Key points to remember:
- FinCEN and OFAC issued a joint NPRM on April 8, 2026, requiring stable coin issuers must comply with banking secrecy obligations.
- The GENIUS Act, signed into law on July 18, 2025, gives issuers like Circle and Tether approximately 60 days to submit public comments.
- Authorized payment stable coin issuers must deploy technical controls to block, freeze and reject transactions that violate U.S. sanctions.
New federal rules require Stablecoins Issuers must block sanctioned transactions
The joint Notice of the proposed rulemaking by the Financial Crimes Enforcement Network and the Office of Foreign Assets Control implements key provisions of Guiding and Establishing Domestic Innovation for the United States. Stablecoins Act, signed into law July 18, 2025. The proposal formally classifies authorized payments stable coin issuers, or PPSI, as financial institutions subject to the banking secrecy law.
THE GENIUS Law established the first comprehensive federal framework governing payment stable coins in the United States. It restricts issuance to entities supervised by the federal or state government and directs Treasury to tailor compliance obligations to the size and risk profile of each issuer.
Under the proposed rulePPSIs must establish a written AML/CFT program approved by the board of directors. This program must include a risk assessment process, internal controls, independent testing, ongoing employee training, and a U.S.-based compliance officer. Individuals convicted of crimes related to financial crimes are not permitted to serve in this officer position.
The proposal also requires PPSIs to file suspicious activity reports for transactions that may indicate violations of the law. Issuers must also comply with the recordkeeping rule for funds transfers of $3,000 or more and transmit the information required under the travel rule to other financial institutions.
A specific provision of the GENIUS Act requires issuers to maintain technical capabilities to block, freeze and reject transactions that violate federal or state law or any lawful order from regulators or law enforcement. These controls apply to both primaries and secondaries. stable coin markets.
On the sanctions side, OFAC requires PPSIs to adopt an effective sanctions compliance program, built around five elements: senior management commitment, risk assessment, internal controls, testing and training. Issuers must incorporate risk-based safeguards to identify and reject transactions that would violate U.S. sanctions.
FinCEN said it generally will not pursue enforcement actions against issuers whose programs meet the rule’s standards, absent material or systemic deficiencies. The agency will play a central role in oversight and must be informed before other regulators take major oversight actions.
The regulations complement previous Treasury actions. In March 2026, the Office of the Comptroller of the Currency issued proposed prudential standards covering reserve asset requirements. In early April 2026, Treasury also issued a separate NPRM establishing principles for state-level regulatory regimes, which allows issuers with less than $10 billion outstanding stable coins elect state oversight within an approved framework.
Major stable coin transmitters, including Circle and Tether, as well as new market entrants, will need to evaluate how the proposed requirements affect their existing compliance structures. The risk-based rule design aims to direct resources toward higher-risk customers and activities.
“President Trump is strengthening America’s leadership in digital financial technology,” said Treasury Secretary Scott Bessent. REMARK. “This proposal will protect the U.S. financial system from national security threats without hindering the ability of U.S. businesses to move forward in the payments space. stable coin ecosystem. »
The NPRM will be published in the Federal Register in the coming days. FinCEN and OFAC are expected to set a 60-day public comment period following publication. A fact sheet on the proposal is available from the Treasury.
Stakeholders operating in the stable coin The industry should review the entire regulation and consider submitting comments before the deadline.
