2026 Perspectives for the Public Sector

The Legislative Landscape: Shaping Stablecoins and Tokenization in the Digital Asset Era T he GENIUS Act, signed into law by President Trump on July 18, 2025, marked the beginning of a new era for digital asset legislation inWashington, D.C. While the bipartisan passage of this legislation through an increasingly partisan Congress was monumental, it should be viewed as merely the starting line for the race toward a comprehensive digital assets legal and regulatory framework in the United States, not the finishing line. Significant work remains: the Treasury and bank regulators must still draft the mandated rulemakings; a coherent structure integrating diverse state regulatory regimes with new federal requirements still needs to be developed; and an international framework establishing comparability for foreign-issued USD- denominated stablecoins under substantially similar regulations have yet to be formally constructed. Perhaps even more crucial for the digital assets ecosystem, Congress is currently deliberating market structure legislation. This legislation aims to definitively determine what constitutes a security, what qualifies as a commodity, which assets fall under the jurisdiction of the Commodities Futures Trading Commission (CFTC) or the Securities and Exchange Commission (SEC), as well as other fundamental questions critical to the digital assets economy. It is important to recognize that even if this exceptionally complex legislation were to pass in 2026, regulators would likely spend significant time, perhaps years, developing the necessary regulations. This implies that while the world’s largest single market (currently) has made a respectable start, the race to regulate stablecoins, cryptocurrency, and tokenized assets in the United States, has, in fact, only just commenced. Andy Taylor Head of Public Sector NAM Federal & Local Governments John Finnigan Head of Public Sector NAM & Development Organizations Ryan Rugg Global Head of Digital Assets Treasury and Trade Solutions Karl Haddeland Federal Government Affairs Citi Perspectives for the Public Sector 43