Weighted average tenor exceeds the 93-day ceiling for Treasury bills held as reserve assets. Three holdings mature outside the window. Roll or reclassify before certification.
GENIUS Act § 4(a)(1)(A)Built for the regimes that decide who can issue, custody and trade digital assets
From working out which obligations actually bind you, through to the filing leaving the building with a name against it.
Map every entity against both perimeters. Four of six in scope is a very different programme from six of six.
Agents draft filings against encoded rules, citing the source provision beside every requirement applied.
A specialist reviews what the agents produced and signs it off. Nothing leaves on an algorithm's say-so.
Rules are still moving. When one is amended you learn what changed and which filings it touches.
Regulatory filings are among the most sensitive documents a firm produces. We treat them that way.
Audit in progress
Certification underway
No shared infrastructure
Every action, human or agent
In July 2025 the United States had no federal statute for stablecoins. The UK had a discussion paper. Firms were regulated by analogy, when they were regulated at all: a bit like e-money, a bit like payments, depending on who you asked.
Then the GENIUS Act was signed. Eleven companies filed for national trust charters inside eighty-three days. The Bank of England opened its consultation that November. The FCA took twenty sandbox applications and raised its estimate of UK issuers from ten to twenty-five.
By June 2026 the FCA had published five policy statements in one go. The machinery did not keep up. US agencies went past their own rulemaking deadline, and the return forms are still being designed. Firms have to build compliance programmes against rules that are settled in principle and unfinished in practice.
We have done this before. Our team built regulatory reporting infrastructure inside a globally systemically important bank, pulling supervisory information together from dozens of source systems, reconciling it, and getting it out before the deadline.
Undrstudy helps the teams building the future of money do the same job for rules that are still being written.
Full access to the reporting suite, a named specialist on your account, and entity scoping across both perimeters. We take on a limited number of firms so the desk stays properly staffed per client rather than spread thin.
No. Much of the work happens before rules commence: building against published drafts, flagging what's settled against what's still proposed, and drafting consultation responses. We engage with regulators directly too, so what we learn there feeds back into what you file.
Yes, and it's the most common starting point. The September gateway is the nearest hard deadline for UK firms, and existing money-laundering registrations will not convert automatically into equivalent permissions. If you also have a US entity, the cross-border mapping matters more than most firms expect.
No. Agents draft and check. A specialist reviews and signs off before anything is submitted. Every action is logged and every requirement carries a citation back to the source provision.