On September 19, 2025 the U.S. Department of the Treasury (Treasury) issued an Advanced Notice of Proposed Rulemaking (ANPR), an early-stage rulemaking step that will require Treasury to issue a subsequent proposal to seek additional public input before any regulations may be finalized, requesting public comment regarding its implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The ANPR addresses a range of topics, including anti-money laundering (AML) compliance, as the Treasury looks to carry out its rule adoption responsibility by striking a balance between embracing digital assets innovation and effective risk management.
The GENIUS Act subjects permitted payment stablecoin issuers (PPSIs) to “all Federal laws applicable to financial institutions located in the United States relating to economic sanctions, prevention of money laundering, customer identification and due diligence”, and tasks the Treasury with issuing regulations related to effective AML and sanctions programs, monitoring and reporting suspicious activity, and technical capabilities and policies and procedures to block, freeze, and reject impermissible transactions, among other items.
In the Illicit Finance section of the ANPR, the Treasury poses specific questions about the regulatory design for AML and sanctions programs, unique risks and operational differences of PPSIs, technical and procedural approaches for PPSIs to comply with orders and prevent sanctioned or prohibited secondary-market transfers, and what regulatory clarity would help define the technological capabilities required to comply with laws and regulations. For foreign PPSIs, the Treasury request views on the criteria for designation as noncompliant, the appropriate scope and standards for licenses or waivers, and what the agency should consider clarifying how issuers can comply with lawful orders related to the Office of Foreign Assets Control lists.
The Illicit Finance section of the ANPR builds on the Treasury’s Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets, issued on August 18, 2025. Together, these issuances represent a significant step toward auditable standards and guidance for AML, sanctions compliance, customer due diligence, and transaction monitoring. Specifically, they aim to equip stablecoin issuers with effective, proportionate, and interoperable controls that function across both domestic and international markets.
The ANPR established a comment period ending on October 20, 2025; however an update was issued to extend the comment period by 15 days. As such, comments are now due by November 4, 2025.
Next Steps
Governance, auditability, and privacy-preserving compliance are just as critical as new technology. The Treasury’s request is more than a regulatory exercise - it is an invitation to the industry to help shape the future of digital asset oversight, specifically from a Bank Secrecy Act, AML, and sanctions perspective.
At Forvis Mazars, we believe this is a moment to engage - not only to ensure your voice is heard, but also to help regulators understand the real-world challenges and opportunities financial institutions face. By contributing, firms can both protect their interests and influence standards that will define the industry for years to come.