United StatesTreasury, FinCEN, OFAC and the banking agencies
The GENIUS Act takes effect on 18 January 2027.
The GENIUS Act creates the first federal framework for US payment stablecoins and makes permitted issuers financial institutions for Bank Secrecy Act purposes. The implementing rules are still being written, and the statutory effective date does not move to accommodate that.
Next dated obligation
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Timeline (5)
GENIUS Act effective date
Permitted payment stablecoin issuers become subject to the Act's requirements, including the AML/CFT and sanctions programme obligations that follow from being treated as a BSA financial institution.
Who is in scope
Anyone issuing a payment stablecoin to US persons, and anyone intending to become a permitted issuer.
What to do
Have a written AML programme and a sanctions programme that a supervisor could read today, not a plan to write one. The Act mandates a sanctions compliance programme by statute, which is new.
“Beginning on January 18, 2027, the expected effective date of the GENIUS Act”
Treasury proposed rule on issuance, offering and sale
Treasury proposed rules implementing section 3 of the GENIUS Act, covering the issuance, offering and sale of payment stablecoins in the United States.
Who is in scope
Issuers and anyone offering or selling payment stablecoins to US persons.
What to do
Read the proposal against your own product. The comment window is the last point at which the shape of these rules is still negotiable.
Comments on the Treasury proposal are due 60 days after Federal Register publication. Treasury's release states the 60 day window but not a calendar date, and the Federal Register document could not be read directly to confirm one.
Who is in scope
Anyone who wants the final rule to account for how their product works.
What to do
Check the Federal Register entry for the exact closing date before relying on it. Sixty days from mid-August 2026 puts it in October.
FinCEN and OFAC AML/CFT and sanctions proposed rule
FinCEN and OFAC jointly proposed the AML/CFT programme and sanctions compliance programme rules that apply to permitted payment stablecoin issuers.
Who is in scope
Permitted payment stablecoin issuers.
What to do
This is the document that tells you what your programme has to contain. Build against it now rather than waiting for the final rule, because the effective date is fixed and the final rule is not yet out.
“Federal Register document 2026-06963, published 10 April 2026: Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements”
Statutory rulemaking deadline for the federal regulators
Confirm before launch
The Act gave the primary federal payment stablecoin regulators one year from enactment to issue final rules. Reporting indicates that deadline passed in July 2026 without final rules, which is why the effective date now matters more than the rulemaking timetable.
Who is in scope
The regulators, not regulated firms, but it changes what firms can rely on.
What to do
Do not wait for final rules before building. Confirm the current rulemaking status directly with the OCC bulletin before treating any of this as settled.
18 January 2027. Treasury states this is the expected effective date, being the earlier of eighteen months after enactment or one hundred and twenty days after the primary federal payment stablecoin regulators issue final implementing regulations.
Does the effective date move if the rules are not final?
No. The statutory date stands on its own. Final rules arriving late compresses the time to prepare rather than extending the deadline.
What does the GENIUS Act require of a stablecoin issuer for AML?
A permitted payment stablecoin issuer is treated as a financial institution for Bank Secrecy Act purposes, so it needs an AML/CFT programme, customer due diligence including beneficial ownership at the twenty five percent threshold, and, for the first time by statute, a sanctions compliance programme.
Is your policy ready for this date?
Two ways to find out without a call: have your current policy graded against this regulator, or read the rule pack the Onboarding Agent would run for you.
Hub created. Effective date and Treasury proposed rule verified against Treasury's own release; the comment closing date and the missed rulemaking deadline are marked for confirmation.
Dates marked “confirm before launch” are ones we have not yet read in a primary source. We would rather show you that than a date we are not sure of. This is not legal advice.