Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements (Joint Proposed Rule)

Date issued: Apr. 10 2026

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TURBOFAC Commentary (1101 words)

Notes:

1) This comment addresses the OFAC-related portion of this “Joint Proposed Rule” (“JPR”) of OFAC and FinCEN to implement the portion of the Genius Act that requires issuers of stablecoins to have sanctions compliance policies. This requirement is administered by OFAC, and there will be regulations in 31 CFR Ch. V to implement the regulations. The stablecoin-related regulations will not impose any substantive sanctions prohibitions; they only require compliance programs aimed at ensuring compliance with substantive prohibitions that OFAC does administer.

2) JURISDICTION OVER “SECONDARY MARKET” TRANSACTIONS

There are a number of notable statements in the OFAC portion of the JPR that have implications for U.S .persons other than the U.S. person stablecoin issuers. The first category of these pertains to the scope of OFAC’s regulations in the context of “secondary market transactions” by issuers of stablecoins....