Key Takeaways:
FinCEN and OFAC issued a joint NPRM on April 8, 2026, requiring stablecoin issuers to comply with Bank Secrecy Act obligations. The GENIUS Act, enacted July 18, 2025, gives issuers like Circle and Tether roughly 60 days to submit public comments. Permitted payment stablecoin issuers must deploy technical controls to block, freeze, and reject transactions violating U.S. sanctions. New Federal Rules Require Stablecoin Issuers to Block Sanctioned TransactionsThe proposal also requires PPSIs to file Suspicious Activity Reports for transactions that may indicate violations of law. Issuers must also comply with the Recordkeeping Rule for fund transfers of $3,000 or more and transmit required information under the Travel Rule to other financial institutions.
FinCEN said it generally will not pursue enforcement actions against issuers whose programs meet the rule’s standards, absent significant or systemic failures. The agency will play a central role in oversight and must be notified before other regulators take major supervisory actions.
The NPRM will be published in the Federal Register in the coming days. FinCEN and OFAC are expected to set a 60-day public comment period upon publication. A fact sheet on the proposal is available through Treasury.
