On February 25, the Office of the Comptroller of the Currency (OCC) released a 376‑page notice of proposed rulemaking (NPRM) to implement the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for entities under its jurisdiction. The proposed rule would create a comprehensive framework for “payment stablecoin” issuers supervised by the OCC, foreign payment stablecoin issuers accessing the U.S. market, and certain custody activities by OCC‑regulated banks. The NPRM was published in the Federal Register on March 2, with the 60-day comment period ending on May 1, 2026. The NPRM also poses more than 200 specific questions for public comment on definitions, activities, reserves, liquidity, and other key design choices.

On April 21, four major banking trade associations — the American Bankers Association, Bank Policy Institute, Consumer Bankers Association, and Independent Community Bankers Association (collectively, the associations) — sent a joint letter to the U.S. Department of the Treasury (Treasury), the Federal Deposit Insurance Corporation (FDIC), the Financial Crimes Enforcement Network (FinCEN), and the Office of Foreign Assets Control (OFAC) requesting an additional 60 days to comment on three key proposed rules implementing the GENIUS Act after the Office of Comptroller of the Currency (OCC) issues a final rule implementing the GENIUS Act for entities subject to the OCC’s jurisdiction. These rulemakings address, respectively, how to determine whether state stablecoin regimes are “substantially similar” to the federal framework (discussed here), prudential standards for FDIC‑supervised permitted payment stablecoin issuers and insured depository institutions, and Anti-Money Laundering (AML)/Countering the Financing of Terrorism (CFT) and sanctions compliance program requirements for stablecoin issuers.

Yesterday, U.S. Representatives Young Kim (R-CA) and Sam Liccardo (D-CA) introduced the Payments Access and Consumer Efficiency Act of 2026 (PACE Act). The bill would create an optional federal framework for large state‑regulated payment companies, giving qualifying firms Office of the Comptroller of the Currency (OCC) supervision and potential direct access to Federal Reserve payment rails, in exchange for bank‑like prudential and customer‑protection standards. It is an early‑stage proposal with uncertain prospects but significant implications for nonbank payments and bank–fintech partnerships.

The Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and National Credit Union Administration (NCUA) jointly issued a notice of proposed rulemaking to modernize anti-money laundering and countering the financing of terrorism (AML/CFT) compliance program requirements. The proposed rule is intended to align their rules with FinCEN’s parallel amendments under the Bank Secrecy Act and the Anti-Money Laundering Act of 2020 (discussed here). FinCEN’s proposal lays out the big-picture requirements for AML/CFT programs under the Bank Secrecy Act, while the federal banking agencies’ proposal takes those rules and aligns them to their own supervisory and examination frameworks so they can actually oversee and enforce the requirements for financial institutions. Comments are due no later than June 9, 2026.

Troutman Pepper Locke’s Securities Investigations and Enforcement team counsels and defends clients through all stages of securities enforcement proceedings. Our attorneys have served in key government agencies and regulatory bodies, and bring their insight to bear in each representation. The team includes a former branch chief of the Division of Enforcement at the SEC, former enforcement lawyers, regulators and government attorneys, assistant United States Attorneys and former assistant attorneys general, as well as in-house counsel for public companies. Our lawyers and practice have been identified as leaders in the field by publications such as the Legal 500, SuperLawyers, Benchmark Litigation, and Chambers USA.

The Securities and Exchange Commission’s (SEC) April 7, 2026, press release on its fiscal year (FY) 2025 enforcement results is less about numbers and more about a philosophical reset. Under Chairman Paul Atkins and Commissioner Mark Uyeda, who served as acting chair prior to the chairman’s confirmation, the SEC is expressly stepping back from what it characterizes as “regulation by enforcement” and volume‑driven metrics, and recentering on what it has described as fraud, investor harm, and congressional intent. For registrants and other market participants, this shift has direct consequences for how enforcement risk is likely to be assessed going forward.

On April 7, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking (NPRM) that would significantly revise Bank Secrecy Act (BSA) anti-money laundering and countering the financing of terrorism (AML/CFT) program requirements across a broad range of financial institutions. The proposal is a central element of the U.S. Department of the Treasury’s effort to modernize the AML/CFT framework by moving away from purely technical, process-driven compliance toward demonstrable effectiveness in identifying, mitigating, and reporting money laundering, terrorist financing, and related illicit finance risks.

The U.S. Department of the Treasury has issued a notice of proposed rulemaking (NPRM) to implement the broad-based principles set out in the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act for determining when a state-level regulatory regime for “state qualified payment stablecoin issuers” is “substantially similar” to the federal regulatory framework. That determination is the gateway for state-chartered, nonbank stablecoin issuers with up to $10 billion in outstanding stablecoins to operate primarily under state oversight rather than as federally supervised “permitted payment stablecoin issuers.” Comments will be due 60 days after publication in the Federal Register.