Stablecoins & Payments
Stablecoin and payments counsel.
Legal counsel for companies issuing, integrating or building on stablecoins and digital-asset payment rails, from product design through licensing and launch.
What We Do
From product design to launch.
- Issuer pathway analysis — whether and how a project fits the GENIUS Act’s permitted-issuer routes: bank subsidiaries, federal qualified issuers, and state-qualified issuers under the $10 billion threshold.
- Distribution and integration — the legal questions for exchanges, wallets and fintechs that offer or settle in stablecoins for U.S. customers.
- Money transmission and licensing — FinCEN money services business registration and state money-transmitter licensing, including New York’s BitLicense.
- Reserves, disclosures and redemption — reviewing user terms and public disclosures against the requirements that apply to the product.
- AML and sanctions — Bank Secrecy Act and OFAC sanctions compliance frameworks for payment flows.
- High-risk merchants — which cannabis and other restricted businesses a stablecoin or payment provider can serve, and on what evidence. See our guide to stablecoins and cannabis after rescheduling.
- Partner agreements — contracts with banks, custodians, processors and payment partners.
The Landscape
A new federal framework.
The GENIUS Act, enacted July 18, 2025, created the first federal framework for payment stablecoins. Its implementing rules are still being written.
- Who may issue — issuance of payment stablecoins in the United States is limited to permitted issuers that meet federal or state requirements on reserves, disclosures and compliance.
- When it takes effect — the core provisions take effect by January 18, 2027, or earlier if final regulations come first. Federal regulators proposed implementing rules during 2026, and final rules were still pending as of October 2026.
- Who else is affected — under Treasury’s proposed rule, digital-asset service providers may not offer or sell payment stablecoins from non-permitted issuers after July 18, 2028.
Who It’s For
Built for teams moving money.
- Issuers and prospective issuers — evaluating whether and how to issue a payment stablecoin.
- Fintechs and payment companies — adding stablecoin settlement or payouts to an existing product.
- Exchanges and wallets — distributing or supporting stablecoins for customers.
- Banks and financial institutions — exploring stablecoin services or tokenized deposits.
When to Call
- Before you design the product — so licensing and compliance shape the architecture rather than follow it.
- Before you add stablecoin payments — to an existing product or customer base.
- When a partner asks — a bank, exchange or processor requests your regulatory analysis.
- Before you serve New York — where state licensing can apply.
Next Step
Two ways to start.
Want a written assessment first?
The Launch Readiness Assessment is a fixed-scope review with a written Launch Risk Map, a preliminary view on the questions that decide your launch, and a 30-Day Legal Action Plan, offered after your consultation.
See the Assessment →This page is general information, not legal advice, and does not create an attorney–client relationship.