Davis Polk counsel Justin Levine was quoted in CoinDesk discussing the GENIUS Act’s compliance timeline for foreign stablecoin issuers.

The article highlighted that after the three-year grace period for compliance, U.S. crypto platforms won’t be able to offer stablecoins from issuers who haven’t met all regulatory requirements. However, there is disagreement on whether foreign issuers have the same three-year compliance period.

“Upon the effectiveness of the GENIUS Act, foreign issuers will need to immediately comply with lawful orders to seize and freeze coins held by illicit actors, but they will have a runway of approximately two more years to prepare for the additional requirements so that their coins may remain eligible for listing on U.S. centralized trading platforms,” Justin said, adding that one of those remaining requirements – registration with the OCC – is likely to require a “significant undertaking.”

“So they do have time, as long as they comply with seize and freeze orders, but those that want to have their coins continue to be traded on U.S. centralized platforms and have that liquidity should still be thinking about it right now, even if it’s not imminent that they’re going to get delisted, ” he added.

“Tether’s USDT hits 2-year countdown threatening its position on U.S. crypto platforms,” CoinDesk (July 20, 2026)

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