In a recent Law360 article, Baker McKenzie partner David Zaslowsky examines the FDIC’s most recent proposed rule to implement the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act. The proposed rule represents the financial crime compliance pillar of this emerging regime, following earlier agency proposals addressing application procedures and prudential requirements.Under the proposed rule, FDIC-supervised permitted payment stablecoin issuers would be required to implement robust, risk-based compliance programs. These programs would encompass core…
The Federal Deposit Insurance Corporation (FDIC) has taken a significant step toward implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”) by approving a notice of proposed rulemaking (NPRM) that would establish a comprehensive Bank Secrecy Act (BSA) and anti-money laundering (AML) compliance framework for certain stablecoin issuers. The proposal signals that stablecoin issuance within the U.S. regulatory perimeter will be subject to compliance expectations closely aligned with those applicable…
The Federal Reserve’s announcement on April 24, 2025, to withdraw prior guidance and supervisory letters concerning banks’ involvement in cryptocurrency and stablecoin activities is the latest turn by US regulators under President Trump to ease cryptocurrency regulation in the United States. See our earlier posts here, here, here and here. On the campaign trail, President Trump vowed to make the U.S. the “crypto capital of the planet.” The Fed’s announcement said the Fed would work…
On April 7, 2022, the US Federal Deposit Insurance Corporation (FDIC) issued a Financial Institution Letter (“FIL”) requiring that all FDIC-supervised institutions that intend to engage in, or that are engaged in, any activities involving or related to crypto assets notify the FDIC. Because the overwhelming majority of U.S. banks are insured by the FDIC, the FIL means that nearly all banks must now disclose their crypto activities to the FDIC. The definition of crypto…