Regulatory Alerts2026-04-08 | PDF OnlyAdded
Proposed Rule to Implement the GENIUS Act’s Anti-Money Laundering Obligations and Sanctions Compliance Program Requirements
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) propose a joint rule treating permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act. The proposal requires PPSIs to establish risk-based anti-money laundering and countering the financing of terrorism programs, including independent testing, officer designation, and employee training. It mandates technical capabilities to block or freeze transactions violating U.S. sanctions, file suspicious activity reports for primary market activity, and maintain specific recordkeeping and due diligence standards. The rule also outlines enforcement policies and a consultation framework between FinCEN and primary federal regulators.