Nobody Holds the Licence Yet: The Stablecoin Market Stalled at $320bn While Washington Missed Its Own Deadline — and the Wrappers Are Onshoring to the OCC, Not to Cayman
Regulated stablecoin issuance has not started and the float has stalled — as of the as-of date every GENIUS implementing document (OCC Docket OCC-2025-0372; the FinCEN/OFAC joint proposal) is still a proposal, so no 120-day trigger has run, the 18-month backstop of 18 January 2027 controls, and there is not one permitted payment stablecoin issuer to name; two Fed publications a month apart put the market flat at $317bn (6 April 2026) and $320bn (May 2026) with growth "moderated," and Tether calls its own $183bn float "broadly stable" — while the legal wrappers are moving ONSHORE into the OCC's perimeter (Circle's final OCC approval for First National Digital Currency Bank, N.A. on 10 July 2026; Bridge/Stripe's preliminary charter on 12 February 2026; Tether issuing from El Salvador, not George Town), not to Cayman, which GENIUS Sec. 2(23) categorically bars from issuance ("a person formed in the United States"), which has no stablecoin regime or reserve rules to be found "comparable" under Sec. 18, whose VASP register SHRANK to 18 entities in Q4 2025 from 20 in Q1 2025 with exactly 1 registrant for "issuance of virtual assets," and whose only genuinely new digital-asset franchise — tokenised funds — is 12 provisionally registered funds out of 31,145 (0.04%), anchored by a $312,976,695 Circle-linked mutual fund whose token is issued out of Bermuda and sold only to non-US persons.