The federal GENIUS Act stablecoin rules are being written in public right now, and the window to shape them closes within weeks. Comments on the FDIC's Bank Secrecy Act and sanctions compliance standards for stablecoin issuers are due by 4 August 2026, and the FinCEN-led Customer Identification Program proposal follows on 21 August 2026. Our view is simple: if US stablecoin issuance is anywhere on your roadmap, these two comment files are part of your licensing strategy, and once the second window shuts the regime's compliance perimeter is largely set without you.
The proposal to read closely is the CIP rule. It would treat permitted payment stablecoin issuers, PPSIs, as financial institutions under the Bank Secrecy Act, a clear step up from the money services business footing most US crypto firms operate on today. That means bank-grade onboarding and record-keeping, priced accordingly, whichever charter route you take. Budget for it now, not after the final rule lands.
Two GENIUS Act stablecoin rules, two August deadlines
The FDIC proposal, approved by its board on 22 May 2026 and published in the Federal Register on 5 June 2026, sets Bank Secrecy Act, anti-money-laundering and OFAC sanctions programme standards for stablecoin issuers supervised by the FDIC. Comments close 4 August 2026.
The joint proposal from FinCEN, the OCC, the Federal Reserve, the FDIC and the NCUA, published on 22 June 2026, would require every PPSI to run a written Customer Identification Program: verifying each customer's name, address, date of birth or formation date and identification number, screening against government sanctions lists, and retaining identification records for five years after an account closes. The proposed compliance date is 12 months after the final rule issues, and the agencies' own analysis puts the new annual expenditure at up to $193 million across the public and private sectors. Comments close 21 August 2026.
What is a permitted payment stablecoin issuer?
Under the GENIUS Act, enacted on 18 July 2025, a PPSI is the licensed vehicle for issuing payment stablecoins in the United States: a federally qualified nonbank, an insured depository institution subsidiary, or a state-qualified issuer beneath the Act's $10 billion issuance threshold where Treasury deems the state regime substantially similar.
That third path remains unsettled. Treasury's proposed state-equivalence test closed for comment on 2 June 2026 and no final rule has issued. Trade outlets reported in July 2026 that the agencies passed the Act's one-year rulemaking mark on 18 July 2026 with the core rulebook still unfinished. For anyone sequencing a US application against an EU launch the timing gap is real: MiCA e-money token issuance runs through an EMI authorisation you can pursue today, and you can compare EMI requirements across the EEA, while the US federal route cannot be fully specified until these rules finalise, plus the proposed 12-month compliance runway.
Why respond before the windows close
The agencies pose eight numbered questions in the CIP proposal, including whether obligations should extend to secondary-market activity, whether digital identity and verifiable credentials should be recognised for verification, and whether one PPSI may rely on another issuer's programme. The answers filed by 21 August 2026 will shape onboarding costs for every future issuer. Silence is an answer too, and rarely the one that serves you.
We log authorisation-relevant developments like these, dated and sourced, in our changes feed, alongside the live United States crypto licensing entry. For the half-year view of how US stablecoin and market-structure rules sit against other regimes, see the State of Crypto Licensing reports.
Sources
- Federal Register: FDIC, Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers, 5 June 2026
- Federal Register: Permitted Payment Stablecoin Issuer Customer Identification Program, joint proposal, 22 June 2026
- FDIC press release on the BSA and sanctions proposal, 22 May 2026
- OCC Bulletin 2026-3 on GENIUS Act implementation
This article is informational only and is not legal advice.