Federal Reserve Moves To Close Stablecoin Loopholes With New Customer ID Rules

The Federal Reserve proposed Thursday that payment stablecoin issuers maintain written customer identification programs, a move that signals Washington’s determination to bring digital asset markets under the same anti-money laundering discipline long applied to traditional banks — even as regulators race to finalize rules before a statutory deadline this coming January.

The proposal would require so-called permitted payment stablecoin issuers, or PPSIs, to collect from each new customer a legal name, date of birth or formation, physical address, and a government-issued identification number before opening an account. 

The Federal Reserve framework mirrors CIP obligations that banks, broker-dealers, mutual funds, and futures commission merchants have operated under for more than two decades. Regulators will take public feedback on the proposal for 60 days.

The Federal Reserve’s action follows a wave of rulemaking set in motion by the Genius Act — formally, the Guiding and Establishing National Innovation for U.S. Stablecoins Act — which President Trump signed into law in July 2025.

That landmark legislation created the first federal regulatory system for stablecoins, mandating 100% reserve backing with liquid assets and subjecting issuers to the Bank Secrecy Act for the first time. 

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The statute requires stablecoin issuers to establish effective anti-money laundering, sanctions compliance, and customer identification programs. The Genius Act becomes effective on the earlier of January 18, 2027, or 120 days after primary federal regulators issue their final implementing rules.

Federal Reserve Governor cautions towards stablecoins

Federal Reserve Governor Michael Barr has emerged as the most vocal voice of caution within the regulatory apparatus, even as his colleagues have embraced digital assets with new openness. Speaking in March at a Federalist Society conference in Washington, Barr warned that stablecoins face material risks around reserve asset quality, regulatory arbitrage, anti-money laundering gaps, and financial stability — concerns he argued the Genius Act’s primary text does not resolve on its own. 

“While some digital asset service providers are subject to anti-money laundering and anti-terrorist financing requirements in their home jurisdiction, it is far too easy for bad actors to evade these restrictions and operate without detection when transacting in digital assets,” Barr said in a statement Thursday. 

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Barr, who previously served as the Federal Reserve’s top bank cop, contends that detailed rulemaking remains the critical instrument for translating the statute’s intent into enforceable protections.

Thursday’s proposal is the latest in a dense sequence of rulemakings from multiple agencies. In April 2026, the Treasury Department’s Financial Crimes Enforcement Network and the Office of Foreign Assets Control issued a joint proposed rule requiring PPSIs to adopt written AML and countering-the-financing-of-terrorism programs and a full sanctions compliance framework. 

That rule would carve PPSIs out of the existing money services business category and treat them as a distinct class of BSA-covered financial institutions — a significant structural change, given FinCEN’s finding that roughly half of known stablecoin issuers have not registered as MSBs at all. 

The FDIC and OCC each issued their own notices of proposed rulemaking in parallel, covering licensing, reserves, capital requirements, and redemption standards. The CIP proposal announced Thursday is a separate, complementary rulemaking to those AML and sanctions rules.

Stablecoin rules and nuance

The proposed customer identification requirements carry technical nuance tailored to stablecoin markets. Unlike banks, a PPSI can face demands for direct redemption from token holders who acquired coins on the secondary market rather than through a direct issuance relationship. 

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The proposal addresses this by defining an “account” to include that redemption event, meaning an individual who acquires a stablecoin on an exchange and later redeems it directly with the issuer would trigger CIP obligations at the moment of that interaction. 

Purely secondary market transactions in which the PPSI is not a direct counterparty — including transfers conducted via smart contract — would not constitute an account relationship under the proposed framework.

The timeline for finalization is tight. With the Genius Act’s effective date potentially arriving as early as 120 days after the agencies publish their final rules, the window for comment, revision, and adoption is compressed. Final CIP rules are not expected before 2027, which means the statute could take effect before its customer identification architecture is fully in place. 

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