Tarbert urges Congress to finalize GENIUS and CLARITY

Heath Tarbert testified to the House Financial Services Committee on Sept. 2, 2026 that Congress should implement the GENIUS Act and complete the CLARITY Act to preserve U.S. control of dollar payment rails. The hearing was titled “Strengthening the American Economy: Promoting Growth, Opportunity, and Prosperity.”

In written testimony titled “Dollar Statecraft in the Internet Financial System,” Tarbert described payment stablecoins as payment infrastructure that should operate under U.S. law. He laid out three priorities for lawmakers: implement GENIUS faithfully, close routes for evasion, and finish the market-structure work embodied in CLARITY. In that testimony he wrote, “That is the core model Circle uses for USDC today.”

Tarbert outlined elements he said GENIUS requires: identifiable one-to-one reserves held in specified high-quality liquid assets, guaranteed par redemption, public reserve disclosures, day-to-day supervision, and compliance with the Bank Secrecy Act and sanctions rules. He characterized GENIUS as a prudential framework for payment-stablecoin issuance and supervision.

He noted timing details in his testimony: the GENIUS Act’s general effective date is the earlier of Jan. 18, 2027 or 120 days after the primary federal payment-stablecoin regulators issue final implementing regulations. He pointed to Treasury rulemaking activity in August 2026 on issuance, offer and sale provisions tied to GENIUS and said parts of the statutory framework still require final regulations to be fully operative.

Tarbert warned that treating enactment of GENIUS as equivalent to full operability of all issuer obligations would misstate effective dates, foreign-issuer restrictions, and which entities will hold which powers at each stage. He said finishing the regulatory architecture matters for market participants sizing compliance programs and for treasury desks using stablecoin rails.

Tarbert became Circle president in January 2025 after joining the company in July 2023 as chief legal officer and head of corporate affairs. He oversees legal, compliance, risk, policy, communications, talent operations and international expansion for Circle Internet Group. His prior public roles include Assistant Secretary of the Treasury for International Markets and Development and chairman and CEO of the Commodity Futures Trading Commission. He also worked in the private sector, including as chief legal officer at Citadel Securities.

The Office of the Comptroller of the Currency granted final approval on July 10 for First National Digital Currency Bank, N.A., a federally chartered bank to operate as Circle National Trust. The charter initially authorizes fiduciary digital-asset custody, with management of USDC reserves described as a future capability. Tarbert’s testimony and Circle materials distinguish the entity currently issuing USDC from the national-trust path that could assume reserve-management duties later.

Congress has enacted the GENIUS Act; the CLARITY Act remains the market-structure companion awaiting final resolution. Tarbert’s testimony repeated Circle’s preference for federal rules that align regulatory defaults with the one-to-one reserve and guaranteed-par redemption model used for USDC, while noting that full legal effect depends on forthcoming implementing regulations.