GENIUS Act compliance

The Act takes effect for issuers on the earlier of 18 January 2027 and 120 days after the regulator's final rules (§ 20). That is the target date for everything marked "being implemented". This page is updated whenever a control changes state; the date of the last review is at the bottom.

Licence

§ 3(a)Being implemented · target before 18 January 2027

What the Act requires: Only a permitted payment stablecoin issuer may issue a payment stablecoin in the United States.
How we meet it: QvaPay, Inc. operates today as a FinCEN-registered Money Services Business. The application as a permitted issuer (State regime for issuers under $10 billion outstanding, or Federal through the OCC) is filed with the regulator the Board designates before the effective date. Until then QUSD operates as the stored-value unit of an MSB, not as a permitted payment stablecoin.
Where to see it: Regulatory status

§ 3(b)Being implemented · target before 18 January 2027

What the Act requires: From 18 July 2028, a digital asset service provider may only offer payment stablecoins issued by permitted issuers.
How we meet it: Before that date QvaPay reviews the third-party stablecoins it accepts on deposits and withdrawals and keeps only those from permitted issuers or foreign issuers under a comparable regime.

Reserve

§ 4(a)(1)(A)Being implemented · target before 18 January 2027

What the Act requires: Identifiable reserves of at least 1:1 in permitted assets: U.S. currency and Federal Reserve balances, insured deposits, Treasury bills of 93 days or less, Treasury repos and reverse repos, government money market funds, or tokenized versions of those assets.
How we meet it: The reserve is held today one-to-one in USDC in Company cold and hot custody wallets, and published every month. USDC is not a permitted reserve asset under the Act: the reserve migrates to permitted assets (insured deposits, Treasury bills and government money market funds) before the effective date, and the composition by category is published in the monthly report.
Where to see it: Monthly reserve disclosure

§ 4(a)(2)In force

What the Act requires: Reserves may not be pledged, rehypothecated or reused, except for short-term liquidity with Treasury bills and custodial obligations.
How we meet it: The QUSD reserve is not lent, pledged or invested. The Savings product is a separate liability with its own balance and is not funded from the QUSD reserve.
Where to see it: Fund safeguarding

Redemption

§ 4(a)(1)(B)In force

What the Act requires: Public redemption policy with clear and conspicuous procedures for timely redemption; limitations only if imposed by the regulator.
How we meet it: 1 QUSD = 1 USD, redeemable at par at any time through any enabled withdrawal rail up to the available balance. Redemptions are held only under a legal obligation (sanctions, open monitoring alert, incomplete identity), never for liquidity. The full policy is published.
Where to see it: Redemption policy

§ 4(a)(1)(B)In force

What the Act requires: All redemption fees are disclosed publicly, clearly and in plain language, and any change is announced with at least 7 days' prior notice.
How we meet it: Each rail's fee is published in advance on the coins page and shown before every withdrawal is confirmed. Fee changes are announced at least 7 days in advance on the reserve page and in the dashboard banner.
Where to see it: Fees by rail

Disclosure and certification

§ 4(a)(1)(C)Being implemented · target before 18 January 2027

What the Act requires: Publish every month on the website the total outstanding stablecoins and the composition of the reserve, with the average tenor and geographic location of custody of each category.
How we meet it: The reserve page publishes every month the QUSD outstanding (contract supply read from the Stacks network at the cut-off), the reserve by category, the custody location and tenor of each instrument, and the coverage. Each report is frozen when published. First report: September 2026 month-end.
Where to see it: Monthly reserve disclosure

§ 4(a)(3)Being implemented · target before 18 January 2027

What the Act requires: The CEO and the Chief Compliance Officer certify every month the accuracy of the report to the regulator, subject to the same penalties as 18 U.S.C. § 1350(c) for a knowingly false certification.
How we meet it: No report is published with a single signature: the flow requires two certifications by two different administrators (CEO and Chief Compliance Officer), each with name, title, date and an express attestation. The signatures are shown on the public report. Submission to the regulator starts with the licence.
Where to see it: Certified report

§ 4(a)(3)Being implemented · target before 18 January 2027

What the Act requires: The monthly information is examined by a registered public accounting firm.
How we meet it: Each monthly report will carry the name of the examining firm and the reference of its report, published on the same page. Until an examination exists, the page says so expressly instead of omitting it.
Where to see it: Report methodology

§ 4(a)(4)Being implemented · target before 18 January 2027

What the Act requires: Capital, liquidity, reserve diversification and risk-management requirements, tailored to the business model, under the primary regulator's rules.
How we meet it: The Company will adopt the capital and liquidity standards the regulator sets when it issues its rules. Until then it keeps the reserve one-to-one, with no leverage on it, and a published business continuity plan.
Where to see it: Business continuity

