The US Department of the Treasury is the cabinet-level department responsible for federal finance, debt management, and economic policy, and on tokenisation it is the policy-coordinating department whose bureaus (FinCEN, OFAC) and councils (FSOC, the Stablecoin Certification Review Committee) sit at the centre of US digital-asset rulemaking. Treasury is the GENIUS Act framework owner, the FSOC convener, the parent of OFAC (Office of Foreign Assets Control) which runs the sanctions perimeter, and the parent of OFR (Office of Financial Research) which provides the analytical backbone for digital-asset financial-stability assessment. The Treasury Secretary chairs the Stablecoin Certification Review Committee that approves non-financial public companies wishing to issue payment stablecoins under GENIUS, and Treasury is the lead policy coordinator across the SEC, CFTC, OCC, Federal Reserve, and FDIC on cross-cutting digital-asset rule-making. For a tokenisation operator with US exposure, Treasury is the agency whose policy posture sets the tone the bureau-level supervisors then operationalise.
Role in tokenisation
Treasury's tokenisation surface has four load-bearing components. First, the OFAC sanctions perimeter on digital-asset addresses. OFAC has the authority to designate specific wallet addresses as Specially Designated Nationals (SDNs), with the practical effect that US persons and US-touching entities are prohibited from transacting with the designated addresses. The August 2022 Tornado Cash designation was the most consequential test of the OFAC sanctions tool against a smart-contract protocol rather than a person or legal entity; subsequent litigation (Van Loon v. Department of the Treasury, Fifth Circuit, November 2024) held that immutable smart contracts are not "property" within the OFAC statutory definition, narrowing the agency's authority to sanction smart-contract addresses (Fifth Circuit Van Loon opinion). The post-Van-Loon OFAC posture treats wallet-level designations on smart-contract protocols differently from designations on individual or legal-entity wallets.
Second, the FSOC convening role. The Financial Stability Oversight Council, chaired by the Treasury Secretary, brings together the heads of the SEC, CFTC, Federal Reserve, OCC, FDIC, NCUA, FHFA, CFPB, and an independent insurance member to coordinate on systemic financial-stability questions. FSOC's 2022 report on digital-asset financial stability (FSOC Report on Digital Asset Financial Stability Risks and Regulation) was the most consequential US federal interagency assessment of digital-asset risks during the prior cycle. FSOC's stablecoin work in 2025-2026 informed GENIUS Act drafting and continues to coordinate the implementing rule-making across the prudential and market regulators.
Third, the GENIUS Act framework ownership and the Stablecoin Certification Review Committee. Treasury is the framework owner for GENIUS, with the policy direction set at the Secretary level and the implementing rule-making coordinated through Treasury, the OCC, the Federal Reserve, the FDIC, and FinCEN. The Stablecoin Certification Review Committee (chaired by the Treasury Secretary) reviews applications from non-financial public companies wishing to issue payment stablecoins, with the certification requirement designed to limit non-financial-firm stablecoin issuance to companies whose financial activities do not raise systemic-risk concerns. The certification process is novel and the operating practice has yet to be fully tested.
Fourth, the President's Working Group on Financial Markets and Treasury's stablecoin policy positioning. The PWG produced two consequential stablecoin reports during the prior cycles (the November 2021 PWG stablecoin report and the September 2022 stablecoin policy summary) that set the analytical foundation for what eventually became GENIUS. Treasury's stablecoin policy positioning has consistently emphasised the cash-leg priority (stablecoins as payment instruments backed by short-dated Treasuries and cash equivalents) and the federal-perimeter priority (federal supervision of stablecoin issuance with state regulation as a complement rather than a substitute). Treasury's December 2025 monthly Treasury statements include detailed analysis of stablecoin reserve composition and Treasury bill purchase patterns by stablecoin issuers, which has become the most-watched US Treasury data series for tokenisation operators tracking the dollar-stablecoin dependence.
Operating model
Treasury's regulatory toolkit on tokenisation runs through the bureau structure (FinCEN for AML supervision, OFAC for sanctions, OFR for analytical work, the Office of Tax Policy for digital-asset taxation), the council structure (FSOC for interagency coordination, the Stablecoin Certification Review Committee for non-financial-firm stablecoin issuance), and the direct policy structure (the Office of Domestic Finance, the Office of International Affairs, the Office of Financial Markets). The bureau-level supervision is operationally separate from Treasury's core policy work; FinCEN and OFAC operate under Treasury authority but with their own statutory mandates and operational independence.
The OFAC sanctions enforcement mechanism on digital-asset addresses operates through three steps. Designation under the SDN list, which adds the address to the publicly available OFAC list of sanctioned parties. Enforcement on US persons and US-touching entities transacting with the designated address, which can include civil penalties, criminal referral, and corporate compliance action. Delisting under specific conditions, with the criteria varying by sanctions programme. The Tornado Cash delisting in March 2025 (following the Van Loon opinion) was the first wallet-address delisting after a court found the original designation unlawful.
