Crypto enhancement to the complete US “financial infrastructure” by 2028: Is Trump aligned with this goal?

Earlier this year, President Donald Trump pledged a “21st Century” payment enhancement without necessitating a central bank digital currency, placing the GENIUS Act at the forefront of the initiative.

The legislation is already enacted; however, the operational guidelines are still pending.

In July, Trump commended the cryptocurrency sector, stating:

“You have certainly as an industry gone up more than anybody. Nobody’s gained the respect in such a short period of time.”

He proceeded to make a significant commitment to the industry he now holds in high regard,

“Many Americans are unaware that behind the scenes, the technical backbone of the financial system is decades out of date[…] but payments and money transfers are costly and take days or even weeks to clear.

Under this bill, the entire ancient system will be eligible for a 21st-century upgrade using the state-of-the-art crypto technology[…]

This will increase demand for US treasuries, lower interest rates and secure the dollar’s status as the world’s reserve currency for generations to come.”

Trump also expressed his belief that stablecoins contribute to safeguarding the dollar. He claimed that he is “not going to let the dollar slide,” asserting that with a “smart president, you’re never going to let the dollar slide.”

At the time of his speech, the dollar had depreciated by 12% since he assumed office in January. Subsequently, it appreciated by 3% over the following months.

Notably, as the dollar declined, Bitcoin surged. Currently, the dollar is rebounding, while Bitcoin is experiencing a downturn.

Can Trump maintain the dollar’s strength without compromising on crypto?

Bitcoin vs the dollar 2025 (Source: TradingView)

The Treasury commenced processes related to the GENIUS Act on September 18 with an advance notice of proposed rulemaking that seeks feedback on how to license issuers, establish capital and liquidity requirements, and define permissible activities for banks.

The consultation phase is the initial step toward binding standards that would enable banks and payment firms to issue fully backed dollar stablecoins under federal oversight.

From banning CBDCs to rewiring the payments stack

The initial promise was framed as modernizing an “ancient” system without creating a CBDC.

In an executive action signed on January 23, Trump instituted a ban on CBDCs, and bills to formalize it have passed the House but are not yet enacted. The policy direction is established, while statutory details and implementation are still pending.

Oversight has evolved in a manner that is significant for banks aiming to integrate with crypto infrastructure. This spring, the OCC, Federal Reserve, and FDIC rescinded previous “ask permission first” guidelines and reopened custody, stablecoin, and payment DLT activities, which will alleviate friction once the Treasury finalizes the standards.

The OCC also released specific bulletins regarding bank activities related to digital assets, reestablishing permissible pathways under review for safety and soundness. According to the OCC, clarity on allowable activities will align with the GENIUS framework for issuers and payment stablecoin service intermediaries.

Throughput on public stablecoin networks is already considerable by on-chain metrics, although a significant portion is intra-exchange and automated, rather than point-of-sale transactions. Industry research from McKinsey positions the stablecoin concept as tokenized cash for settlement and treasury, rather than a direct replacement for consumer transactions from the outset.

According to McKinsey, distribution and last-mile integration drive real-economy impact once backing standards converge under regulations like GENIUS. After reserves are standardized, competition will focus on who controls distribution among merchants, acquirers, and wallets.

Instant rails catch up to crypto speed

Legacy instant payment systems are not remaining static. According to the Federal Reserve’s FedNow statistics, the network settled 2.5 million payments totaling $307 billion in the third quarter.

The private Real-Time Payments network processed $481 billion in the second quarter, achieving a single-day record of 1.81 million transactions and $5.2 billion on October 3. Swift reports that 90% of cross-border payments now reach the destination bank within one hour on GPI, which reduces the speed gap that previously distinguished public chains from correspondent banking.

The competitive advantage for crypto networks lies in 24/7 availability, weekend and cross-border settlement, programmability, and capital efficiency at the treasury level, rather than sheer domestic speed.

The infrastructure that connects these advantages to everyday commerce is becoming operational. Visa has broadened stablecoin settlement support across additional currencies and chains, and is enhancing this capability with more acquirers.

Mastercard has introduced end-to-end functionalities to facilitate stablecoin transactions from wallets to checkouts, and has initiated regional settlement rollouts for USDC and EURC in areas where cross-border friction is highest.

According to Visa Investor Relations and Mastercard, these integrations allow for the movement of stablecoins into acquirer ledgers and settlement files without altering the consumer checkout experience.

Pilot programs with fintech infrastructure providers, including those with Finastra and regional partners, indicate that operational rails are active in limited forms. Acquirer and PSP adoption can scale with clearer rules on liability, capital, and reserve composition.

When the ‘replacement’ becomes measurable

Policy timing establishes the parameters for when a “replacement” rail can be assessed in practice. Following the administrative sequence, Treasury’s ANPRM in September is typically succeeded by a notice of proposed rulemaking in the following quarters, and then a final rule after a comment period.

According to the Treasury docket, the final GENIUS regulations are anticipated for implementation in 2026, contingent on adherence to timelines. Concurrently, banking agencies must establish capital, liquidity, and oversight standards for PPSIs and for banks that hold reserves or intermediate stablecoin settlements.

Market-structure legislation, including the Digital Asset Market Clarity Act that passed the House in July, would clarify the classification of exchanges and commodities versus securities, but has less immediate impact on payments.

Future adoption will hinge on whether card networks and acquirers transition their settlements to stablecoins, which can lower costs or expedite processing times. The realistic near-term trajectory is replacement in settlement, rather than at the point of sale.

