Compliance Tracker

Reviewed 2026-06-18 by Pharos compliance research

AUSD is a fiat-backed U.S. dollar stablecoin with 1:1 redemption, reserve attestations, and institutional payment and settlement use cases.

Agora's OCC national trust bank charter application (received 2026-04-20) is under review with no approval granted. No GENIUS Act PPSI approval, state-qualified approval, or registered foreign-issuer exception was found for AUSD. GENIUS Act rulemaking remains in proposed-rules phase with no PPSI approvals issued to any issuer as of 2026-06-18.

Agora filed its OCC national trust bank charter application on April 20, 2026 (received by OCC; public portion available as PDF on OCC licensing page), pursuing the federal-qualified-nonbank pathway under GENIUS Act. CEO Nick van Eck confirmed in April 2026 that the OCC trust charter is Agora's intended GENIUS Act onshore PPSI pathway. No PPSI approval has been granted — GENIUS Act rulemaking is still in proposed-rules phase as of 2026-06-18. No registered foreign-issuer exception found. Application status: under review (not approved).

Reviewed 2026-06-18 by Pharos compliance research

CASH is a Bridge-issued U.S. dollar payment stablecoin for Phantom with 1:1 redemption through Bridge.

No token-specific GENIUS PPSI approval, state-qualified approval, or official PPSI application was located for CASH. The OCC conditional trust bank charter (CD-1365, Feb 2026) applies to a new bank entity under Bridge Ventures LLC, not to BBI (the actual CASH issuer). The PPSI application framework remains in proposed-rulemaking phase as of 2026-06-18.

Bridge Building Inc. (BBI), the legal issuer of CASH via Bridge Open Issuance, is a Stripe subsidiary and licensed state money transmitter (NMLS #2450917). On Feb 12, 2026, the OCC conditionally approved Bridge Ventures LLC (BVL, BBI's parent) to organize Bridge National Trust Bank (OCC Corporate Decision #1365), a new federally chartered national trust bank that would issue stablecoins and custody digital assets under direct OCC oversight. This conditional trust-bank charter covers a new bank entity under BVL, not BBI directly; BBI remains a state money transmitter. Because the chartered entity is not yet formed and BBI is the actual CASH issuer, issuerPathway remains unknown rather than federal-qualified-nonbank. Bridge markets its platform as GENIUS-ready but no token-specific PPSI approval or official GENIUS application has been filed or publicly disclosed for CASH. authorizationStatus stays issuer-announced-intent. No enforcement actions found.

Reviewed 2026-06-18 by Pharos compliance research

ctUSD is a MoonPay-issued U.S. dollar payment stablecoin using M0 infrastructure with 1:1 mint and redemption.

No token-specific public GENIUS PPSI approval, state-qualified approval, or official application filing was located for ctUSD or MoonPay USA LLC. MoonPay's public posture as of June 2026 is intent-signaling only, with no regulator-grade authorization source found.

MoonPay positions ctUSD as 'designed to align with the forthcoming GENIUS Act guidelines' (Citrea launch blog, Jan 2026) and MoonPay VP Harrison described GENIUS as a regulatory 'permission slip' at Consensus Miami 2026 (May 8, 2026). No token-specific PPSI application, state-qualified approval, or OCC/FDIC filing was found as of 2026-06-18. The application framework remains in NPRM stage. MoonPay holds a NYDFS Limited Purpose Trust Charter (2025) and MTLs in 49 states, which could support a state-qualified or federal-qualified-nonbank pathway under GENIUS, but no pathway has been publicly declared.

Reviewed 2026-06-18 by Pharos compliance research

FIUSD is a pre-launch fully reserved USD-backed stablecoin platform from Fiserv designed for financial-institution and payment-system use. Fiserv acts as infrastructure provider; participating banks are the actual stablecoin issuers under the IDI-subsidiary pathway.

No token-specific public GENIUS PPSI approval, state-qualified approval, or official application source was located for FIUSD or for any of its participating bank issuers. The PPSI application framework remains under proposed rulemaking as of June 2026.

Fiserv describes FIUSD as fully reserved and redeemable at $1. The model is 'issued through banks, accepted through merchants': Fiserv is the technology/infrastructure platform; participating FI clients (e.g. Bank of North Dakota, Huntington) are the actual PPSI issuers via the IDI-subsidiary pathway under GENIUS. CEO Lyons confirmed July 2026 live date at Bernstein Strategic Decisions conference (June 3, 2026). StoneCastle acquisition (completed Dec 2025) includes a stablecoin/crypto custody license. No PPSI approval exists — the approval framework itself remains in proposed rulemaking as of June 2026.

Reviewed 2026-06-18 by Pharos compliance research

Frax issuer-intent materials confirmed via FIP-430 and FIP-432; OCC licensing tracker checked 2026-06-18 shows no pending application from Frax Finance, Financial Reserves and Asset Exploration Inc., or FRAX Inc.; no PPSI approval, state-qualified approval, or official application found.

Frax governance passed FIP-430 (April 2025) and FIP-432 (July 2025) to prepare frxUSD for U.S. GENIUS Act payment-stablecoin charter compliance and formally transfer compliance and collateral management to FRAX Inc (formerly FinresPBC / Financial Reserves and Asset Exploration Inc.). The OCC digital-assets licensing application tracker (checked 2026-06-18) lists no pending application from Frax Finance, Financial Reserves and Asset Exploration Inc., or FRAX Inc. StableCharter.com categorizes status as 'PREPARING.' The GENIUS Act application framework itself remains in proposed-rule stage. authorizationStatus remains issuer-announced-intent — issuer intent is clear and well-documented but no official PPSI application has been filed. issuerPathway set to federal-qualified-nonbank reflecting the OCC nonbank PPSI route being pursued (not an IDI subsidiary, not foreign-registered); neither FIP explicitly names OCC but FRAX Inc. is a US nonbank entity with no state PPSI registration found, making the OCC federal nonbank pathway the only consistent federal route.

Reviewed 2026-06-18 by Pharos compliance research

MUSD is a Bridge-issued U.S. dollar payment stablecoin for MetaMask using M0 infrastructure and 1:1 redemption.

No PPSI approval, state-qualified approval, or official GENIUS Act PPSI application has been publicly filed or granted for MUSD or Bridge Building Inc. The OCC conditional trust bank charter CD-1365 (Feb 2026) is for a new entity 'Bridge National Trust Bank' — a conditional pre-approval for an entity not yet operational, not a final charter for the current issuer Bridge Building Inc. No monthly attestation reports for MUSD were found; MetaMask's own reserve explainer notes mUSD's attestation history is still being built.

Bridge and MetaMask materials describe MUSD issuance and redemption, but no token-specific public GENIUS PPSI approval exists as of 2026-06-18. In February 2026 the OCC issued conditional approval CD-1365 for a new entity 'Bridge National Trust Bank' (a subsidiary to be organized by Bridge Ventures LLC) to organize a federally chartered national trust bank for stablecoin issuance, custody, and reserve management. This is a conditional pre-approval for an as-yet-unopened entity — not a final charter for Bridge Building Inc. (the current MUSD issuer). issuerPathway remains unknown until Bridge National Trust Bank receives final OCC approval and begins issuing MUSD. Monthly reserve attestations: the MetaMask reserve explainer explicitly states mUSD's attestation history 'is still being built' with no confirmed monthly cadence; monthlyAttestationPresent remains false.

Reviewed 2026-06-18 by Pharos compliance research

pathUSD functions as Tempo routing and quote-token infrastructure; its payment-stablecoin treatment remains less clear than consumer-facing Bridge issued stablecoins.

No PPSI approval, state-qualified approval, or official GENIUS Act application was located for pathUSD or Bridge; the OCC conditional trust charter is a separate pre-existing pathway. No PPSI approval has been granted to any issuer as of 2026-06-18.

Bridge (OCC filing ID 343543) received conditional approval for a federally chartered national trust bank on Feb 12, 2026 — the same track as Circle, Ripple, Paxos, BitGo, and Fidelity Digital Assets. This is a trust charter conditional approval under existing OCC authority, not a PPSI approval under the GENIUS Act; the PPSI application framework itself remains in proposed-rulemaking. Bridge publicly describes its stack as GENIUS Act-ready. pathUSD is Tempo's TIP-20 quote token issued via Bridge infrastructure; no token-specific GENIUS authorization was located.

Reviewed 2026-06-18 by Pharos compliance research

PYUSD is a Paxos-issued U.S. dollar payment stablecoin distributed by PayPal with 1:1 redemption and monthly reserve attestations.

Paxos received OCC conditional trust-charter approval Dec 2025, but no PPSI approval exists – the GENIUS Act PPSI application framework remains in proposed-rules rulemaking as of June 7, 2026.

On December 12, 2025, the OCC granted Paxos Trust Company conditional approval to convert from its NYDFS limited purpose trust charter to a national trust bank charter (OCC NR-2025-125). This is a conditional trust-charter conversion, not a PPSI approval under the GENIUS Act (whose application framework remains in proposed-rules rulemaking). Paxos publicly announced PYUSD will align with GENIUS Act requirements as rules are finalized. The authorizationStatus remains issuer-announced-intent because no PPSI approval framework or application process yet exists. The OCC rulemaking (Bulletin 2026-3) is also scrutinizing PayPal's 4% PYUSD reward program as a potential indirect interest payment prohibited under GENIUS.

Reviewed 2026-06-18 by Pharos compliance research

RLUSD is a U.S. dollar payment stablecoin issued through Ripple's NYDFS-chartered subsidiary with 1:1 redemption and monthly reserve attestations.

