The USA has rejected CBDC, but stablecoins can still freeze digital dollars and interact with government agencies.
America rejects CBDC, but is building a similar control system.
Washington has legally abandoned the launch of a retail digital dollar by the Federal Reserve. But at the same time, a new model for regulating stablecoins is being formed. It gradually establishes functions for freezing funds, blocking transactions, their rejection, or temporary suspension. Such mechanisms can be applied to both private dollar tokens and increasingly to tokenized financial assets.
In January, President Donald Trump signed an order prohibiting government agencies from creating, issuing, or promoting a U.S. central bank digital currency.
This step clearly demonstrated the political position: Washington wants to appear as an opponent of CBDC.
However, subsequent regulatory decisions indicate a more complex picture.
In July 2025, the GENIUS Act was adopted. It created a federal regulatory system for licensed stablecoin issuers. The law requires the implementation of anti-money laundering programs, compliance with sanctions regimes, monitoring of suspicious operations, and the technical capability to block, freeze, or reject transfers at the lawful request of authorities.
This does not mean that a hidden analog of a CBDC has already emerged in the U.S. A stablecoin remains a private obligation of the issuer, not a direct claim on the central bank.
Moreover, the current system lacks a unified national transaction registry, a universal government wallet, or indications that federal authorities plan to transition the population to a retail payment system under the control of the Federal Reserve.
If this is not a CBDC, why does everything look so similar?
But the question arises: does Washington really reject the very idea of a CBDC, or is it simply avoiding this term while simultaneously creating a regulated system of private digital dollars that may practically provide similar control tools?
It is precisely the gap between the legal status and how the system will operate for users that is becoming the main political issue.
This dispute is also noticeable at the state level. It has been ongoing for over a year.
Several states have enacted laws against CBDC. At the same time, it is more accurate to say that they limited their use rather than completely banned it.
Florida changed its legislation in 2023 and excluded CBDC from the category of money within the UCC system.
Wyoming in 2025 articulated its position even more directly. The state's legislative findings state that a CBDC could lead to the centralization of financial data, strengthen the link between household spending and the government, and simplify restrictions on certain purchases.
This wording is important because it sets a benchmark for the entire discussion. Now the main question sounds different: can regulated stablecoins provide the same control tools but without direct issuance by the Federal Reserve?
The federal government is already partially answering this question.
The White House report from July 30, 2025, states that one of the 'unique features' of stablecoins is the ability of issuers to interact with law enforcement and freeze or seize assets.
In the same report, Congress was urged to consider a special law for digital assets. It would allow financial organizations to temporarily hold funds during short investigations related to possible thefts or fraud without the risk of legal consequences.
At the same time, the document supports the right to self-custody of crypto assets and lawful transfers between users without the involvement of a financial intermediary.
As a result, a multi-layered regulatory model is forming.
On one hand, there is rhetoric about free and decentralized transactions. On the other, tools for control are emerging at the center of the regulated dollar infrastructure.
The architecture that Washington is effectively building
The GENIUS Act translated this approach from political recommendations into a legal norm.
The document requires that authorized stablecoin issuers have the technical capability as well as internal policies and procedures for blocking, freezing, and rejecting individual transactions. They are also required to comply with lawful orders from authorities.
The wording of the law is broad enough. Such orders may include requirements to seize assets, freeze them, destroy tokens, or prevent the transfer of stablecoins. The main condition is that the order must specify particular accounts or coins and be subject to verification.
The same requirements apply to foreign stablecoins if they are offered to users in the U.S.
As a result, the U.S. position appears quite consistent: there is no retail CBDC, but there is a private sector of digital dollars with built-in control mechanisms.
One example clearly illustrates this contradiction.
A company associated with the U.S. president has its own stablecoin. The website World Liberty Financial states that Donald Trump and associated entities have a significant economic stake in the project. Meanwhile, BitGo acts as the official issuer and custodian of the USD1 token.
In the risk documents, it is stated that BitGo may restrict access for individual addresses. The company may also temporarily or fully freeze USD1 if it believes that the address is associated with illegal activity or violates service rules.
In addition, BitGo has the right to transfer information to law enforcement, comply with legal orders, and block transfers between certain on-chain addresses.
Political rhetoric sounds like 'against CBDC.' But the operational documents themselves contain functions that critics of CBDC have warned about for many years. And such a model is encountered not only with the token associated with Trump.
In the USDC risk documents, it is stated that Circle can block individual addresses, temporarily or permanently freeze tokens, transfer data to law enforcement, and comply with legal requirements.
In January 2026, Tether launched USA₮ for the U.S. market. The announcement emphasized that this token is not legal tender and is not issued by the government.
This distinction is still important. But from a practical standpoint, one fact is already obvious.
Stablecoins with a freeze function already exist.
The political discussion has now shifted. The main question is different: will these powers remain targeted tools for law enforcement or become a regular part of the digital dollar infrastructure.
The size of the market helps to understand the scale, but it is also important to look at its structure.
In the July report from the White House, it was stated that as of July 14, 2025, the volume of fiat-backed stablecoins was $238 billion. Current market data shows about $313 billion. The market has noticeably grown in less than a year.
But looking at usage, the picture appears more restrained than the overall figures suggest.
According to a BCG report for 2026, the annual volume of stablecoin transfers on the blockchain exceeds $62 trillion. However, the actual economic activity amounts to only about $4.2 trillion.
The rest of the turnover is related to trading, liquidity management, and other infrastructure of the crypto market.
This payment infrastructure is strategically important. But for now, it has not become the primary means of payment for ordinary consumers in the U.S. economy.
The scale of the market makes architecture particularly important.
