Introduction

On June 18, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), together with the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, and the National Credit Union Administration (collectively, the “Agencies”) issued a joint notice of proposed rulemaking (“NPRM”) to implement certain customer identification program (“CIP”) requirements under the Guiding and Establishing National Innovation for U.S. Stablecoins Act (“GENIUS Act”).[1]