIUS Act compliance make USDC the natural foundation for any sophisticated stable asset allocation.

PYUSD (PayPal USD) - Retail Integration with Yield
PayPal’s $1.4 billion stablecoin offers unique advantages through its integration with 300M+ users and 25M+ merchants. GENIUS Act compliant with NYDFS regulation, PYUSD provides 3.7% annual yield while maintaining full USD backing through Paxos Trust Company. Multi-chain deployment via LayerZero across 13+ networks enhances utility for cross-chain strategies.

USD1 (World Liberty Financial) - Emerging Institutional Leader
The fastest-growing stablecoin in history, USD1 reached $2.3 billion market cap in under 90 days. 100% backed by USD reserves in short-term U.S. Treasury bills managed by Fidelity Investments, with BitGo Trust Company issuance providing regulatory structure. Chainlink Proof of Reserves ensures real-time verification, while zero-fee minting and redemption enhance capital efficiency.

Category 2: Institutional-grade tokenized treasury products

BUIDL (BlackRock USD Institutional Digital Liquidity Fund) - Institutional Gold Standard
At $2.1+ billion, BUIDL represents 41% of the entire tokenized Treasury market. 100% investment in cash, U.S. Treasury bills, and repo agreements maintains stable $1.00 NAV while paying daily accrued dividends as new tokens monthly. Available across 7+ blockchains with BNY Mellon custody and PwC auditing, BUIDL offers institutional investors 24/7 access to Treasury yields with blockchain settlement advantages.

BENJI/FOBXX (Franklin Templeton OnChain U.S. Government Money Fund) - Pioneer Tokenized Fund
Franklin Templeton’s $780 million fund was the first U.S.-registered mutual fund to use blockchain as system of record. 99.5% investment in U.S. government securities, cash, and collateralized repo agreements targets $1.00 stable value. With 690+ holders—more than any competing tokenized Treasury—BENJI demonstrates successful retail-institutional crossover appeal across 8+ blockchain networks.

Category 3: Yield-bearing vehicles from compliant base assets

Ondo Finance Suite - Treasury Yield Optimization
OUSG (Ondo Short-Term US Government Bond Fund)
The $500+ million fund provides institutional exposure to short-term Treasuries primarily through 90% allocation to BlackRock’s BUIDL fund. This structure offers 5% yields with the security of underlying BlackRock treasury management, creating a layered institutional approach to yield generation.

USDY (Ondo US Dollar Yield)
Ondo’s $630 million retail-accessible product maintains 100% backing through short-term U.S. Treasury bills and bank deposits, delivering 4-5% yields while maintaining dollar peg stability. The implementation serves non-U.S. investors seeking Treasury exposure with stablecoin-like accessibility.

Spark Protocol - Multi-chain yield enhancement
sUSDC (Spark Savings USDC)
Operational across Ethereum, Base, Arbitrum, Optimism, and Unichain, sUSDC transforms static USDC into yield-generating assets earning 4.5-8.75% APY through Sky Savings Rate mechanism. The ERC-4626 tokenized vault standard ensures DeFi composability while $7.9 billion protocol TVL provides robust backing. Unlike rebasing tokens, sUSDC uses accumulating value model for seamless integration.

sUSDT (Coming Soon)
Spark’s USDT implementation will extend proven yield-bearing framework to Tether-based strategies, providing similar multi-chain accessibility and yield generation for the world’s largest stablecoin.

Aave - DeFi-Native Interest Generation
aUSDC (Aave Interest-Bearing USDC)
With $35 million market capitalization, aUSDC demonstrates mature DeFi lending protocol integration. Automatic yield generation from Aave’s lending activities creates variable returns responding to market conditions, with rates increasing during periods of elevated borrowing demand. The simplicity—deposit USDC, receive yield-bearing aUSDC—makes this accessible for diversified yield strategies.

Category 4: Commodity-backed stable value alternative

Gold-Backed Tokens - Non-correlated stability
XAUT (Tether Gold)
At $1.4 billion market capitalization, XAUT provides 1 troy ounce LBMA Good Delivery gold per token stored in Swiss vaults. Latest attestation shows 7.7 tons backing 246,523 tokens with physical redemption capability, offering 24/7 gold trading with fractional ownership and safe-haven characteristics during market uncertainty.

