Zero dollars. That’s the fine here, but the compliance bill coming due for nonbank stablecoin issuers is the real number to watch.
FinCEN, alongside the OCC, Federal Reserve, FDIC and NCUA, issued a joint proposal last month forcing “permitted payment stablecoin issuers” to build customer identification programs modeled on the ones banks have run for decades. The trigger is the GENIUS Act, signed into law in 2025, which extended Bank Secrecy Act customer identification obligations to stablecoin issuers. Comments are due August 21, with a 12-month runway to comply once a final rule lands.
Here’s who actually eats this cost: nonbank issuers currently regulated as money transmitters. Banks already run full KYC. Money transmitters don’t, they only verify identity above certain transaction thresholds. This rule closes that gap, per a Mayer Brown analysis of the FDIC’s notice, and it’s the nonbank players who’ll need to staff up compliance teams from scratch.
Regulators drew a line at the smart contract. Secondary-market transfers, where a user just holds or trades a token, don’t trigger ID checks. Only direct issuer relationships do: issuance, redemption, conversion, custody. But they haven’t settled what happens when someone buys on an exchange and later redeems straight with the issuer. That gap could decide onboarding costs for issuers built around redemption-heavy models.
No stablecoin issuer has paid a dime under this rule yet. It doesn’t exist. But the August 21 comment deadline is the next date that matters for anyone building a PPSI business plan.
— Marcus Webb