Treasury Proposes GENIUS Act AML Rules for Stablecoins
Summary
The US Department of the Treasury, through FinCEN and OFAC, published a joint proposed rule on April 10, 2026 to implement the AML/CFT and sanctions compliance requirements of the GENIUS Act for permitted payment stablecoin issuers (PPSIs). The proposal would require PPSIs to establish written AML/CFT programs, file SARs, and maintain OFAC-compliant sanctions programs — marking the first federal mandate requiring a US person to maintain an effective sanctions compliance program. Comments are due June 9, 2026.
PPSIs that are currently assessing their GENIUS Act compliance frameworks should focus on the proposed 'reasonable particularity' standard for wallet and stablecoin seizures, as this may provide liability protection that did not exist under prior OFAC guidance. Firms with US-based AML/CFT programs should identify gaps against the proposed requirements before the June 9 comment deadline, since the program's structure closely mirrors existing FinCEN requirements and most remediation steps are already known.
What changed
The proposed rule would extend Bank Secrecy Act obligations to permitted payment stablecoin issuers, requiring written AML/CFT programs, SAR filing, independent testing, a US-based compliance officer, and ongoing employee training. It would also create the first statutory requirement for a US person to maintain an OFAC sanctions compliance program, including capabilities to block transactions and seize stablecoins linked to sanctioned parties.
Stablecoin issuers planning to operate under the GENIUS Act framework should monitor this rulemaking closely, as adoption would create explicit federal compliance obligations spanning both AML/CFT and OFAC domains. The open interpretive questions around supervisory deference and examiner expectations will shape how firms design their compliance programs during the comment period.
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Apr 21, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
April 21, 2026
Treasury Announces Proposed Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance
LinkedIn Facebook X ;) Embed On April 8, 2026, the US Department of the Treasury announced a joint proposed rule by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) to implement the anti–money laundering (AML) and sanctions compliance requirements of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the GENIUS Act). 1 Enacted in July 2025 and as we described in an alert, the GENIUS Act introduced the first federal framework for the issuance and regulation of stablecoins in the United States and aimed to strengthen reserve requirements, align state and federal stablecoin laws, and require clear and conspicuous redemption procedures, among other priorities.
This rule, if adopted, represents a major step in operationalizing the framework for the regulation of stablecoins. It will bring permitted payment stablecoin issuers (PPSIs) explicitly within the framework of the Bank Secrecy Act and US sanctions laws.
Core Requirements for PPSIs
The proposal presents several requirements for PPSIs, consistent with the GENIUS Act’s mandate. Most notably, PPSIs must establish and maintain a written AML and countering the financing of terrorism (CFT) program reasonably designed to prevent misuse of payment stablecoins for illicit finance. 2 The program framework closely mirrors FinCEN’s existing AML/CFT program requirements for financial institutions. Treasury emphasized in the proposed rule that AML/CFT programs should be risk-based, ensuring more resources are dedicated to higher-risk customers and activities. Like other financial institutions, PPSIs would further be required to identify, monitor and report suspicious activity to FinCEN through the filing of Suspicious Activity Reports (SARs). 3 Treasury emphasized the importance of SAR reporting to ensure law enforcement visibility into illicit finance risks involving payment stablecoins. Other key elements include independent testing of AML/CFT programs, designation of a qualified AML/CFT compliance officer located in the United States and ongoing employee training tailored to the issuer’s risk profile. 4
Because PPSIs will be formed in the United States pursuant to the GENIUS Act, they will be US persons under OFAC’s regulations and as such subject to OFAC sanctions requirements. However, the proposal would also specifically require PPSIs to adopt and maintain an effective sanctions compliance program. 5 As noted in the preamble, this portion of the GENIUS Act “represents the first time that Federal law has explicitly mandated that a particular U.S. person have an effective sanctions compliance program.” While OFAC’s Framework for OFAC Compliance Commitments has served as a model for the proposed program requirements applicable to PPSIs since it was published in 2019, such explicit statutory and regulatory requirements are novel for US sanctions compliance. The proposed rule would require policies, procedures and internal controls designed to ensure compliance with US economic sanctions laws administered by OFAC. Among other things, the proposal would require PPSIs to have technical capabilities to block, freeze and reject transactions involving sanctioned persons or jurisdictions and to have the capability to “seize, freeze, burn, or prevent the transfer of payment stablecoins it issued” when necessary to comply with a lawful order. 6 While that specific requirement is not new, the proposed rule would set out a “reasonable particularity” standard: PPSIs would be required to seize, freeze, etc., a stablecoin or wallet only if it can be identified with reasonable particularity, which may provide some protection from liability for the PPSI.
Treasury has characterized the proposal as an effort to balance innovation with national security by tailoring illicit finance controls to the specific risks presented by payment stablecoins.
Next Steps
Treasury published the proposed rule in the Federal Register on April 10, 2026. The public is invited to submit comments, which are to be received by June 9, 2026.
Significant interpretive questions remain for PPSIs beginning to assess this proposed framework. These include the standards by which regulators will evaluate the effectiveness of newly required AML/CFT and sanctions compliance programs for stablecoin issuers, the extent to which risk‑based judgments will be afforded supervisory deference, and how Treasury will assess material illicit finance risk in novel payment stablecoin business models. These open questions will inform compliance program design, examiner expectations and enforcement risk as Treasury implements this new compliance regime.
Footnotes
- Financial Crimes Enforcement Network, Press Release, Treasury Proposes Rule to Implement the GENIUS Act’s Requirements to Counter Illicit Finance (April 8, 2026), https://www.fincen.gov/news/news-releases/treasury-proposes-rule-implement-genius-acts-requirements-counter-illicit.
- Financial Crimes Enforcement Network, Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements (Proposed Rule), 91 Fed. Reg. 18,582 (April 10, 2026), https://www.govinfo.gov/content/pkg/FR-2026-04-10/pdf/2026-06963.pdf.
- Proposed Rule at 18592.
- Proposed Rule at 18598.
- Proposed Rule at 18604.
- Proposed Rule at 18605. ;) ;) Report ### Related Posts
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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.
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2026
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