PAXG (PAX Gold)
The $1.1 billion NYDFS-regulated token maintains 1 fine troy ounce backing through 400 oz London Good Delivery bars stored in LBMA-approved Brink’s vaults. As the leading tokenized gold by market cap since 2019, PAXG offers institutional adoption with fractional ownership capabilities for portfolio diversification beyond dollar-denominated assets.

Educational Framework for market analysis

Understanding stablecoin categories: The market divides into distinct segments based on regulatory compliance, backing mechanisms, and operational structures.

Compliance-based classification: GENIUS Act compliant stablecoins operate within clear federal frameworks. Non-compliant alternatives exist outside these regulations, facing potential U.S. market access restrictions.

Backing mechanism diversity: Institutional tokenized Treasury products operate under securities regulations distinct from payment stablecoin frameworks. Commodity-backed tokens provide alternative exposure outside dollar-denominated assets.

Risk-Return profiles: Different stablecoin structures present varying risk characteristics. Regulatory compliance, liquidity depth, and technical implementation all factor into individual risk assessments.

This analytical framework helps understand market structure without prescribing specific allocation decisions. Individual circumstances, risk tolerance, and regulatory jurisdiction determine appropriate stablecoin selection for any given situation.

Regulatory landscape: The GENIUS and CLARITY Acts reshape stablecoin markets

The July 2025 passage of the GENIUS Act represents the most significant regulatory development in U.S. stablecoin history, establishing the first comprehensive federal framework while simultaneously creating restrictions that fundamentally alter the yield-bearing stablecoin landscape. Understanding these regulatory shifts is essential for understanding the evolving digital asset ecosystem.

The GENIUS Act: Federal Framework with Yield Restrictions

Signed into law by President Trump on July 18, 2025, the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) establishes clear operational requirements for “payment stablecoins.” [2][3][4][7] The legislation mandates 100% reserve backing through U.S. dollars, short-term Treasury bills, or equivalent cash instruments, with monthly disclosures certified by CEOs and CFOs under penalty of law [1][2].

The most impactful provision for yield-bearing stablecoins: Section 9 explicitly prohibits permitted payment stablecoin issuers from paying any form of interest or yield to holders. [5][23] This restriction applies to “any form of interest or yield… solely in connection with the holding, use, or retention of such payment stablecoin.” [0][5] The prohibition aims to prevent risks similar to those that triggered crypto lending collapses, treating payment stablecoins as transaction mediums rather than investment vehicles.

Critical implications for market structure:

• Traditional stablecoins like USDC, USDT remain unaffected as they never offered yield
• Direct yield-bearing stablecoins violate GENIUS Act if issued by regulated U.S. entities
• Third-party arrangements may provide regulatory distinctions—the Act’s language focuses on issuer-provided yield, potentially allowing affiliates or independent protocols to offer returns
• Foreign stablecoins face market access restrictions unless from jurisdictions deemed “substantially similar” by Treasury [14][25]

The legislation creates a bifurcated market: federally-regulated “permitted payment stablecoin issuers” gain legitimacy and institutional adoption pathways, while yield-bearing alternatives face regulatory uncertainty or outright prohibition depending on their structural implementation.

The CLARITY Act: defining digital asset jurisdiction

The Digital Asset Market Clarity Act, passed by the House on July 17, 2025 with strong bipartisan support (294-134 vote), awaits Senate consideration. [11][12][15] Unlike GENIUS Act’s stablecoin focus, CLARITY addresses broader digital asset market structure by delineating Securities and Exchange Commission (SEC) versus Commodity Futures Trading Commission (CFTC) jurisdiction [9][10][13].

Key provisions affecting stablecoin markets:

• Payment stablecoins explicitly excluded from securities classification, reinforcing GENIUS Act framework
• “Digital commodities” regulated primarily by CFTC, with SEC retaining anti-fraud authority
• Clear pathways for tokens to transition from securities to commodities as networks mature
• Stablecoin-related activities on SEC-regulated platforms maintain SEC oversight for fraud prevention

The Senate Banking Committee released an alternative discussion draft—the Responsible Financial Innovation Act (RFIA)—creating uncertainty about final legislative form [14][16]. However, both approaches recognize stablecoins as distinct from other digital assets, requiring specialized regulatory treatment.

Senate passage timing remains uncertain, with estimates ranging from late 2025 to early 2026 [15][17]. The Trump administration has indicated strong preference for Senate bills to pass as-written without House modifications, suggesting final legislation may differ substantially from the current House version [16].

