The GENIUS Act makes permitted payment stablecoin issuers financial institutions for Bank Secrecy Act purposes, and in April 2026 FinCEN and OFAC jointly proposed the AML/CFT and sanctions programme rules that follow from it. This pack sets onboarding evidence to the BSA customer due diligence baseline a PPSI is measured against, including the federal beneficial ownership rule's 25 percent threshold.
UBO threshold set to 25 percent.
The federal beneficial ownership rule requires a covered financial institution to identify each individual who directly or indirectly owns 25 percent or more of the equity interests of a legal entity customer, plus one individual with significant responsibility to control or manage it.
control is a required fact for entity customers.
The same rule requires the control prong as well as the ownership prong: a single individual with significant responsibility for managing the entity, identified even when no one crosses the 25 percent ownership threshold.
The full entity evidence set applies rather than a lighter crypto-native checklist.
The GENIUS Act treats permitted payment stablecoin issuers as financial institutions for Bank Secrecy Act purposes, so the AML programme, customer due diligence and sanctions expectations that apply to a bank or MSB apply to the issuer.
Cited to official guidance rather than a specific subsection.
source_of_funds evidence expires after 180 days.
Ongoing due diligence requires updating customer information on a risk basis rather than relying on what was collected at onboarding. Six months is the working window this pack applies to funding evidence.
Iran, North Korea, Myanmar, Cuba and Syria are prohibited jurisdictions.
The proposed rule requires a permitted payment stablecoin issuer to maintain a sanctions compliance programme, the first time such a programme has been mandated by statute. Refusing onboarding from comprehensively sanctioned jurisdictions is the baseline that programme starts from.
Cited to official guidance rather than a specific subsection.
This pack is a starting point, not legal advice. It sets ClearSet’s onboarding evidence requirements to a defensible baseline for the regime, and every rule stays editable in your settings with each change recorded in the audit trail.
Start with the GENIUS stablecoin pack already applied.
Pick it during setup and your first assessment runs against these rules. Change any of them afterwards; every change is recorded.