WASHINGTON, DC (June 10, 2026) |
The Defense Credit Union Council (DCUC) has submitted a comment letter to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) following FinCEN regarding its joint proposed rule with the Office of Foreign Assets Control (OFAC) implementing provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act).
The proposed rule would treat permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act (BSA), establish anti-money laundering obligations, impose specific statutory requirements for PPSIs, and require effective sanctions compliance programs.
“DCUC supports Treasury’s efforts to combat illicit finance and implement the GENIUS Act in a manner that promotes financial integrity and responsible innovation. As this framework is developed, it is critical that implementation remains workable for credit unions and does not unintentionally limit their ability to participate in emerging payment systems,” says Jason Stverak, DCUC Chief Advocacy Officer.
DCUC voiced that final rules must be designed to be workable for credit unions and should not inadvertently create barriers that reserve participation in stablecoin-related activities to only the largest financial institutions. DCUC urged FinCEN and OFAC to ensure that requirements remain proportionate to an institution’s size, complexity, risk profile, and level of engagement in stablecoin activities.
DCUC also stressed that credit unions engaging in limited stablecoin-related activities should not be subject to the same supervisory expectations as large-scale issuers, and that examination standards must reflect actual risk exposure.
“We strongly support the agencies’ continued emphasis on risk-based compliance frameworks, as credit unions have long relied on risk-based approaches to allocate resources toward higher risk products, services, and transactions,” adds Stverak.
DCUC supports applying risk-based principles to sanctions compliance obligations, ensuring institutions can tailor programs appropriately rather than adopting one-size-fits-all requirements. The recommendations called for avoiding duplicative regulatory requirements, as many credit unions already maintain robust BSA, customer due diligence, suspicious activity reporting, and sanctions compliance programs.
DCUC encouraged FinCEN and OFAC to clarify that existing compliance frameworks should be leveraged where appropriate, rather than requiring redundant systems or processes, and called for strong interagency coordination among FinCEN, OFAC, the National Credit Union Administration (NCUA), and other regulators.
“We encourage FinCEN and OFAC to provide advance guidance, training materials, and industry webinars prior to examinations, along with continued interagency coordination to support consistent implementation in this emerging regulatory space,” Stverak says.