GENIUS Act: Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance: Notice of Proposed Rulemaking
AI Analysis
The OCC issued a notice of proposed rulemaking on June 22, 2026 to implement Bank Secrecy Act and sanctions compliance standards for OCC-supervised permitted payment stablecoin issuers under the GENIUS Act. The proposal matters because it would formalize AML/CFT and OFAC compliance expectations, create an OCC enforcement framework, and establish a consultation channel with FinCEN for significant actions.
Key dates
- 2026-06-22
- OCC bulletin announcing the notice of proposed rulemaking was issued
- 2026-07-22 Deadline
- Planned deadline for comments, if the Federal Register publication date aligns with the bulletin date and the OCC’s 30-day comment period is measured from publication
Suggested considerations
- Compliance teams may wish to assess whether the entity falls within the OCC-supervised PPSI category or within the state-qualified issuer population covered by OCC authority under the GENIUS Act.
- Firms may wish to review existing AML/CFT and sanctions controls against the BSA, FinCEN, and OFAC requirements referenced in the proposal, including reporting, monitoring, and risk assessment procedures.
- Compliance teams may wish to map governance, escalation, and record-sharing workflows to the proposed OCC-FinCEN consultation framework, particularly for potential significant supervisory or enforcement matters.
- Firms may wish to consider whether their current policies, procedures, and internal controls are sufficiently tailored to stablecoin-specific risks and whether additional board or senior management oversight would be needed.
- Compliance teams may wish to evaluate whether they should submit comments during the 30-day Federal Register comment period if aspects of the proposed framework could affect operating models or compliance design.
What changed
The proposed rule would require OCC-supervised PPSIs to comply with the BSA, sections 4(a)(5) and 4(a)(6)(B) of the GENIUS Act, and applicable FinCEN and OFAC regulations, including AML/CFT program, sanctions program, and reporting requirements. It would also create a supervision and enforcement framework for PPSI AML/CFT programs, so the OCC can take AML/CFT supervisory and enforcement action against covered issuers. The rule would establish a formal consultation process between the OCC and FinCEN when the OCC intends to initiate an AML/CFT enforcement action or a significant AML/CFT supervisory action. It would also permit PPSIs to share certain nonpublic OCC information with the FinCEN Director relating to an existing or potential AML/CFT enforcement action or significant AML/CFT super
Compliance impact
The proposal signals a material increase in AML/CFT and sanctions compliance scrutiny for OCC-supervised stablecoin issuers, with explicit supervisory and enforcement consequences for program deficiencies. The OCC describes a framework that could support significant supervisory action or enforcement action, making program design, governance, and escalation controls more consequential for affected
Who is affected
Related regulations
References
AI-generated analysis. May contain errors or omissions — verify with the original OCC source before acting. Full disclaimer.
What the OCC said
The Office of the Comptroller of the Currency (OCC) is issuing a notice of proposed rulemaking to implement Bank Secrecy Act (BSA) and sanctions compliance standards applicable to OCC-supervised permitted payment stablecoin issuers (PPSI), as required by the Guiding and Establishing National Innovation for U.S…
Extract from OCC . Read the full notice at the source for the authoritative text.