OCC

OCC’s GENIUS Act NPRM Creates a Two-Stage Stablecoin Rulebook

The OCC’s GENIUS Act NPRM advances a prudential framework for payment stablecoin issuance and limited custody, while explicitly deferring GENIUS-related BSA/AML and OFAC implementation to a separate Treasury-coordinated rulemaking—creating a staged compliance sequence.

Laurie Shrout

06 Mar 2026 — 4 min read

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TL;DR:
The OCC’s GENIUS Act NPRM advances stablecoin issuance and limited custody rules now, while deferring GENIUS BSA/AML and OFAC implementation to a separate Treasury-coordinated rulemaking—creating a two-stage compliance sequence.

What you need to know

The move: The OCC issued an NPRM to implement the GENIUS Act, covering payment stablecoin issuance and certain custody activities for entities subject to OCC jurisdiction. (OCC)
Why it matters: The OCC says this NPRM does not include the GENIUS Act regulations it is required to promulgate related to BSA/AML and OFAC sanctions and that those will be addressed in a separate rulemaking coordinated with Treasury — changing how governance teams sequence readiness. (OCC)
Who should care: Bank regulatory affairs leaders (national banks/FSAs), stablecoin issuer executives and counsel, financial-crime owners (BSA/AML/OFAC), and custody/payments infrastructure leaders at OCC-supervised entities. (OCC)

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