GENIUS Act Becomes Law: Implications for Commercial Real Estate

On July 18, 2025, President Trump signed the Guiding and Establishing National Innovation for US Stablecoins Act of 2025 ("GENIUS Act") into law. This legislation establishes a comprehensive federal framework for the regulation of payment stablecoins—digital assets pegged to the U.S. dollar and backed by high-quality liquid reserves. While the law primarily targets digital finance, it may hold significant potential for transforming commercial real estate (CRE) transactions.

What the GENIUS Act Does

The GENIUS Act aims to provide regulatory clarity and oversight for the issuance and use of payment stablecoins in the U.S. Key provisions include:

• Restricting issuance to regulated banks and approved nonbank entities
• Declaring compliant stablecoins as non-securities under U.S. law
• Requiring compliance with anti-money-laundering (AML) and Know-Your-Customer (KYC) protocols under the Bank Secrecy Act
• Mandating full reserve backing using high-quality liquid assets
• Instituting new disclosure and consumer protection requirements

The law will become effective in 18 months or 120 days after the issuance of implementing regulations, whichever is earlier. Federal and state regulators are now tasked with drafting these rules. Existing stablecoin issuers have up to three years to transition and meet compliance standards.

Why CRE Professionals Should Pay Attention

While digital assets and blockchain technology may seem far removed from commercial real estate, stablecoins are increasingly being used to streamline real estate deals. The GENIUS Act could accelerate this trend by providing a clear legal foundation for their use in CRE contexts.

Potential Use Cases in CRE

Several emerging applications may benefit from the regulatory clarity offered by the GENIUS Act:

• Faster Settlements: Stablecoin transfers can settle with finality in minutes rather than days.
• Cross-Border Transactions: International buyers can pay directly in stablecoins, avoiding currency conversions and banking delays.
• Smart Contract Escrow: Blockchain-enabled contracts can automate fund transfers when conditions are met, potentially reducing reliance on some third-party services.
• Tokenized Real Estate: Property rights can be traded as digital tokens, enabling fractional ownership, use rights and increasing market liquidity.
• Digital Payment Integration: CRE platforms are beginning to support stablecoin payments, streamlining rent collection, property sales, and leasing.

Looking Ahead

As the GENIUS Act ushers in a new era of digital asset regulation, commercial real estate firms may find new efficiencies and opportunities through the adoption of stablecoin-based solutions. While the law's full impact will depend on forthcoming regulatory guidance, the framework is now in place for broader exploration and adoption.

Firms interested in leveraging digital payments or blockchain-based transaction tools should begin evaluating their strategies in light of the GENIUS Act.

For additional insights or to discuss potential use cases in your operations, please contact our team.