American Fintech Council Comments on Stablecoin AML/CFT Rules

The GENIUS Act became law in 2025, but rules crafted by various regulators were due on July 18, 2026.

Today, the American Fintech Council distributed a statement on the Office of the Comptroller of the Currency and its AML/CFT requirements. The OCC’s proposal is viewable here. Requirements include high-quality reserves like cash and T-bills and a path to become a permitted payment stablecoin issuer (PPSI).

Ian P. Moloney, Chief Policy Officer at the AFC, stated:

“The American Fintech Council (AFC) commends the OCC for advancing a thoughtful framework to implement the GENIUS Act’s anti-money laundering (AML), countering the financing of terrorism (CFT), and sanctions compliance requirements for permitted payment stablecoin issuers. As the proposal is finalized, it will be important to establish a coordinated federal supervisory framework that aligns with existing Bank Secrecy Act, FinCEN, and OFAC requirements in order to provide regulatory consistency and strengthen protections against illicit finance.”

“The final rule should also provide clear, risk-based supervisory expectations that promote effective compliance, regulatory certainty, and continuous improvement while avoiding unnecessary duplication of existing compliance obligations. Additionally, the framework should remain technology neutral, allowing institutions to deploy the compliance technologies and risk management tools best suited to their business models.”

“AFC appreciates the opportunity to provide feedback on the proposed rule and looks forward to continuing to work with the OCC to support a modern regulatory framework that will strengthen the long-term safety of the U.S. payment stablecoin market.”



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Disclosure Quest

Reg A - Form 1-A Filings Beta

Beta. Initial Form 1-A only. Target raise is the stated Amount to be Raised, totaled. Compared with the same dates one year earlier.

YTD: Jan 1, 2026 - Oct 22, 2026 vs Jan 1, 2025 - Oct 22, 2025

Share this graph
Number of Filings130Prior 125 +4.0%
Target Raise, Total$3.37BPrior $3.54B -4.7%
This YTDYear priorChange
Filings 130 125 +4.0%
Target raise $3.37B $3.54B -4.7%

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Source: DisclosureQuest. Initial Form 1-A only.

Created by Crowded Media Group

This display counts initial Form 1-A filings only. It does not represent subsequent filings, including Form 1-A/A amendments or Form 1-A POS post-qualification updates filed by the issuer. Amounts are the stated Amount to be Raised on the initial filing, not capital raised and not amounts revised in later filings.

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