A year after the signing of the U.S. GENIUS Act, the question of whether Tether's USDT can continue to be traded on U.S. cryptocurrency platforms has once again become a focus of market attention. Legal opinions differ regarding the compliance timeline for foreign stablecoin issuers, but the general consensus is that Tether still has time to fulfill most of the requirements.

The period before 2028 is the main transition period.

The bill sets a three-year transition period for stablecoin issuers, with an overall deadline of July 2028. However, for stablecoins issued overseas, such as USDT, some obligations may not be implemented until the end of the transition period.

According to CoinDesk, citing lawyers, once the bill takes effect, foreign issuers may need to immediately cooperate with U.S. law enforcement to execute freeze and seizure orders on assets involved in illegal activities. As for whether they can continue to be listed on U.S. centralized exchanges, the implementation of these requirements is expected to be later.

A lawyer who has long provided legal services for stablecoin regulation said that foreign issuers who wish to maintain liquidity on U.S. platforms need to start preparing now, as subsequent requirements include registration with the U.S. Office of the Comptroller of the Currency, which is itself a very demanding arrangement.

Trading platforms may adjust in advance

The report notes that the regulatory details are not yet finalized, leaving considerable room for trading platforms to make their decisions. Some platforms with lower risk appetites may delist non-compliant stablecoins before the official deadline, while larger platforms with more legal resources may wait until the regulatory guidelines become clearer before making a decision.

A proposal previously released by the U.S. Office of the Comptroller of the Currency also indicated that 2028 remains the overall compliance deadline, but certain requirements targeting foreign issuers will be triggered earlier when the legislation takes effect. The key focus currently being repeatedly mentioned is primarily cooperation with law enforcement in freezing and seizing assets.

• Complete registration with the Office of the Comptroller of the Currency.
• Place reserve assets in US financial institutions
• Accept domestic regulations comparable to US standards

Tether has not yet released the full details.

Compared to Circle, which is actively aligning with the new framework, Tether has not yet publicly explained how USDT will fully comply with the new US regulations. Tether CEO Paolo Ardoino stated last year that the company would comply with the GENIUS Act and planned to launch a separate token for the US market while ensuring USDT meets the requirements for foreign issuers.

The bill sets clearer requirements for compliant stablecoin reserves, focusing on highly liquid assets such as cash and short-term U.S. Treasury bonds. This has brought Tether's reserve structure under continued scrutiny.

Even before US regulatory details have been fully finalized, Tether has launched its stablecoin USAT for the US market and continues to advance its corporate payments and cross-border settlement business. However, based on current adoption, USAT's market size remains significantly smaller than USDT's.

Expansion continues outside the United States

Despite unresolved compliance issues in the United States, Tether has recently accelerated its investment and payment expansion in multiple markets. This month, the company led a $7 million funding round for Pact Labs, with plans to integrate USAT into the US payroll payment infrastructure.

In corporate treasury scenarios, Hyundai Motor's US and Mexican operations recently completed a $20,000 cross-border treasury pilot transfer via the Avalanche blockchain, using USDT. Latin America is also a key region for Tether, with the company recently investing in the Brazilian exchange Mercado Bitcoin and the Argentine digital bank Ualá.

However, Tether's overseas expansion cannot replace the regulatory requirements it faces in the US market. Since the supporting rules for the GENIUS Act are not yet fully finalized, whether USDT can ultimately remain on US trading platforms depends on the speed of Tether's compliance efforts and clearer guidance from US regulators.