Stablecoins moved $891 billion between July and September 2026, according to a Coinbase report produced by The Block Pro Research and published on October 20, 2026. The next day, the Office of the Comptroller of the Currency (OCC), the US federal banking regulator, published the first final rule implementing the GENIUS Act, the US law governing these digital dollars. The issuers it supervises have until January 18, 2027 to comply.
A stablecoin that moves mostly while the banks sleep
Quarterly volume has more than quadrupled since early 2023, according to the Coinbase report titled "The Always-On Dollar". Spread over the hours in the quarter, that comes to a little over $400 million transferred every hour, nights and weekends included, according to the calculation reported by Journal du Coin.
This figure is an "adjusted" volume. The report strips out bots and automated activity.
The report also measures when transfers take place. Over the twelve months to the end of July 2026, nearly 73% of transfers went out outside US banking hours. This calculation excludes transfers of less than 1 dollar, self-transfers and token mints or burns.
At those hours, a wire through Fedwire, the Federal Reserve's network, does not go through. A transfer of USDT or USDC on Tron, Ethereum or Solana does.
Volume surges, supply stagnates
Total stablecoin supply stands at around $304 billion as of October 21, 2026, according to DefiLlama as cited by Journal du Coin. Tether's USDT accounts for $183 billion of it, Circle's USDC for $72 billion. The same dollar therefore changes hands more often: roughly three times per quarter, according to the same article.
A transfer is not a payment. Part of these flows corresponds to arbitrage between platforms, margin deposits on derivatives or treasury round trips. The Block itself presents the study as a measure of transfers, not of spending.
Banks are nonetheless getting involved. According to the report, seven of the ten largest US banks have already tested stablecoins or tokenized deposits for their settlements, and the other three have announced plans to do so. They join traders and cross-border payment channels. Their exact share of the $891 billion remains hard to isolate.
Who issues these digital dollars?
Two issuers dominate: Tether and Circle hold 85% of a market worth more than $300 billion, according to Journal du Coin. Together, USDT and USDC weigh in at $255 billion.
Their model rests on reserves. These are largely invested in US Treasury bills, which earns them several billion dollars in interest a year. The holder, for their part, receives nothing from the issuer: the GENIUS Act prohibits issuers from paying interest.
The two giants are not in the same position with regard to the new rule:
- Circle applied to the OCC for a federal bank charter back in June 2025. It now has 89 days to come into compliance.
- Tether depends on a US Treasury decision on whether the Salvadoran regime is "comparable". That decision does not yet exist.
What the GENIUS Act now requires of issuers
The OCC's rule comes late. Donald Trump signed the GENIUS Act on July 18, 2025, and the law gave regulators one year to publish their rules. July 2026 passed without a text. The OCC is nonetheless the first: the Fed, the FDIC (the federal deposit insurer) and the Treasury are still working on theirs.
The text covers licensed payment stablecoin issuers and foreign issuers that fall under the OCC. It also covers certain custody activities of the institutions the OCC supervises. Reserves, redemption, capital and risk management take effect at the same time as the law.
Around 328 comments came in during the consultation, and the text has changed since the February 2026 proposal:
| Issue | February 2026 proposal | Final rule of October 21, 2026 |
|---|---|---|
| Yields paid by third parties (platforms, affiliates) | Presumption of evasion, with the issuer having to prove otherwise | Case-by-case review; the OCC can act against any "clear evasion" |
| Redemption deadline | Two business days, with an automatic seven-day extension | Two business days; extension on request to the OCC if redemptions exceed 10% of outstanding issuance within 24 hours |
| Minimum capital | $5 million for the first three years | $5 million, on a permanent basis |
| Issuers already in operation | Not mentioned by the sources | Temporary exemption possible with a "substantially complete" licensing application |
The yield issue was the most eagerly awaited. US banks wanted to extend the interest ban to exchanges, which get around the rule through rewards programs. Coinbase and PayPal still pay such rewards on USDC and PYUSD. They are buying time, without a blank check.
The Fed, for its part, keeps a presumption of this kind in its proposal of September 24, 2026, open for comment until November 30. The two regulators therefore read yields in opposite ways, with the same January 18, 2027 deadline.
And in Switzerland, what framework for a stablecoin?
FINMA, the Swiss Financial Market Supervisory Authority, set out its doctrine as early as September 11, 2019, in a supplement to its guidelines on initial coin offerings (ICOs). It looks at the economic function of a token rather than its form, and applies the principle of "same risks, same rules".
In practice, the requirements depend on the assets backing the token and on the holder's rights. According to FINMA, a stablecoin mainly touches on anti-money laundering and securities trading. The Banking Act, the Collective Investment Schemes Act and the Financial Market Infrastructure Act may also apply.
The Geneva-based Libra project served as an example in 2019. FINMA considered that it would need a payment system licence, with additional requirements on capital, liquidity and reserve management. A basic condition: the issuer, not the holders, had to bear alone the gains and risks of managing the reserves. A Swiss payment system is moreover automatically subject to the Anti-Money Laundering Act.
Swiss institutions remain cautious. In the University of St. Gallen's Swiss Blockchain Survey 2026, 80% of the 25 institutions surveyed in Switzerland and Liechtenstein see stablecoins and central bank digital currencies as the major trend of the next three to five years. But only 20% already offer stablecoin or settlement services, 20% are planning to and 60% have no plans at all. 46% cite regulatory or compliance requirements among the obstacles.
What this changes for a holder in Switzerland
A Swiss holder of USDT or USDC holds a token issued outside Switzerland. The OCC's rules on reserves, redemption and capital target the issuers it supervises, such as Circle if its charter application succeeds. The sources do not say how these rules apply to a holder based outside the United States.
Two points remain clear. First, the issuer does not pay interest: a yield displayed by a platform is a reward from that platform, which the OCC will review on a case-by-case basis. Second, a record volume of transfers says nothing about an issuer's soundness or about a token's future value. This article does not constitute investment advice.
What we don't know yet
- The anti-money laundering rules: FinCEN and OFAC, two US Treasury agencies, published their proposals in April 2026, with no final version to date.
- The texts from the Fed, the FDIC and the Treasury, which could diverge from the OCC's on yields.
- The opening date for licensing applications, which the OCC will announce in a separate release.
- The fate of Tether, pending the Treasury's decision on the Salvadoran regime.
- The banks' share of the $891 billion transferred in the third quarter of 2026.
