Regulatory Convergence in the Digital Era: The Impact of the U.S. GENIUS Act on Stablecoins and Colombia’s Decree 1069 on Low-Value Payment Systems

By Daniel Peña Valenzuela, Partner Peña Mancero Abogados

1. Introduction

The rapid evolution of financial technologies has prompted governments worldwide to reassess their regulatory frameworks. This paper examines the intersection between the United States’ GENIUS Act—an ambitious legislative effort to regulate stablecoins—and Colombia’s Decree 1069 of October 2025, which modernizes the country’s low-value payment systems. By analyzing the implications of these two instruments, the paper explores how cross-border regulatory developments influence domestic financial ecosystems, particularly in emerging markets such as Colombia.

The digitization of financial services has catalyzed a paradigm shift in how payments are processed, assets are stored, and trust is established in economic transactions. In response, governments have begun to craft legislation that addresses the challenges and opportunities posed by digital currencies and decentralized payment infrastructures. The GENIUS Act in the United States and Colombia’s Decree 1069 represent two such efforts, each tailored to its respective jurisdiction yet sharing common regulatory aspirations. This paper investigates the potential synergies and tensions between these frameworks and their implications for Colombia’s financial sector.

2. The GENIUS Act: A New Regulatory Framework for Stablecoins

Enacted in July 2025, the GENIUS Act (Guaranteeing Essential National Infrastructure Using Stablecoins) constitutes the first comprehensive federal legislation in the United States aimed at regulating the issuance, circulation, and oversight of stablecoins. Key provisions of the Act include:

    • Mandatory asset backing for stablecoin issuers, with reserves held in highly liquid instruments such as U.S. Treasury securities.
    • Licensing requirements under the Federal Reserve and Securities and Exchange Commission (SEC), depending on the nature of the stablecoin.
    • Obligations for interoperability with existing payment systems and digital wallets.
    • Consumer protection mandates, including transparency in transaction fees, dispute resolution mechanisms, and data privacy safeguards.

The GENIUS Act positions stablecoins as legitimate instruments within the broader financial system, potentially paving the way for their integration into mainstream payment infrastructures. Its extraterritorial influence is particularly relevant for countries with strong financial ties to the U.S. or with significant remittance flows denominated in dollars.

3. Colombia’s Decree 1069: Reforming Low-Value Payment Systems

In October 2025, Colombia’s Ministry of Finance issued Decree 1069, a landmark regulation aimed at enhancing the efficiency, security, and accessibility of low-value payment systems. The decree mandates:

    • Real-time interoperability among financial institutions with over 1.5 million active accounts.
    • Minimum service availability thresholds of 99% per month for payment platforms.
    • Standardized procedures for error correction and fraud mitigation.
    • The establishment of the National Payments Council, a multi-stakeholder advisory body comprising representatives from the public and private sectors.

Decree 1069 reflects Colombia’s commitment to fostering financial inclusion and digital transformation. By prioritizing low-value transactions, the regulation targets the everyday financial needs of consumers and small businesses, which are often underserved by traditional banking models.

4. Points of Convergence: Regulatory Synergies and Strategic Alignment

Despite their distinct scopes and jurisdictions, the GENIUS Act and Decree 1069 exhibit notable areas of convergence. These include:

a. Interoperability as a Strategic Imperative

Both regulations underscore the importance of interoperability. The GENIUS Act requires stablecoins to integrate seamlessly with existing payment networks, while Decree 1069 enforces real-time interoperability among Colombian financial institutions. This shared emphasis facilitates cross-border transactions and lays the groundwork for stablecoin adoption in Colombia’s domestic payment landscape.

b. Consumer Protection and Trust

The GENIUS Act and Decree 1069 both prioritize consumer protection. The former mandates transparency and dispute resolution for stablecoin users, while the latter introduces protocols for error correction and fraud prevention in low-value payments. These provisions are essential for building trust in digital financial services, particularly among populations with limited financial literacy.

c. Institutional Coordination and Governance

The creation of the National Payments Council in Colombia and the dual oversight of stablecoins by U.S. regulatory agencies reflect a broader trend toward collaborative governance. Such institutional arrangements enable regulators to respond dynamically to technological innovations and market developments, while also fostering international dialogue on best practices.

5. Implications for Colombia’s Financial Ecosystem

The GENIUS Act’s enactment has several implications for Colombia, both direct and indirect:

a. Catalyzing Fintech Innovation

The regulatory clarity provided by the GENIUS Act may encourage U.S.-based stablecoin issuers to expand into emerging markets, including Colombia. This could stimulate competition and innovation within the Colombian fintech sector, particularly in areas such as remittances, peer-to-peer payments, and digital savings.

b. Risk of Disintermediation

The proliferation of stablecoins as payment instruments may challenge the traditional role of banks as intermediaries. Decree 1069 seeks to mitigate this risk by compelling banks to modernize their payment infrastructures and offer competitive digital services.

c. Regulatory Gaps and the Need for Harmonization

Colombia currently lacks a dedicated legal framework for stablecoins. The GENIUS Act may serve as a model for future legislation, helping Colombian regulators to define the legal status, operational requirements, and supervisory mechanisms for stablecoin issuers operating domestically.

6. Challenges and Opportunities

Challenges

    • Regulatory Fragmentation: The absence of global standards for stablecoins may lead to jurisdictional conflicts and compliance burdens for cross-border operators.
    • Technological Readiness: Colombian financial institutions must invest in infrastructure upgrades to meet the interoperability and availability standards set by Decree 1069.
    • Public Awareness: The adoption of digital payment instruments requires robust consumer education initiatives to ensure informed usage and risk mitigation.

Opportunities

    • Financial Inclusion: Stablecoins and low-value digital payments can extend financial services to underserved populations, particularly in rural and informal sectors.
    • Cost Efficiency: Digital transactions reduce operational costs for businesses and consumers, enhancing economic productivity.
    • Foreign Investment: A coherent and forward-looking regulatory environment may attract international fintech firms seeking expansion opportunities in Latin America.

7. Policy Recommendations

To capitalize on the regulatory momentum generated by the GENIUS Act and Decree 1069, Colombian policymakers should consider the following actions:

    • Draft a comprehensive stablecoin law, incorporating lessons from the GENIUS Act and tailored to Colombia’s economic and technological context.
    • Strengthen cybersecurity protocols for digital payment platforms, including mandatory audits and incident reporting mechanisms.
    • Promote regional regulatory harmonization, particularly within the Pacific Alliance, to facilitate cross-border financial integration.
    • Launch nationwide financial literacy campaigns, focusing on digital payments, data privacy, and fraud prevention.

Conclusion

The GENIUS Act and Decree 1069 represent pivotal steps in the global and local regulation of digital financial instruments. Their convergence illustrates a shared commitment to modernizing payment systems, enhancing consumer protection, and fostering innovation. For Colombia, the challenge lies in translating these regulatory developments into tangible improvements in financial inclusion, technological resilience, and economic competitiveness. By aligning domestic policy with international best practices, Colombia can position itself as a regional leader in the digital finance revolution.