No GENIUS Act PPSI application, state-qualified PPSI approval, or official PPSI filing was located for RLUSD or Standard Custody & Trust Company. OCC December 2025 conditional approval is a trust bank charter under existing OCC authority, not a PPSI approval under the GENIUS Act.

RLUSD is issued by Standard Custody & Trust Company, LLC (SCTC), a NYDFS-chartered limited purpose trust company. Ripple also received a conditional OCC approval (December 12, 2025) to establish Ripple National Trust Bank (RNTB) as a de novo national trust bank to manage RLUSD reserves — this is an OCC trust bank charter under existing authority, not a GENIUS Act PPSI approval. Ripple's stated GENIUS compliance pathway is NYDFS state equivalency (SCTC). No PPSI application or approval exists as of 2026-06-18; the GENIUS Act rulemaking remains at the NPRM stage.

Reviewed 2026-06-18 by Pharos compliance research

Roughrider Coin is a pre-launch USD bank-to-bank payment stablecoin pilot announced by Bank of North Dakota with Fiserv infrastructure.

No token-specific GENIUS PPSI approval, state-qualified approval, official application, or final issuer-pathway source was located for Roughrider Coin.

Bank of North Dakota and Fiserv publicly announced Roughrider as a USD-backed stablecoin pilot and reference the U.S. stablecoin framework, but no token-specific GENIUS PPSI approval, state-qualified approval, or official application was found. The issuer pathway remains unknown because the public materials do not identify a final PPSI route for the BND/Fiserv deployment.

Reviewed 2026-06-18 by Pharos compliance research

USAT is publicly described as a U.S. dollar-backed token with 1:1 redemption through Tether and Anchorage Digital Bank, marketed explicitly as a GENIUS Act-compliant payment stablecoin.

No PPSI approval, state-qualified status, or official GENIUS Act application has been publicly filed or granted for Anchorage Digital Bank or USAT as of 2026-06-18. Anchorage explicitly uses forward-looking language ('expects to become a PPSI') confirming intent, not approval. The GENIUS Act rulemaking remains at the NPRM stage with no final rules issued.

Anchorage Digital Bank is an uninsured OCC-chartered national trust bank (the first federally chartered crypto bank, chartered January 2021). Under the GENIUS Act, this corresponds to the federal qualified payment stablecoin issuer (FQPSI) pathway supervised by the OCC. Anchorage has submitted a comment letter on the OCC NPRM and publicly states it expects to become a PPSI once the GENIUS Act framework takes effect (rules still in proposed-rulemaking stage as of 2026-06-18). No PPSI approval has been granted to any issuer. The OCC's proposed rule raises a potential 'one issuer, one brand' restriction that could affect Anchorage's white-label model (it currently issues USAT, USDtb/Ethena, USDGO/OSL, and a forthcoming USDPT/Western Union).

Reviewed 2026-06-18 by Pharos compliance research

USD1 is a U.S. dollar payment stablecoin issued 1:1 via BitGo Trust infrastructure with reserve attestations and public redemption policy — squarely within the apparent-payment-stablecoin definition.

No token-specific GENIUS PPSI approval, state-qualified approval, or official PPSI application was located for USD1. The January 2026 OCC charter filing by WLTC Holdings is a trust-charter application under existing OCC authority, not a GENIUS PPSI application.

USD1 is legally issued by BitGo Trust Company (operating post-conditional-OCC-approval as BitGo Bank & Trust, N.A.); World Liberty Financial Inc. is the brand sponsor/co-founder. In January 2026, WLTC Holdings LLC (a WLFI subsidiary) filed a de novo OCC national trust bank charter application to establish World Liberty Trust Company, N.A., which would take over direct issuance and custody of USD1 if approved. The OCC charter applications are under existing OCC authority — not GENIUS Act PPSI applications. No GENIUS PPSI framework has been finalized; issuer-announced-intent remains the correct status. No token-specific GENIUS PPSI approval, state-qualified approval, or official PPSI application was located.

Reviewed 2026-06-18 by Pharos compliance research

USDB is Bridge's dollar stablecoin for stablecoin financial accounts, with 1:1 reserves and mint/redeem infrastructure managed by Bridge Building Inc.

No PPSI approval, state-qualified approval, or official GENIUS Act application found for Bridge or USDB. Bridge holds a conditional OCC trust bank charter (not a PPSI grant) and self-describes as GENIUS-ready. GENIUS Act rulemaking remains at proposed-rules stage with no approvals granted to any issuer as of 2026-06-18.

Bridge Building Inc. (BBI), a Stripe subsidiary, received OCC conditional approval Feb 12, 2026 (CD1365) to organize Bridge National Trust Bank — a federal nonbank trust charter that maps to the federal-qualified-nonbank GENIUS pathway. Bridge publicly markets USDB and its Open Issuance platform as 'GENIUS-ready' (per bridge.xyz blog and Stripe Open Issuance announcement). No PPSI approval or official GENIUS application has been filed or granted; the application framework is still in proposed-rules rulemaking. GENIUS Act is not yet effective (effective date: Jan 18, 2027 at latest). Bridge is also a registered MSB with state MTLs for current operations.

Reviewed 2026-06-18 by Pharos compliance research

USDC is publicly issued as a U.S. dollar payment stablecoin with 1:1 redemption and monthly reserve attestations.

No GENIUS PPSI approval or state-qualified approval has been granted to any issuer; OCC conditional trust charter (Dec 2025) is pre-GENIUS-application-framework and not a PPSI status; no public application filed under GENIUS Act rulemaking.

Circle received conditional OCC approval on Dec 12 2025 for First National Digital Currency Bank, N.A. — a federal-qualified-nonbank trust charter pathway consistent with the GENIUS Act framework. This is a conditional charter under existing OCC authority, not a PPSI approval; GENIUS Act rulemaking remains in proposed-rules phase with no approvals granted. Pharos found no token-specific public GENIUS PPSI approval as of review.

Reviewed 2026-06-18 by Pharos compliance research

USDGO is publicly described as a U.S. dollar token issued by Anchorage Digital Bank with 1:1 redemption and reserve attestations.

No token-specific public OCC GENIUS PPSI approval, official application, or registration was located for USDGO. Anchorage has publicly announced intent and submitted GENIUS Act comment letters, but the PPSI approval framework is still in proposed-rules rulemaking as of 2026-06-18.

Anchorage Digital Bank N.A. holds an OCC national trust bank charter (granted 2021) and is an uninsured national trust bank — not FDIC-insured and not an IDI subsidiary. Under the GENIUS Act, the federal-qualified-nonbank pathway covers uninsured national banks chartered by the OCC approved to issue payment stablecoins; this is the correct pathway for Anchorage. Anchorage has publicly announced intent to qualify as a PPSI and submitted comment letters to the OCC on the GENIUS Act NPRM, but no PPSI approval or formal application has been submitted — the approval framework is still in proposed-rules rulemaking as of 2026-06-18 (GENIUS Act effective Jan 18, 2027 or 120 days after final rules). No token-specific public OCC GENIUS approval found for USDGO.

Reviewed 2026-06-18 by Pharos compliance research

USDP is a Paxos-issued U.S. dollar payment stablecoin with 1:1 redemption and monthly reserve attestations.

No token-specific public GENIUS PPSI approval, state-qualified approval, or official PPSI application source was located for USDP. OCC conditional trust charter approval (December 2025) is a charter action, not a PPSI authorization under GENIUS.

Paxos converted its NYDFS limited purpose trust charter to an OCC national trust bank charter on December 12, 2025 (conditional approval). This positions Paxos on the federal-qualified-nonbank pathway under GENIUS. No PPSI application framework exists yet (still in proposed-rule stage as of 2026-06-18); no PPSI approval has been granted to any issuer. USDP continues to be Paxos-issued and covered by federal OCC oversight but has no GENIUS PPSI authorization.

Reviewed 2026-06-18 by Pharos compliance research

USDPT is a U.S. dollar stablecoin issued by Anchorage Digital Bank for Western Union's global payment and settlement network.

No PPSI approval, official PPSI application, or state-qualified approval has been located for USDPT or Anchorage Digital Bank. The PPSI application framework remains in proposed rulemaking. Anchorage has publicly stated it expects PPSI status once the GENIUS Act becomes effective, confirming issuer-announced-intent.

Anchorage Digital Bank, N.A. is the OCC-chartered national trust bank issuing USDPT for Western Union. ADB explicitly states it expects to become a PPSI once the GENIUS Act becomes effective (Jan 18, 2027 at the latest). The issuerPathway is federal-qualified-nonbank because ADB holds an OCC national trust charter but is uninsured (no FDIC insurance required), placing it outside the IDI-subsidiary category and instead on the federal nonbank/OCC pathway. A 2022 OCC consent order for BSA/AML deficiencies was fully terminated by the OCC in August 2025; no active enforcement action exists as of the review date. No PPSI approval or application has been filed; the PPSI application framework remains in proposed rulemaking.

Reviewed 2026-06-18 by Pharos compliance research

USDsui is a Bridge-issued U.S. dollar payment stablecoin for Sui with 1:1 redemption through Bridge Open Issuance.

No PPSI approval, state-qualified approval, or official GENIUS Act PPSI application has been publicly filed or approved for Bridge or USDsui. Bridge's OCC conditional charter approval is a trust-charter action under existing OCC authority, not a GENIUS Act PPSI authorization.

