What the STABLE Act Means for Stablecoin Issuers in 2025

Vidushi Tiwari
May 8, 2025

The Stablecoin Transparency and Accountability for a Better Ledger Economy (STABLE) Act of 2025 (H.R. 2392) was introduced by Representative Bryan Steil (R-WI) and co-sponsored by Representative French Hill (R-AR) as part of a broader push to establish comprehensive oversight for stablecoin markets. It arrives at a pivotal moment in Washington, as Congress shifts from reactive enforcement to proactive, durable frameworks for digital asset oversight. The bill reflects a bipartisan effort to formalize stablecoin issuance through legislation rather than agency interpretation, laying down structural rules for a market that has outgrown regulatory ambiguity. By placing oversight under the OCC (Office of the Comptroller of the Currency) and mandating fully backed, liquid reserves, the Act reframes stablecoins as bank-like instruments—with the obligations that come with systemic trust. It isn’t about curbing innovation. It’s about setting the perimeter of the financial system.

With the competing GENIUS Act having failed to advance in the Senate, STABLE now stands as the most viable federal proposal for regulating payment stablecoins. But it’s important to remember: this is still draft legislation.While the STABLE Act has cleared committee, its provisions remain subject to public comment, committee markups, and political negotiation before it can move to a full House vote and potential reconciliation with the Senate. That said, this blog offers a grounded look at what a compliant future could look like if this framework moves forward—breaking down its key requirements, risks, and operational implications for issuers, intermediaries, and compliance teams.

Key Provisions of the STABLE Act

What Is a Payment Stablecoin?

The STABLE Act defines a payment stablecoin as a digital asset that is or is intended to be used for payments or settlement, and either (i) is redeemable at a fixed monetary value or (ii) is marketed as maintaining a stable value relative to that amount. This broad framing ensures the law captures both fully redeemable stablecoins and those that function or appear stable, even without a formal redemption mechanism. The aim is to regulate how stablecoins are used and perceived in the financial system, not just how they're structured. 

Crucially, the Act clarifies that payment stablecoins are not treated as securities, removing ambiguity around overlapping jurisdiction and reinforcing that this framework is tailored for money-like instruments, not investment products.

Stablecoin Oversight and the OCC’s Regulatory Role

The STABLE Act introduces a federal-first oversight model for stablecoins, placing the OCC at the center of regulatory authority. The OCC is responsible for licensing, supervision, and enforcement for federally chartered nonbank issuers, including oversight of reserve practices, AML compliance, and redemption procedures.

At the same time, the Act allows for a dual regulatory track: state-chartered issuers may operate under state supervision, but only if their regulatory frameworks are certified by the Treasury Department as meeting or exceeding federal standards. This coordination is designed to prevent regulatory arbitrage while preserving some role for states with strong supervisory systems.

To support this structure, the Act envisions the use of memoranda of understanding (MOUs) between federal and state regulators to facilitate joint oversight, information sharing, and enforcement cooperation. Therefore, while the STABLE Act allows state regulators to remain active supervisors, it does so under a federalized framework—not a fully dual system. States can issue rules, conduct oversight, and share information, but only if their regulatory standards meet or exceed those set at the federal level—ensuring consistency without ceding control.

Only entities designated as Permitted Payment Stablecoin Issuers (PPSIs) are allowed to issue payment stablecoins under the STABLE Act*. These include:

  • Federally licensed nonbank entities approved by the OCC,
  • Subsidiaries of Insured Depository Institutions (IDIs), and
  • State-chartered institutions operating under Treasury-certified regimes.

This structure narrows who can issue stablecoins and raises the compliance bar, aligning issuance with bank-like standards. Oversight extends beyond the issuer to its parent company and institution-affiliated parties—including executives, affiliates, and key service providers—bringing the full operational chain under regulatory scrutiny. In doing so, the STABLE Act mirrors the supervisory reach of federal banking law, embedding stablecoin oversight into a tested regulatory framework.

