Anti-Money-Laundering Standards for Stablecoin Issuers: The FDIC Proposal and Comparative International Developments
On 22 May 2026, the Federal Deposit Insurance Corporation (FDIC) approved a proposed rule applying bank-grade anti-money-laundering and sanctions obligations to a defined category of stablecoin issuer. The measure brings certain issuers, previously regulated in many cases under lighter money-transmitter requirements, within the federal Bank Secrecy Act framework. The development is one component of a wider pattern in which the United States and a number of other jurisdictions have extended financial-crime obligations to stablecoin issuance, treating it as a regulated payment activity subject to the same anti-money-laundering expectations applied to established financial institutions.
Scope and requirements of the FDIC proposal
The proposal is issued under the GENIUS Act, the 2025 federal statute that restricts stablecoin issuance to approved entities designated Permitted Payment Stablecoin Issuers (PPSIs). The rule applies specifically to PPSIs that operate as subsidiaries of insured state nonmember banks and state savings associations supervised by the FDIC. It amends the FDIC's existing regulations (12 CFR Part 350) to incorporate Bank Secrecy Act and sanctions standards and adds a new subpart governing AML/CFT supervision and enforcement.
Under the proposal, affected issuers would be required to maintain anti-money-laundering and counter-terrorist-financing (AML/CFT) programmes, conduct customer and transaction screening, file suspicious-activity reports, and comply with United States economic sanctions administered by the Office of Foreign Assets Control (OFAC). The proposal additionally establishes a mechanism for the FDIC to consult the Financial Crimes Enforcement Network (FinCEN) before initiating certain enforcement actions, and provides for the sharing of examination findings, draft enforcement materials, and workpapers, subject to protections for privileged information.
The FDIC states that the rule is intended to reduce the frequency and severity of harm associated with sanctioned and criminal actors transacting through digital assets. The anti-money-laundering dimension is distinct from the prudential requirements the agency addressed separately in an April 2026 proposal covering reserves, redemption, capital, risk management, and custody.
The proposal within the broader United States framework
The FDIC is one of several agencies implementing the GENIUS Act, which assigns licensing and supervisory responsibilities to the Office of the Comptroller of the Currency (OCC), the Federal Reserve, the FDIC, the National Credit Union Administration (NCUA), and state regulators. On the financial-crime side, FinCEN and OFAC published a joint proposed rule in April 2026 implementing the statute's directive to treat PPSIs as financial institutions for Bank Secrecy Act purposes, with FinCEN amending its chapter X regulations to apply AML obligations and OFAC introducing provisions requiring a sanctions-compliance programme. The FDIC's May proposal adds supervisory and enforcement provisions consistent with that federal baseline.
The statute also creates a federal-state dimension relevant to anti-money-laundering standards. A state-qualified issuer with no more than $10 billion in outstanding stablecoins may opt for state-level regulation, but only where the state regime is determined to be "substantially similar" to the federal framework, including with respect to AML and sanctions compliance. The Treasury Department issued a proposal in April 2026 setting out principles for that determination. The FDIC has estimated that between five and 30 of its supervised institutions might seek to issue payment stablecoins through subsidiaries during the framework's initial years.
Comparative international developments
A number of other jurisdictions have adopted or advanced stablecoin frameworks that incorporate anti-money-laundering obligations alongside reserve and redemption requirements. Sources describe a broad common structure across these regimes: mandatory licensing of issuers, full reserve backing, redemption at par, and AML and customer-due-diligence requirements.
In the European Union, the Markets in Crypto-Assets regulation (MiCA) addresses stablecoins as e-money tokens and asset-referenced tokens, requiring issuer authorisation and full reserve backing, with crypto-asset service providers subject to AML/CFT obligations under the EU's broader anti-money-laundering regime. MiCA's stablecoin titles have applied since mid-2024, with transitional measures in some member states extending to 1 July 2026.
In the United Kingdom, a stablecoin regime is being developed by the Financial Conduct Authority and the Bank of England, drawing on par-value reserve backing, redemption rights, and financial-crime controls derived from existing money-laundering regulations; certain details remain to be finalised.
In Asia, the Monetary Authority of Singapore has established a framework for single-currency stablecoins requiring full reserve backing, timely redemption, and AML/CFT compliance. Hong Kong's Stablecoins Ordinance took effect on 1 August 2025, making the issuance of a fiat-referenced stablecoin a licensed activity supervised by the Hong Kong Monetary Authority, including for foreign issuers of Hong Kong dollar-referenced tokens, with reserve, segregation, disclosure, audit, and AML/CFT requirements. The United Arab Emirates has introduced licensing and reserve requirements through its payment-token regulation, and Japan regulates stablecoins under its Payment Services Act.
