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BPI-TCH comment re: Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements (Docket No. FINCEN-2026-0100)
The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC) are jointly issuing a notice of proposed rulemaking to implement the GENIUS Act’s directive to treat permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA) and to propose applicable anti-money laundering and countering the financing of terrorism (AML/CFT) obligations for PPSIs and certain other specific obligations required by the GENIUS Act. The proposed rule would also implement the GENIUS Act’s directive to require PPSIs to maintain an effective sanctions compliance program. Although issuing this proposed rule jointly, FinCEN and OFAC are proposing independent changes to two different chapters of Title 31 of the Code of Federal Regulations.
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