Customer Identification Program (CIP)
Verify the identity of each customer before establishing a relationship.
Stablecoin regulation
GENIUS Act Compliance Guide
A guide to the Guiding Uniform Innovation for the Nation's Digital Economy (GENIUS) Act — compliance requirements for payment stablecoin issuers (PPSIs) and digital asset service providers.
Key takeaways
- The GENIUS Act establishes a regulatory framework for payment stablecoins (PPSIs) and digital assets.
- Compliance with BSA/AML requirements is mandatory for PPSIs and digital asset service providers.
- Customer Identification, Customer Due Diligence, and OFAC sanctions screening apply at onboarding and ongoing.
- Suspicious Activity Reports must be filed with FinCEN as needed.
Show me the regulation
The exact citation, snapshot fields, retention period, and OMINEX events that satisfy each rule covered in this guide.
Each panel below is the full structured detail for a regulation referenced in this guide — drawn from the OMINEX regulation registry. Expand any one to see the citation, what it requires in plain language, what fields the examiner reads from the snapshot, the retention period, and the specific OMINEX event types that produce the evidence.
What is the GENIUS Act?
The Guiding Uniform Innovation for the Nation's Digital Economy (GENIUS) Act is U.S. legislation aimed at establishing a comprehensive regulatory framework for payment stablecoins (PPSIs) and other digital assets. It seeks to clarify the regulatory landscape, protect consumers, and ensure compliance with anti-money-laundering and Bank Secrecy Act requirements.
For payment stablecoin issuers and digital asset service providers, compliance with the GENIUS Act is critical for operating legally within the U.S. financial system.
Key compliance requirements
Customer Due Diligence (CDD)
Understand the nature and purpose of customer relationships and identify beneficial owners.
Enhanced Due Diligence (EDD)
Apply enhanced scrutiny for higher-risk customers, jurisdictions, and transactions.
OFAC sanctions screening
Screen customers and counterparties against the Office of Foreign Assets Control list.
Suspicious Activity Reporting (SAR)
Report any suspicious activity to FinCEN within the applicable filing window.
Recordkeeping
Maintain records of all transactions and compliance efforts for the required retention period.
Independent testing
Regularly test the AML program for effectiveness through internal audit or external review.
BSA officer
Designate a Bank Secrecy Act compliance officer to oversee day-to-day program operations.
Ongoing compliance timeline
| Cadence | Compliance activities |
|---|---|
| Ongoing | CIP, CDD, EDD for high-risk customers, OFAC sanctions screening, transaction monitoring. |
| As needed | Suspicious Activity Reports, responding to law enforcement requests, updating compliance policies. |
| Regularly | Independent testing of AML program, employee training, reviewing and updating risk assessments. |
| Annually | BSA officer reporting to the board, reviewing the overall compliance program. |
From rule to operating fit
This rule is one part of the broader digital asset compliance picture your team still has to prove in front of buyers, auditors, and regulators.
The mandate map shows where verification and recordkeeping requirements already apply across digital assets, tokenized capital markets, and related infrastructure. The business case explains how OMINEX helps teams reduce manual proof gathering, answer diligence faster, and move deals forward with less operational drag.
Originally published May 2025 · Last reviewed December 2025