Bridge received conditional OCC approval (Feb 12, 2026) to organize Bridge National Trust Bank, NA — an uninsured national trust bank, which maps to the 'federal-qualified-nonbank' PPSI pathway under the OCC's GENIUS Act NPRM. Bridge publicly states its compliance framework 'already positions Bridge to be GENIUS ready.' This is a trust-charter conditional approval under existing OCC authority, not a PPSI approval under the GENIUS Act (which remains in proposed-rules phase). No PPSI approvals exist as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

USDT is a fiat-referenced dollar stablecoin marketed for payments, transfers, and 1:1 redemption through Tether for eligible customers.

Tether CEO Paolo Ardoino publicly committed on July 18 2025 (day the GENIUS Act was signed) that Tether will comply via the GENIUS Act foreign issuer pathway, with three years to meet all requirements including AML and audited reserves. Tether's January 27 2026 USAT press release explicitly states USDT is 'progressing towards GENIUS Act compliance' while USAT (issued by Anchorage Digital Bank, N.A.) serves the U.S. domestic market. No formal foreign-issuer registration has been filed for USDT — the Treasury equivalency-determination process is still in NPRM phase as of June 2026 and no comparability determination for El Salvador/Tether has been issued. foreignExceptionStatus remains unknown (more conservative than registration-pending) because no application framework is finalized and no formal filing exists. Historical CFTC and NYAG actions are tracked as enforcement-warning evidence for Tether/USDT history; they do not establish a current GENIUS authorization decision.

Reviewed 2026-06-18 by Pharos compliance research

USDtb is publicly described as a U.S. dollar-backed stablecoin issued by Anchorage Digital Bank against BUIDL and cash reserves.

No PPSI approval, PPSI application, or official authorization found for USDtb or Anchorage Digital Bank under the GENIUS Act; the PPSI approval framework remains in proposed-rules phase as of 2026-06-18. Anchorage's own comment letter describes anticipated future PPSI status, not current approval.

Anchorage Digital Bank N.A. is an OCC-chartered uninsured national trust bank — not a deposit-taking IDI, not a state entity. Under the GENIUS Act's taxonomy, this places it in the federal-qualified nonbank issuer (FQPSI) pathway supervised by the OCC. In its comment letter to the OCC's GENIUS Act NPRM (2026), Anchorage stated it 'expects to become a permitted payment stablecoin issuer (PPSI) pursuant to the GENIUS Act, once effective' — forward-looking intent, not a current approval. No PPSI approvals have been granted to any issuer as of 2026-06-18; the PPSI approval framework remains in proposed-rules phase (OCC NPRM issued Feb 2026, final rules not yet published). issuerPathway corrected from unknown to federal-qualified-nonbank based on Anchorage's OCC national trust bank charter.

Reviewed 2026-06-18 by Pharos compliance research

Sonic Labs markets USSD as a Treasury-backed, 1:1 mint/redeem dollar built on GENIUS-compatible frxUSD infrastructure; the issuer's public positioning treats it as a payment stablecoin subject to the GENIUS Act.

No token-specific PPSI approval, state-qualified approval, official GENIUS Act application filing, or comparable foreign-issuer exception was located for USSD or Sonic Labs / Sonic USA LLC in any federal or state regulatory database. Sonic Labs' GENIUS compatibility claims are issuer marketing, not regulatory disclosures.

Sonic Labs publicly markets USSD as 'fully compatible with the GENIUS Act' and has established Sonic USA LLC (Delaware) for U.S. regulatory engagement. No PPSI application, OCC/FDIC/Federal Reserve filing, or state-qualified authorization has been found. The GENIUS Act rulemaking remains in proposed-rules phase with no PPSI approvals granted to any issuer as of 2026-06-18. Foreign exception status updated to not-applicable as the issuer is U.S.-domiciled.

Reviewed 2026-06-18 by Pharos compliance research

AED-RAKBANK is a pre-launch dirham-backed payment token planned for 1:1 AED redemption under CBUAE oversight.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, OCC foreign-issuer registration, or Treasury comparability determination was located for AED-RAKBANK or RAKBank.

RAKBank has announced CBUAE in-principle approval for an AED payment token, but no U.S. GENIUS PPSI approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was found.

Reviewed 2026-06-18 by Pharos compliance research

AID is presented as a 1:1 mintable and redeemable AI-dollar stablecoin backed by U.S. Treasuries and stable assets, consistent with a payment stablecoin as defined under the GENIUS Act.

No PPSI approval, state-qualified approval, official application, registered foreign-exception, or Singapore comparability determination was found for GAIB or AID. The foreign-exception framework is still being built through NPRMs; no state has been certified as substantially similar and no third-country comparability determination has been issued by Treasury as of 2026-06-18.

AID has issuer-style 1:1 mint/redeem and reserve disclosures attested by McMillan Woods (HK) CPA Limited, but no public GENIUS authorization or foreign-issuer comparability exception was found. The GENIUS Act was enacted July 18, 2025; all implementing rules remain at NPRM stage as of 2026-06-18 with no PPSI approvals granted and no Singapore comparability determination issued by Treasury. GAIB is Singapore-domiciled; the foreign-exception pathway (GENIUS Act s.18) requires a Treasury comparability determination for Singapore's regime, which has not been published.

Reviewed 2026-06-18 by Pharos compliance research

apxUSD has stablecoin-like mint/redeem mechanics, but collateral consists of preferred equity in Digital Asset Treasury companies rather than cash or government securities, the Terms of Service explicitly disclaim that financial terminology carries its customary legal meaning, and US persons are blocked from the platform — all of which cloud GENIUS payment-stablecoin applicability.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception found. Apyx ToS confirms BVI domicile and blocks US persons; no GENIUS Act reference in any issuer document.

apxUSD is stablecoin-adjacent but its preferred-share collateral (primarily STRC, Strategy preferred equity) and BVI domicile make GENIUS payment-stablecoin classification unresolved. The Terms of Service explicitly state the protocol is facilitated by Preference Capital (BVI) Ltd. under BVI law, describe apxUSD as a protocol-generated asset rather than a claim against any legal entity, and block US, EU, UK, and Canadian persons from accessing the platform. A depeg event occurred on 2026-06-04 with apxUSD trading at $0.90–$0.93 due to STRC preferred-share volatility.

Reviewed 2026-06-18 by Pharos compliance research

AUDD is a 1:1 AUD-backed payment stablecoin with institutional redemption, multichain distribution, and Coinbase Wallet custody availability for US users (trading restricted to non-US Coinbase users).

No token-specific public US GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception was located for AUDD. Foreign exception registration framework remains in proposed-rulemaking phase as of 2026-06-18.

AUDD is a foreign non-USD payment stablecoin with some US presence (Coinbase Wallet custody; not tradable on Coinbase for US-based users). No GENIUS PPSI approval, state-qualified approval, official application, or foreign-issuer exception registration found. Foreign exception framework still under proposed rulemaking (Treasury NPRM FR 2026-06489). Monthly William Buck attestations confirmed through May 2026.

Reviewed 2026-06-18 by Pharos compliance research

avUSD is the non-yield Avant base token backed 1:1 by USDC and redeemable through protocol mint/redeem flows.

No token-specific U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception was located for avUSD or Avant Protocol Foundation across OCC rulemaking materials, issuer disclosures, and news sources checked June 2026.

avUSD has stablecoin-like reserve and redemption disclosures; no public GENIUS approval or foreign-issuer exception source was found. Terms of Use (avantprotocol.com) govern under BVI law and refer to 'Avant Protocol Foundation and its affiliates' as the operating entity; company profiles list Palo Alto, CA as operational HQ but no US legal entity name is disclosed. BVI domicile retained as primary; issuerPathway kept unknown pending clearer entity structure disclosure.

Reviewed 2026-06-18 by Pharos compliance research

AZND materials describe a yield-bearing stablecoin and mint/redeem mechanics, but no public GENIUS approval, official application, or foreign registration source was located.

AZND is a yield-bearing Asia Dollar product with mint/redeem mechanics; GENIUS treatment remains unresolved.

Reviewed 2026-06-18 by Pharos compliance research

BILS is a regulator-approved shekel stablecoin designed for 1:1 NIS redemption from segregated Israeli reserves.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, OCC foreign-issuer registration, or Treasury comparability determination was located for BILS or Bits of Gold.

BILS has Israeli regulatory approval for a limited stablecoin launch, but no U.S. GENIUS PPSI approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was found.

Reviewed 2026-06-18 by Pharos compliance research

cgUSD is a fixed-price USD-pegged stablecoin with 1:1 USDC redemption designed for broad DeFi and payment use, which fits the functional profile of a payment stablecoin. However, the legal issuer (Cygnus Information Limited) appears operated by ARKS Labs, which is primarily domiciled in Hong Kong with only a FinCEN MSB registration (31000226418649) in the US, creating genuine ambiguity over whether GENIUS Act jurisdiction applies via a domestic or foreign-issuer pathway.

No GENIUS Act PPSI approval, state-qualified status, official application, or foreign exception registration found across issuer disclosures, OCC NPRM materials, and third-party trackers. ARKS Labs holds a FinCEN MSB registration but no PPSI-pathway filing.

cgUSD is issued by Cygnus Information Limited (confirmed from website footer copyright), operated by ARKS Labs which is HK-based with a US FinCEN MSB registration. Functionally fits payment-stablecoin profile but issuer domicile ambiguity keeps applicability as unclear. GENIUS Act still in proposed-rules phase; no PPSI approvals exist for any issuer as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

cUSD is USD-pegged and vault-redeemable at ~1:1, which superficially resembles a payment stablecoin, but its proportional basket redemption mechanism (socializing losses across redeemers), absence of a disclosed legal issuer entity, and the protocol's self-description as code-enforced rather than institutionally backed create genuine ambiguity about whether a legal 'permitted issuer' exists under the GENIUS Act definition. The stcUSD product separates yield; cUSD itself does not natively pay yield.