The FSOC coordination mechanism runs through quarterly meetings, principal-level coordination on cross-cutting questions, and joint statements or reports on systemic-stability questions. The Council does not have direct rule-making authority but its assessments and recommendations carry significant interagency weight. Treasury staff support the Council's analytical work and prepare materials for principal-level review.
Why it matters
Three structural reasons. First, OFAC sanctions enforcement on digital-asset addresses is the most consequential US sovereign action on the on-chain perimeter, with implications for stablecoin issuer freeze obligations, exchange compliance programmes, and DeFi protocol design. The Van Loon decision narrowed but did not eliminate the agency's authority, and the post-Van-Loon OFAC posture continues to designate individual and legal-entity wallets while treating smart-contract addresses with more legal caution. Second, the GENIUS Act framework ownership and the Stablecoin Certification Review Committee give Treasury a direct policy seat on the most consequential US digital-asset legislation since the 2010 Dodd-Frank Act. Third, the FSOC convening role and Treasury's policy positioning on cross-cutting digital-asset questions make Treasury the natural locus for US sovereign coordination on questions that span banking, securities, derivatives, and AML perimeters.
The competitive frame is partly the bureau-level supervisors operating under Treasury authority (FinCEN, OFAC) and partly the federal financial regulators that coordinate with Treasury through FSOC and through joint rule-making (SEC, CFTC, OCC, Federal Reserve, FDIC). Treasury's role is more coordinator than direct supervisor, but the policy direction Treasury sets shapes what the supervisors then operationalise. The Treasury Secretary's posture on digital-asset questions is the single most consequential US executive-branch voice on the topic.
APAC angle
OFAC's sanctions enforcement on digital-asset addresses has been studied closely by APAC compliance teams as the operational template for sanctions screening on on-chain transactions. The Tornado Cash designation, the Van Loon decision, and the subsequent OFAC posture recalibration are the most-cited US digital-asset sanctions developments by APAC supervisors and operators. MAS, HKMA, and the FSA Japan have all referenced OFAC's framework in their own guidance on virtual-asset service provider sanctions screening obligations.
Treasury's stablecoin policy positioning is the most-watched US sovereign voice on the dollar-stablecoin question by APAC central banks evaluating their own stablecoin frameworks. The HKMA's posture on the HK Stablecoins Ordinance design, the FSA Japan's posture on PSA stablecoin amendments, and MAS's posture on the SCS framework all referenced the US Treasury-led federal perimeter design as a comparator. Treasury's monthly data on stablecoin Treasury bill holdings is one of the few public series tracking the dollar-stablecoin demand pattern that APAC central banks use to model their own currency-stablecoin liquidity scenarios.
Recent moves
- 2025-2026. GENIUS Act framework ownership and FSOC coordination on implementing rule-making across the SEC, CFTC, OCC, Federal Reserve, FDIC, and FinCEN.
- 2026 onward. Stablecoin Certification Review Committee operating practice develops as non-financial-firm stablecoin issuance applications come into the perimeter.
- March 2025. OFAC delists Tornado Cash from the SDN list following the Van Loon decision (Treasury press release).
- November 2024. Fifth Circuit decision in Van Loon v. Department of the Treasury holding that immutable smart contracts are not property within the OFAC statutory definition (Fifth Circuit opinion).
- October 2022. FSOC Report on Digital Asset Financial Stability Risks and Regulation (FSOC report).
- August 2022. OFAC designation of Tornado Cash smart-contract addresses, the most consequential test of OFAC sanctions on a protocol rather than an entity (OFAC press release).
- November 2021. President's Working Group on Financial Markets stablecoin report published, setting the analytical foundation for what eventually became GENIUS (PWG stablecoin report).
Open questions
- How OFAC reformulates its posture on smart-contract address designations post-Van-Loon, and whether subsequent litigation produces further narrowing of the agency's authority on protocol-level enforcement.
- How the Stablecoin Certification Review Committee operates in practice; the committee's first applications and decisions are the worked examples not yet established.
- Whether Treasury publishes a consolidated stablecoin reserve-composition data series, or whether the issuer-level monthly attestations remain the primary public data source.
- The interaction with international sanctions coordination (G7, FATF) on digital-asset sanctions enforcement; the post-Van-Loon US posture differs from the EU and UK postures on smart-contract enforcement.
- Agentic commerce posture. Treasury has not published on AI agents holding tokenised dollar positions or on whether agentic transactions on sanctioned addresses introduce novel attribution questions for OFAC enforcement.