The regulatory landscape for digital assets shifted dramatically in July 2025. President Trump signed the GENIUS Act into law, creating the first federal stablecoin framework. The House passed two additional landmark bills—the CLARITY Act and Anti-CBDC Act—that now head to an uncertain Senate. Meanwhile, 53 banking associations launched coordinated opposition to what they see as competitive threats to traditional deposits.
For Governance, Risk and Compliance (GRC) professionals, this isn’t about “crypto” anymore. It’s about preparing compliance programs for a fundamental shift in how money and financial services operate. The question isn’t whether digital assets will require enterprise-level risk management, it’s whether your organization will be ready when full implementation begins in 2027.
The Strategic Miscalculation: Why Traditional Finance is Fighting Back
While crypto advocates celebrated legislative victories, a powerful counterforce mobilized. On August 13, 2025, the American Banking Association and 52 state banking groups sent joint letters to Senate leadership demanding amendments to the GENIUS Act. Their concerns reveal the competitive dynamics GRC professionals must now navigate:
Deposit Flight Risk: Treasury estimates suggest stablecoins could drain up to $6.6 trillion from traditional bank deposits. This isn’t speculation—it’s why your organization’s digital asset policies now intersect with liquidity management and treasury operations.
Regulatory Arbitrage: Uninsured stablecoin issuers may operate across state lines without the regulatory requirements that apply to federally insured banks. GRC professionals must assess whether their institutions face competitive disadvantages or compliance gaps.
Interest Payment Workarounds: Banking groups warn that while the GENIUS Act prohibits direct interest payments on stablecoins, issuers could partner with exchanges to offer indirect yield programs. This creates gray areas that compliance teams must monitor.
The crypto industry’s $135 million in 2024 election spending focused on fighting regulatory overreach. They underestimated the entrenched political influence of traditional banking, which now represents an organized opposition with deeper institutional relationships and systemic risk arguments that resonate with policymakers.
Implementation Reality: Laws Need Regulations
Even the signed GENIUS Act is essentially a legislative architectural blueprint waiting for operational details from the executive branch of the United States government. Federal agencies have until July 18, 2026, to issue implementing regulations, with full compliance required by January 18, 2027.
What we still don’t know about the GENIUS Act:
- Specific examination procedures for stablecoin issuers
- Detailed reserve composition requirements beyond “high-quality liquid assets”
- Enforcement priorities and penalty structures
- Coordination protocols between state and federal regulators
For the CLARITY and Anti-CBDC Acts, we’re even earlier in the process. If they pass the Senate with amendments, expect another 12-24 month rulemaking period. Even if all goes as planned by the administration, it will be 2027-2028 before any comprehensive digital asset regulatory framework is fully operational.
Your 90-Day GRC Action Plan
Days 1-30: Assessment and Foundation Building
Immediate Risk Assessment
- Inventory current digital asset exposure across business lines
- Identify clients, counterparties, or investments with digital asset activities
- Review existing AML/BSA programs for digital asset transaction monitoring capabilities
- Assess treasury and cash management policies for stablecoin considerations
Regulatory Monitoring Infrastructure
- Establish tracking systems for GENIUS Act implementing regulations (due July 2026)
- Monitor Senate action on CLARITY and Anti-CBDC Acts
- Subscribe to federal banking agency guidance on digital asset examination procedures
- Create stakeholder communication protocols for regulatory updates
Professional Development
- Identify 2-3 team members for specialized digital asset compliance training
- Establish relationships with legal counsel specializing in digital asset regulation
- Join professional associations offering digital asset GRC education (AML Association, ACAMS crypto working groups)
Days 31-60: Policy and Process Development
Policy Framework Updates
- Draft digital asset addendum to existing investment policy
- Update AML/BSA policies to address digital asset transaction monitoring
- Develop preliminary stablecoin custody and succession protocols
- Create digital asset incident response procedures
Technology and Vendor Assessment
- Evaluate compliance management systems for digital asset transaction monitoring
- Research blockchain analytics tools for AML investigations
- Assess vendor due diligence processes for digital asset service providers
- Review cybersecurity frameworks for digital asset custody considerations
Training Program Development
- Create basic digital asset literacy curriculum for compliance staff
- Develop scenario-based training for digital asset AML red flags
- Establish ongoing education protocols for evolving regulations
Days 61-90: Implementation and Future-Proofing
Pilot Program Launch
- Implement enhanced due diligence procedures for digital asset-related customers
- Test blockchain analytics tools with compliance team
- Conduct tabletop exercises for digital asset compliance scenarios
- Begin quarterly regulatory update communications to stakeholders
Strategic Positioning
- Assess opportunities for competitive advantage through early digital asset compliance readiness
- Develop relationships with digital asset service providers and technology vendors
- Create framework for evaluating stablecoin issuance opportunities (banking institutions)
- Establish metrics for measuring digital asset compliance program effectiveness
Critical Knowledge Areas for GRC Professionals
Regulatory Classification Systems
Understanding how assets move between SEC (securities) and CFTC (commodities) oversight under the proposed CLARITY Act framework. This determines examination procedures, registration requirements, and compliance obligations.
