The GENIUS Act: America's First Stablecoin AML Framework and What It Means for Issuers

In April 2026, FinCEN and OFAC jointly published a proposed rule implementing the GENIUS Act — America's first federal regulatory framework for payment stablecoins.

The core requirement: permitted payment stablecoin issuers (PPSIs) will be treated as financial institutions under the Bank Secrecy Act. Full AML programs, sanctions compliance, suspicious activity reporting, and customer due diligence. Comments due June 9, 2026.

What the GENIUS Act Requires

AML Program: Internal policies, designated compliance officer, ongoing training, independent testing.

Sanctions Compliance: For the first time mandated by statute. Risk-based screening, transaction monitoring for evasion, blocking procedures.

SAR Filing: Suspicious activity reports for transactions involving illegal funds, evasion, or no apparent lawful purpose.

Customer Identification: CIP at the issuer level.

Who This Affects

Circle (USDC): Best positioned. Already registered as money transmitter, Treasury-weighted reserves, regular attestation reports.

Tether (USDT): Harder path. No full independent audit, opaque structure. May need to restructure US operations.

New entrants: Traditional banks now have a clear regulatory framework for stablecoin issuance.

What to Do Before June 9

Submit comments. Assess your stablecoin exposure. Update your compliance framework.

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