The Genius Act does not blanket-exempt exchanges and wallets from per-state licensing.

The GENIUS Act, enacted in July 2025, exempts federally qualified payment stablecoin issuers and licensed depository institution or credit union subsidiaries from state-level business authorization and licensing requirements under Section 5, but does not extend that blanket exemption to exchanges, wallets, or payment firms. Companies handling stablecoins in the U.S. must still assess whether they receive, custody, exchange, or transmit customer assets, since those activities fall outside the issuer exemption. The distinction matters because it preserves state licensing obligations for much of the stablecoin distribution and custody chain even as issuance moves under a federal framework. What to watch next is how state regulators and stablecoin-handling intermediaries interpret the boundary between issuance and ancillary services as the law takes effect.