FinCEN/OFAC NPRM Comment Window Halfway Closed
April 24 marks the midpoint of the 60-day FinCEN and OFAC NPRM comment window for stablecoin issuers under the GENIUS Act. Forty-five days remain.
What Changed
April 24 marks the midpoint of the 60-day public comment window for the joint FinCEN and OFAC Notice of Proposed Rulemaking implementing the GENIUS Act's AML/CFT and sanctions compliance framework for permitted payment stablecoin issuers. The window opened April 8 and closes June 9, 2026. The final rule becomes effective 12 months after final issuance.
Who It Affects
Permitted payment stablecoin issuers (PPSIs), banks and depository institutions that operate or sponsor PPSIs, money services businesses currently registered as stablecoin issuers under the MSB framework, and any compliance technology vendor or service provider supporting this category. The rule indirectly affects every counterparty that touches a PPSI-issued stablecoin in primary or secondary markets, including custodians, exchanges, and on-chain service providers.
What to Do
Issuers and affected parties have 45 days remaining to file substantive comments. Three priorities. First, draft and file a formal comment letter through Regulations.gov citing docket number FINCEN-2026-0006. Second, focus comment energy on the four solicited issues most likely to shape the final rule: secondary market technical controls, risk assessment refresh triggers, secondary market SAR filings, and the boundaries of customer due diligence as applied to peer-to-peer flows. Third, retain qualified counsel before June 1 to review and file. Letters submitted after June 9 are not considered.
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