Reserve and Custody Requirements
The GENIUS Act requires 100% reserve backing with liquid assets, but implementing regulations will determine operational details like custody standards, acceptable reserve assets, and reporting requirements.
AML/BSA Implications
Digital asset transactions create unique challenges for transaction monitoring, suspicious activity reporting, and customer identification programs. Blockchain analytics provide new investigative tools but require specialized expertise.
Examination Priorities
Federal banking agencies will develop examination procedures for institutions with digital asset activities. Early indicators suggest focus on risk management, AML compliance, and consumer protection.
Preparing for Regulatory Evolution
The current legislative framework provides general outlines, but practical compliance requirements will emerge through:
- 2025-2026: Congressional consideration of CLARITY and Anti-CBDC Acts, with implementing regulations for GENIUS Act
- 2027: Full GENIUS Act implementation begins, with likely regulatory adjustment period
- 2027-2028: Comprehensive digital asset framework becomes operational
GRC professionals who begin building competency now will have competitive advantages when full implementation begins. Those waiting for “final” rules risk being unprepared for rapidly evolving compliance obligations.
The Institutional Reality
Major banks already recognize this shift. JPMorgan, Goldman Sachs, and BlackRock have launched digital asset services while their industry associations lobby against crypto-friendly regulations. This reflects institutional recognition that digital assets represent business opportunities despite competitive concerns about traditional banking models.
For GRC professionals, this creates a two-front challenge: preparing for digital asset compliance obligations while navigating industry opposition that may influence final regulatory implementation.
Your Competitive Advantage Opportunity
Digital asset regulation is moving from regulatory gray areas toward comprehensive federal oversight. The transformation has begun, but it’s far from complete. GRC professionals who invest in understanding the emerging regulatory architecture will provide valuable guidance during this transition.
Ensure your compliance program will be ready to provide competent, confident guidance when clients need it most. Begin building foundational competency now. Monitor legislative developments closely. Prepare for implementation timelines measured in years, not months. And remember that even when regulations are finalized, the digital asset landscape will continue evolving as markets, technology, and policy priorities change.
The smartest GRC professionals are positioning themselves as knowledgeable advisors in the integrated traditional-digital finance economy that’s emerging.
Your 90-day action plan starts now.
Forbes Digital Assets, /digital-assets, Leadership, /leadership, Business, /business, standard The regulatory landscape for digital assets shifted dramatically in July 2025. President Trump signed the GENIUS Act into law, creating the first federal stablecoin framework. The House passed two additional landmark bills—the CLARITY Act and Anti-CBDC Act—that now head to an uncertain Senate. Meanwhile, 53 banking associations launched coordinated opposition to what they see as competitive threats to traditional deposits.
For Governance, Risk and Compliance (GRC) professionals, this isn’t about “crypto” anymore. It’s about preparing compliance programs for a fundamental shift in how money and financial services operate. The question isn’t whether digital assets will require enterprise-level risk management, it’s whether your organization will be ready when full implementation begins in 2027.
The Strategic Miscalculation: Why Traditional Finance is Fighting Back
While crypto advocates celebrated legislative victories, a powerful counterforce mobilized. On August 13, 2025, the American Banking Association and 52 state banking groups sent joint letters to Senate leadership demanding amendments to the GENIUS Act. Their concerns reveal the competitive dynamics GRC professionals must now navigate:
Deposit Flight Risk: Treasury estimates suggest stablecoins could drain up to $6.6 trillion from traditional bank deposits. This isn’t speculation—it’s why your organization’s digital asset policies now intersect with liquidity management and treasury operations.
Regulatory Arbitrage: Uninsured stablecoin issuers may operate across state lines without the regulatory requirements that apply to federally insured banks. GRC professionals must assess whether their institutions face competitive disadvantages or compliance gaps.
Interest Payment Workarounds: Banking groups warn that while the GENIUS Act prohibits direct interest payments on stablecoins, issuers could partner with exchanges to offer indirect yield programs. This creates gray areas that compliance teams must monitor.
The crypto industry’s $135 million in 2024 election spending focused on fighting regulatory overreach. They underestimated the entrenched political influence of traditional banking, which now represents an organized opposition with deeper institutional relationships and systemic risk arguments that resonate with policymakers.
Implementation Reality: Laws Need Regulations
Even the signed GENIUS Act is essentially a legislative architectural blueprint waiting for operational details from the executive branch of the United States government. Federal agencies have until July 18, 2026, to issue implementing regulations, with full compliance required by January 18, 2027.
