FinCEN and OFAC filed a joint proposed rule on April 8 to implement AML and sanctions compliance requirements for stablecoin issuers under the Genius Act.
The Genius Act is the federal stablecoin framework. The joint filing matters because it puts two separate enforcement mandates under one rule: FinCEN administers AML compliance programs; OFAC administers U.S. sanctions. Together, they’re co-authoring the compliance rulebook for stablecoin issuers. A joint rulemaking means stablecoin issuers won’t be able to satisfy one agency while ignoring the other’s requirements.
The proposed rule is where the Genius Act stops being a statute and starts generating compliance obligations for the stablecoin industry. AML and sanctions program requirements are the kind that come with examinations, civil penalties, and enforcement actions. For stablecoin issuers, this is the compliance framework they’ll now need to build.
The rule is proposed, not final. The public comment period that follows is stablecoin issuers’ window to shape the compliance requirements before they become binding obligations.
James Okafor