Understanding yield-bearing classification uncertainty

The GENIUS Act’s yield prohibition creates significant uncertainty for various stablecoin implementations. Different structural approaches face different levels of regulatory clarity:

Implementations with unclear status:

• Interest-bearing wrapped tokens like sUSDC and aUSDC occupy uncertain territory if structured as third-party protocols rather than issuer-provided yield
• Tokenized Treasury products (BUIDL, BENJI, OUSG) fall outside payment stablecoin definition, operating as regulated securities or investment products
• Foreign stablecoins from comparable jurisdictions face different legal frameworks depending on home country regulations

Regulatory classification ambiguities:

• The Act targets issuer-provided yield specifically; legal interpretation remains uncertain regarding whether DeFi protocols offering returns on stablecoins constitute prohibited arrangements
• Affiliate structures remain legally ambiguous—the Act’s language leaves unclear whether affiliates of issuers can provide yield-bearing services
• The 18-month implementation period (or 120 days post-final regulations) extends into 2026-2027, with final classifications pending additional regulatory guidance

Implementation timeline:
Federal regulators must issue implementing regulations within one year of enactment, with the Act taking effect 18 months post-passage or 120 days after final regulations, whichever comes first [8][18][20][22][24]. This timeline extends into 2026-2027, with market structure evolving based on forthcoming regulatory interpretations [1][26].

Stablecoin market segmentation Post-GENIUS Act

The regulatory landscape has created three analytically distinct stablecoin categories:
Category 1 - GENIUS Act Compliant Payment Stablecoins: USDC, PYUSD, USD1 operate within clear federal regulatory frameworks. Zero yield but explicit legal status and operational certainty under federal banking supervision.

Category 2 - Tokenized Securities/RWAs: BUIDL, BENJI, OUSG, USDY exist outside payment stablecoin definition, offering Treasury-backed yields through traditional securities structures. Subject to securities regulation as separate asset class from payment stablecoins.

Category 3 - Undefined Regulatory Status: Interest-bearing protocols (sUSDC, aUSDC), synthetic stablecoins (USDe), and certain foreign alternatives operate without clear GENIUS Act classification. Legal status depends on structural implementation and ongoing regulatory guidance.

Market participants evaluate these categories based on individual risk tolerance, regulatory jurisdiction, and compliance requirements. As regulations develop through 2026-2027 implementation, market structure will evolve based on enforcement priorities and additional regulatory guidance.

This analytical framework examines regulatory compliance as a critical evaluation dimension for stablecoin assessment in U.S. markets, alongside technical implementation and yield characteristics.

Conclusion: The transformed stablecoin landscape

The stablecoin market’s evolution from static dollar-pegged tokens to yield-generating instruments represents a fundamental shift in digital asset infrastructure. The July 2025 passage of the GENIUS Act adds a critical regulatory dimension, establishing the first federal framework while restricting direct yield offerings from payment stablecoin issuers. This dual transformation—technological innovation constrained by regulatory boundaries—has created a complex market structure.

This landscape reflects three simultaneous dynamics: the technical capabilities of yield-bearing innovations, the regulatory constraints imposed by new federal frameworks, and the varying risk-return profiles across different stablecoin categories. Regulatory compliance and technical sophistication have emerged as equally important analytical dimensions.

The market structure now includes traditional stablecoins with clear legal status, tokenized Treasury products offering institutional-grade yield through established securities frameworks, and interest-bearing protocols occupying undefined regulatory status. Each category presents distinct characteristics that market participants evaluate based on their individual circumstances.

The next 12-18 months will prove critical as regulators implement GENIUS Act provisions, the Senate considers CLARITY Act passage, and the industry adapts business models to new legal requirements. Sagix Apothecary will continue monitoring these developments, regulatory guidance releases, and enforcement actions to provide educational analysis of the evolving stablecoin market structure.

Legal Disclaimers and Disclosures

Educational Purpose Only: This content is provided exclusively for educational and market analysis purposes. It should not be construed as investment advice, financial planning guidance, policy recommendations, or official economic analysis. Any stablecoin analysis or portfolio discussions are presented as educational material, not recommendations for action. Market patterns provide context for learning but do not predict future financial system outcomes or investment performance.

AI-Assisted Research Disclosure: This market analysis was researched and written with substantial assistance from artificial intelligence technology (Claude, Anthropic). While extensive efforts were made to verify all statistical claims, market data, and protocol analysis against authoritative sources, readers should independently verify any information before relying on it for academic, professional, investment, or portfolio decisions.

