The US has rejected CBDCs, but stablecoins can still freeze digital dollars and interact with government agencies.
America Rejects CBDCs but Builds a Similar System of Control
Washington has legally refused to launch a retail digital dollar from the Federal Reserve System. At the same time, a new model for regulating stablecoins is taking shape. It is gradually enshrining the functions of freezing funds, blocking transactions, rejecting them, or temporarily suspending them. Such mechanisms can be applied to private dollar tokens as well as, increasingly, to tokenized financial assets.
In January, President Donald Trump signed an order prohibiting government agencies from creating, issuing, or promoting a US central bank digital currency.
This step clearly showed the political position: Washington wants to appear as an opponent of CBDCs.
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, monitoring of suspicious activities, and the technical ability to block, freeze, or reject transfers at the lawful request of authorities.
This does not mean that a hidden equivalent of CBDCs has already appeared in the US. A stablecoin remains a private obligation of the issuer, not a direct claim on the central bank.
Moreover, the current system does not have a single national transaction registry, a universal government wallet, or signs that federal authorities plan to move the population to a retail payment system managed by the Federal Reserve.
If This Isn't a CBDC, Why Does It Look So Similar
But the question arises: does Washington really reject the very idea of a CBDC, or is it simply avoiding the name while simultaneously creating a regulated system of private digital dollars that in practice may provide similar control tools?
It is precisely the gap between legal status and how the system will work for users that is now becoming the main political issue.
This debate is also noticeable at the state level. It has been ongoing for more than a year.
Several states have passed laws against CBDCs. However, it is more accurate to say that they have restricted their use, not completely banned them.
Florida changed its legislation back in 2023 and excluded CBDCs from the category of money within the UCC system.
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Wyoming in 2025 formulated its position even more directly. The state's legislative findings state that CBDCs could lead to the centralization of financial data, strengthen the link between household spending and the state, and make it easier to restrict certain purchases.
This wording is important because it sets the tone 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 System?
The federal government is already partially answering this question.
In a White House report dated July 30, 2025, it is stated 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 advised to consider a special law for digital assets. It would allow financial organizations to temporarily hold funds during short investigations related to possible theft or fraud, without the risk of legal consequences.
At the same time, the document also supports the right to self-custody of crypto assets and legal transfers between users without the involvement of a financial intermediary.
As a result, a multi-layered regulatory model is being formed.
On the one hand, there is rhetoric about free and decentralized transactions. On the other, control tools are emerging at the core of the regulated dollar infrastructure.
The Architecture That Washington Is Actually Building
The GENIUS law translated this approach from political recommendations into legal norms.
The document requires authorized stablecoin issuers to have the technical capability, as well as internal policies and procedures, to block, freeze, and reject 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 also apply to foreign stablecoins if they are offered to users in the US.
As a result, the US position looks fairly consistent: there is no retail CBDC, but there is a private sector of digital dollars with built-in control mechanisms.
One example illustrates this contradiction well.
A company associated with the US president has its own stablecoin. On the World Liberty Financial website, it is stated that Donald Trump and related entities have a significant economic stake in the project. At the same time, BitGo is the official issuer and custodian of the USD1 token.
Risk documents state that BitGo can restrict access for certain addresses. The company can also temporarily or fully freeze USD1 if it believes an address is associated with illegal activity or violates service rules.
In addition, BitGo has the right to share information with law enforcement, comply with legal orders, and block transfers between certain on-chain addresses.
The political rhetoric sounds like “against CBDCs.” But the operational documents themselves contain features that CBDC critics have been warning about for many years. And this model is not unique to the Trump-linked token.
Risk documents for USDC state that Circle can block certain addresses, temporarily or permanently freeze tokens, share data with law enforcement, and comply with legal requirements.
In January 2026, Tether launched USA₮ for the US market. The announcement specifically 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 clear.
Stablecoins with the ability to freeze funds 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 routine part of the digital dollar infrastructure?
Market size helps to understand the scale, but it's also important to look at its structure.
In the July White House report, it was said that as of July 14, 2025, the volume of fiat-backed stablecoins was $238 billion. Current market data already shows about $313 billion. In less than a year, the market has grown significantly.
But if you look at usage, the picture is more restrained than the overall numbers suggest.
According to the BCG report for 2026, the annual volume of stablecoin transfers on the blockchain exceeds $62 trillion. However, real economic activity is only about $4.2 trillion.
