Under the GENIUS Act, the Comptroller of the Currency (OCC) just rolled out new proposals to make stablecoin issuers follow Bank Secrecy Act (BSA) and sanctions rules. Working alongside Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC), the new regulations mean that any payment stablecoin issuers overseen by the OCC will have to keep solid anti-money laundering (AML) and sanctions compliance programs in place.
What exactly is the OCC asking for?
Basically, if you are a stablecoin issuer under the OCC’s watch, you’ve got some new homework. The proposed rule says you need to fall in line with the Bank Secrecy Act and the specific parts of the GENIUS Act. Thus, this is not just about checking boxes; it means setting up serious programs to stop money laundering and cut off funding for terrorism.
You’ll also need to keep FinCEN and OFAC happy by sticking to their specific playbooks for sanctions and regular reporting. It seems a lot, but the main goal is to “keep the whole system clean and transparent,” they said.
The proposal also lays out how the OCC is going to keep an eye on issuers and what happens if someone breaks the rules. Interestingly, they have agreed to chat with FinCEN before bringing the hammer down on anyone.
There’s a bit of a “carrot” here, too: if an issuer builds a truly solid compliance program, they get a “safe harbor.” This is essentially a legal shield that protects them from certain fines or regulatory headaches down the road. If you have thoughts on this, the OCC is all ears; they are looking for public feedback for the next 30 days once this hits the Federal Register.
The GENIUS Act framework
The GENIUS Act, which officially became law back in July 2025, basically sets up the big-picture rules for the whole payment stablecoin scene and puts some strict limits on who is actually allowed to issue them. A really key part of this law is that it classifies these issuers as official “financial institutions,” which effectively means they are on the hook for the full suite of federal regulations.
We are talking about everything from following sanctions and preventing money laundering to the standard “know your customer” (KYC) checks that traditional banks have to deal with. It is a major shift in how these companies have to operate on a day-to-day basis to stay compliant.
When it comes to who is actually calling the shots, the OCC takes the lead as the primary regulator for all the non-bank issuers out there. On the other side of the fence, the Federal Deposit Insurance Corporation (FDIC) has already laid out its own specific game plan for banks and the various other financial institutions that fall under its watch.
This ensures that whether you are a bank subsidiary or a tech-focused non-bank firm, there is a clear set of AML, sanctions, and Countering the Financing of Terrorism (CFT) requirements you need to follow. It is all about making sure every corner of the stablecoin market is playing by the same high-stakes rules to keep the system secure.