Accuracy and Liability Limitations: While extensive effort has been made to ensure market data accuracy through authoritative sources, the authors make no warranties about completeness, accuracy, or currency of information. Cryptocurrency and stablecoin markets involve rapidly changing conditions, and data may contain revisions, measurement inconsistencies, or reporting variations across different time periods and data sources.

Liability Protections: The authors, publishers, and Sagix Apothecary assume no responsibility for errors, omissions, or consequences arising from the use of this information. This includes any errors that may result from AI assistance in research, writing, or data analysis. Users assume full responsibility for any decisions or actions taken based on this content.

Investment Risk Warning: Stablecoin and cryptocurrency analysis does not constitute investment advice or recommendations. Past performance, whether historical or hypothetical, does not guarantee future results. All digital assets carry risk of loss, and readers should conduct their own research and consult qualified financial advisors before making investment decisions. Yield-bearing stablecoins involve additional risks including smart contract vulnerabilities, regulatory uncertainty, and counterparty risks not present in traditional financial instruments.

No Professional Relationship: This content does not create any professional, advisory, fiduciary, or client relationship between the reader and Sagix Apothecary, its authors, or affiliated entities. Readers seeking financial, investment, legal, regulatory, or policy guidance should consult qualified professionals licensed in their jurisdiction.

Regulatory Considerations: References to regulatory frameworks including the GENIUS Act and SEC guidance are presented for educational context only. Regulatory environments vary by jurisdiction and change frequently. This content should not be interpreted as legal or compliance advice for any specific jurisdiction’s regulatory requirements.

Methodological Note: This analysis synthesizes findings from multiple cryptocurrency data platforms, protocol documentation, regulatory filings, and market analysis sources. Market capitalization and yield data are subject to rapid change in volatile cryptocurrency markets. The numbered citation system allows readers to verify specific claims against original sources rather than relying on secondary interpretations.

Publication Information: Last Updated: September 2025 | Series: Sagix Apothecary Market Analysis | Publisher: Sagix Apothecary

Sources and References

[0] Congress.gov. “Text - S.1582 - 119th Congress (2025-2026): GENIUS Act.” https://www.congress.gov/bill/119th-congress/senate-bill/1582/text. Published/Accessed: September 2025.

[1] Federal Register. “GENIUS Act Implementation.” https://www.federalregister.gov/documents/2025/09/19/2025-18226/genius-act-implementation. Published: September 19, 2025.

[2] The White House. “Fact Sheet: President Donald J. Trump Signs GENIUS Act into Law.” https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-signs-genius-act-into-law/. Published: July 18, 2025.

[3] Paul Hastings. “The GENIUS Act: A Comprehensive Guide to US Stablecoin Regulation.” https://www.paulhastings.com/insights/crypto-policy-tracker/the-genius-act-a-comprehensive-guide-to-us-stablecoin-regulation. Published: July 18, 2025.

[4] Mayer Brown. “GENIUS Act Signed into Law: US Enacts Federal Stablecoin Legislation.” https://www.mayerbrown.com/en/insights/publications/2025/07/genius-act-signed-into-law-us-enacts-federal-stablecoin-legislation. Published: July 18, 2025.

[5] WilmerHale. “What the GENIUS Act Means for Payment Stablecoin Issuers, Banks, and Custodians.” https://www.wilmerhale.com/en/insights/client-alerts/20250718-what-the-genius-act-means-for-payment-stablecoin-issuers-banks-and-custodians. Published: July 18, 2025.

[6] Congress.gov. “Text - S.919 - 119th Congress (2025-2026): GENIUS Act of 2025.” https://www.congress.gov/bill/119th-congress/senate-bill/919/text. Published/Accessed: March 18, 2025.

[7] Gibson Dunn. “The GENIUS Act: A New Era of Stablecoin Regulation.” https://www.gibsondunn.com/the-genius-act-a-new-era-of-stablecoin-regulation/. Published: July 18, 2025.

[8] Arnold & Porter. “What You Need To Know About Incoming Stablecoin Legislation.” https://www.arnoldporter.com/en/perspectives/advisories/2025/06/incoming-stablecoin-legislation-stable-and-genius-acts. Published: June 2, 2025.

[9] Congress.gov. “Text - H.R.3633 - 119th Congress (2025-2026): Digital Asset Market Clarity Act.” https://www.congress.gov/bill/119th-congress/house-bill/3633/text. Published/Accessed: 2025.