The rest of the turnover is related to trading, liquidity management, and other crypto market infrastructure.
This payment infrastructure is strategically important. But so far, it has not become the main means of settlement for ordinary consumers in the US economy.
Market Scale Makes the Architecture Especially Important
That is why the discussion about the future of stablecoins is now 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 a Citi forecast published in April 2026, stablecoin issuance could reach $1.9 trillion by 2030 in the base scenario. In a more optimistic scenario, the figure could rise to $4.0 trillion.
Analysts also expect a sharp increase in turnover. In the base scenario, transaction volume could approach $100 trillion, and in a more optimistic scenario reach $200 trillion if asset velocity remains high.
Such estimates show that decisions being made now could have long-term consequences. Mechanisms for executing legal orders, freezing funds, and temporarily blocking operations in the future may extend to a much larger share of digital dollar transactions.
At the same time, the discussion is already going beyond just stablecoins.
In December 2025, DTCC announced that it had 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, and the launch is planned for the second half of 2026.
The list of assets that can participate in the program includes major US company stocks, ETFs, and US government bonds.
In the accompanying materials, the company specifically emphasizes infrastructure requirements. These include wallet registration, management systems, transaction transparency, platform resilience, and token features that take regulatory requirements into account.
Thus, the question is gradually changing. It's no longer just about whether a stablecoin can be frozen. Increasingly, the discussion is 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 move to infrastructure with user identification and the ability to intervene by legal request, the line between private and government 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 allowed may still reflect government policy priorities.
This argument is often called functional convergence of systems. It does not require claiming 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 also has serious opponents.
In its 2025 annual report, the Bank for International Settlements (BIS) acknowledged that tokenization could change the financial system. At the same time, the report expresses doubts that stablecoins will become its foundation.
Instead, experts point to other elements of future infrastructure. These include tokenized central bank reserves, bank money, and government bonds.
Citi analysts reach a similar conclusion from the market side. Their forecast states that by 2030, bank tokens could process from $100 trillion to $140 trillion in transactions. For corporate clients, this format may be more attractive, since privacy on public blockchains remains a serious problem.
If you add to this the volume of payments via FedNow in 2025, it becomes clear that the future system is unlikely to be built around a single instrument.
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 base scenario assumes the development of a regulated system of private digital dollars, not the launch of a retail CBDC in the US.
In this scenario, the country maintains a public stance against CBDCs, develops the stablecoin market under the control of the GENIUS law, and at the same time leaves room for other forms of digital money. This includes self-custody of assets, transfers between users, the FedNow system, and other formats of tokenized money.
Freezing of funds in this case remains a targeted measure and is applied based on the law, rather than becoming a universal control mechanism.
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However, the system is gradually getting used to intervention. For many critics of CBDCs this seems unexpected, since the model formally remains private.
The main change may turn out to be not only legal but also cultural. Blocking operations, freezing funds, and temporary holds are gradually ceasing to be seen as exceptional measures. Over time, they may become a regular part of the regulated digital dollar infrastructure.
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 gradually improve.
Institutional flows are distributed among stablecoins, bank tokens, and other authorized payment systems. This means users are not tied to a single dominant digital dollar.
In such a system, the US gets more digital dollars, but they do not turn into a single state infrastructure.
In this model, bitcoin also retains its role. It remains the largest digital asset without an issuer, without a fund freezing function, and without a mechanism for executing legal orders at the protocol level. Stablecoins, meanwhile, continue to serve as the regulated dollar segment within the crypto industry.
The negative scenario looks less dramatic than the popular talk of a “Federal Reserve wallet.” But it may be 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 is in the gradual expansion of practice. This may manifest in broader wallet checks, more frequent temporary fund blocks, and more aggressive interpretation of suspicious activities. At the same time, pressure on issuers and exchanges may increase so that they first block operations and only then deal with user complaints.
Formally, such a system still will not be a CBDC.
However, for users, it may begin to resemble the control usually associated with CBDCs.
This leads to a fairly simple conclusion.
The US is not launching a retail CBDC.
But the country is already building a system of private digital dollars in which some control mechanisms that CBDC critics warn about already exist and may spread as the stablecoin market grows and tokenization develops.
The next political debate will be about restrictions. How broad legal orders can be. How long temporary fund blocks can last. What protection procedures exist if a freeze occurs by mistake. And whether self-custody of assets will 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 US or a private version of the same control mechanisms the country publicly rejects.
