GENIUS Act mapping
The GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins) sets reserve-backing, public-disclosure, and examination expectations for permitted payment stablecoin issuers. This page maps each expectation to the CapchaCloud artifact that is designed to support it — with the limits of each artifact stated as plainly as the capability.
This is not a compliance product. Nothing here guarantees, certifies, or confers GENIUS Act compliance, and this page is not legal advice. CapchaCloud is software: it seals tamper-evident evidence of what an issuer attested and when. Reserves themselves — their existence, custody, composition, and audit — remain the issuer's and its regulators'/auditors' responsibility. Have your counsel review any use of these artifacts in a regulatory context.
Expectation → artifact mapping
| GENIUS Act expectation (plain English) | CapchaCloud artifact (designed to support) | What it does — and does not — prove |
|---|---|---|
| Reserve backing disclosure. Issuers must publicly disclose reserve backing on a recurring (monthly) basis. | Public reserve-adequacy receipts (examiner portal) — a signed, printable, offline-verifiable receipt regenerable on demand, plus an opt-in daily cadence that seals coverage snapshots. | Proves what the tenant attested and when, with a hash-chained event log behind it. Does not prove the reserves exist or were audited — figures are tenant-attested only. |
| 1:1 reserve coverage visibility. Supervisors expect to see outstanding liabilities against reserves. | ALM ledger coverage ratio (basis points) recomputed from the immutable event log on every public read — never a mutable cache. | Proves the arithmetic of attested figures and the log's integrity. A ratio above 10000 bps is reported coverage, not verified collateral. |
| Examination-ready records. Examiners should be able to inspect records without friction. | Examiner read-only portal: one-file JSON bundle (state + receipt + chain head + anchors + verify steps), printable attestation pages, and an ISO 20022 (camt.052-shaped) projection for bank tooling — no login, no shared credentials. | Makes the evidence portable and independently checkable. It packages tenant-attested evidence; it is not an examination, audit opinion, or supervisory determination. |
| Tamper-evident record-keeping. Records should resist after-the-fact alteration. | CapchaChain: audit events folded into daily Ed25519-signed Merkle blocks, timestamped by independent RFC 3161 authorities and anchored into Bitcoin via OpenTimestamps — proofs any standard OTS client can verify without trusting CapchaCloud. | Proves existence-at-time and non-alteration of the sealed record. Tamper-evident, not tamper-proof; anchoring says nothing about whether the underlying attestation was true. |
| Independent review of disclosures. Monthly disclosures are expected to be examined by an outside accountant. | Monthly external-cosign slots (cadence automation) + the RSN cosigner registry: an outside party attaches its own Ed25519 signature over the monthly factset. | Provides the technical slot for an independent signature. The cosignature is whatever the cosigner's engagement says it is — CapchaCloud does not turn it into an audit. |
| Operational monitoring. Issuers are expected to watch for reserve/circulation anomalies. | Autonomous settlement monitor (per-tenant opt-in): daily sweep seals anomaly findings — velocity breaches, unresolved discrepancies — for human review. | Detection + sealed evidence only. The monitor takes no action on any transaction — no block, hold, reversal, or recovery — and a finding is a heuristic flag, not a fraud determination. |
Stated limits (read before relying on any of this)
- All reserve figures are tenant-attested. The platform seals attestations; it does not verify bank balances, custodial accounts, or asset composition.
- CapchaCloud never touches, holds, or moves funds, and confers no charter, insurance, license, or regulatory status.
- Bitcoin anchoring proves a record existed by a point in time — it says nothing about the truth of what was recorded.
- Statutory text and agency rulemaking evolve; mapping entries reflect our understanding at publication and are not legal advice. This page itself is offered for counsel review.
See it working: a live demo attestation (tenant-attested demo figures) · examiner portal · CapchaBanking console · public chain explorer.