US Stablecoin Oversight: Which Authority Covers Which Activity?

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Calling a US-linked stablecoin regulated does not identify the responsible entity, permitted activity, relevant authority or effective date. Issuance, reserve custody, token custody and distribution may involve different supervisory arrangements.

For corporate treasurers, audit firms and institutions, the purpose of a regulatory map is to make these relationships explicit. An authority’s name is not an overall safety rating for the arrangement.

Separate enacted legislation from implementation

The GENIUS Act is Public Law 119-27, approved on 18 July 2025. It establishes a framework for payment stablecoins with different issuer and supervisor categories. Enactment alone does not establish that every implementing requirement already applies to every participant.

A dated assessment should distinguish enacted law, proposed regulation, final regulation and application to the specific case. Commencement and transitional provisions must be read in the relevant instruments, rather than inferred from a policy announcement.

The US responsibility map

Authority	Relevant perimeter	Documented source and status
OCC	National banks, federal institutions and relevant federal issuer categories	Bulletin 2026-3: implementation proposal
Federal Reserve	Issuers within Board supervision	Two proposals announced on 24 September 2026
FDIC	Including issuing subsidiaries of insured state non-member banks within its remit	Requirements and standards proposal, 7 April 2026
NCUA	Issuers within the credit-union perimeter	Operating standards proposal, 15 May 2026
State supervisor, including NYDFS	Entities and activities under the relevant state regime	NYDFS guidance, 8 June 2022, limited to supervised issuers
FinCEN	Applicable anti-money-laundering obligations	PPSI customer-identification proposal, 18 June 2026
OFAC	Applicable US sanctions	Virtual-currency guidance, 15 October 2021; not issuance permission

These are the documents identified as of 16 October 2026. The table does not establish that no other final or entity-specific rule exists. An issuer assessment must establish its individual status and the rules effective on the decision date.

GENIUS Act section 20 uses the earlier of eighteen months after enactment and 120 days after the relevant primary federal regulators issue final implementing regulations. The resulting 18 January 2027 statutory long-stop must therefore be read alongside the alternative trigger.

Separate law, proposal and individual decision

Apply the map to contracts

A fictional French company buys through a platform, holds with a custodian and seeks dollar redemption. Seller, custodian and issuer may owe different obligations. Supervision of the reserve bank does not automatically cover each contract.

A defensible selection decision could retain the asset for further assessment while withholding allocation until the issuer’s status and the French holder’s rights are established. BECTRA can organise this monitoring and treasury evidence file. The map itself is not a solvency assessment.

Conclusion

The useful question is: which authority oversees this entity, for this activity, on this date? BECTRA structures monitoring around activities and evidence, producing a reviewable decision record rather than matching a token brand with a regulator’s name.