Dólar na blockchain: O jogo maior por trás da Lei GENIUS

O stablecoin total market cap has surpassed 320 billion USD, with USDT and USDC holding more than the Australian national foreign exchange reserves in U.S. debt. After nearly a year since the signing of the “GENIUS Act” in the United States, supporting regulations are being implemented intensively. This is not just a piece of crypto regulation law — it is a strategic reconfiguration of dollar hegemony in the digital age.

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一、Four days ago, the BIS sounded the alarm

On April 20, 2026, the General Manager of the Bank for International Settlements (BIS), Pablo Hernández de Cos, issued the strongest warning to date regarding stablecoins. He specifically named USDT and USDC — which together account for about 90% of the approximately 320 billion USD stablecoin market — and bluntly stated that these assets behave more like investment products than cash, highlighting five specific risks: credit supply contraction, financial stability turmoil, monetary policy failure, erosion of fiscal sovereignty, and regulatory arbitrage.

The BIS warning is not accidental. It chose to speak out at this juncture precisely because the size of stablecoins has already touched a genuine systemic threshold.

For reference: Australia’s foreign exchange reserves are about 150 billion USD, Brazil’s are around 145 billion USD. The U.S. Treasuries held by two private companies already exceed the reserves of most medium-sized economies. This means that the issuance pace of stablecoins has substantially influenced the short-term U.S. bond yields — a domain once monopolized by the Federal Reserve.

二、GENIUS法案：美国史上第一部稳定币联邦法律

To understand the current situation, one must start from the source. On July 18, 2025, Donald Trump officially signed the “Guidance and Establishment of the U.S. Stablecoin National Innovation Act” (GENIUS Act), the first federal legislation in U.S. history specifically targeting payment stablecoins, marking the transition of U.S. crypto regulation from “fragmented enforcement” to “systematic governance.”

The core provisions of the bill are not complicated, but each points to clear political and economic intentions:

① 100% Reserve Requirement: Issuers must collateralize with USD cash or U.S. short-term Treasury bonds maturing within 93 days at a 1:1 ratio, thoroughly banning the previous practice of Tether using commercial paper. ② Dual licensing system: Issuers with a market value over 10 billion USD are directly regulated by the Federal Reserve and OCC; small and medium issuers can opt for state-level regulation but must meet the “substantive equivalence” standard. ③ Mandatory technical freezing capabilities: Issuers must have the technical ability to freeze, destroy, or block specific transactions upon a legal order — applicable not only to U.S. entities but also to foreign issuers entering the U.S. market. ④ Complete ban on algorithmic stablecoins: The lessons from TerraUSD’s collapse in 2022 are directly embedded into the legislation, making all stablecoins not fully backed by assets illegal.

After the bill was signed, supporting rules quickly followed. In March 2026, OCC released a draft implementing the GENIUS Act; in April, the Treasury issued principles for state-level regulatory equivalence, FinCEN and OFAC jointly published anti-money laundering and sanctions compliance requirements, and FDIC also announced specific implementation details for its regulated institutions. The regulatory framework’s skeleton rapidly took shape within these months.

三、稳定币收益之战：谁在保护谁的利益？

However, as the regulatory framework accelerated its implementation, a game over “whether stablecoins can pay interest” nearly derailed the next phase of legislation — the CLARITY Act.

The starting point was Coinbase CEO Brian Armstrong. In January 2026, he publicly withdrew support for the Senate Banking Committee’s version of the CLARITY Act, mainly because: the Senate version explicitly prohibits stablecoin issuers and their related distribution platforms from paying any form of passive income to holders. If this clause takes effect, it would directly cut off Coinbase’s stablecoin interest business — which brought in $355 million in revenue in Q3 2025. Just hours after Armstrong withdrew support, Senate Banking Committee Chair Tim Scott announced a delay in the review process.

The American Bankers Association (ABA) and other banking lobbying groups strongly pushed for this ban, with a straightforward rationale: if stablecoins can offer returns close to short-term U.S. Treasuries (historically 3.5%-5%) and bank deposit rates are near zero, it would trigger trillions in deposit shifts, threatening community banks’ lending capacity.

—— American Bankers Association lobbying stance, early 2026

But the White House Council of Economic Advisers (CEA), in a report released on April 8, directly rebutted this logic: banning stablecoin yields entirely would only increase bank loans by about $2.1 billion (less than 0.02%) but would cause a net welfare loss of $800 million for consumers. Even under the most extreme assumptions, the boost to community bank loans is minimal.