That is why the discussion about the future of stablecoins is reaching a new level. These assets have long ceased to be a niche product, but they have not yet become a universal means of payment for ordinary users.
According to Citi's forecast published in April 2026, the volume of stablecoin issuance may reach $1.9 trillion by 2030 in the baseline scenario. In a more optimistic scenario, the figure could rise to $4.0 trillion.
Analysts also expect a sharp increase in turnover. In the baseline scenario, the volume of transactions could approach $100 trillion, and in a more optimistic scenario, reach $200 trillion if the speed of asset circulation remains high.
Such estimates show that the decisions made now could have long-term consequences. Mechanisms for enforcing legal orders, freezing funds, and temporarily blocking operations in the future may extend to a significantly larger share of operations with digital dollars.
At the same time, the discussion is already going beyond just stablecoins.
In December 2025, DTCC announced that it received a so-called no-action letter from the SEC to launch a tokenization service for certain assets held through the DTC system. Testing will take place in a controlled environment, with a launch planned for the second half of 2026.
The list of assets that may participate in the program includes large shares of American companies, ETFs, and U.S. government bonds.
In the accompanying materials, the company separately emphasizes the requirements for infrastructure. Among them are wallet registration, management systems, transaction transparency, platform resilience, and token functions that consider regulatory requirements.
Thus, the question is gradually changing. It is no longer just about whether a stablecoin can be frozen. There is an increasing discussion about what part of the tokenized financial system will be built around the same control mechanisms.
If monetary equivalents, collateral assets, fund shares, and government bonds transition to an infrastructure with user identification and the possibility of intervention by legal requirement, the boundary between private and public control for users may become less noticeable.
At the same time, the issuer can remain a private company. The custodian can also be private. Even the trading platform can be private. But the conditions under which asset movement is permitted may still reflect the priorities of public policy.
This argument is often referred to as functional convergence of systems. It does not require asserting that stablecoins are CBDCs.
Rather, it is about monetary instruments and tokenized assets beginning to use the same mechanisms for verification, suspension, cancellation, or prohibition of transactions.
However, this position has serious opponents.
In the annual report for 2025, the Bank for International Settlements (BIS) acknowledged that tokenization could change the financial system. However, the report expresses doubts that stablecoins will become its foundation.
Instead, experts point to other elements of future infrastructure. Among them are tokenized reserves of central banks, bank money, and government bonds.
Citi analysts draw a similar conclusion from the market side. Their forecast states that by 2030, bank tokens could process between $100 trillion and $140 trillion in transactions. For corporate clients, this format may prove more attractive, as privacy in public blockchains remains a serious issue.
If you add to this the volumes of payments through FedNow in 2025, it becomes clear that the future system is unlikely to be built around one tool.
Rather, it is about a multi-layered financial infrastructure where different payment rails will compete and be used for different tasks.
What the next 3-7 years might look like
The baseline scenario assumes the development of a regulated system of private digital dollars, rather than the launch of a retail CBDC in the U.S.
In such a scenario, the country maintains a public position against CBDCs, develops the market for stablecoins under the GENIUS law's control, and simultaneously leaves room for other forms of digital money. This refers to self-custody of assets, transfers between users, the FedNow system, and other formats of tokenized money.
The freezing of funds remains a targeted measure and is applied based on the law, rather than becoming a universal control mechanism.
However, the system is gradually getting used to intervention. For many critics of CBDC, this seems unexpected, as the model formally remains private.
The main change may turn out to be not only legal but also cultural. Blocking transactions, freezing funds, and temporary holds are gradually ceasing to be perceived as exceptional measures. Over time, they may become a normal part of the regulated infrastructure of the digital dollar.
There is also a more optimistic scenario.
In it, competition maintains balance. Self-custody of assets remains a real alternative. Transfers between users remain legal, and privacy tools are gradually improving.
Institutional flows are distributed among stablecoins, bank tokens, and other permitted payment systems. This means that users are not tied to a single dominant digital dollar.
In such a system, the U.S. obtains more digital dollars, but they do not turn into a unified state infrastructure.
In this model, Bitcoin also retains its role. It remains the largest digital asset without an issuer, without a freeze function, and without a mechanism for enforcing legal orders at the protocol level. Stablecoins continue to play the role of a regulated dollar segment within the crypto industry.
The negative scenario appears less dramatic than popular discussions about the 'Fed wallet.' But it may prove more realistic.
Legal powers remain formally limited, but the practice of application is gradually expanding.
The White House report already states that issuers can cooperate with law enforcement to freeze and seize assets. The document also proposes considering a law that would allow financial organizations to temporarily hold funds during short investigations.
On paper, this is about fighting fraud, sanctions violations, and theft.
But the risk lies in the gradual expansion of the practice. This may manifest in broader wallet checks, more frequent temporary freezes of funds, and a more aggressive interpretation of suspicious transactions. At the same time, pressure on issuers and exchanges may increase to block transactions first and then deal with user complaints.
Formally, such a system will still not be a CBDC.
However, for users, it may begin to resemble the control usually associated with a CBDC.
This leads to a fairly simple conclusion.
The U.S. is not launching a retail CBDC.
But the country is already building a system of private digital dollars, in which some control mechanisms that critics of CBDC warn about already exist and may spread as the stablecoin market grows and tokenization develops.
The next political discussion will revolve around restrictions. How broad can legal orders be? How long can a temporary freeze of funds last? What protection procedures exist if a freeze occurred by mistake? And will self-custody of assets remain a real alternative as the regulated digital dollar infrastructure grows?
The answers to these questions will determine whether a truly multi-layered system of digital money will appear in the U.S. or a private version of the same control mechanisms that the country publicly rejects.
#CBDC #usa #GeniusACT #etf #SEC