Cap Protocol has no publicly disclosed GENIUS authorization, application, or state-qualified status; no legal issuer entity is named in public documentation; basket redemption design diverges from GENIUS payment-stablecoin model; no PPSI application framework exists yet.

Cap documents basket-based vault redemption rather than a clean fiat issuer redemption promise. No legal entity is publicly disclosed as the issuer. The protocol operates code-enforced protection without named regulatory oversight. Until a legal issuer entity is disclosed and pathway to GENIUS compliance clarified, applicability remains unclear.

Reviewed 2026-06-18 by Pharos compliance research

DAI is generated by protocol CDP vaults with no legal PPSI issuer entity. No GENIUS authorization, state-qualified approval, official application, or issuer-announced intent was found. GENIUS rulemaking remains at proposed-rules stage with no approvals granted to any issuer as of June 2026.

DAI is a protocol stablecoin generated against collateral through CDP vaults and the LitePSM; there is no legal PPSI issuer entity. Whether DAI qualifies as a payment stablecoin under the GENIUS Act definition remains structurally unclear. No PPSI application, state-qualified approval, or issuer-announced intent found as of June 2026. GENIUS rulemaking remains in proposed-rules phase (no final rules, no approvals).

Reviewed 2026-06-18 by Pharos compliance research

dUSD is a DeFi-native, crypto-collateralized stablecoin issued by a Singapore-domiciled non-profit foundation (Trinity Foundation Ltd.) that explicitly restricts US persons from accessing the protocol; GENIUS Act scope over foreign DeFi issuers with a US geo-block is legally uncertain, so applicability remains unclear rather than definitively in or out of scope.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for dUSD; Trinity Foundation Ltd. (Singapore, ACRA UEN 202414739E) is the legal entity and has no identified US regulatory pathway.

Issuer is Trinity Foundation Ltd., a Singapore non-profit public company limited by guarantee (ACRA UEN 202414739E, registered 2024-04-15); it states it does not control or operate dTRINITY on any blockchain. US persons are explicitly excluded from the protocol (Restricted Regions page lists United States). Note: Singapore is also listed as a restricted jurisdiction, though the foundation is domiciled there — this reflects the protocol's legal distancing from the foundation entity. Terms of Use are governed by Cayman Islands law. GENIUS Act applicability to a foreign non-profit foundation operating a permissionless DeFi protocol with a US geo-block is legally unresolved; no PPSI approval or issuer pathway was identified.

Reviewed 2026-06-18 by Pharos compliance research

EJPY is a pre-launch trust-type yen stablecoin planned for 1:1 JPY redemption under Japan's Payment Services Act framework.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, OCC foreign-issuer registration, or Treasury comparability determination was located for EJPY or Japan Blockchain Foundation.

EJPY is planned as a Japanese trust-type stablecoin, but no U.S. GENIUS PPSI approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was found.

Reviewed 2026-06-18 by Pharos compliance research

Telcoin lists eMXN as a live Digital Cash stablecoin issued under a Nebraska-chartered Digital Asset Depository Bank, positioning it as a 1:1 MXN-backed payment instrument.

No GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception was located for eMXN or Telcoin. The Nebraska charter is a state-law instrument and no state has been certified as substantially similar under GENIUS as of June 2026. Telcoin publicly frames its Nebraska charter as GENIUS-aligned but has not filed a formal GENIUS PPSI application; the application framework itself remains in proposed rulemaking.

Telcoin Digital Asset Bank holds a Nebraska Digital Asset Depository charter (final approval Nov 2025) and has publicly positioned itself as GENIUS Act-aligned through that framework. No GENIUS PPSI approval or filed application exists; the GENIUS Act is still in proposed-rules rulemaking and no state has been certified as substantially similar. The telco.in/digital-cash page states Telcoin will publish monthly attestations -- future tense as of June 2026; none have been located in public sources. No eMXN-specific reserve disclosure URL was found. The stored issuerPathway remains unknown; Telcoin frames Nebraska as its intended GENIUS-aligned route, but no achieved state-qualified approval was found.

Reviewed 2026-06-18 by Pharos compliance research

EURC is a euro-referenced Circle stablecoin issued as a MiCA e-money token by Circle Internet Financial Europe SAS with 1:1 euro redemption and monthly reserve attestations.

No token-specific GENIUS PPSI approval, state-qualified approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was located for EURC or Circle Europe.

EURC is payment-stablecoin-like, but its issuer is Circle Europe under MiCA/ACPR rather than Circle Internet Financial, LLC. No U.S. GENIUS PPSI approval, OCC foreign-issuer registration, or Treasury comparability determination was found for EURC/Circle Europe.

Reviewed 2026-06-18 by Pharos compliance research

eUSD is a bank-issued U.S. dollar payment stablecoin with KYC-gated mint and redemption through Telcoin Digital Asset Bank.

No GENIUS Act PPSI approval, official application, or state-qualified GENIUS authorization was found for Telcoin Digital Asset Bank or eUSD. The Nebraska DADI charter (November 2025) is a state banking authorization under the Nebraska Financial Innovation Act, not a GENIUS Act authorization. The GENIUS Act state-regime comparability process (Treasury NPRM FR 2026-06489) has not designated Nebraska as a substantially similar regime. No GENIUS Act PPSI approvals have been granted to any issuer as of June 7, 2026.

Telcoin Digital Asset Bank holds a Nebraska Digital Asset Depository Institution charter (signed November 12, 2025) under the Nebraska Financial Innovation Act. The company has publicly committed to publishing monthly reserve attestations from an external auditor, but no published attestation reports were found as of 2026-06-18. News sources characterize eUSD as operating in alignment with the GENIUS Act, but no direct issuer statement announces a GENIUS PPSI application, and no state-regime comparability determination has been made for Nebraska under the GENIUS Act Treasury NPRM. The Nebraska DADI charter is a state banking authorization, not a GENIUS Act PPSI authorization. Retaining no-public-authorization-found as the conservative and accurate status.

Reviewed 2026-06-18 by Pharos compliance research

Electronic USD is a Reserve Protocol RToken with on-chain basket collateral and governance rather than a legal fiat issuer.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for eUSD. No GENIUS approvals have been granted to any issuer as of 2026-06-18; rulemaking remains at NPRM stage.

eUSD is stablecoin-adjacent but protocol-governed; no public GENIUS approval or issuer pathway source was found. The payment use case via RPay (Latin America) makes applicability genuinely unclear rather than a clean non-payment-token exclusion.

Reviewed 2026-06-18 by Pharos compliance research

FDUSD is a BVI-issued U.S. dollar stablecoin with 1:1 redemption, segregated reserves, and monthly reserve attestations.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, or foreign-issuer registration was located for FDUSD or FD121 (BVI) Limited. The OCC foreign payment stablecoin issuer registration framework remains in proposed-rulemaking; no registrations have been granted to any entity as of 2026-06-18.

First Digital publishes reserve and redemption disclosures but no public U.S. GENIUS permitted-issuer approval or foreign-issuer registration was located. The applicable GENIUS Act pathway for FD121 (BVI) Limited is the OCC foreign payment stablecoin issuer (FPSI) registration route; however, the foreign-exception registration framework itself remains in proposed-rulemaking as of 2026-06-18 and no registration has been filed. First Digital has stated general intent to pursue licensing in select markets but has not made a GENIUS-specific public announcement.

Reviewed 2026-06-18 by Pharos compliance research

FIDD is a Fidelity-issued U.S. dollar payment stablecoin with 1:1 redemption and monthly reserve attestations, issued by a federally chartered OCC-supervised national trust bank.

No PPSI approval, state-qualified approval, or official PPSI application found for FIDD. The OCC conditional trust charter (Dec 12, 2025) confirms issuer pathway but is explicitly not a PPSI approval. No PPSI application framework exists; rulemaking is at NPRM stage.

Fidelity Digital Assets received a conditional OCC national trust bank charter approval on December 12, 2025 (conversion from NY state trust company). This is a trust-charter conditional approval under existing OCC chartering authority — it is not a PPSI approval under the GENIUS Act, which remains in proposed-rules rulemaking. No PPSI application framework exists yet and no issuer has received PPSI status. FIDD launched publicly on February 4, 2026; Fidelity positions FIDD as aligning with GENIUS Act reserve standards but has not announced a formal PPSI application.

Reviewed 2026-06-18 by Pharos compliance research

Frax governance describes legacy FRAX as AMO-driven and not compatible with GENIUS/STABLE-style payment-stablecoin architecture; no public GENIUS authorization or application source was located.

Frax governance describes legacy FRAX as AMO-driven and not aligned with the newer payment-stablecoin architecture.

Reviewed 2026-06-18 by Pharos compliance research

FUSD has issuer-style 1:1 minting and reserves, but it is natively yield-bearing and backed by tokenized T-bills/MMFs; the GENIUS Act's payment stablecoin definition may exclude yield-bearing/rebasing instruments, leaving applicability genuinely unresolved.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for FUSD or FinChain Bermuda Limited. Issuer holds a BMA digital asset business license only.

FUSD is stablecoin-adjacent, but yield-bearing reserve-token mechanics make GENIUS payment-stablecoin applicability unresolved. Issuer is FinChain Bermuda Limited (a separate accounts company / SAC), a wholly owned subsidiary of FinChain Holdings (Cayman) Limited, itself backed by Fosun Wealth Holdings. BMA digital asset business license confirmed. No US authorization pathway initiated as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

GUSD is a U.S. dollar payment stablecoin issued by Gemini Trust Company with 1:1 redemption and reserve attestations.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, official application, or foreign exception source was located for GUSD. Gemini disclosures focus on NYDFS standing and reserve reporting; no formal GENIUS pathway announcement found as of 2026-06-13.

