The OCC issued a proposed AML rulemaking Monday requiring permitted payment stablecoin issuers (PPSIs) under its supervision to comply with the Bank Secrecy Act and the GENIUS Act’s AML/CFT provisions. It’s the first formal extension of BSA’s full compliance architecture to the stablecoin sector.
PPSIs would need to maintain an AML/CFT program meeting FinCEN and OFAC standards, including sanctions screening and countering the financing of terrorism requirements. The OCC also proposed a supervision and enforcement framework specifically for PPSI AML/CFT programs, plus a consultation mechanism between the OCC and FinCEN before the OCC initiates an AML/CFT enforcement action or significant supervisory action.
Monday’s rulemaking wasn’t the week’s only PPSI proposal. Days earlier, the OCC joined the Federal Reserve, FinCEN, the FDIC, and the NCUA on a five-agency customer identification rule requiring stablecoin issuers to maintain a customer identification program, the same KYC standard banks and credit unions have followed for decades. Comments on that rule close 60 days after Federal Register publication.
The structural signal is sequencing. Congress passed the GENIUS Act; now five agencies are simultaneously building out its compliance infrastructure in parallel rulemaking tracks: AML, sanctions, KYC. That’s not incremental rulemaking, that’s a deliberate full-stack regulatory buildout. Any stablecoin issuer not already mapping its program to BSA’s pillars is watching the clock.
OCC’s AML/CFT proposal accepts public comment for 30 days after Federal Register publication. A final rule would make noncompliance an OCC enforcement matter, not just a FinCEN one.
James Okafor