Summary
FinCEN and federal banking agencies jointly proposed a rule on June 18, 2026, establishing customer identification program (CIP) requirements for Permitted Payment Stablecoin Issuers (PPSIs) under the GENIUS Act. The OCC followed on June 22 with conforming changes to align its earlier March AML/CFT proposal with the April OFAC/FinCEN NPRM. Comments on the CIP NPRM are due by August 21, 2026, and on the OCC conforming NPRM by July 24, 2026.
The CIP NPRM would limit CIP obligations to the primary market — a PPSI interacting directly with a customer for issuance, redemption, or conversion of stablecoins. Secondary market transactions (users sending stablecoins directly to one another) would be excluded. The substantive requirements mirror existing CIP rules for banks, including collection of legal name, date of birth, address, and identification number, with verification through documentary or non-documentary methods.
Key Facts
- CIP NPRM: proposed June 18, 2026; comments due August 21, 2026
- OCC Conforming NPRM: proposed June 22, 2026; comments due July 24, 2026
- Scope: primary market only (issuance, redemption, conversion with PPSI)
- Excluded: secondary market transactions (peer-to-peer transfers)
- CIP requirements: mirror bank rules (name, DOB, address, ID number)
- Verification: documentary or non-documentary methods; before or after account opening
- Reliance: PPSI can rely on other financial institutions for CIP (written contract required)
- Compliance date: 12 months after effective date of final rule
- OCC enforcement: only for "significant or systemic" program failures
- OCC requests comment on: reserve asset protection, fees, direct redemption for non-customers
- Key structural decision: "account" and "customer" defined to exclude secondary market
- Smart contract interaction: does not establish direct relationship with PPSI
Why It Matters
The GENIUS Act AML/CFT rules are a critical piece of the stablecoin regulatory puzzle. By limiting CIP to primary market transactions, the agencies have made a pragmatic choice that avoids the impossible task of requiring stablecoin issuers to KYC every wallet holder. The bank-like CIP requirements are manageable for institutional issuers but represent a significant compliance build for smaller or non-traditional firms. The OCC's "significant or systemic" enforcement threshold provides meaningful comfort for PPSIs with good-faith compliance programs.