GUSD is NYDFS-approved/greenlisted as a New York virtual currency stablecoin, but no GENIUS PPSI approval, state-qualified GENIUS approval, official application, or issuer-announced GENIUS pathway was found.

Reviewed 2026-06-18 by Pharos compliance research

HKD-HSBC is a pre-launch HKD fiat-referenced stablecoin licensed by HKMA and planned for 1:1 HKD redemption.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, OCC foreign-issuer registration, or Treasury comparability determination was located for HKD-HSBC or HSBC Hong Kong.

HSBC holds an HKMA stablecoin issuer licence for a planned HKD stablecoin, but no U.S. GENIUS PPSI approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was found.

Reviewed 2026-06-18 by Pharos compliance research

HKDAP is a pre-launch HKD fiat-referenced stablecoin licensed by HKMA and planned for 1:1 HKD redemption.

No token-specific U.S. GENIUS approval, official application, state-qualified approval, OCC foreign-issuer registration, or Treasury comparability determination was located for HKDAP or Anchorpoint Financial Limited.

Anchorpoint holds an HKMA stablecoin issuer licence for HKDAP, but no U.S. GENIUS PPSI approval, official application, OCC foreign-issuer registration, or Treasury comparability determination was found.

Reviewed 2026-06-18 by Pharos compliance research

Honey is a Berachain-native asset with stablecoin-like use and reserve-backed mechanics, but current public materials do not establish an issuer obligation that clearly resolves GENIUS payment-stablecoin applicability.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or announced intent was located for HONEY or the Berachain Foundation. The issuer is a Cayman Islands foundation with no publicly disclosed U.S. regulatory pathway under the GENIUS Act.

GENIUS applicability remains unclear because Honey is protocol-native and reserve-backed, but the public source set does not clearly establish an issuer-redeemable payment stablecoin obligation.

Reviewed 2026-06-18 by Pharos compliance research

JupUSD is a USD-pegged reserve-backed token issued on Solana for payment/settlement use within Jupiter's DeFi ecosystem; it presents as a payment stablecoin under GENIUS Act definitions. Jupiter's Terms of Service restrict US-based users, but this is an access restriction, not a legal carve-out from GENIUS applicability.

No GENIUS approval, application, or issuer pathway for JupUSD or its issuer (Jupiter) found across federal/state regulator sources and issuer disclosures. USDtb's Anchorage/GENIUS pathway applies to the reserve asset issuer (Anchorage Digital Bank N.A.), not JupUSD itself.

JupUSD's primary reserve asset (USDtb) is now issued in the US by Anchorage Digital Bank N.A. under a GENIUS-compliant framework (announced July 24, 2025; Anchorage is the USDtb issuer, not JupUSD's issuer). JupUSD itself has no GENIUS authorization — it is a separate token issued by Jupiter on Solana with no disclosed US legal entity or regulatory registration. Jupiter restricts US users in its ToS but no formal foreign-exception determination has been made. No public GENIUS approval, application, or issuer pathway source for JupUSD itself was located.

Reviewed 2026-06-18 by Pharos compliance research

M is M0's core dollar token minted and burned by permissioned minters against eligible off-chain collateral verified by validators.

No PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for M0 Foundation or the M token. M0 Foundation is Swiss-domiciled and acts as a protocol/governance layer, not as a US-formed PPSI. Permissioned Minters (Anchorage, Bridge, etc.) are the actual token issuers and may seek individual GENIUS Act authorization, but no such public filing was found as of 2026-06-18.

M0 Foundation is a Swiss-domiciled protocol layer and governance entity — not itself a US-formed PPSI candidate. Actual M token minting is performed by separately permissioned Minter entities (MXON, Anchorage Digital, Bridge/Stripe, MoonPay, etc.), which may individually seek GENIUS Act status. No PPSI application, state-qualified approval, or foreign-issuer exception has been publicly announced for M0 Foundation or the base M token. Rulemaking remains at NPRM stage as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

MNEE is a USD-backed stablecoin issued by MNEE Limited with contractual mint and redemption rights for verified customers.

No U.S. GENIUS Act PPSI approval, state-qualified status, official application, or FPSI registration found for MNEE Limited. The FPSI registration framework is still under proposed rulemaking. Antiguan FSRC licensing provides no U.S. GENIUS status.

MNEE Limited is an Antigua-incorporated issuer holding an FSRC Class A Digital Asset Business License. The GENIUS Act was enacted July 18, 2025 but is not yet effective (effective date: January 18, 2027 at the latest, or 120 days after final rules). MNEE holds no U.S. PPSI approval, state-qualified status, or public foreign-issuer registration. The foreign payment stablecoin issuer (FPSI) registration pathway (OCC) is still being defined through NPRMs with comment periods through mid-2026; no FPSI registration is yet possible. No issuer announcement of a formal GENIUS Act compliance filing was found — a third-party Medium article describes a possible compliance strategy but is not an issuer disclosure.

Reviewed 2026-06-18 by Pharos compliance research

MOVEUSD is a CFX-issued dollar token for payment and settlement flows, redeemable through designated channels for approved customers.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, or official application source was located for MOVEUSD. CFX's 'GENIUS-ready' marketing claim describes architectural alignment, not a regulatory pathway.

MOVEUSD public materials describe CFX issuance and designated redemption channels, but Pharos found no public GENIUS issuer intent, PPSI approval, state-qualified approval, or official application source. CFX's July 30 2025 press release describes MOVEUSD as 'GENIUS-ready' (first on Ethereum and Base), framing this as architectural alignment with reserve and redemption requirements — this is marketing language, not a formal PPSI pathway announcement, and does not meet the bar for issuer-announced-intent. The original reserveDisclosureUrl (docs.moveusd.com/docs/disclosures-disclaimers) now redirects to docs.cfx.to with no dedicated reserve disclosure page found; reserveDisclosurePresent updated to false accordingly.

Reviewed 2026-06-18 by Pharos compliance research

Brale operates as a FinCEN-registered MSB and state money transmitter; no PPSI application, state-qualified approval, or official GENIUS authorization source was found for Brale or MXNe specifically as of 2026-06-18.

MXNe is a Brale-issued peso stablecoin with U.S. money-transmitter context, but no GENIUS permitted-issuer approval or official application was located. Brale operates as a FinCEN-registered MSB and licensed money transmitter (NMLS #2376957). The June 2026 Visa/Brale SBC proof-of-concept on Canton Network does not change MXNe's GENIUS status. Brale has not announced a PPSI pathway election (state-qualified vs. federal nonbank) as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

pUSD is a non-interest-bearing USDC wrapper with payment-like use on Plume Chain. The legal issuer is Nest, a Marshall Islands DAO LLC, and the token explicitly restricts U.S. persons from minting. Whether secondary-market access or the payment use case brings it within GENIUS Act scope remains unresolved in proposed rulemaking.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for pUSD. Issuer (Nest, Marshall Islands DAO LLC) explicitly restricts U.S. persons and has made no public GENIUS authorization filing.

pUSD is issued by Nest (Marshall Islands DAO LLC, LEI 254900BB9T1QYAT04892), not Plume directly. Plume manages the underlying BoringVault infrastructure. The token explicitly excludes U.S. persons from minting per Nest/Plume product documentation and RWA.xyz eligibility listing (Non-U.S. Investors only). No GENIUS authorization has been sought. Applicability remains unclear because secondary-market exposure to U.S. persons is possible and the GENIUS Act's foreign-issuer scope is still being defined in NPRMs.

Reviewed 2026-06-18 by Pharos compliance research

rUSD is a USD-pegged, 1:1 mintable/redeemable stablecoin that structurally meets the GENIUS Act definition of a payment stablecoin. However, the issuer explicitly excludes US persons from the protocol and interface via its Terms of Service, and the ToS is governed by Cayman Islands law, indicating the issuer has not sought any US regulatory pathway.

Reservoir's ToS explicitly bars US persons from rUSD; Cayman Islands governing law and absence of any named US legal entity confirm the issuer has not engaged with GENIUS Act compliance. No PPSI approval, state-qualified approval, official application, or foreign exception registration was found.

The Reservoir Terms of Service explicitly state that rUSD is not offered to US persons and that US persons are not permitted to use the Interface or Protocol. The ToS is governed by Cayman Islands law. No named legal issuer entity is disclosed; the protocol is operated by Reservoir Protocol, incubated by Fortunafi. No GENIUS Act pathway, PPSI application, or foreign exception engagement was identified.

Reviewed 2026-06-18 by Pharos compliance research

RUSD is described as a USD-referenced stable-value token for settlement and treasury use with authorized-participant issuance and redemption.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for RUSD. The foreign-issuer exception registration framework remains in proposed rulemaking with no exceptions granted to any issuer as of 2026-06-18.

RUSD has issuer-style stablecoin disclosures, but no public GENIUS approval or foreign-issuer exception source was found. RIB Group Holdings Ltd / RIB Digital operates from Hong Kong/UK; no OCC, FDIC, Federal Reserve, or state regulatory filing identified. The foreign-issuer exception framework itself remains in proposed-rules phase as of 2026-06-18 with no registered exceptions granted to any issuer.

Reviewed 2026-06-18 by Pharos compliance research

SBC is a Brale-issued U.S. dollar payment stablecoin with 1:1 redemption and monthly attestations.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, or official application source was located for SBC as of 2026-06-18. Brale continues to operate under existing FinCEN MSB and state money transmitter licenses with no announced GENIUS pathway.

