What Was Filed
The U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) jointly published a proposed rule on April 8, 2026 to implement the anti-money laundering and sanctions compliance provisions of the GENIUS Act — the Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law by President Trump in July 2025.
The proposed rule would formally classify permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA). That classification is not symbolic. It triggers a full suite of compliance obligations that most crypto-native stablecoin issuers have never been formally required to maintain, including anti-money laundering programs, countering the financing of terrorism controls, suspicious activity reporting, customer due diligence, and the technical capability to block, freeze, and reject transactions linked to sanctioned actors or illicit activity.
The OFAC component requires issuers to establish a risk-based sanctions compliance program with regular internal auditing, ongoing screening of wallet addresses against the Specially Designated Nationals list, and defined protocols for when sanctioned address interactions occur during minting, redemption, or secondary transfers.
“Bringing stablecoin issuers into full BSA/OFAC compliance effectively turns them into bank-like gatekeepers. That means significantly more wallet freezes, transaction blocking and asset seizures at scale.” — Snir Levi, CEO of Nominis
The Timeline
The proposed rule opens a 60-day public comment period from the date of publication. The GENIUS Act sets statutory deadlines beyond that: final implementing regulations must be issued by July 18, 2026, and full enforcement begins no later than January 18, 2027. Alternatively, the law becomes effective 18 months after its July 2025 signing, whichever comes first.
The day before the Treasury filing, on April 7, the Federal Deposit Insurance Corporation (FDIC) published its own GENIUS Act proposed rule. The FDIC’s version establishes a prudential framework for FDIC-supervised stablecoin issuers and confirmed that stablecoin holders will not be covered by deposit insurance, though reserve assets backing those stablecoins — held on deposit at insured institutions — would retain FDIC protection. The two proposals together form a multi-agency implementation wave converging in a short window.
What Issuers Will Need to Build
Under the proposed framework, stablecoin issuers must designate a compliance officer responsible for overseeing AML and CFT programs — a U.S.-based individual without prior convictions tied to financial misconduct including insider trading, cybercrime, or fraud. They must implement systems capable of identifying, monitoring, and reporting suspicious transactions in real time and must build operational workflows for blocking or freezing wallets when sanctions exposure is detected.
FinCEN noted the obligations are designed to be “fit for purpose” — scaled to the size and complexity of each issuer — and that the agency generally would not take enforcement action against issuers that have already implemented adequate compliance procedures at the time the rule takes effect. That language signals a degree of regulatory forbearance for issuers who demonstrate good-faith preparation rather than waiting for the enforcement deadline.
Treasury Secretary Scott Bessent framed the proposal as compatible with, not hostile to, stablecoin growth: “This proposal will protect the U.S. financial system from national security threats without hindering American companies’ ability to forge ahead in the payment stablecoin ecosystem.” The administration’s position is that compliance infrastructure and market expansion are complementary, not in tension.
The Broader Regulatory Picture
The GENIUS Act implementation is moving through multiple federal agencies simultaneously while the broader digital asset market structure legislation remains stalled in the Senate. The CLARITY Act, which passed the House last year, has not yet been scheduled for a markup by the Senate Banking Committee. Crypto and banking industry representatives have been meeting with White House officials on unresolved issues including stablecoin yield — a provision that would ban stablecoin issuers from paying yield to holders.
The White House Council of Economic Advisers said on April 8 that a yield ban “would do very little to protect bank lending” and would impose costs on users, signaling White House skepticism of that particular provision. The Senate Banking Committee had not rescheduled a markup as of the same day.
Civil liberties advocates have flagged a separate concern about the FinCEN/OFAC framework. Coin Center noted that requiring issuers to collect identifying information about users on public blockchains raises financial surveillance risks if implemented without adequate privacy safeguards. The comment period is the primary mechanism for those concerns to be formally addressed before the rule is finalized.
