Methodology · United States (GENIUS Act)
How the US tracker is built. All data is official; our calculations are marked.
Sources
- NYDFS, Virtual Currency Business Licensing: the “Regulated Entities” table (39 rows), the Greenlist and notices of voluntary surrender, transcribed on 21 Oct 2026. DFS blocks automated downloads, so this is a dated snapshot that we re-read by hand.
- OCC interpretations and decisions: every charter decision whose text describes digital-asset activities of the bank (17 decisions), with the bank's proposed activities quoted from the decision, and Supervisory Condition Letter 2026-01 (Anchorage).
- Federal Register API: documents mentioning “GENIUS Act”, refreshed on each build; we keep those with “stablecoin” or “GENIUS” in the title (20 on 21 Oct 2026).
- The Act: Congress.gov and the GPO compilation; Treasury's interim final rule for the effective date.
Source Hierarchy
- official NYDFS, OCC, Federal Register, the Act.
- company the firm's own release (none used in the US hub so far).
- press · secondary none used.
Labels
- OCC national bank: an operating OCC-chartered bank with crypto activities (Anchorage).
- NYDFS licensed + OCC approval: on DFS's list and holding an OCC conditional approval.
- NYDFS licensed: on DFS's list (BitLicense, BitLicense plus money transmitter licence, or limited purpose trust charter).
- OCC conditional approval: conditional or preliminary conditional charter approval only. It is not permission to operate.
- Not on either list: major firms we track with no DFS entry and no OCC decision. This says nothing about licences in other states.
- Stablecoin issuance: whether the OCC decision describes stablecoin issuance by the bank (“plans”), says the bank will not issue (“will not”), or does not mention it.
- Type: the strongest authorisation on record: national trust bank (OCC), NY trust charter, BitLicense plus money transmitter licence, BitLicense.
- Brands: we group DFS rows and OCC decisions under one brand only where the legal name or the decision names the brand (for example Bridge Ventures LLC, “a Stripe, Inc. company”).
Limits
- Licences and charters from other states (money transmitter licences, state trust and bank charters) are not covered yet.
- DFS gives month and year only for the date granted.
- Our calculations: 18 July 2028 (3 years after enactment) and days left.
Corrections
Write to press@vasptracker.com with the page and the source. Published corrections: none.
Cite This Page
VASP Tracker, “Methodology: US GENIUS Act Tracker”, https://vasptracker.com/en/us/methodology/ (accessed 21 Oct 2026). CC BY 4.0.