​The GENIUS Act was signed into law on July 18, 2025. Eleven months in, Treasury has published an ANPRM (September 2025) soliciting comment on implementation, FinCEN and OFAC jointly proposed an AML and sanctions framework for permitted payment stablecoin issuers (April 2026), Treasury proposed principles for acceptable state stablecoin regimes (April 2026), and the OCC issued Bulletin 2026-3 on the agency rulemaking. Final rules from FinCEN, OFAC, the Fed, and the OCC are still pending as of June 2026. The proposed AML/sanctions rules would take effect 12 months after final issuance.
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The Guiding and Establishing National Innovation for U.S. Stablecoins Act of 2025 (the GENIUS Act) established the first federal framework for payment stablecoins. The statute does several things at once. It defines "permitted payment stablecoin issuer" (PPSI), reserves the activity of issuing payment stablecoins to PPSIs, sets the 1:1 backing requirement, requires reserves in US dollars or other low-risk assets, creates a federal-charter path under the OCC and the Fed, and creates a state-path option for issuers under approved state regimes.
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It also tasks Treasury, FinCEN, OFAC, the Fed, the OCC, and the FDIC with issuing implementing regulations. The statutory deadlines varied by agency and topic. What follows is what those agencies have actually shipped between July 2025 and June 2026.
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The joint FinCEN and OFAC proposed rule, published in April 2026, lays out the AML and sanctions compliance program requirements for PPSIs. It treats PPSIs as financial institutions for Bank Secrecy Act purposes, requires a written AML compliance program, designates a compliance officer, mandates customer identification and ongoing monitoring, and imposes record-keeping and SAR-filing obligations consistent with other regulated financial institutions.
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On the OFAC side, PPSIs would be required to maintain sanctions screening programs covering both transactional counterparties and any wallet-level controls available through the smart contract or off-chain identity systems they deploy.
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The proposed effective date is 12 months after final rule issuance. That gives issuers a year of runway to build the operational machinery, but only once the final rule lands.
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The GENIUS Act allows a stablecoin issuer to operate under an approved state regime as an alternative to federal charter. Treasury's April 2026 proposal lays out the principles under which a state regime can be certified as acceptable. The proposed criteria align state regimes with federal-charter substance on reserves, segregation, audit, redemption, and supervisory oversight, while preserving meaningful state discretion on implementation.
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This is the gating regulation for the next state-issued stablecoin launches. Wyoming's Frontier Stable Token is operating under a state-statute structure that predates the federal framework. Future state launches will likely wait for Treasury's certification framework to be finalized before going public.
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Several pieces of the implementation puzzle remain open as of June 2026.

Eleven months is fast for major financial regulation. By the equivalent point in Dodd-Frank's implementation cycle, only the most procedural rules had been issued. The GENIUS Act has ANPRM + NPRM stages running across multiple agencies in parallel, which is an unusual cadence for a brand new financial-products statute.
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The pace is also imperfect. Final rules from FinCEN, OFAC, the OCC, the Fed, and Treasury all remain outstanding. Issuers can read the proposed rules but cannot yet build to a finalized standard. That gap, between proposed and final, is where the next 12 months of implementation will play out.
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Three things define whether the GENIUS Act lands cleanly through 2026 and into 2027. First, whether FinCEN and OFAC finalize their AML and sanctions rule, starting the 12-month clock. Second, whether Treasury certifies its first state regime, clearing the path for the next state-issued stablecoin launch. Third, whether the OCC charters its first federally regulated PPSI, which is the moment the federal-path framework moves from paper to practice.
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Any of the three crossing the line moves the next 12 months from a comment-letter phase into an operational phase. None of the three has yet.
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The milestones in the tracker are pulled from the Federal Register (federalregister.gov), Treasury press releases (home.treasury.gov), the OCC bulletin library (occ.treas.gov), and contemporaneous coverage from Mayer Brown, Paul Hastings, and Davis Polk on the agency rulemakings. The statute text is on congress.gov as S.394 (119th Congress).
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