Circle has submitted a formal comment letter to the Office of the Comptroller of the Currency [OCC], supporting stricter regulatory standards for stablecoin issuers under the proposed GENIUS Act framework.
The submission, filed on 1 May, responds to the OCC’s proposed rule establishing a licensing regime for payment stablecoins in the United States, covering areas such as reserve management, risk controls, and operational standards.
Circle is the issuer of the USDC stablecoin, one of the largest dollar-backed tokens with a market cap of over $78 billion.
U.S. stablecoin rules move toward implementation
The proposed framework is part of efforts to implement the GENIUS Act, which aims to create a formal regulatory structure for dollar-backed stablecoins.
If finalized, the rules would require issuers to operate as standalone, ring-fenced entities with strict oversight, including:
- full reserve backing
- reliable redemption mechanisms
- strong compliance and risk management systems
Circle said the framework represents a key step toward integrating stablecoins into the broader financial system, particularly as their role in payments continues to expand.
Circle pushes for global standards and equal competition
In its submission, Circle emphasized that U.S. regulatory standards should serve as a global benchmark for digital dollar systems.
The company also argued that all stablecoin issuers, domestic or international, should operate under the same regulatory requirements to prevent regulatory arbitrage.
Circle further stressed that stablecoins must remain fully redeemable and interoperable across platforms. It warned that fragmentation could weaken liquidity and trust in digital payment systems.
Consumer protection and risk controls in focus
The letter highlights the importance of consumer protection, particularly the ability of users to redeem stablecoins reliably at any time.
Circle also called for robust risk management frameworks covering credit, liquidity, operational, and anti-money laundering risks.
The company noted that stablecoins should not be treated as equivalent to tokenized bank deposits, arguing that the two serve different roles within the financial system and require distinct regulatory approaches.
Stablecoin regulation enters critical phase
The OCC’s rulemaking process marks one of the most advanced efforts to formalize stablecoin oversight in the United States.
Industry feedback, including Circle’s submission, is expected to shape the final framework, which could influence how digital dollars are issued and used globally.
Final Summary
- Circle has submitted a comment letter supporting stricter U.S. stablecoin regulations under the proposed GENIUS Act framework.
- The move reflects growing momentum toward formal oversight, with the final rules likely to shape global standards for digital dollar systems.

