Coinbase Asks Treasury to Clarify Foreign Stablecoin Payment Rules
The request concerns cross-border payments in which U.S. customers do not buy, hold or acquire rights to the foreign-issued tokens.

Coinbase has asked the U.S. Treasury Department to clarify how proposed limits on foreign-issued stablecoins would apply to cross-border payments in which U.S. customers never gain rights to the tokens.
The request, submitted Oct. 19, concerns certain foreign-issued payment stablecoins used as intermediate assets. Coinbase wants service providers to be able to use them in payments moving into or out of the United States when customers here do not buy or hold the tokens, or acquire rights to use, transfer or redeem them.
The distinction is whether a foreign stablecoin passes through a payment or is offered or made available to a U.S. customer. Coinbase argues the two situations should be treated differently under the proposed limits. Its filing is a policy request; it does not change Treasury’s proposal.
The proposal would generally restrict digital-asset service providers from offering, selling or making foreign-issued payment stablecoins available in the United States. To qualify, an issuer would need the technological capacity to comply with lawful orders and would need to comply with applicable lawful orders and reciprocal arrangements.
The proposal implements Section 3 of the GENIUS Act, which covers payment-stablecoin issuance and U.S. offers or sales. Coinbase’s request asks Treasury to clarify how those limits apply when a U.S. customer does not acquire rights to a foreign token used in a payment flow.
Treasury issued the proposal Aug. 17 and published it in the Federal Register Aug. 18. The comment period closed Oct. 19.
The GENIUS Act is expected to take effect Jan. 18, 2027.