The GENIUS Act regulates issuers. We're not one.
In July 2025 the United States passed the GENIUS Act — its first federal framework for payment stablecoins. In April 2026 the FDIC proposed RIN 3064-AG19 to implement it: reserve accounting, audit standards, capital rules, and deposit-insurance treatment for stablecoin issuers and the banks that hold their reserves.
Every one of those obligations attaches to the same two roles: the party that issues the stablecoin, and the party that custodies the funds. DNS://Money is neither. This page explains exactly where we sit relative to that regulatory perimeter — and why it is an architectural fact, not a marketing claim.
Where the rule's burdens actually land
The GENIUS Act and RIN 3064-AG19 govern reserves, custody, capital, and insured deposits. Map each obligation to who carries it, and the line is clean:
| Regulated obligation | Who carries it | DNS://Money |
|---|---|---|
| Hold & segregate stablecoin reserves | Issuer (e.g. Standard Custody & Trust Co.) | No — holds no reserves |
| Custody customer funds | Chartered custodian | No — never custodies |
| Reserve accounting & attestations | Issuer | No — n/a |
| Deposit insurance & Part 330 recordkeeping | Insured depository institution | No — not a bank |
| Capital requirements | Parent bank / IDI | No — n/a |
| Resolve a name to a payment endpoint & route it | — | Yes — this is us |
DNS://Money resolves a pay: alias to a deterministic on-chain settlement address, verifies the resulting payment, and records it. It reads the money path — it never holds it. There is no intermediary account that takes a payment in and forwards it out. That is the same hard architectural line described across the rest of the system: a name registry, a resolver, a deterministic router, and ISO 20022 compatible message generation — never a bank.
The dollars are regulated. We just move them.
When a payment settles in RLUSD, the regulated entity in the picture is the stablecoin's issuer, not DNS://Money. RLUSD is issued by Standard Custody & Trust Co., a New York limited-purpose trust company chartered and supervised by the NYDFS. Its reserves are held in segregated short-dated U.S. Treasury securities at greater than 1:1 backing, with monthly third-party attestations by Deloitte & Touche.
That separation is the whole point. The asset you settle in carries its own regulatory pedigree; DNS://Money is the deterministic resolution-and-routing layer that delivers a payment in that asset to the right place. We ride a regulated rail — we don't improvise one, and we don't become one.
Two settlement paths, both non-custodial
There is exactly one thing DNS://Money never does in either path: receive a customer's funds and hold them. Beyond that, two flows exist:
- Payer-signed. In the consumer wallet flow, the payer signs and submits their own XRP Ledger payment; the destination is the recipient's resolved address. DNS://Money resolves and records — it never signs or touches the funds.
- Service-signed. An authenticated developer can ask the API to settle on their behalf, in which case DNS://Money sends the payment from its own wallet directly to the recipient. That spends our own capital as a payment service — it is not custody (no customer funds are received and forwarded) and not stablecoin issuance.
In both cases the value moves directly to the recipient on the ledger. Nothing is pooled, and nothing is held on a customer's behalf.
Read the API →FAQ
Is DNS://Money a stablecoin issuer under the GENIUS Act?
No. DNS://Money does not issue any stablecoin. It is a payment-orchestration and alias-resolution layer that routes settlement in regulated stablecoins like RLUSD, which is issued by Standard Custody & Trust Co. under NYDFS supervision. The GENIUS Act and the FDIC's RIN 3064-AG19 govern issuers and custodians of payment stablecoins — categories DNS://Money does not fall into.
Does DNS://Money hold customer funds or custody crypto?
No. DNS://Money never receives, pools, holds, or custodies customer funds — there is no intermediary account that takes a payment in and forwards it out. Every payment settles directly on the XRP Ledger to the recipient's resolved address, and DNS://Money's role is to resolve the alias, verify the on-chain settlement, and record it. It holds no reserves and no customer deposits.
Is DNS://Money subject to FDIC rule RIN 3064-AG19?
No. RIN 3064-AG19 implements the GENIUS Act for FDIC-supervised permitted payment stablecoin issuers, custodians, and insured depository institutions. DNS://Money is none of those — it is a non-custodial orchestration and address-resolution layer — so the rule's reserve, capital, and deposit-insurance obligations do not apply to it.
What is RLUSD and is it regulated?
RLUSD is a U.S. dollar-backed stablecoin issued by Standard Custody & Trust Co., a New York limited-purpose trust company chartered and supervised by the NYDFS. Its reserves are held in segregated short-dated U.S. Treasury securities at greater than 1:1 backing, with monthly third-party attestations by Deloitte & Touche.
If DNS://Money doesn't hold money, how does a payment to a pay: alias work?
A pay: alias resolves deterministically to the recipient's on-chain settlement address, and the payment settles directly on the XRP Ledger to that address. In the consumer flow the payer signs and submits the transaction from their own wallet; in all flows the value goes straight to the recipient and is never pooled, held, or routed through a DNS://Money account. DNS://Money resolves the alias and records the settlement — it is never an intermediary that holds the funds.
This page describes DNS://Money's technical architecture and regulatory posture for general information. It is not legal advice and is not a regulatory determination by any agency. RIN 3064-AG19 was a proposed FDIC rule; its public comment period closed on 2026-06-09.