Cross-border enforceability of these issuer-level obligations depends in part on the broader anti-money-laundering infrastructure. The Financial Action Task Force has reported that legislation implementing the Travel Rule, which requires originator and beneficiary information to accompany transfers, had been enacted in 85 of 117 surveyed jurisdictions in 2025. This framework supports sanctions screening and the tracing of suspicious activity where stablecoin transfers cross jurisdictional boundaries.
Distinctive features of stablecoin AML compliance
Several characteristics of stablecoins differ from the instruments for which the Bank Secrecy Act and comparable regimes were originally designed, and these differences bear on the application of anti-money-laundering requirements. Stablecoins settle continuously rather than within defined banking hours; they are typically recorded on public blockchains, which call for transaction-monitoring methods distinct from those used for wire transfers; and they move across borders frequently, increasing the volume and complexity of sanctions screening. The FDIC invited public comment on whether its proposed standards are appropriately calibrated to these features, including the continuous settlement window, blockchain-based monitoring, and cross-border sanctions screening.
Commentary on the frameworks identifies a recurring trade-off. The properties that make stablecoins suited to rapid, low-cost, cross-border payments are also those that present money-laundering and sanctions-evasion risks. The regulatory response across jurisdictions has been to retain the instrument while requiring issuers to apply financial-crime controls comparable to those of regulated financial institutions. Supporters of this approach argue that such controls support broader and institutional adoption; some observers note that the associated compliance costs may bear more heavily on smaller and crypto-native issuers than on established banks.
Outlook
The FDIC proposal is open for public comment for 60 days following publication in the Federal Register, and the final form of the United States rules will depend on the combined output of the FDIC, OCC, Federal Reserve, NCUA, FinCEN, and OFAC. The broader pattern across jurisdictions points toward a common baseline: stablecoin issuers, whether structured as United States bank subsidiaries, EU e-money institutions, or HKMA-licensed entities, are increasingly subject to anti-money-laundering obligations of the kind long applied to traditional financial institutions. The extent to which these frameworks achieve consistent application across borders will become clearer as the relevant comment periods close and remaining rules are finalised.
References
FDIC, "FDIC Board Approves Proposal to Address Bank Secrecy Act and Sanctions Compliance Standards for FDIC-Supervised Permitted Payment Stablecoin Issuers" (22 May 2026) — https://www.fdic.gov/news/press-releases/2026/fdic-board-approves-proposal-address-bank-secrecy-act-and-sanctions
Hunton Andrews Kurth, "FDIC Proposes AML and Sanctions Rule for Permitted Stablecoin Issuers" (May 2026) — https://www.hunton.com/blockchain-legal-resource/fdic-proposes-aml-and-sanctions-rule-for-permitted-stablecoin-issuers
National Law Review, "FDIC Proposes AML and Sanctions Standards for Stablecoin Issuers" (May 2026) — https://natlawreview.com/article/fdic-proposes-aml-and-sanctions-standards-stablecoin-issuers
GN Crypto, "FDIC Advances BSA and Sanctions Rule for Bank-Linked Stablecoins" (May 2026) — https://www.gncrypto.news/news/fdic-bsa-sanctions-rule-bank-linked-stablecoins/
Holland & Knight, "FinCEN and OFAC Propose AML/Sanctions Rules for Stablecoin Issuers Under GENIUS Act" (Apr 2026) — https://www.hklaw.com/en/insights/publications/2026/04/fincen-and-ofac-propose-aml-sanctions-rules-for-stablecoin-issuers
Federal Register, "Permitted Payment Stablecoin Issuer AML/CFT Program and Sanctions Compliance Program Requirements" (10 Apr 2026) — https://www.federalregister.gov/documents/2026/04/10/2026-06963/permitted-payment-stablecoin-issuer-anti-money-launderingcountering-the-financing-of-terrorism
BVNK, "Global stablecoin regulations 2026: What enterprises need to know" (Jan 2026) — https://bvnk.com/blog/global-stablecoin-regulations-2026
Sumsub, "Global Stablecoin Compliance: GENIUS Act, MiCA, Hong Kong, Singapore, and More Key Rules" — https://sumsub.com/blog/global-stablecoin-compliance-guide/
Stablecoin Insider, "The Ultimate Guide to Stablecoin Regulations Worldwide in 2025-2026" (Dec 2025) — https://stablecoininsider.org/stablecoin-regulations/
Hacken, "Stablecoin Regulation: An Overview for Issuers and Exchanges" (Feb 2026) — https://hacken.io/discover/global-stablecoin-regulation/
Blockchain Council, "Stablecoin Regulation in 2026: Reserve, Licensing, Audit Requirements" (Mar 2026) — https://www.blockchain-council.org/cryptocurrency/stablecoin-regulation-2026-reserve-licensing-audit-requirements/
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