Four Major Crypto Developments are Redrawing the Map for CPAs

Sean Stein Smith, CPA, DBA, CMA, CGMA, CFE, City University of New York – Lehman College – September 5, 2025

This summer has not just nudged the crypto world — it’s reconfigured the landscape entirely. Four major developments are reshaping the terrain: the enactment of the GENIUS Act, the House passage of the CLARITY Act, accelerating institutional adoption of Bitcoin and the rise of non-bank stablecoin issuers (including Wyoming’s Frontier token). Along with evolving tax rules, each carries direct implications for CPA firms. The question is no longer whether to engage — but how quickly.

The GENIUS Act Brings Stablecoin Oversight

For the first time, the federal government has enacted a stablecoin regulatory framework. The GENIUS Act mandates that payment stablecoins be backed one-for-one with high-quality liquid reserves, requiring monthly disclosures and forbidding interest payments to coinholders. It also creates a tiered system allowing both bank and Office of the Comptroller of the Currency (OCC)-approved non-bank issuers — including certain state-authorized entities — to participate in issuance.

For CPAs, this shift opens new avenues: expect demand for reserve attestations, SOC reporting over issuance/redemption processes, and advisory around liquidity, segregation and internal disclosures.

In addition, the Act’s bankruptcy provisions elevate holders’ priority claims over stablecoin reserves, creating novel risk modeling needs. CFOs will look to accountants to quantify these risks, model liquidation versus reorganization scenarios and assess covenant impacts.

CLARITY Act Advances Market Structure Reform

Meanwhile, the CLARITY Act, passed by the House in mid-summer, promises to demarcate authority between the Securities and Exchange Commission (SEC) and the Commodity Futures Trading Commission (CFTC), streamline digital-asset registration and disclosure and clarify market-structure rules. Even in anticipation of Senate action, firms are already being asked to prepare “CLARITY-ready” controls and financial-statement treatment assessments. In effect, it serves as a practical rulebook for what was once only hinted at in earlier initiatives like FIT21.

Institutional Buying Normalizes Bitcoin

Bitcoin’s institutional embrace has accelerated. Spot Bitcoin exchange traded funds (ETFs), approved in early 2024, now carry tens of billions in assets — BlackRock’s IBIT alone leads the way — offering regulated, audited wrappers with daily net asset values (NAVs).

For CPAs, this means more work with 40-Act reporting, handling broker-generated 1099 data and adapting investment-policy statements. Public-company filings will also see new fair-value accounting, consolidation issues and disclosure requirements tied to crypto holdings.

Beyond ETFs, direct corporate treasury adoption of Bitcoin is on the rise. Under ASU 2023-08 (effective for fiscal years starting after December 15, 2024), fair-value measurements, impairment histories, volatility in earnings and potential Camtek (CAMT) exposure now matter — so firms must update accounting memos, valuation controls and tax planning strategies accordingly.

Stablecoins Expand Beyond Banks — Wyoming Leads

Stablecoins issued by non-bank actors are no longer hypothetical. The GENIUS Act explicitly permits OCC-approved non-bank and state-authorized issuers below certain thresholds. Wyoming has seized the opportunity with its Frontier Stable Token (FRNT) — a fully reserved, over-collateralized, dollar-pegged token launched across seven blockchains, with monthly attestations and named custodial and audit partners.

This state-issued stablecoin presents a new kind of client: government-backed digital assets requiring multi-chain reconciliation, treasury income accounting, third-party risk frameworks and ongoing assurance over reserves. Expect this model to be replicated elsewhere.

Tax Movements: The Ground Is Shifting

On the tax side, holders still treat crypto as property — wash-sale rules don’t apply (yet). Brokers and platforms are rolling out Form 1099-DA starting in 2025, with transition relief. Tax professionals will have to help clients reconcile cost basis across wallets, custodians and DeFi platforms — especially since seemingly routine on-chain actions can trigger taxable events.

For companies, ASU 2023-08 moves fair-value gains and losses into the income statement, impacting adjusted financial income — and potentially CAMT obligations. Treasury teams must model exposures from both GAAP and tax perspectives.

What CPA Firms Should Do Now

1. Craft a comprehensive crypto-care matrix, including:

ASU 2023-08 financial reporting readiness
Stablecoin reserve attestation capabilities
Tax strategy and compliance (e.g., basis tracking, CAMT modeling)
Broker/1099-DA preparedness
Governance, risk and CLARITY/GENIUS compliance advisory

2. Build cross-functional crypto pods that unite assurance professionals, tax specialists, risk advisors and data analysts. Crypto work is inherently collaborative.

3. Issue client-facing policy statements explaining:

The services the firm will (and won’t) offer
Pricing for continuous assurance services
Independence safeguards when dealing with token issuers or custodians

This summer’s developments signal that crypto finance is moving from fringe novelty to institutional mainstream. For CPAs, this isn’t a wave to ride — it’s a new bedrock. Those who act now can define the framework clients will rely on for years to come.

Sean D. Stein Smith

Dr. Sean Stein Smith, CPA, DBA, CMA, CGMA, CFE, is an associate professor at the City University of New York – Lehman College. He is a member of the NJCPA Board of Trustees, a New Jersey CPA Political Action Committee Trustee and participates on several interest groups.

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