GENIUS Act section 4(a)(5) and (6): permitted issuers are treated as financial institutions under the Bank Secrecy Act and must maintain AML and CFT programs, records and reports, an effective customer identification program with enhanced due diligence, an effective economic sanctions compliance program, and technical capabilities, policies and procedures to block, freeze and reject impermissible transactions and to comply with lawful orders; Treasury coordinates blocking actions with issuers. Implementing FinCEN and OFAC rules were proposed in April 2026.
The graph holds this control, the 0 it maps to, and the evidence behind each claim, over MCP and REST.