GENIUS Act Does Not Exempt Stablecoin Firms From State Licensing

The GENIUS Act's federal stablecoin framework is narrower than its branding suggests: it licenses issuers, not the surrounding plumbing. Exchanges, wallets, payment processors and remittance firms remain exposed to a patchwork of FinCEN registration and state-level licensing, with definitions and exemptions that vary by jurisdiction. For compliance teams, that means a federal approval is a starting point rather than a safe harbor, and licensing strategy still has to be mapped state by state. Whether regulators or states move to harmonize those overlapping regimes is the open question worth watching.