Georgia Enacts Payment Stablecoin Licensing Framework

On May 11, Georgia enacted the Georgia Payment Stablecoin Act, creating a state regulatory framework for payment stablecoin issuers. The bill authorizes the Georgia Department of Banking and Finance to license and supervise certain entities issuing payment stablecoins and is intended to align Georgia law with the federal GENIUS Act.

The law establishes a comprehensive framework governing licensing, reserves, disclosures, examinations, and permissible activities for licensed payment stablecoin issuers. Specifically, the law:

• Requires licensing and state supervision. Persons issuing payment stablecoins in Georgia generally must qualify as licensed or otherwise permitted issuers under the statute. Licensed issuers will be subject to annual examinations, renewal requirements, reporting obligations, and oversight by the Georgia Department of Banking and Finance.
• Establishes reserve and redemption requirements. Licensed issuers must maintain reserves backing outstanding payment stablecoins on at least a one-to-one basis using specified highly liquid assets, including cash, insured deposits, and certain short-term Treasury instruments. Issuers also must publicly disclose reserve compositions and maintain redemption policies addressing fees and redemption procedures.
• Imposes compliance and operational obligations. The law treats licensed issuers as financial institutions for Bank Secrecy Act purposes and requires anti-money laundering, sanctions, customer identification, and suspicious activity monitoring programs. The statute also directs the department to establish capital, liquidity, governance, operational risk, and third-party risk management standards.
• Restricts certain activities and representations. Licensed issuers generally may only engage in stablecoin issuance, redemption, reserve management, and related custodial activities. The statute further prohibits issuers from paying interest or yield on payment stablecoins and restricts marketing that could suggest government backing, legal tender status, or deposit insurance protection.

Putting It Into Practice: Georgia’s enactment reflects early state efforts to build payment stablecoin regimes around the federal GENIUS Act framework. Rather than treating stablecoin issuance as traditional money transmission, the law creates a separate licensing and supervisory path with reserve, redemption, disclosure, and compliance obligations. Payment stablecoin issuers, custodians, and other digital asset companies should monitor whether additional states adopt similar frameworks and assess whether existing compliance programs are positioned for both federal and state supervision.