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ARTICLE · 10 APRIL 2026

FinCEN And OFAC Propose AML/Sanctions Rules For Stablecoin Issuers Under GENIUS Act

Holland & Knight
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The Financial Crimes Enforcement Network and OFAC have jointly proposed groundbreaking regulations implementing the GENIUS Act's federal framework for payment stablecoin issuers.

United StatesFinance and Banking
Peter Hardy
Peter Hardy
Andrew W. Balthazor
Andrew W. Balthazor
Stephanie L. Connor
Stephanie L. Connor
Camila Lopez
Camila Lopez
Siana Danch
Siana Danch
Madeline Schonberger
Madeline Schonberger
Andres Fernandez
Andres Fernandez
Gabriel Caballero Jr.
Gabriel Caballero Jr.
Matt Rosenbaum
Matt Rosenbaum
+2 more
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Highlights

  • The Financial Crimes Enforcement Network (FinCEN) and U.S. Department of the Treasury's Office of Foreign Asset Control (OFAC) have jointly published a proposed rule to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), a 2025 law creating the first federal regulatory framework for U.S. payment stablecoins.
  • The GENIUS Act mandated that permitted payment stablecoin issuers (PPSIs) be treated as financial institutions for purposes of the Bank Secrecy Act, requiring certain anti-money laundering and countering the financing of terrorism compliance obligations. Critically, PPSIs will be required to maintain effective sanctions compliance programs, the first time that such compliance programs have been mandated by law.

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