What we still don’t know about the GENIUS Act:
Specific examination procedures for stablecoin issuers
Detailed reserve composition requirements beyond “high-quality liquid assets”
Enforcement priorities and penalty structures
Coordination protocols between state and federal regulators
For the CLARITY and Anti-CBDC Acts, we’re even earlier in the process. If they pass the Senate with amendments, expect another 12-24 month rulemaking period. Even if all goes as planned by the administration, it will be 2027-2028 before any comprehensive digital asset regulatory framework is fully operational.
Your 90-Day GRC Action Plan
Days 1-30: Assessment and Foundation Building
Immediate Risk Assessment
Inventory current digital asset exposure across business lines
Identify clients, counterparties, or investments with digital asset activities
Review existing AML/BSA programs for digital asset transaction monitoring capabilities
Assess treasury and cash management policies for stablecoin considerations
Regulatory Monitoring Infrastructure
Establish tracking systems for GENIUS Act implementing regulations (due July 2026)
Monitor Senate action on CLARITY and Anti-CBDC Acts
Subscribe to federal banking agency guidance on digital asset examination procedures
Create stakeholder communication protocols for regulatory updates
Professional Development
Identify 2-3 team members for specialized digital asset compliance training
Establish relationships with legal counsel specializing in digital asset regulation
Join professional associations offering digital asset GRC education (AML Association, ACAMS crypto working groups)
Days 31-60: Policy and Process Development
Policy Framework Updates
Draft digital asset addendum to existing investment policy
Update AML/BSA policies to address digital asset transaction monitoring
Develop preliminary stablecoin custody and succession protocols
Create digital asset incident response procedures
Technology and Vendor Assessment
Evaluate compliance management systems for digital asset transaction monitoring
Research blockchain analytics tools for AML investigations
Assess vendor due diligence processes for digital asset service providers
Review cybersecurity frameworks for digital asset custody considerations
Training Program Development
Create basic digital asset literacy curriculum for compliance staff
Develop scenario-based training for digital asset AML red flags
Establish ongoing education protocols for evolving regulations
Days 61-90: Implementation and Future-Proofing
Pilot Program Launch
Implement enhanced due diligence procedures for digital asset-related customers
Test blockchain analytics tools with compliance team
Conduct tabletop exercises for digital asset compliance scenarios
Begin quarterly regulatory update communications to stakeholders
Strategic Positioning
Assess opportunities for competitive advantage through early digital asset compliance readiness
Develop relationships with digital asset service providers and technology vendors
Create framework for evaluating stablecoin issuance opportunities (banking institutions)
Establish metrics for measuring digital asset compliance program effectiveness
Critical Knowledge Areas for GRC Professionals
Regulatory Classification Systems
Understanding how assets move between SEC (securities) and CFTC (commodities) oversight under the proposed CLARITY Act framework. This determines examination procedures, registration requirements, and compliance obligations.
Reserve and Custody Requirements
The GENIUS Act requires 100% reserve backing with liquid assets, but implementing regulations will determine operational details like custody standards, acceptable reserve assets, and reporting requirements.
AML/BSA Implications
Digital asset transactions create unique challenges for transaction monitoring, suspicious activity reporting, and customer identification programs. Blockchain analytics provide new investigative tools but require specialized expertise.
Examination Priorities
Federal banking agencies will develop examination procedures for institutions with digital asset activities. Early indicators suggest focus on risk management, AML compliance, and consumer protection.
Preparing for Regulatory Evolution
The current legislative framework provides general outlines, but practical compliance requirements will emerge through:
2025-2026: Congressional consideration of CLARITY and Anti-CBDC Acts, with implementing regulations for GENIUS Act
2027: Full GENIUS Act implementation begins, with likely regulatory adjustment period
2027-2028: Comprehensive digital asset framework becomes operational
GRC professionals who begin building competency now will have competitive advantages when full implementation begins. Those waiting for “final” rules risk being unprepared for rapidly evolving compliance obligations.
The Institutional Reality
Major banks already recognize this shift. JPMorgan, Goldman Sachs, and BlackRock have launched digital asset services while their industry associations lobby against crypto-friendly regulations. This reflects institutional recognition that digital assets represent business opportunities despite competitive concerns about traditional banking models.
For GRC professionals, this creates a two-front challenge: preparing for digital asset compliance obligations while navigating industry opposition that may influence final regulatory implementation.
Your Competitive Advantage Opportunity
Digital asset regulation is moving from regulatory gray areas toward comprehensive federal oversight. The transformation has begun, but it’s far from complete. GRC professionals who invest in understanding the emerging regulatory architecture will provide valuable guidance during this transition.
Ensure your compliance program will be ready to provide competent, confident guidance when clients need it most. Begin building foundational competency now. Monitor legislative developments closely. Prepare for implementation timelines measured in years, not months. And remember that even when regulations are finalized, the digital asset landscape will continue evolving as markets, technology, and policy priorities change.
The smartest GRC professionals are positioning themselves as knowledgeable advisors in the integrated traditional-digital finance economy that’s emerging.
Your 90-day action plan starts now.
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