OCC Application Process for Nonbank Stablecoin Issuers

Nonbank entities must apply directly to the OCC, submitting:

  • Financial and governance disclosures
  • Risk and reserve management plans
  • Operational and compliance documentation

The OCC is required to review applications within 120 days, and must issue written explanations for rejections. Approved issuers are subject to ongoing quarterly reporting, periodic examinations, and activity restrictions unless explicitly cleared by regulators. The process mirrors traditional bank licensing—but is purpose-built for stablecoins, embedding them in a compliance-first framework without requiring a full banking charter.

Stablecoin Reserve Requirements and Risk Management Rules

The STABLE Act mandates that all payment stablecoins be backed 1:1 by safe, liquid assets—primarily to ensure users can redeem at par even during market stress. This reserve model is intentionally conservative, positioning stablecoins closer to cash than to yield-generating instruments.

Permitted reserves include:

  • Cash or central bank balances
  • U.S. Treasuries with maturities under 93 days
  • Overnight Treasury repos

Not allowed:

  • Corporate debt, crypto assets, or algorithmic collateral

Reserves must be held in segregated accounts—separate from the issuer’s operating funds—and cannot be reused (rehypothecated) without regulatory approval.

Issuers are also required to:

  • Redeem at par on demand—$1 in, $1 out
  • Publish monthly disclosures on their website showing total stablecoins in circulation and breakdown of reserve composition
  • Attest disclosures by a CEO or CFO

Critically, the Act prohibits stablecoin issuers from paying interest—preserving their role as transactional instruments, not investment products. While these protections reinforce user trust, they also raise the compliance bar—especially for crypto-native firms operating without legacy banking infrastructure.

AML and CFT Compliance Obligations for Stablecoin Issuers

The STABLE Act brings stablecoin issuers under the full scope of the Bank Secrecy Act (BSA), meaning they must operate with the same AML rigor expected of traditional financial institutions. This includes:

  • FinCEN Registration: Ensure timely registration with the Financial Crimes Enforcement Network (FinCEN) to establish the legal foundation for AML/CFT obligations.​
  • Risk-Based AML Program: Develop and implement a risk-based AML program tailored to the specific operational and customer risk profiles of the stablecoin issuer. This includes policies, procedures, and internal controls designed to mitigate identified risks.​
  • Customer Due Diligence (CDD): Conduct thorough CDD processes, including Know Your Customer (KYC) procedures, to verify the identities of customers and assess their risk levels. Enhanced due diligence should be applied to higher-risk customers.​
  • Transaction Monitoring: Deploy real-time monitoring tools capable of identifying high-risk behavior, including interactions with sanctioned actors, mixers, or darknet-linked addresses. Platforms like Merkle Science’s Compass support:
    • Prebuilt FinCEN-style typologies for rapid deployment
    • Customizable rules to align alerts with specific risk appetite
    • AI-driven behavioral detection to surface laundering patterns
    • Advanced heuristics for HRE and sanctions evasion
    • Integrated investigation workflows to triage and document alerts efficiently
  • Suspicious Activity Reporting (SAR): Establish procedures for the timely filing of Suspicious Activity Reports with FinCEN when suspicious transactions are detected. Ensure that staff are trained to recognize and escalate potential issues appropriately.​
  • Ongoing Compliance Training: Provide regular training to employees on AML/CFT regulations, internal policies, and procedures to maintain a culture of compliance and ensure that staff remain informed about emerging risks and regulatory changes.​
  • Independent Audit Function: Maintain an independent audit function to periodically assess the effectiveness of the AML/CFT program and recommend improvements.

The STABLE Act doesn’t prescribe how monitoring must be done—but it does expect issuers to demonstrate that controls are proportionate, responsive, and auditable. That means investing in infrastructure that evolves as risks evolve.

Regulations for Stablecoin Custodians and Wallet Providers

Under the STABLE Act, custodial intermediaries—such as wallet providers and custodians holding payment stablecoins—are subject to stringent requirements to safeguard customer assets. Key provisions include:

  • Asset Segregation: Custodians must segregate customer assets from their own, ensuring that client funds are protected from the custodian's creditors in the event of insolvency.
  • Prohibition on Commingling: While custodians can commingle assets of multiple customers in an omnibus account at an insured depository institution or trust company, they cannot commingle these assets with their own.
  • Regulatory Oversight: Custodial services must be provided by entities supervised or regulated by federal or state banking regulators, ensuring adherence to established financial safeguards.

