September 11, 2025

Impact of the AML Provisions in the GENIUS ACT

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The passage of the GENIUS Act has opened the floodgates for stablecoins. Dozens of new issuers (if not more) are expected to enter the market in the coming months, and the total volume outstanding continues to increase at a rapid pace.

As regulators begin to write the rules for these new stablecoin issuers, one of the key areas to watch is anti-money laundering (AML) compliance. Responsible market participants will be looking for the development of reasonable, risk-based standards that require issuers to prudently control financial crime risk, while not being so onerous that the river of innovation is completely dammed.

To learn more about this important issue, Mayer Brown is hosting a webinar with Brad Resnikoff, a financial crimes expert, and Matt Bisanz, a risk and regulator partner. Brad and Matt will explore the key AML provisions of the GENIUS Act, including:

  • What it means for stablecoin issuers to be treated as financial institutions under the Bank Secrecy Act.
  • The types of AML compliance obligations that the Financial Crimes Enforcement Network may impose on stablecoin issuers.
  • How the U.S. Treasury Department will work with industry to develop new compliance strategies to detect money laundering involving digital assets.
  • Where the government may, or should, tailor AML regulations to reflect the unique attributes of payment stablecoins.

For additional information, please contact Alexandra Auth at aauth@mayerbrown.com or +1 212 506 2589.

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