Reviewed 2026-06-18 by Pharos compliance research

SOFID is a U.S. dollar payment stablecoin issued by SoFi Bank, N.A. with 1:1 mint and redemption.

No token-specific public GENIUS PPSI approval, state-qualified approval, or official application source was located for SOFID as of 2026-06-18. GENIUS Act is law (enacted July 2025) but implementing regulations remain in proposed-rules phase; no PPSI applications have been accepted yet. SoFi Bank N.A. is an OCC-supervised IDI and under GENIUS would issue via a subsidiary; no such subsidiary PPSI application was found.

Reviewed 2026-06-18 by Pharos compliance research

sUSD is explicitly designed as a yield-bearing stablecoin that passes T-bill interest to holders via Solana Token-2022 interest extension. The GENIUS Act Section 4(a)(11) prohibits permitted payment stablecoin issuers from paying any form of interest or yield to holders solely in connection with holding the stablecoin. Whether sUSD qualifies as a 'payment stablecoin' subject to this prohibition (and therefore potentially non-compliant as currently structured) or falls outside the payment-stablecoin definition as a yield-bearing investment instrument remains unresolved pending final GENIUS Act implementing regulations. No official guidance has classified yield-bearing RWA-backed stablecoins. Applicability is genuinely unclear.

No GENIUS authorization, official PPSI application, state-qualified status, or foreign-registration has been located for Solayer Labs, Inc. or sUSD. The GENIUS Act framework remains in proposed-rules phase; no PPSI approvals have been granted to any issuer as of 2026-06-18.

Solayer Labs, Inc. is a US-incorporated company headquartered in San Francisco (CA corp, doc #6557004). sUSD is a yield-bearing stablecoin backed by US Treasury bills via a partnership with OpenEden (Moody's-rated RWA platform). The yield is passed to holders through Solana Token-2022 interest extension mechanics — a design that sits in regulatory tension with the GENIUS Act's yield prohibition on payment stablecoin issuers. No GENIUS authorization, application, or registration found. No enforcement action found. The applicability question (payment stablecoin vs. excluded yield instrument) will only be resolved once final GENIUS implementing regulations are issued.

Reviewed 2026-06-18 by Pharos compliance research

TUSD is a U.S. dollar-pegged stablecoin with issuer-managed redemption and daily reserve attestations.

No token-specific public U.S. GENIUS approval, official application, state-qualified approval, or foreign-issuer registration source was located for TUSD/Techteryx. SEC action against prior operators TrueCoin/TrustToken (settled Sep 2024) supports a warning/notice posture for TUSD reserve representations but does not constitute a Techteryx prohibited/revoked action. No FinCEN or OFAC action against Techteryx found.

Techteryx (current TUSD issuer, BVI-incorporated) has no confirmed U.S. GENIUS approval, application, or foreign-issuer exception. The SEC settled charges in September 2024 against prior TUSD operators TrueCoin LLC and TrustToken Inc. for false reserve representations through April 2023; Techteryx was not named, so this is tracked as a warning/notice posture rather than a prohibited/revoked current-issuer action. Ongoing civil litigation in Hong Kong and Dubai (worldwide asset freeze of $456M tied to First Digital Trust/Aria Commodities reserve dispute) does not constitute a U.S. enforcement action against Techteryx. TUSD delisted from EEA-regulated venues by Q1 2025 (Kraken, Binance) and several Binance spot pairs delisted April 2026.

Reviewed 2026-06-18 by Pharos compliance research

United Stables' own site carries an explicit disclosure that $U has not obtained registration, authorization, or licensing under the GENIUS Act of 2025; no public GENIUS approval, application, or foreign registration source was located on re-verification 2026-06-18.

United Stables states $U has not obtained registration, authorization, or licensing under the GENIUS Act.

Reviewed 2026-06-18 by Pharos compliance research

USD0 is a 1:1 USD-pegged, RWA-backed token redeemable on-chain — token-level characteristics fit "payment stablecoin" under the GENIUS Act. However, the issuer is Usual DAO, a France-domiciled decentralized autonomous organization with no US legal entity. Whether and how the GENIUS Act's issuer-level obligations reach a DAO issuer domiciled in France is genuinely unclear, especially while foreign-issuer comparability rules remain in proposed-rulemaking phase.

USD0 is DAO-issued and redeemable against RWA collateral; re-verification confirms no public GENIUS authorization, state-qualified approval, official application, or foreign registration source was located as of 2026-06-18.

USD0 is DAO-issued (Usual DAO holds 100% protocol asset ownership per UIP-15, Dec 2025) with Usual Labs SAS (France) acting as service provider, not issuer. No public GENIUS authorization, state-qualified approval, official application, or foreign-exception registration was located. Applicability marked unclear because GENIUS Act issuer-level obligations on a France-domiciled DAO with no US legal entity remain unresolved while foreign-issuer comparability rulemaking is still at NPRM stage.

Reviewed 2026-06-18 by Pharos compliance research

USDA is an Anzens-issued U.S. dollar stablecoin designed for mint, burn, send, receive, and off-ramp payment flows.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, or official application source was located for USDA/Anzens Inc. Re-verified June 2026 with no change in status.

Anzens describes USDA as 100% backed and issued by Anzens Inc. (FinCEN MSB, 17 state no-objection letters), with reserves held at BitGo Trust. Pharos found no GENIUS PPSI approval, state-qualified approval, official application, or public intent statement. A LinkedIn post from EMURGO (2026) references a first proof-of-reserves examination report, but no dedicated reserve attestation or transparency URL is published on anzens.com or findable from public sources; reserveDisclosurePresent corrected to false. USDA relaunched under Encryptus partnership after a 2023 pause.

Reviewed 2026-06-18 by Pharos compliance research

No public GENIUS approval, official application, or foreign registration source was located for USDai; USD.AI Foundation confirmed as Cayman Islands DAO steward with no U.S. regulatory presence.

USD.AI publishes reserve data through its Proof of Reserves documentation and M0/Usual/Gauntlet vault disclosures, but no U.S. federal GENIUS issuer approval exists. Treat as prospective-pathway-only until a permitted payment stablecoin issuer is identified.

Reviewed 2026-06-18 by Pharos compliance research

No public GENIUS approval, state-qualified approval, official application, foreign-exception registration, or issuer-announced intent was located for USDaT. Saturn is BVI-domiciled and geofences US persons; no GENIUS pathway disclosure found in issuer materials.

Saturn documents USDaT reserve and redemption mechanics, but no public GENIUS issuer approval or registration was located. USDat is explicitly geofenced away from US and EEA users per protocol design; Saturn is BVI-domiciled with no known US regulatory registration.

Reviewed 2026-06-18 by Pharos compliance research

No token-specific U.S. GENIUS PPSI approval, state-qualified approval, official application, foreign-exception determination, or comparability finding was located for USDCV or SG-FORGE. SG-FORGE actively restricts US persons and has not announced intent to seek US market access under GENIUS. The foreign-exception framework itself remains in proposed-rulemaking.

MiCA authorization and SG-FORGE reserve/redemption disclosures do not establish a public U.S. GENIUS permitted-issuer approval or registered foreign-issuer exception. SG-FORGE actively restricts US persons from holding USDCV (Regulation S offshore-transaction carve-out only). The GENIUS Act foreign-issuer exception requires a Treasury MiCA-comparability determination plus OCC registration — a pathway still in proposed-rulemaking as of 2026-06-18 with no determination issued. No public indication SG-FORGE has initiated or intends to initiate that process.

Reviewed 2026-06-18 by Pharos compliance research

USDD is presented as the TRON DAO Reserve's dollar-pegged stablecoin for payments, with over-collateralized reserves and PSM swap/redemption mechanics.

No GENIUS PPSI approval, official application, state-qualified approval, or registered/comparability-determined foreign-issuer exception was found for USDD or its issuer TRON DAO Reserve. No Treasury determination of comparable foreign regulation has been made for any jurisdiction as of this review date. The GENIUS Act approval framework itself remains in proposed-rulemaking phase.

USDD has self-reported reserve and PSM/redemption disclosures (usdd.io/data), but no formal third-party attestation. No GENIUS PPSI approval, application, or comparability determination for a foreign issuer exception was found. TRON DAO Reserve is Dominica-domiciled; Treasury has not yet finalized criteria for "comparable foreign regulation" under GENIUS. The April 2026 OFAC-coordinated Tether USDT freeze on TRON wallets and May 2026 UK sanctions on HTX are not GENIUS Act enforcement actions against USDD or its issuer.

Reviewed 2026-06-18 by Pharos compliance research

USDe is a synthetic delta-neutral dollar with a nominal $1 redemption obligation but backed by crypto derivatives positions and liquid stablecoins rather than HQLA (cash, Fed balances, short-term Treasuries). The GENIUS Act requires payment stablecoins to maintain 1:1 HQLA reserves; USDe's synthetic mechanism likely disqualifies it from qualifying as a PPSI even if it nominally meets the definitional element of a fixed-value redemption obligation. The Act mandates a separate regulatory study on non-payment stablecoins, suggesting synthetic dollars occupy an unresolved category. Applicability is marked unclear pending that study and final rulemaking.

No token-specific U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception was located for USDe. Ethena's GENIUS-compliant activity is limited to USDtb (a separate product issued via Pallas BVI Ltd / Anchorage Digital Bank). No enforcement actions found. GENIUS Act not yet effective.

USDe is a synthetic dollar rather than a fiat reserve stablecoin; GENIUS payment-stablecoin applicability is unresolved pending final rulemaking and the mandated non-payment stablecoin study. Ethena is separately pursuing GENIUS-compliant issuance via USDtb (partnered with Anchorage Digital Bank) — that is a distinct product issued by a separate entity (Pallas BVI Ltd / Anchorage Digital Bank). No GENIUS Act enforcement actions exist and the Act is not yet effective (effective date: 2027-01-18 at latest).

