Decision record for stablecoin freeze orders
From freeze request to review-ready record.
FreezeScope shows where an order’s stated scope and a token’s executable scope do not align, routes unresolved judgment to a human, and preserves the resulting issuer-owned evidence record.
- NO KEYS HELD
- NO FREEZES EXECUTED
- NO OFFICIAL FILING GENERATION
Where it fits
Between detection and execution.
A stablecoin is a blockchain token designed to track a currency such as the U.S. dollar. Some issuers retain contract controls that can restrict specified token addresses when a valid legal or policy basis applies.
- 01
Risk signal or legal request
- 02
FreezeScope evidence + scope record
- 03
Authorized human judgment
- 04
Issuer-controlled execution and reporting
Screening identifies risk. FreezeScope records the issuer’s decision. Custody and token systems execute authorized action.
A mandate, a clock, and live pain — converging in 2026.
- JUL 18 2025JUL 18 2025
The mandate.
The GENIUS Act was enacted. It requires permitted payment-stablecoin issuers to maintain the technical capability to comply with lawful orders; those orders must identify the stablecoins or accounts with reasonable particularity.
- APR 10 2026APR 10 2026
The proposal.
FinCEN and OFAC published a joint proposed rule at 91 FR 18582, including proposed Parts 502 and 1033. As proposed and nonfinal, material sanctions-program violations could carry up to $100,000 per day, plus up to another $100,000 per day for knowing violations.
- JUN 9 2026JUN 9 2026
Comments closed.
The comment period for that proposal closed. Implementation planning now has concrete proposed requirements to evaluate.
- JAN 18 2027JAN 18 2027
No later than Jan. 18, 2027.
The Act takes effect by this date unless final implementing regulations trigger its earlier 120-day path.
Primary sources:GENIUS Act (Pub. L. 119-27) (opens in a new tab)91 FR 18582 (proposed rule) (opens in a new tab)Treasury (effective date) (opens in a new tab)
One evidence record. Three levels of scrutiny.
The same public illustrative case, organized for the people who must understand it—not three products.
- Recommended
Quick Overview (opens in a new tab)
What happened, what was established, what remains unknown, and who decides next.
Compliance Control Review (opens in a new tab)
What is complete, what is blocked, and what the standing record hands off.
Counsel Decision Review (opens in a new tab)
The unresolved question, the recorded readings, and what the evidence can and cannot prove.
Show the record. Show its limits.
Issuer-owned record
Facts, scope, action, and gaps remain with the issuer.
Per-claim proof status
Each claim keeps its own status. In this demo, an attestation is never presented as proof.
Verification boundary
Displays the artifacts and the cryptographic hashes that link them. The separately delivered private evaluation kit contains the executable offline verifier.
Inspect the record before you book the meeting.
Do not send confidential matter data by email. Arrange a secure follow-up first.