The GENIUS Act Clock Is Ticking. The Rules Are Not Ready.
The GENIUS Act’s January 18, 2027 effective date is now locked regardless of agency rulemaking progress. Six agencies missed the July 18, 2026 Section 14(b)(5) deadline – only NPRMs were published. The compliance cliff for issuers is real: the prohibition takes effect but implementing rules may not be finalized. Circle remains the only issuer with…