27

December

2025

OCC and Treasury advance GENIUS Act implementation

On March 6, 2026, the Treasury Department published a report to Congress outlining its policy approach to anti-money laundering and countering the financing of terrorism (AML/CFT) obligations for digital assets under the GENIUS Act. The report emphasizes a risk-based supervisory framework and states that Treasury will coordinate with federal regulators to develop AML/CFT standards applicable to digital asset market participants. The report follows the OCC’s February 25, 2026 Notice of Proposed Rulemaking to implement the first comprehensive prudential regulatory framework for payment stablecoin issuers under the Act, together advancing interagency implementation of the GENIUS Act.

The OCC proposal would codify payment stablecoin issuance as a prudentially regulated financial activity under 12 C.F.R. Part 15 and establish capital, liquidity, reserve, custody, redemption, and risk management standards applicable to national banks, federal savings associations, and federal qualified nonbank issuers. The proposal also describes the transition of state-supervised payment stablecoin issuers to federal oversight once outstanding issuance exceeds $10 billion, requires issuers to satisfy redemption requests within two business days under ordinary market conditions, and would require certain foreign payment stablecoin issuers offering coins to U.S. persons to register with the OCC and comply with supervisory standards. Consistent with the GENIUS Act’s prohibition on interest or yield, the proposal also clarifies that the OCC will evaluate rewards programs, rebates, and similar payments based on economic substance rather than form.

Last updated 03/06/2026.


United States (Regulatory)

History:

  • Mar 6, 2026: Treasury Department publishes a report to Congress outlining its policy approach to anti-money laundering and countering the financing of terrorism (AML/CFT) obligations for digital assets under the GENIUS Act. Report to Congress from the Secretary of the Treasury.
  • Feb 25, 2026: OCC issues an NPRM proposing the first comprehensive prudential framework for payment stablecoin issuers under the GENIUS Act. OCC Bulletin 2026-3.
  • Dec 16, 2025: FDIC issues Notice of Proposed Rulemaking (NPRM) establishing application and approval procedures for insured depository institutions seeking to issue payment stablecoins under the GENIUS Act.
  • Nov 4, 2025: The public comment period for the Treasury Department’s GENIUS Act ANPRM closes.
  • Sep 19, 2025: The Treasury Department issues an advance notice of proposed rulemaking (ANPRM) to solicit public comment on questions relevant to the GENIUS Act’s implementation. 90 Fed. Reg. 45159.
  • Aug 18, 2025: The Treasury Department and the Treasury’s Financial Crimes Enforcement Network (FinCEN) issues a request for comment on innovative methods to detect illicit activity involving digital assets (relevant to the requirements of Section 9(a) of the GENIUS Act). 90 Fed. Reg. 40148.
  • Jul 18, 2025: President Donald Trump signs the GENIUS Act into law, making it the first major federal statute governing cryptocurrency and establishing a regulatory framework for payment stablecoins. S.1582.
  • Jul 17, 2025: The House of Representatives passes the GENIUS Act in a 308–122 vote, clearing the final legislative hurdle and sending the bill to President Trump for signature.
  • Jun 17, 2025: The Senate passes the GENIUS Act with bipartisan support in a 68–29 vote, advancing the landmark stablecoin legislation to the House of Representatives for consideration.
  • May 01, 2025: Sen. Bill Hagerty (R-Tenn.) introduces a new version of the GENIUS Act to the Senate of the 119th Congress. S.1582.
See the NPRM
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Amil Malik

Amil assists with various client matters in connection with digital assets and the adoption of blockchain technology, including general corporate law, securities law, and financial services regulation. She joined DLx Law after receiving her J.D. from the George Washington University School of Law, where much of her studies focused on national security and cybersecurity law.

Amil received her B.B.A./B.A. with high honors from the University of Texas at Austin. Between university and law school, Amil worked as a mergers and acquisitions analyst in New York, where she performed financial valuations and analysis as part of advisory services provided to sell-side and buy-side clients across media, consumer, technology, shipping, and financial technology industries. Amil is licensed to practice law in the District of Columbia.

Tom Momberg

+17186645458 tom.momberg@dlxlaw.com

Tom advises clients in an array of matters related to blockchain technology, decentralized finance, banking and payments systems, financial products, and financial technology applications. He joined DLx Law as an attorney after working as in-house counsel for a payments and banking software service provider, advising on various legal and regulatory matters, operations, risk, customer due diligence, and corporate best practices.

Tom received his J.D. from George Mason University Law School in Virginia and his B.A. from the University of Wisconsin-Milwaukee. Tom is a former journalist, and, while in law school, he interned for DLx Law and served as a law clerk for several federal institutions in Washington, D.C., including the CFTC, FCC, and House Judiciary Committee. Tom is admitted to practice law in the District of Columbia and the State of Oregon.

Sarah Chen

+19296345691 sarah.chen@dlxlaw.com

Sarah advises clients in all matters related to the adoption of blockchain technology, including general corporate, venture financing, securities laws and financial regulatory. Prior to joining DLx Law, Sarah was a senior associate in the M&A group of an international law firm headquartered in New York City, advising public companies and private equity firms on mergers, acquisitions, and other corporate transactions.

Sarah received her B.A. from New York University, magna cum laude, and her J.D. from Columbia Law School where she was a James Kent Scholar. During law school, Sarah also served as a judicial extern to the Hon. Debra Ann Livingston of the U.S. Court of Appeals for the Second Circuit. Sarah is licensed to practice law in the State of New York.

Gregory Strong

+3027665535 greg.strong@dlxlaw.com

Greg focuses on advising entities regarding legal issues associated with the adoption of blockchain technology. Prior to joining DLx Law, Greg was a Deputy Attorney General in the Delaware Department of Justice. He served as the Director of the Investor Protection Unit for three years and was responsible for administering and enforcing the provisions of the Delaware Securities Act. Prior to his appointment as Director of the Investor Protection Unit, Greg was the Director of the Consumer Protection Unit for three years.

Greg has successfully represented the State of Delaware in many complex civil enforcement matters alleging violations of Delaware investor and consumer protection statutes and has extensive litigation experience. Greg graduated from Lehigh University with a B.S. in Finance and received his J.D./M.B.A. from Temple University.

Angela Angelovska-Wilson

+12023651448 angela@dlxlaw.com

Angela is an early distributed ledger technology adopter and a leading authority in the evolving global legal and regulatory landscape surrounding distributed ledger technology and smart contracts. Prior to co-founding DLx Law, Angela served as the Chief Legal & Compliance Officer of Digital Asset and was part of the founding team.

Prior to joining Digital Asset, Angela was a partner at Reed Smith where she regularly advised clients on the implementation of new technologies to finance and the complex regulatory schemes involved in the development, creation, marketing, sale and servicing of various financial services and products. Before Reed Smith, Angela spent most of her career in various roles at Latham & Watkins, where she was recognized by The Legal 500 US among the top finance attorneys in the U.S.

Angela has a deep understanding of the Fin-Tech industry and in particular the distributed ledger industry, having been involved in a number of startups in various roles, as an employee, entrepreneur and advisor. In addition to DLx Law, Angela is also co-founder of Sila Inc., an innovative technology company.