Lawful orders and AML

§ 4(a)(5)In force

What the Act requires: The issuer is a financial institution under the Bank Secrecy Act: effective AML program with a designated officer, record retention, suspicious-activity monitoring and reporting, a customer identification program with enhanced due diligence, and a sanctions program with list verification.
How we meet it: Board-approved BSA/AML program with a Chief Compliance Officer reporting to the Board; document and liveness identity verification; OFAC screening at onboarding, on an ongoing basis and on every withdrawal destination; Travel Rule; monitoring rules Q1 to Q7 with a SAR register; 10-year record retention.
Where to see it: AML program OFAC screening Monitoring and SAR

§ 4(a)(6)In force

What the Act requires: Technological capability to comply with any lawful order: seize, freeze, burn or prevent the transfer of the stablecoin, and coordination with Treasury to block transactions.
How we meet it: On the ledger, today: a confirmed sanctions match or a lawful order restricts the account (no withdrawals, transfers or sales), freezes the QUSD balance and reports it as blocked property under 31 CFR § 501.603; every action is audited with actor and date.
Where to see it: Screening and blocking

§ 4(a)(6)In force

What the Act requires: The same capability over QUSD circulating on the blockchain.
How we meet it: The QUSD contract (SIP-010 on Stacks, published as open source with its test suite) has a two-way blocklist, seizure into a blocked-property account, burn under order, pause, and key separation (cold owner, operational minter, compliance officer). Freezing is a contract action, not a key action: the compliance officer executes it and it is recorded onchain, whoever holds the wallet.
Where to see it: QUSD contract (GitHub)

§ 5(i)Being implemented · target before 18 January 2027

What the Act requires: Within 180 days of approval and annually, certify to the regulator that the AML and sanctions program is reasonably designed to prevent money laundering and terrorist financing.
How we meet it: The program already exists and has an independent review under contract. Certification to the regulator starts with the licence and repeats every year.
Where to see it: AML program

Governance and activities

§ 4(a)(7)In force

What the Act requires: Activities limited to issuing and redeeming the stablecoin, managing the reserve and providing custody of stablecoins, reserves and private keys, plus what directly supports them.
How we meet it: QvaPay issues and redeems QUSD, holds the reserve in Company wallets segregated from operating funds and provides the payment services that support that activity. Reserve keys are held by the Company; the keys of a holder's own wallet never are.
Where to see it: Permitted fund flows

§ 4(a)(8)In force

What the Act requires: It is prohibited to condition the service on the customer buying another product or forgoing a competitor.
How we meet it: No QvaPay service requires purchasing another paid product. Optional products can be used or not without affecting the issuance, redemption or transfer of QUSD.

§ 4(a)(10)Not applicable

What the Act requires: Annual GAAP audited financial statements, public and filed with the regulator, for issuers with more than $50 billion outstanding.
How we meet it: QvaPay is far below the threshold. Outstanding figures are published every month in the reserve report.

§ 4(f)In force

What the Act requires: No individual convicted of insider trading, embezzlement, cybercrime, money laundering, terrorist financing or financial fraud may serve as an officer or director of the issuer.
How we meet it: The three-member Board, one independent, applies that exclusion to officers and directors and reviews it at every appointment.
Where to see it: Corporate governance

§ 11Being implemented · target before 18 January 2027

What the Act requires: In an issuer insolvency, stablecoin holders rank ahead of every other creditor with respect to the reserve.
How we meet it: The reserve is kept segregated from operating funds and holders come first on it. The statutory priority applies by law to the permitted issuer; meanwhile segregation and redemption at par are already in force.
Where to see it: Fund safeguarding

Name, marketing and interest

§ 4(a)(9)In force

What the Act requires: The name may not use U.S. Government terms ("United States", "USG"), and marketing may not suggest it is legal tender or issued or guaranteed by the Government. The abbreviation "USD" is allowed.
How we meet it: Token name: QvaPayUSD, symbol QUSD. The whole site, the app, the emails and the token metadata carry the notice that QUSD and balances are not legal tender or deposits, are not FDIC-insured and are not issued or backed by the Government. Claim sweep documented on 7 September 2026.
Where to see it: Token metadata

§ 4(e)In force

What the Act requires: It is unlawful to represent that the stablecoin is backed by the full faith and credit of the United States, guaranteed by the Government or covered by federal deposit insurance.
How we meet it: No QvaPay surface makes that claim. The footer, the reserve page and this page expressly deny it.

§ 4(a)(11)In force

What the Act requires: The issuer pays the holder no interest or yield of any form solely for holding, using or retaining the stablecoin.
How we meet it: Holding QUSD earns nothing. The Savings product is a separate balance, with its own account and published rate, that the customer opens by choice and that is not available to accounts verified with a U.S. document.
Where to see it: No interest

QUSD and QvaPay balances are not legal tender, are not deposits, are not insured by the FDIC or any government agency, and are not issued or backed by the United States government. Balances do not earn interest.

Last review: 5 October 2026.

Compliance program · Reserve disclosure · Permitted fund flows