On March 20, Senators Tillis and Alsobrooks proposed a compromise framework: “rewards” linked to user activity could be permitted, while purely passive savings yields would be banned. The problem is, there are no clear legal or technical precedents for the boundary between the two. This debate, in essence, is a game of interests among banking, crypto-native institutions, regulators, and Congress re-drawing the boundaries of benefits.

四、四方博弈：谁赢，谁输，谁在观望

Winner: USDC (Circle)

Leading in compliance, monthly audits, and a regulatory framework tailored for the GENIUS Act, solidifying its competitive advantage. Expected to hold over 90% of the compliant market share.

Adapter: USDT (Tether)

Offshore operation mode under pressure, but with a market cap of 320 billion USD and a circulating supply of 18.7 billion USD, surpassing most sovereign reserves. Regulatory compliance will be its only ticket into the U.S. market.

Damaged: Small and medium crypto platforms

High costs of licensing and compliance barriers will push most small and medium stablecoin projects out of the competitive arena. Leading platforms like Coinbase will see their moat deepen.

Strategic Observers: Hong Kong & Asian markets

Hong Kong’s “Stablecoin Regulations” completed legislation by late 2025, providing a compliant path for multi-currency (including offshore RMB) stablecoins. Whether the U.S. legislative framework can accelerate the development of RMB stablecoins remains a key variable to watch.

五、美元上链：这是一场"再美元化"战略

Peeling back the layers of technology and law, the political economy logic of the GENIUS Act is actually very clear: it is the U.S.’s digital strategic counterattack against the wave of “de-dollarization.”

Over the past decade, the global trend of “de-dollarization” has been fermenting: Russia and Iran shifting to local currency settlements; BRICS countries exploring alternative payment networks; some Middle Eastern oil producers beginning to accept non-dollar oil settlements. The share of the dollar in global foreign exchange reserves has fallen from over 70% in the 2000s to about 59% today.

Stablecoins provide a clever countermeasure. Its underlying logic is a closed loop: user buys stablecoins → issuer uses reserves to buy U.S. Treasuries → dollar demand expands, U.S. bonds find buyers. Circle CEO has publicly stated that every additional $10 billion in USDC reserves will bring about $6 billion in short-term financing to the U.S. Treasury. Standard Chartered estimates that the scale expansion of compliant stablecoins could generate up to $1.6 trillion in new short-term Treasury demand.

More critically, stablecoins bypass SWIFT and traditional banking systems, entering the gray areas where the dollar coverage is weak — such as ordinary citizens after the peso’s devaluation in Argentina, daily transactions in Venezuela, small cross-border merchants in Southeast Asia… These users rely on USDT, and the on-chain dollar reach extends further and deeper than any U.S. bank.

六、三个还悬而未决的关键变量

The GENIUS Act has been enacted, but the entire framework remains in a dense rule-making period. The following three variables will determine the final form of this “dollar on-chain” strategy:

① Will the CLARITY Act pass? This bill aims to establish a comprehensive regulatory framework for the entire digital asset market, and on March 17, it marked a historic ruling by the SEC and CFTC recognizing Bitcoin, Ethereum, and other major assets as “digital commodities.” The question is: the November 2026 midterm elections form a hard deadline — if the House flips, the pro-crypto Republican legislative coalition could disintegrate, and the bill might be shelved for up to four years. JPMorgan predicts that if the CLARITY Act passes mid-2026, institutional capital entering digital assets will accelerate significantly in the second half of the year.

② The stance of Federal Reserve Chair candidate Kevin Warsh on crypto assets. His financial disclosures show a crypto investment portfolio exceeding $100 million — if this candidate takes over the Fed, digital assets will be integrated into mainstream financial infrastructure policy considerations in an unprecedented way.

③ Asia’s response speed. The BIS warning on April 20 specifically pointed out the “digital dollarization” risks faced by Asian banking systems: even if Asian countries issue local currency stablecoins as protective measures, these tokens can still be exchanged for USDT on decentralized exchanges with just a few clicks after going on-chain. The pace of Hong Kong’s offshore RMB stablecoin development, and the regulatory standards competition between Singapore and Dubai, will form the “Asian variables” in the future digital currency order.

Meaningful fact: The U.S. took three years to block China’s AI chips, and another three years to weave the dollar into the global blockchain infrastructure.

The former is defensive — preventing opponents; the latter is offensive — actively expanding. Both are happening simultaneously. And the cleverness of stablecoins lies in the fact that they do not require government promotion; private enterprises will spontaneously complete the “dollar colonization” work — every USDT transaction inadvertently reinforces the network effect of the dollar.

The BIS’s alarm signals, Asian central banks’ anxiety, China’s CIPS and digital yuan accelerating — the war over “whose currency will become the settlement unit in the on-chain world” has only just begun its true confrontation.