Abstract. The GENIUS Act mapped onto the actual transaction architecture — not a legal summary, but the compliance cartography. Where each provision fires across the 8-stage STP lifecycle, where the three rulemakings stand, and which of the 53 paths in the Atlas registry each section reaches.
How it works. Each row is a GENIUS section. Each column is an STP stage. A lit cell means that provision creates compliance obligations at that stage.
What stands out. §6 AML/BSA concentrates at stages 2–5 (identity and routing). §4 Reserves fires at stages 4, 6, 7 (where money is committed and moved). §8 Foreign Issuers lights up at 1, 2, 5 — the cross-border exposure points.
The big picture. Three parallel rulemakings, one deadline. OCC is writing PPSI licensing and reserve attestation. Treasury is writing state oversight and foreign issuer registration. FDIC is writing the path for insured depository institutions into stablecoin.
Key dates. June 2, 2026 — all three comment periods close. July 18, 2026 — final rules due (one year after signing). January 18, 2027 — full enforcement begins.
The bottom line. The window between now and final rules is when the compliance architecture is being decided. Every issuer, custodian, and infrastructure provider integrating stablecoins should be tracking these NPRMs.
Near-universal. §3 (Definitions) and §6 (AML/BSA) fire on virtually every path.
Broad but selective. §4 (Reserves) is lighter on DeFi paths where issuers aren't in the loop. §8 (Foreign Issuers) concentrates on cross-border paths — CCTP, remittance corridors, wholesale FX, and RWA cross-chain.
What's missing matters. Pure DeFi paths (Uniswap, Aave, Lido) show minimal GENIUS exposure — §3 and §6 only. This doesn't mean unregulated — separate frameworks (SEC, CFTC) apply.