Part V is live.

A foreign issuer that wants to sell payment stablecoins to US customers needs one thing before it can register with the OCC: a Treasury Secretary determination that its home jurisdiction's regulatory regime is "comparable" to the GENIUS Act.

Treasury has published no criteria for that determination. No timeline has been set. No foreign jurisdiction has received one.

The gate exists. The key does not.

Part V maps the full cross-border architecture:

• the four mechanisms of US sovereign control over foreign digital dollar circulation,

• the five structural gaps in the comparability determination that explain why no foreign jurisdiction has been approved and no foreign issuer can meaningfully access the US market,

• the US reserve requirement that functions as a geopolitical instrument - and

• the sanctions architecture that gives the United States three independent ways to exclude a foreign issuer from US markets without a GENIUS Act proceeding.

The FDIC comment period closes June 9. The Treasury comparability NPRM has not been published. The framework is being written now.

→ [The GENIUS Files — Part V: Sovereignty & Cross-Border Scale]

Regulation is the actual game.