Implementing The GENIUS Act: FinCEN And OFAC Propose AML And Sanctions Program Requirements

The U.S. Department of the Treasury’s (Treasury) Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) recently issued a joint proposed rulemaking (Proposal) that would implement the anti-money laundering and sanctions program requirements of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).¹ If adopted as proposed, the new program requirements would apply to “permitted payment stablecoin issuers” (PPSIs) as defined by the GENIUS Act and would become effective 12 months after publication of the final rule. In addition to seeking general comments on the Proposal, FinCEN and OFAC posed nearly 60 specific questions on which they solicited feedback. Comments are due by June 9, 2026.