Agencies Propose Stablecoin Issuer Customer Identification Program Rule

The Financial Crimes Enforcement Network (FinCEN), acting jointly with the Office of the Comptroller of the Currency (OCC), the Board of Governors of the Federal Reserve System (the Board), the Federal Deposit Insurance Corporation (FDIC) and the National Credit Union Administration (NCUA), has issued a notice of proposed rulemaking implementing the customer identification program (CIP) provisions of the Guiding and Establishing National Innovation for US Stablecoins Act (GENIUS Act).

The proposal gives effect to the Act's directive that permitted payment stablecoin issuers (PPSIs) be treated as financial institutions under the Bank Secrecy Act (BSA) and maintain an effective CIP covering the identification and verification of account holders. The rule would establish minimum CIP requirements for PPSIs and clarify when an issuer has a customer and account relationship triggering identification and verification. The CIP obligations are framed as comparable to those already applied to other BSA-covered institutions: a written, risk-based program, collection of specified identifying information, identity verification within a reasonable period, recordkeeping, screening against designated government lists and customer notice.

The scoping decisions are where the practitioner interest lies. The proposed definition of "account" — a formal relationship established to provide services such as the issuance or redemption of a stablecoin — is what triggers the CIP obligation, with carve-outs where no formal relationship exists, where interaction occurs solely through a smart contract, or where holdings arise absent other indicators of a relationship. Consistent with that approach, secondary-market participants are excluded from CIP collection despite most stablecoin activity occurring there, on practicality grounds, and the agencies declined to require capture of wallet identification numbers. Identifying information must be retained for five years after account closure, with verification records held for five years from creation.

The rule closes a long-standing gap. Although stablecoin issuers were named as money services businesses under the BSA from 2019, the MSB classification carried no affirmative CIP requirement; the GENIUS Act removes that exemption for PPSIs. The CIP proposal sits alongside the separate FinCEN/Office of Foreign Assets Control (OFAC) AML/countering the financing of terrorism (CFT) and sanctions-compliance rulemaking published in April 2026, and together the two instruments form the federal BSA framework for the sector.

Comments are due by 21 August 2026, 60 days after Federal Register publication. Issuers and the federally regulated institutions on which they may place limited reliance should be mapping customer and account relationships against the proposed definitions now, since the line between primary-market obligation and secondary-market exclusion will determine where verification controls actually need to sit.

Read the press release here.