PSPs and acquirers can net merchant receivables in USDC or EURC on weekends or across borders, then utilize bank funds where they are more economical or where policy necessitates it.

If this method scales, the consumer experience remains unchanged while the backend routes through multiple systems. According to Mastercard, multi-rail acceptance is already a program objective.

For banks, the renewed OCC guidance indicates that reserve custody, tokenized cash activities, and payments DLT can be situated within existing risk frameworks once final rules define eligibility and oversight.

Stablecoins, Treasuries, and the dollar strategy behind GENIUS

The dollar strategy embedded in GENIUS relies on fully backed reserves held in Treasury bills and cash. If supply and distribution expand under federal licensing, the reserve base creates a consistent demand for short-dated U.S. government debt.

A larger stablecoin supply directs demand into 1- to 3-month bills, thereby bolstering dollar distribution internationally, provided that par convertibility and intraday liquidity are strong.

J.P. Morgan has released a conservative estimate regarding the market’s scale, while McKinsey and Standard Chartered outline larger potential outcomes. The range is less significant than convertibility, audits, and narrow-banking-style safeguards that address bank supervisors’ concerns about the singularity of money, elasticity, and integrity.

There exists an alternative path where public stablecoins plateau and bank-led tokenized deposits take precedence. The Bank for International Settlements describes a next-generation system centered around tokenized deposits and unified ledgers anchored in central bank reserves.

Along this route, most real-economy transactions utilize FedNow, RTP, and SWIFT GPI both domestically and internationally, with tokenization integrated within bank balance sheets and wholesale platforms. Public stablecoins would then remain a crypto-native rail with restricted use.

The outcome depends on how U.S. regulations address bank access, capital, and liquidity, as well as how card and acquirer networks price weekend and foreign exchange corridors.

The early scorecard on Trump’s ‘replacement’ system

Short-term assessments indicate progress, not completion. Rules are under consultation, the OCC and the Fed have softened their stance on bank participation, SEC leadership has changed, and the card networks are implementing.

Outstanding elements include the final GENIUS regulations, coordinated bank capital and liquidity treatments for PPSIs and bank intermediaries, and widespread acquirer adoption among the largest merchant processors.

Meanwhile, instant payment systems are advancing. According to FRB Services, FedNow value and volume are increasing quarter over quarter. RTP’s throughput and transaction limits have expanded, which diminishes the domestic gap that crypto once capitalized on.

For those monitoring whether the replacement is authentic, observe metrics that evaluate the settlement concept rather than relying on consumer-facing anecdotes. Key dates to note include Treasury’s NPRM and final rule milestones, OCC and Fed capital and liquidity specifics, and acquirer dashboards that indicate the proportion of merchant settlements routed to stablecoins by corridor and day of the week.

Track the number of banks that maintain stablecoin reserves and operate on- and off-ramps under OCC guidance. Compare stablecoin weekend and FX costs against Swift GPI routes at the corridor level. Monitor aggregate Treasury bill holdings by licensed issuers against auction sizes. These are the indicators that translate political commitments into tangible payments infrastructure.

Rail	Recent datapoint	Source
FedNow	$307B settled in Q3 2025, 2.5M payments	FRB Services
RTP	$481B in Q2 2025, Oct. 3 record 1.81M tx / $5.2B	PYMNTS
Swift GPI	90% reach destination bank within one hour	Swift
Visa	Expanded stablecoin settlement support, more coins and chains	Visa IR
Mastercard	End-to-end stablecoin capabilities live in select regions	Mastercard
GENIUS rules	ANPRM opened Sept. 18, 2025	U.S. Treasury

In summary, crypto is emerging as a settlement layer within multi-rail payments, while the consumer experience remains unchanged.

The true turning point will occur once GENIUS regulations are finalized and acquirer adoption is reflected in measurable settlement flows.

Is Trump on track to deliver a true ‘replacement’?

Thus far, Trump has established a direction rather than constructed a completed system. The CBDC ban, the GENIUS framework, and a more favorable stance from the OCC and Fed toward bank participation all steer U.S. policy toward crypto-based settlement systems.

Card networks and PSPs are integrating those systems into production, and banks are being informed of what “permissible” entails. This represents real advancement toward a crypto-native settlement layer.

However, a complete replacement of legacy systems is far from accomplished. FedNow, RTP, and Swift GPI are scaling concurrently, rather than being phased out. GENIUS standards are still under review, bank capital regulations for PPSIs remain unresolved, and acquirer adoption is in initial pilot stages rather than being implemented across the board.

Even on an aggressive timeline, much of the heavy lifting, including final regulations, bank balance-sheet treatment, and cross-border corridor development, is expected to take place in 2026, and realization is likely to extend beyond his second term.

The most plausible outcome is not a straightforward exchange of one system for another, but a multi-rail framework where stablecoins and tokenized deposits manage settlement in the background while cards and instant bank transfers remain the consumer interfaces.

In that scenario, Trump can credibly assert that he has advanced the system toward crypto rails and away from a CBDC, but the “replacement” he envisioned will resemble a gradually reconfigured backend rather than a sudden elimination of legacy systems.

So is he on track?

At this point, he is on track to influence how the next-generation framework is structured, rather than completely replacing legacy systems within a single term.

The current assessment indicates: policy momentum and active pilots, but no definitive shift where the majority of U.S. and global retail payments transition to crypto settlement.

Until bank capital and liquidity standards are finalized, and acquirer dashboards reflect stablecoins capturing a significant share of settlement, Trump’s replacement remains a developing concept, not a fully realized system.

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