Notabene Response to FinCEN AML/CFT Program NPRM

For the first time in OFAC's history, U.S. regulators are codifying an explicit sanctions compliance program requirement in regulation. Also for the first time, FinCEN is treating stablecoin issuers as a distinct financial institution category under the Bank Secrecy Act rather than as money services businesses with a crypto wrapper.

The joint proposed rule FinCEN and OFAC issued in April implementing the Permitted Payment Stablecoin Issuer (PPSI) framework under the GENIUS Act is the most consequential digital asset rulemaking the U.S. has embarked on in a decade.

Notabene filed our response to the notice of proposed rulemaking (NPRM), answering eleven substantive questions across the AML/CFT and sanctions program sections.

‍