FinCEN/OFAC Joint NPRM: Full BSA Compliance Required for Stablecoin Issuers
Stablecoin issuers will face the same AML/sanctions rules as banks. No lighter-touch alternative.
What Changed
On April 8, FinCEN and OFAC jointly released a proposed rulemaking requiring permitted payment stablecoin issuers under the GENIUS Act to implement full BSA-compliant AML/CFT programs, OFAC sanctions screening, SAR/CTR filing procedures, risk-based CDD, and comprehensive record retention. The regime becomes operational January 2027.
Who It Affects
Every current and prospective stablecoin issuer, banks considering stablecoin subsidiaries, and compliance teams at firms integrating stablecoin rails.
What to Do
Begin building BSA-compliant infrastructure now. The January 2027 deadline requires full compliance programs — not just policies but functioning systems, trained personnel, and tested procedures.
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