[10] Congress.gov. “Actions - H.R.3633 - 119th Congress (2025-2026): Digital Asset Market Clarity Act.” https://www.congress.gov/bill/119th-congress/house-bill/3633/all-actions. Published/Accessed: 2025.

[11] GovTrack.us. “H.R. 3633: Digital Asset Market Clarity Act of 2025.” https://www.govtrack.us/congress/bills/119/hr3633. Published/Accessed: July 17, 2025.

[12] House Financial Services Committee. “Chairman Hill Commends Passage of Landmark Digital Asset Bills.” https://financialservices.house.gov/news/documentsingle.aspx?DocumentID=410815. Published: July 17, 2025.

[13] Fintech and Digital Assets Blog. “The CLARITY Act, Treasury Companies, and the (Digital) Commodity Pool.” https://www.fintechanddigitalassets.com/2025/07/the-clarity-act-treasury-companies-and-the-digital-commodity-pool/. Published: July 29, 2025.

[14] Consumer Financial Services Law Monitor. “Senate Banking Committee Releases Draft Digital Asset Market Structure Bill and Request for Information.” https://www.consumerfinancialserviceslawmonitor.com/2025/08/senate-banking-committee-releases-draft-digital-asset-market-structure-bill-and-request-for-information/. Published: August 4, 2025.

[15] CoinDesk. “The Clock Is Ticking on Crypto Market Structure Legislation.” https://financialservices.house.gov/news/documentsingle.aspx?DocumentID=410871. Published: September 16, 2025.

[16] Troutman Pepper. “Senate Bill Could Overhaul Digital Asset Market Structure.” https://www.troutman.com/insights/senate-bill-could-overhaul-digital-asset-market-structure/. Published: September 15, 2025.

[17] Morgan Lewis. “House Committees Advance Digital Asset Market Clarity Act of 2025.” https://www.morganlewis.com/pubs/2025/06/bipartisan-majorities-in-two-house-committees-vote-to-advance-the-digital-asset-market-clarity-act-of-2025. Published: June 20, 2025.

[18] Latham & Watkins. “The GENIUS Act of 2025: Stablecoin Legislation Adopted in the US.” https://www.lw.com/en/insights/the-genius-act-of-2025-stablecoin-legislation-adopted-in-the-us. Published: July 24, 2025.

[19] The White House. “Fact Sheet: President Donald J. Trump Signs GENIUS Act into Law.” https://www.whitehouse.gov/fact-sheets/2025/07/fact-sheet-president-donald-j-trump-signs-genius-act-into-law/. Published: July 18, 2025.

[20] Sidley Austin. “The GENIUS Act: A Framework for U.S. Stablecoin Issuance.” https://www.sidley.com/en/insights/newsupdates/2025/07/the-genius-act-a-framework-for-us-stablecoin-issuance. Published: July 21, 2025.

[21] Paul Hastings. “The GENIUS Act: A Comprehensive Guide to US Stablecoin Regulation.” https://www.paulhastings.com/insights/crypto-policy-tracker/the-genius-act-a-comprehensive-guide-to-us-stablecoin-regulation. Published: July 18, 2025.

[22] Wiley Rein. “Building a Digital Asset Regulatory Framework: The GENIUS Act and Next Steps.” https://www.wiley.law/alert-Building-a-Digital-Asset-Regulatory-Framework-The-GENIUS-Act-and-Next-Steps. Published: July 23, 2025.

[23] WilmerHale. “What the GENIUS Act Means for Payment Stablecoin Issuers, Banks, and Custodians.” https://www.wilmerhale.com/en/insights/client-alerts/20250718-what-the-genius-act-means-for-payment-stablecoin-issuers-banks-and-custodians. Published: July 18, 2025.

[24] BakerHostetler. “A New Era for the Stablecoin Industry: The GENIUS Act.” https://www.bakerlaw.com/insights/a-new-era-for-the-stablecoin-industry-the-genius-act/. Published: July 25, 2025.

[25] Steptoe & Johnson. “The GENIUS Act and Financial Crimes Compliance: A Detailed Guide.” https://www.steptoe.com/en/news-publications/blockchain-blog/the-genius-act-and-financial-crimes-compliance-a-detailed-guide.html. Published: August 22, 2025.

[26] Alston & Bird. “GENIUS Act Establishes Federal Regulatory Oversight of Global Stablecoin Industry.” https://www.alston.com/en/insights/publications/2025/07/genius-act-oversight-stablecoin-industry. Published: July 24, 2025.