Stablecoin Issuers as Banks: FinCEN and OFAC Issue Comprehensive AML and Sanctions Rules under the GENIUS Act

On April 8, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”) issued a joint notice of proposed rulemaking (the “Proposed Rule”), which would treat payment stablecoin issuers (“PPSIs”) as financial institutions under the Bank Secrecy Act (“BSA”) and mandate that they comply with a comprehensive suite of anti-money laundering (“AML”), countering the financing of terrorism (“CFT”), and sanctions compliance... By: King & Spalding