Non-Custodial vs Custodial Wallet Exemptions Explained

The STABLE Act distinguishes between custodial and non-custodial wallet providers:

  • Non-Custodial Wallets: Providers offering software or hardware that enables users to self-custody their stablecoins—without having access to users' private keys—are generally exempt from the Act's regulatory requirements.
  • Custodial Wallets: Entities that hold or manage stablecoins on behalf of users fall under the Act's purview and must comply with the associated regulatory obligations.

This distinction ensures that user autonomy is preserved for those opting for self-custody, while imposing necessary oversight on entities that manage assets on behalf of others.

Rules for Foreign Stablecoin Issuers Offering Tokens in the U.S.

The STABLE Act permits foreign stablecoin issuers to offer tokens in the U.S.—but only if the Treasury Secretary certifies that their home jurisdiction has a comparable regulatory framework. This determination is discretionary and lacks predefined criteria, giving Treasury flexibility but also introducing potential uncertainty for non-U.S. firms.

Foreign issuers have 18 months from enactment to meet compliance standards or exit the U.S. market. During this period, they must either:

  • Obtain federal approval, or
  • Ensure their home country is deemed equivalent under Treasury’s review.

Why the STABLE Act’s Reach May Be Limited for DeFi

The STABLE Act allows foreign stablecoin issuers to operate in the U.S., but only if their home country’s regulatory regime is deemed “comparable” by the Treasury Secretary.The goal is clear: align offshore regimes with U.S. standards without imposing a blanket ban.

But the provision stops at intermediaries. It restricts listings and custodial flows, not usage. Foreign stablecoins can still circulate freely through DeFi or self-custody, limiting the Act’s practical reach. The lack of defined comparability criteria, clear penalties, or robust enforcement tools further weakens its bite.

Critics warn this framework may backfire. It risks incentivizing issuers to incorporate offshore while burdening U.S. firms with stricter compliance. It leaves systemic risks tied to dollar-denominated liabilities created abroad largely unaddressed.

In effect, the provision gestures toward global standard-setting, but without clarity or enforcement, it may do little more than reroute risk.

Final Outlook: Rulemaking, Transition & Implementation Realities

The STABLE Act passed the House Financial Services Committee on April 2, 2025, with a 32–17 vote. That’s significant—but not the final word.

If enacted, the STABLE Act will initiate a multi-stage regulatory rollout. The OCC and Treasury will have 12 months to define critical implementation rules—governing reserve composition, issuer approval, foreign comparability, and disclosure standards. Issuers will then enter a 24-month transition window to meet these requirements or withdraw from the U.S. market. Foreign issuers face an 18-month deadline tied to Treasury's comparability assessment.

On paper, these timelines are generous. In practice, their success will depend on several real-world factors:

  • Clarity in Rulemaking: Issuers will need granular guidance—not just principles—to adapt their compliance frameworks. Delays or ambiguity from regulators could stall implementation.
  • Operational Overhaul: Transitioning to full reserve backing, submitting to OCC supervision, and reorganizing legal entities will require time, capital, and staffing—particularly for crypto-native or offshore firms.
  • Regulatory Availability: Agencies will need to be actively engaged with industry stakeholders, providing clear pathways for licensure, interpretation, and dispute resolution.
  • Market Stability: Abrupt exits or confusion around compliance status could spark user uncertainty. A predictable and coordinated rollout is essential to maintain confidence across payment rails and DeFi integrations.

These challenges make the transition period more than just a countdown. It’s a stress test for the regulatory system—and a test of whether stablecoin infrastructure can evolve without fragmenting the market in the process.

*The primary federal regulator for an IDI (insured depository institution) remains its existing banking regulator—either the Federal Reserve, OCC, FDIC, or NCUA. For nonbank stablecoin issuers, the OCC serves as the primary regulator under the STABLE Act.