On October 21, 2026, the Office of the Comptroller of the Currency (OCC) issued a final rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act) for entities subject to OCC jurisdiction. The rule sets out a federal framework for payment stablecoin issuance, reserve management, redemption, custody, capital, supervision, and licensing. It takes effect January 18, 2027. (See our other blog posts on the GENIUS Act and stablecoins here and here.)

This is the OCC’s first comprehensive supervisory framework for federally regulated payment stablecoin activities. One significant piece is missing: the OCC stated that BSA/AML and sanctions requirements will be addressed through a separate rulemaking.

What the Final Rule Covers

The final rule addresses nearly all of the regulations the GENIUS Act directed the OCC to issue. According to the OCC, it establishes standards covering:

  • Permitted activities
  • Reserve assets
  • Redemption
  • Risk management
  • Audits, reporting, and supervision
  • Custody
  • Licensing and registration
  • Capital and operational backstop requirements
  • Foreign payment stablecoin issuers
  • State issuer transitions to federal oversight

The rule appears primarily in new 12 C.F.R. Part 15 and applies to:

  • Subsidiaries of national banks and federal savings associations that issue payment stablecoins
  • Federal qualified payment stablecoin issuers
  • Certain state-qualified payment stablecoin issuers
  • Foreign payment stablecoin issuers subject to OCC authority
  • OCC-supervised entities providing certain stablecoin custody services

Reserve Requirements Focus on Liquidity and Redemption

Issuers must maintain reserve assets with a value equal to or greater than outstanding stablecoins at all times. Beyond that baseline, the OCC adopted a largely principles-based framework, though it kept certain quantitative safeguards. Among other requirements, issuers must:

  • Hold only statutorily permitted reserve assets
  • Maintain at least 5% of reserves in immediately available liquidity
  • Limit exposure to a single counterparty to 40% of reserve assets, subject to certain exceptions
  • Conduct liquidity and reserve stress testing

Tokenized reserve assets are permitted if they provide the same legal rights as their traditional counterparts. Notably absent are certain prescriptive portfolio requirements from the proposal, including a weighted-average maturity limit. The OCC instead relies on liquidity management, stress testing, and supervisory review.

OCC Revises Proposed Redemption and Yield Provisions

Two provisions that drew substantial comment during the proposal process changed in the final rule.

Redemption extensions. The proposal would have automatically extended redemption deadlines when redemption requests exceeded 10% of outstanding issuance value within a 24-hour period. Commenters argued that an automatic extension could itself contribute to market stress, according to the OCC, and the agency dropped it. Under the final rule, issuers must instead notify the OCC when that threshold is reached and seek approval for any extension of the general requirement to satisfy redemption requests within two business days.

Indirect yield. The OCC also abandoned a proposed rebuttable presumption designed to identify indirect yield arrangements that could violate the GENIUS Act’s prohibition on paying interest or yield on payment stablecoins. In the OCC’s view, the presumption risked being both overinclusive and underinclusive. The statutory prohibition remains intact, but particular arrangements will be assessed under a facts-and-circumstances analysis. The agency indicated it may provide additional guidance in this area.

Risk Management, Reporting, and Capital Expectations

The rule’s supervisory framework extends to risk management, reporting, and capital. Its risk management standards are principles-based and modeled in part on existing banking supervisory frameworks. Issuers must maintain programs addressing:

  • Operational risk
  • Liquidity risk
  • Interest rate risk
  • Information technology and cybersecurity risk
  • Third-party risk management
  • Internal controls and audit functions
  • Insider and affiliate transactions

Reporting obligations include:

  • Weekly confidential reports to the OCC
  • Quarterly financial-condition reports
  • Monthly reserve composition reports
  • Monthly executive certifications regarding reserve compliance
  • Annual AML and economic sanctions compliance certifications

Large issuers with more than $50 billion in consolidated outstanding issuance value that are not SEC reporting companies must also prepare annual audited financial statements.

On capital, the OCC declined to adopt a standardized formula. Each issuer will instead be subject to issuer-specific minimum capital requirements, together with a separate operational backstop requirement designed to support ongoing operations during periods of disruption.

BSA/AML Implications Despite a Separate Rulemaking

Substantive BSA/AML and sanctions requirements will come in a later rulemaking, but the final rule already contains several provisions relevant to financial crime compliance.

Start with governance. The rule emphasizes internal controls, risk management, independent review, and executive accountability. None of these is framed as a BSA/AML obligation, yet each features prominently in regulatory assessments of financial crime compliance programs. Section 15.14 adds extensive reporting and recordkeeping obligations that complement the rule’s supervisory framework.

Most directly, issuers must certify within 180 days after approval, and annually thereafter, that they have implemented anti-money laundering and economic sanctions compliance programs reasonably designed to prevent money laundering and terrorist financing, including money laundering involving cartels and designated foreign terrorist organizations.

Meeting these reporting and certification requirements will mean collecting, maintaining, and reporting significant operational and financial information. Firms building compliance frameworks under the GENIUS Act may therefore evaluate them alongside existing financial crime compliance processes and controls.

The sequencing also matters. Because the OCC is addressing AML/CFT requirements in a separate rulemaking, issuers may need to establish governance, reporting, and control frameworks before the details of their federal AML obligations are finalized. Additional guidance is expected through the future OCC and Treasury rulemaking process.

Foreign Issuers and State-Issuer Transitions

The final rule establishes registration and supervisory requirements for foreign payment stablecoin issuers operating under the GENIUS Act’s foreign issuer framework. Among other requirements, registered foreign issuers must hold reserves in U.S. financial institutions sufficient to meet the liquidity demands of U.S. customers, unless a Treasury reciprocal arrangement permits otherwise.

State-qualified payment stablecoin issuers face the Act’s transition framework once consolidated outstanding issuance exceeds $10 billion. The OCC also created a process through which such issuers may seek waivers allowing them to remain subject solely to state supervision.

Key Takeaway

As in several aspects of the proposal, the final rule generally relies on principles-based standards for reserve management, risk management, and oversight, while keeping a number of specific quantitative and reporting requirements. The result is a comprehensive supervisory framework for payment stablecoin issuers under OCC jurisdiction.

Attention now turns to the separate OCC and Treasury rulemaking on BSA/AML and sanctions requirements. That process is expected to provide additional detail on the compliance obligations applicable to entities operating under the GENIUS Act framework. If you would like to remain updated on these issues, please click here to subscribe to Money Laundering Watch. And please click here to find out about Ballard Spahr’s Anti-Money Laundering Team.