Reviewed 2026-06-18 by Pharos compliance research

Coinbase holds NYDFS BitLicense, NYDFS limited-purpose trust charter, and OCC conditional national trust charter (custody), but none of these constitute GENIUS Act PPSI approval. No PPSI approval, state-qualified approval, or official PPSI application has been publicly filed for any issuer; the GENIUS Act framework is still at NPRM stage as of 2026-06-18.

USDF is a Coinbase Custom Stablecoin backed 1:1 by USDC; Coinbase is the functional issuer per its User Agreement and manages issuance, reserves, and smart contract deployment. Flipcash holds the branded identity. No token-specific GENIUS PPSI approval or state-qualified approval has been located. Coinbase received conditional OCC approval for a national trust charter (Coinbase National Trust Company) on April 2, 2026 — this is a custody/trust charter, not a PPSI approval under the GENIUS Act, and does not alter the authorization status here. GENIUS Act rulemaking remains at NPRM stage as of 2026-06-18; no PPSI approvals exist for any issuer.

Reviewed 2026-06-18 by Pharos compliance research

USDG is a MAS-regulated U.S. dollar stablecoin with 1:1 redemption through Paxos Digital Singapore and monthly reserve attestations.

MAS and MiCA issuer evidence was found; OCC trust charter for Paxos Trust confirmed but USDG is not covered by it; no token-specific public U.S. GENIUS PPSI approval, official application, or foreign-issuer registration was located for USDG.

USDG's primary issuing entity is Paxos Digital Singapore (MAS-regulated), with EU issuance by Paxos Issuance Europe Oy (FIN-FSA/MiCA). The GENIUS Act was enacted July 18, 2025, but its PPSI licensing framework remains in proposed-rulemaking phase as of June 2026 with no PPSI approvals granted to any issuer. On December 12, 2025 the OCC conditionally approved Paxos Trust Company, N.A. for a national trust bank charter conversion (from NYDFS); however Paxos confirmed USDG is issued by Paxos Digital Singapore, not Paxos Trust Company, so this OCC charter does not constitute a PPSI authorization for USDG. No public GENIUS Act application, foreign-issuer registration, or comparable-jurisdiction determination has been found for USDG.

Reviewed 2026-06-18 by Pharos compliance research

USDGLO is a Brale-issued U.S. dollar payment stablecoin with 1:1 redemption and monthly attestations.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, or official application source was located for USDGLO. Brale operates as a FinCEN-registered MSB with state money-transmitter licenses; no OCC charter application or PPSI announcement found as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

USDK is KAST's branded USD-pegged payment token for consumer payments and savings, built on M0 programmable stablecoin infrastructure on Solana.

No PPSI approval, state-qualified approval, official application, or registered foreign-issuer exception under the GENIUS Act has been publicly filed or granted for USDK or its issuer KAST Tech. The KAST founder's September 2025 statement of intent to partner with a US-compliant issuer has not translated into any publicly visible application or structural change as of June 2026. No US federal or state regulator has published any filing, acknowledgment, or action regarding KAST or USDK.

KAST Tech is incorporated in Anjouan, Comoros (Reg No. 16223) and explicitly states it is not a bank; licensed services are provided by third-party partners (BitGo, Fireblocks, Tazapay). In September 2025, KAST's founder stated an aspiration to 'upgrade USDK to be issued in the US by an issuer that meets the Genius standard' and referenced ongoing discussions with major issuers — but this remains an informal forward-looking intent, not a formal application. As of 2026-06-18, no PPSI approval or foreign-issuer exception has been filed or granted for USDK under the GENIUS Act. The GENIUS Act rulemaking remains in proposed-rules phase with no final rules issued and no issuer having received a PPSI approval.

Reviewed 2026-06-18 by Pharos compliance research

USDKG is a USD-pegged, issuer-redeemable stablecoin backed by physical LBMA gold under Kyrgyz Republic oversight; it circulates on Ethereum and TRON and is available to retail and institutional investors globally.

No token-specific U.S. GENIUS PPSI approval, state-qualified approval, official application, registered foreign-issuer exception, or enforcement action was located for USDKG, Gold Dollar, or OJSC Virtual Asset Issuer. The issuer operates entirely under Kyrgyz Republic licensing with no known U.S. regulatory presence.

USDKG is commodity-backed (physical LBMA gold) but USD-referenced and issuer-redeemable; the gold backing raises a question whether it qualifies as a payment stablecoin under GENIUS (which targets fiat-referenced instruments), but no definitive exclusion exists and the USD peg makes apparent-payment-stablecoin the more conservative classification. No public GENIUS approval, PPSI application, or foreign-issuer exception was found. The issuer is a Kyrgyz state-owned entity (OJSC Virtual Asset Issuer) with no known U.S. regulatory presence. Listed on Hong Kong's OSL HK exchange (May 2026) — no U.S. regulatory event. No OFAC, FinCEN, or enforcement action found.

Reviewed 2026-06-18 by Pharos compliance research

USDm is a USD-pegged reserve-backed stablecoin designed for payments and cross-border transfers, meeting the GENIUS Act's functional definition of a payment stablecoin. The issuing entity (Mento Labs GmbH) is a German GmbH domiciled in Berlin with no identified US operations, subsidiary, or regulatory presence. The protocol is governed by Mento DAO (MENTO token holders) with a 4/7 multisig Safe as the Celo token owner. Market focus is Africa and emerging markets (MiniPay in Nigeria, Kenya, Ghana). Market cap ~$14M as of June 2026.

No foreign-issuer registration or comparability determination has been sought by Mento Labs GmbH. The issuer has made no public statements about pursuing GENIUS Act compliance or OCC foreign-issuer registration. GENIUS foreign-issuer rules remain in proposed-rules phase as of June 2026.

Searched Federal Register, OCC bulletins (2026-3), FinCEN, and Treasury rulemaking trackers — no mention of Mento Labs or USDm in any GENIUS Act context. Mento Labs GmbH is a German entity with no US subsidiary, no OCC filing, no GENIUS Act compliance announcement. Protocol is DAO-governed; market cap approximately $14M; primary user base is Africa and emerging markets via MiniPay. No geo-restriction on US access but no US-targeted regulatory posture.

The shortlisting rationale cited a named US-nexus issuer (Mento Labs) but this is factually incorrect — Mento Labs GmbH is domiciled in Berlin, Germany. USDm meets the functional definition of a payment stablecoin (USD-peg, reserve-backed, designed for payments) but the issuer is a foreign entity with no US regulatory engagement. The GENIUS Act foreign-issuer pathway could theoretically apply when the framework is effective, but no steps toward compliance have been taken. Conservative status: no-public-authorization-found. Note: top-level reviewer and reviewedAt added to satisfy schema required fields.

Reviewed 2026-06-18 by Pharos compliance research

MegaUSD (BVI) Ltd is incorporated in the British Virgin Islands; US users are explicitly excluded from Mint services. No US PPSI application, state qualification, OCC conditional approval, or foreign-exception filing was found for MegaUSD or its BVI issuer entity. The USDtb 'GENIUS line of sight' claim belongs to Anchorage Digital Bank (USDtb issuer), not to MegaUSD (BVI) Ltd.

Issuer is MegaUSD (BVI) Ltd, incorporated in the British Virgin Islands (confirmed via Terms of Service and Mint User Agreement at app.megausd.money). U.S. users are explicitly excluded from USDm Mint services. The coin's marketing references USDtb's 'line of sight to GENIUS Act compliance' via Anchorage Digital Bank, but this applies to USDtb (the underlying asset), not to MegaUSD (BVI) Ltd itself. No US bank charter, money-transmission license, PPSI application, or foreign-exception filing was found. GENIUS Act rulemaking remains at proposed-rules stage; no PPSI approvals exist anywhere as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

Moneta Digital LLC is a FinCEN-registered MSB (#31000327040139) and NBX holds a Norwegian EMI license; no token-specific U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception was found for USDM. No PPSI approvals have been granted to any issuer as of Jun 2026.

USDM has dual U.S./EEA issuer structure: Moneta Digital LLC (FinCEN MSB) for USA issuance, NBX (Finanstilsynet EMI) for EEA issuance. Norway enacted MiCA via kryptoeiendelsloven effective 1 Jul 2025; NBX whitepaper filed Sep 2024. ESMA EMTWP.csv re-checked Jun 2026: no NBX/USDM row present. GENIUS pathway remains unresolved; no PPSI approval exists for any issuer under the still-pending Act.

Reviewed 2026-06-18 by Pharos compliance research

USDon is issued by a BVI SPV under Regulation S for non-U.S. investors only; no GENIUS Act authorization, PPSI application, or foreign exception status found in any public regulatory record or issuer disclosure as of 2026-06-18.

USDon is issued by a BVI-incorporated SPV (Ondo Global Markets (BVI) Limited) under Regulation S, explicitly restricted to non-U.S. investors. It functions as the internal settlement stablecoin for Ondo Global Markets tokenized-stock platform. The GENIUS Act addresses foreign payment stablecoin issuers (FPSIs) accessing U.S. markets separately from domestic PPSIs; because USDon is structurally excluded from U.S.-person access, the payment-stablecoin classification and any FPSI pathway remain genuinely unresolved pending final FPSI rulemaking.

Reviewed 2026-06-18 by Pharos compliance research

DNB/MiCA issuer evidence and Quantoz reserve/redemption disclosures were found, but no token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for USDQ. The GENIUS Act foreign exception framework rules remain in proposed-rules phase as of 2026-06-18.

