Circle raised $222 million for its proprietary Layer-1 blockchain, Arc, positioning itself not just as a stablecoin issuer but as the owner of the settlement infrastructure USDC relies on. This move, backed by investors like BlackRock and Apollo, highlights a significant structural conflict unaddressed by the GENIUS Act of 2025. While the act focuses on stablecoin reserves and issuer oversight, it remains silent on the market structure implications of an issuer controlling the underlying network—a scenario akin to a currency issuer also owning the payment rails. Traditionally, financial regulations separate issuers from settlement infrastructure to ensure neutrality. With Arc, Circle gains control over transaction ordering, fees, and network rules, potentially favoring USDC over competitors. The article argues that this creates a permanent structural temptation, even if no abuse occurs. The solution lies in applying established market infrastructure principles: mandating neutral transaction ordering, transparent fee schedules, and governance separated from Circle’s commercial interests. The current pre-mainnet phase offers a critical window for regulators to establish these rules before Arc becomes entrenched. Once operational, enforcing changes would be costly and disruptive. The core question remains: should a regulated stablecoin issuer be allowed to own the settlement network its competitors must use? The GENIUS Act doesn’t answer this, but Circle’s Arc strategy makes it urgent.
marsbit2026.05.27




