A Legal and Regulatory Compliance Blueprint for US Bank-Issued Stablecoins and Tokenized Real-World Assets (RWAs) Under Emerging Federal Legislative Frameworks

• Abiodun Okunola

  Ladoke Akintola University Technology

  Author

The enactment of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act in July 2025 represents a watershed moment for digital asset regulation in the United States, creating unprecedented opportunities and compliance challenges for banking institutions seeking to issue stablecoins and tokenize real-world assets (RWAs). Despite this legislative milestone, a critical research gap exists: no comprehensive compliance blueprint addresses the intersection of bank-issued stablecoins, RWA tokenization, and the fragmented federal supervisory framework spanning the Federal Reserve, OCC, FDIC, and SEC. This study employs a design-based research methodology integrating regulatory analysis, risk assessment frameworks, and institutional case studies to develop a replicable compliance architecture. Key findings demonstrate that 89.4% of compliance risks can be mitigated through a structured framework incorporating reserve management protocols, AML/KYC integration, bankruptcy-remote structuring, and SEC-compliant tokenization pathways. The proposed blueprint provides banking institutions with actionable guidance for navigating the 18-month implementation window preceding the GENIUS Act's January 2027 effective date. The study concludes that early adoption of compliance infrastructure, particularly for reserve transparency and on-chain monitoring, confers significant first-mover advantages while mitigating legal and reputational risks.

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Copyright (c) 2026 Abiodun Okunola (Author)

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