Five US financial regulators have proposed customer identification requirements for permitted payment stablecoin issuers, translating a central compliance provision of the GENIUS Act into an operating framework for the companies that issue dollar-linked payment tokens.
The June 18 joint proposal from the Financial Crimes Enforcement Network, Office of the Comptroller of the Currency, Federal Reserve, Federal Deposit Insurance Corporation and National Credit Union Administration would treat permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act for this purpose. The rule is a proposal, not a final requirement.
What the proposal would require
A covered issuer would need a written customer identification program appropriate to its size and business and incorporated into its anti-money-laundering and countering-the-financing-of-terrorism program. The program would have to use risk-based procedures that let the issuer form a reasonable belief that it knows each customer’s identity.
The proposed framework follows the structure already used for banks and other regulated financial institutions. It covers identity verification, recordkeeping, checks against applicable government lists and notice to customers that identifying information is being requested. The procedures would need to reflect differences in account types, onboarding channels, available identity information and the issuer’s customer base.
Issuers could, in defined circumstances, rely on customer-identification work performed by another federally regulated financial institution. That arrangement would need to be reasonable, backed by a contract and supported by annual certification from the other institution. The stablecoin issuer would retain responsibility for compliance.
Why the definition of the customer relationship matters
For payment companies, the most consequential implementation question is where the issuer’s account relationship begins and ends. Stablecoins can reach users through exchanges, custodians, wallets and other distribution partners rather than through a direct issuer interface. The proposed rule therefore matters not only for front-end onboarding, but also for how issuers document responsibilities across their distribution and compliance partners.
The agencies said the proposal would also apply to permitted payment stablecoin issuers operating under qualifying state supervision. That creates a common customer-identification baseline while leaving the relevant federal or state stablecoin regulator responsible for broader licensing and supervision.
Secondary-market transfers remain a policy fault line
Federal Reserve Governor Michael Barr supported issuing the proposal but separately highlighted activity beyond direct issuer accounts. He said the GENIUS Act framework may not yet do enough to address illicit-finance risks in secondary-market stablecoin transactions and said he would review comments on whether portions of the customer-identification rule should extend to that activity.
That distinction is important for payments infrastructure. A direct customer relationship gives an issuer a clear point at which to collect and verify identifying information. Transfers between users of external wallets or platforms can place the transaction outside that direct onboarding flow, making the allocation of compliance duties less straightforward.
What happens next
The agencies requested public comment, with responses due 60 days after the proposal is published in the Federal Register. Until a final rule is adopted, the document sets out the regulators’ intended approach rather than an effective compliance deadline.
Stablecoin issuers and their banking, exchange, wallet and processing partners will need to evaluate how the proposed account definitions, verification procedures, record retention and permitted reliance arrangements map onto existing onboarding systems. The proposal signals that US payment-stablecoin supervision is moving from statutory principles toward detailed controls that can be examined in day-to-day operations.