USDQ is a Dutch MiCA EMT, but no public GENIUS foreign-issuer registration or U.S. permitted-issuer status was located. The GENIUS Act foreign-exception framework remains in proposed-rules phase as of 2026-06-18; no foreign exception registry or comparability determination has been established.

Reviewed 2026-06-18 by Pharos compliance research

Sky documents protocol conversion routes but no legal PPSI issuer entity has emerged; Sky Frontier Foundation explicitly disclaims issuing or managing USDS. No GENIUS authorization, state-qualified approval, official application, or foreign exception status was located for USDS as of 2026-06-18.

Sky documents protocol conversion routes rather than a legal PPSI issuer or direct fiat redemption path. Sky Frontier Foundation explicitly disclaims issuing, custodying, redeeming, or managing reserves for USDS. No PPSI application, state-qualified pathway, or foreign-exception status has been announced as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

Startale and M0 issuer materials were found, but no token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for USDSC. Startale Group remains Singapore-domiciled with no announced U.S. regulatory authorization intent.

USDSC is a Soneium-native M0 extension; M0 infrastructure disclosures do not establish a Startale-specific GENIUS authorization or foreign-issuer exception.

Reviewed 2026-06-18 by Pharos compliance research

USDX is described as a 1:1 USD-referencing token backed by Treasuries and cash equivalents with approved-party redemption.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, registered or comparable foreign-issuer exception, or issuer-announced intent was located for USDX or Hex Trust Digital Assets across OCC bulletins, Federal Register, issuer websites, and web search as of 2026-06-18. GENIUS rulemaking remains at NPRM stage; no approvals exist for any issuer.

USDX has reserve and redemption disclosures, but no public GENIUS approval or foreign-issuer exception source was found. The htdigitalassets.com homepage references regular attestation reports but no dedicated disclosure URL is publicly linked. No GENIUS Act pathway intent announced by Hex Trust as of 2026-06-18.

Reviewed 2026-06-18 by Pharos compliance research

USDz is a private-credit-backed RWA dollar with permissioned QMM mint/redeem mechanics; Anzen Group Ltd explicitly blocks US persons (prohibited jurisdiction in ToS) and holds no regulatory authorization in any jurisdiction, making GENIUS payment-stablecoin applicability unresolved.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for USDz. Anzen Group Ltd's own ToS states it holds no regulatory registration anywhere.

USDz is stablecoin-adjacent but backed by private credit; GENIUS payment-stablecoin applicability is unresolved. The ToS explicitly excludes US persons and states Anzen Group Ltd is not registered with any regulatory body in any jurisdiction. No GENIUS PPSI approval, state-qualified approval, application, or foreign-issuer exception evidence found.

Reviewed 2026-06-18 by Pharos compliance research

No public GENIUS PPSI approval, state-qualified approval, official application, or foreign registration source was located for USN. Issuer is BVI-domiciled with no detected US regulatory footprint. GENIUS Act rulemaking remains at proposed-rules stage with no approved applicants as of 2026-06-18.

Noon documents USN minting, redemption, and reserve transparency, but no GENIUS issuer pathway was located. Issuer confirmed domiciled in Road Town, British Virgin Islands per May 2025 launch press release. No evidence of US regulatory filing, PPSI application, state-qualified pathway, or foreign-exception registration.

Reviewed 2026-06-18 by Pharos compliance research

WSPN issuer, reserve, redemption, and terms materials were reviewed; no token-specific public U.S. GENIUS approval, official application, or registered/comparable foreign-issuer exception source was located for WUSD. The foreign-exception comparability framework remains in proposed rulemaking.

WSPN is a BVI-domiciled entity with a stated FinCEN MSB registration and pending BVI VASP application. WUSD terms restrict U.S. persons. The GENIUS Act foreign-exception comparability framework remains in proposed-rulemaking (Treasury FR 2026-06489; comment deadline June 2, 2026) — no foreign registration can yet be granted. No PPSI approval or US authorization of any kind found.

Reviewed 2026-06-18 by Pharos compliance research

XMD is a U.S.-linked stablecoin index redeemable against a basket of reserve-backed dollar stablecoins rather than a standalone fiat-reserve issuance.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for XMD. Metallicus shows GENIUS awareness but no public authorization posture.

XMD is stablecoin-adjacent and payment-oriented, but its basket-index structure makes GENIUS payment-stablecoin applicability unresolved. Metallicus published educational GENIUS Act content (metaldollar.com, Mar 2026) and operates a credit-union stablecoin sandbox pilot, but no token-specific PPSI approval, state-qualified approval, or official application was found. No GENIUS enforcement action found. Quarterly company reports exist but no monthly reserve attestation.

Reviewed 2026-06-18 by Pharos compliance research

XO is a MoonPay-issued U.S. dollar payment token using M0 infrastructure with wallet-based consumer distribution.

No public GENIUS issuer intent, token-specific PPSI approval, state-qualified approval, or official PPSI application source was located for XO Cash; no state has yet been certified as substantially similar under GENIUS as of 2026-06-18.

MoonPay holds an NYDFS Limited Purpose Trust Company (LPTC) charter (MoonPay Trust Company, LLC, authorized Nov 2025), BitLicense, and money transmitter licenses across 49 states. The NYDFS LPTC is the state regulatory pathway most aligned with the GENIUS Act state-qualified issuer track. No PPSI approval has been granted to any issuer as of 2026-06-18; the state-qualified certification framework is still in proposed rulemaking (Treasury NPRM, Apr 2026). issuerPathway reflects the anticipated regulatory track, not an active approval.

Reviewed 2026-06-18 by Pharos compliance research

XSGD is a MAS-regulated SGD payment stablecoin with Coinbase/Base distribution and public reserve/redemption disclosures.

No token-specific public U.S. GENIUS PPSI approval, state-qualified approval, official application, or registered/comparable foreign-issuer exception source was located for XSGD. Treasury's comparable-regime determination process for Singapore MAS remains open rulemaking with no published determinations as of 2026-06-18.

XSGD is a foreign non-USD payment stablecoin with U.S. availability signals, but no public GENIUS approval or foreign-issuer exception source was found. Treasury has not yet published any comparable-regime list or Singapore MAS determination; the foreign-exception pathway remains open rulemaking as of 2026-06-18. Monthly reserve attestation reports are published by StraitsX (ISCA-listed auditor KK Yap & Associates, 2022–2026 monthly archive on straitsx.com).

Reviewed 2026-06-18 by Pharos compliance research

XUSD is a U.S. dollar stablecoin issued by StraitsX with 1:1 USD redemption and monthly reserve attestations.

MAS licensing and XUSD reserve disclosures confirmed, but no token-specific U.S. GENIUS approval, OCC foreign-issuer registration, or FPSI application was found for StraitsX or XUSD across OCC bulletins, Federal Register NPRMs, and StraitsX's own public disclosures.

StraitsX MAS licensing and XUSD reserve attestations do not establish a U.S. GENIUS permitted-issuer approval or foreign-issuer exception. Under the GENIUS Act, StraitsX would need to register with the OCC as a foreign payment stablecoin issuer (FPSI) to offer XUSD to U.S. persons. No such application has been filed or announced as of 2026-06-18. StraitsX's own blog positions XUSD as B2B/Asia-focused; no US-market authorisation is claimed.

Reviewed 2026-06-07 by Pharos compliance research

BENJI is treated as outside GENIUS payment-stablecoin tracking because it represents shares of a registered money market fund rather than a payment stablecoin.

Reviewed 2026-06-18 by Pharos compliance research

bIB01 is a tracker certificate (a security) referencing the BlackRock iShares $ Treasury Bond 0-1yr UCITS ETF, issued by Backed Assets (JE) Limited (Jersey). GENIUS Act §2(22)(B) (12 U.S.C. §5901(22)(B)) excludes from the payment-stablecoin definition any asset that meets the definition of a security under federal securities laws. Additionally, Backed does not offer or sell to US persons.

bIB01 is outside GENIUS payment-stablecoin scope: (1) it is a tracker certificate/security referencing an ETF, not a payment instrument designed for a fixed amount of monetary value (GENIUS Act §2(22)(B) excludes securities from the definition), and (2) Backed Assets (JE) Limited does not offer or sell to US persons. Issuer domicile is Jersey (Channel Islands); the Swiss DLT Act provides the structural framework for token issuance but does not change the Jersey corporate domicile.

Reviewed 2026-06-07 by Pharos compliance research

BUIDL is treated here as outside GENIUS payment-stablecoin tracking because it is a tokenized fund rather than a payment stablecoin.

Reviewed 2026-06-07 by Pharos compliance research

Gate USD (GUSD) is explicitly characterized by Gate as an investment certificate with an appreciation attribute backed by U.S. Treasury RWA assets, not as a payment stablecoin. Users mint GUSD 1:1 with USDT/USDC and receive principal plus accrued interest upon redemption — a return-above-par design inconsistent with GENIUS Act payment stablecoin definition (redeemable at par, designed as medium of payment/settlement). Gate.io also lists the United States as a Restricted Location in its Terms of Service, further removing this token from GENIUS Act payment-stablecoin reach. The issuing entity operates from the Cayman Islands.

Gate explicitly brands GUSD as an investment certificate with an appreciation attribute, not a medium of exchange. Upon redemption users receive principal plus compounded interest — a return-above-par mechanism incompatible with the GENIUS Act payment stablecoin definition (par redemption, payment/settlement function). Gate.io lists the US as a Restricted Location. No GENIUS Act pathway assessed.