Position on the U.S. Market
This page summarizes WANNA’s current internal view of how G-Series Stablecoin 2.0 (including GUSD) may relate to emerging U.S. stablecoin regulation, and how we intend to position the protocol with respect to the U.S. market.
It is not legal advice, and U.S. regulators and courts remain the final authority on how any law is interpreted and applied.
1. U.S. “Payment Stablecoin” Framework (Conceptual)
Recent U.S. legislative proposals (e.g., the so-called “GENIUS Act” for Payment Stablecoins) generally assume the following structure at their core:
a token that is:
designed primarily for payments and settlement
intended to maintain a stable value relative to a specific fiat currency (e.g., USD)
an issuer that:
has a direct redemption obligation to redeem tokens for fiat
holds reserves in permitted assets (cash, short-term Treasuries, etc.)
is licensed / supervised as a Payment Stablecoin Issuer or equivalent
In this model, the regulated object is essentially:
“A token that is a direct digital promise by a licensed issuer to pay X units of fiat currency on demand.”
2. Why We Currently View G-Series as Outside the U.S. “Payment Stablecoin” Definition
Based on the current design and intended operation, our internal working view is that G-Series (including GUSD) does not directly fall into the U.S. Payment Stablecoin category as typically described.
This view rests mainly on three points:
2.1 No Direct Fiat Redemption Obligation
G-Series tokens do not represent:
a claim on insured bank deposits
a contractual promise by a U.S. bank or money transmitter to pay USD on demand
Where redemption paths exist, they are intended to be:
into other digital assets (e.g., USDC, USDT, other regulated stablecoins)
via non-U.S. financial partners, rather than a direct “1 token = 1 USD” legal obligation from a U.S. issuer
In other words, G-Series is designed as an on-chain infrastructure layer, not as a U.S. retail deposit product.
2.2 Multi-Layer, Asset-Referenced Structure
GUSD and G-Series are intended to be backed primarily by:
existing USD stablecoins
other compliant collateral assets, issued by separate entities under their own regulatory frameworks
G-Series therefore operates as a second-layer, asset-referenced token:
referencing a basket of external stablecoins / assets
rather than being a single, primary “digital dollar” issued under U.S. banking law
This structure is closer to a DeFi / FX / settlement layer on top of other regulated instruments than to the archetypal Payment Stablecoin described in U.S. drafts.
2.3 Non-U.S.-Centric Target Market and Positioning
G-Series is not being designed or marketed primarily as:
a domestic U.S. payments
U.S. retail spending product
The protocol’s core focus is:
multi-currency FX
cross-border flows
use cases outside the U.S. retail banking context
To the extent reasonably possible, front-ends and partners may:
avoid actively targeting U.S. retail users
apply geo-blocking or eligibility filters aligned with their own legal advice
Taken together, these factors support our current internal position that:
“G-Series, including GUSD, is not designed as a U.S. ‘Payment Stablecoin’ with a direct USD redemption obligation, and therefore is not intended to fall within that specific regulatory bucket.”
This is an internal design and positioning stance, not a formal legal conclusion.
3. Access and Restrictions for U.S. Persons
In light of U.S. regulatory uncertainty, our default assumption is conservative:
The protocol is not designed with U.S. retail users as a primary target.
Certain interfaces, offerings, or marketing campaigns may:
explicitly exclude U.S. persons
require KYC/AML to verify non-U.S. status for specific products (especially where RWA or yield is involved)
Third-party front-ends (wallets, exchanges, dApps) integrating G-Series are expected to:
seek their own legal advice for U.S. exposure
implement appropriate geo-restrictions, KYC/AML, and compliance controls according to their licensing and business model
4. If Needed, We Are Prepared to Adapt for the U.S.
We acknowledge that:
U.S. law and guidance around stablecoins may evolve to cover:
second-layer, asset-referenced tokens
on-chain payment systems that rely on regulated stablecoins as collateral
U.S. regulators may, in practice, adopt a broader interpretation of which tokens fall under Payment Stablecoin or related regimes
If either:
entry into the U.S. market becomes strategically important
U.S. regulatory risk becomes more concrete
we are prepared, in principle, to consider measures such as:
partnering with a licensed U.S. Payment Stablecoin Issuer or bank / trust company
adjusting redemption, reserve, and disclosure structures to align with U.S. requirements
localizing certain products (e.g., separate U.S.-only variants) under a specific regulatory framework
or, conversely, restricting or disabling certain features for U.S. persons if compliance is not feasible
Our stance can be summarized as:
“We currently design and position G-Series as outside the narrow U.S. Payment Stablecoin category, but if U.S. law or strategy requires it, we are willing to adapt structure and market access in order to comply.”
5. Disclaimer
This page reflects WANNA’s current internal interpretation and design intent, not a binding legal opinion.
Only U.S. regulators, courts, and licensed counsel can provide authoritative guidance on how U.S. law applies.
Anyone considering:
integrating G-Series with U.S. users
marketing G-Series in the U.S. should obtain their own independent U.S. legal advice before doing so
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