The American Fintech Council has submitted comments on proposed stablecoin AML/CFT rules tied to implementation of the GENIUS Act, adding an industry trade-group response to a rulemaking that would establish anti-money-laundering and sanctions-compliance expectations for permitted payment stablecoin issuers.

The proposal was issued by the U.S. Treasury, which proposed a rule to implement the GENIUS Act’s requirements to counter illicit finance. The rulemaking was published in the Federal Register on April 10, 2026, for public comment and applies to permitted payment stablecoin issuers.

AFC response to the proposed stablecoin rules

The American Fintech Council (AFC) is an industry association representing fintech companies and technology-focused financial firms. Its comments form part of the formal notice-and-comment process through which regulators receive stakeholder feedback before finalizing rules. That process is significant because final compliance obligations can differ from a proposal after agencies review the administrative record and respond to material comments.

The AFC’s position was presented in a statement from Ian P. Moloney, chief policy officer at the American Fintech Council, responding to the proposed rule for payment stablecoin AML/CFT and sanctions-compliance risk management. The group also filed a formal response to the GENIUS Act AML/CFT rulemaking.

Treasury’s proposal is intended to implement AML/CFT requirements under the GENIUS Act for permitted payment stablecoin issuers. The American Fintech Council submitted its comments through Moloney, and the proposal entered the Federal Register comment process on April 10, 2026.

Compliance expectations for permitted payment stablecoin issuers

AML/CFT refers to anti-money-laundering and countering the financing of terrorism. In the stablecoin context, these standards would require issuers to develop programs designed to detect and report suspicious activity and screen for sanctioned parties. For payment stablecoin issuers, those obligations sit alongside broader operational and risk-management expectations because tokens can be transferred across platforms and counterparties at high speed.

According to a FinCEN fact sheet on the proposed permitted payment stablecoin issuer program, the rulemaking describes how such issuers would be expected to manage AML/CFT and sanctions-compliance risk. The regulatory proposal is separate from the AFC’s response: the proposal sets out the government’s planned requirements, while the AFC filing represents stakeholder feedback on that text.

Compliance and monitoring obligations are central to regulatory treatment of stablecoins used in payments. Security incidents involving dollar-pegged tokens, including the reported Arbitrum AFX bridge hack tied to an alleged USDC loss, have underscored why regulators focus on monitoring and reporting around stablecoin flows.

Importance of the public comment process

Stakeholder submissions such as the AFC’s can affect how regulators calibrate final requirements, including the compliance obligations imposed on fintech companies and stablecoin issuers. Trade-group input can indicate where industry participants view proposed rules as workable or overly broad, and can help regulators identify implementation issues before obligations become binding.

AML/CFT standards are widely treated as important to stablecoin legitimacy because payment tokens without credible controls may face resistance from banks, regulators and mainstream adopters. Clear rules addressing illicit-finance risk are also relevant to broader institutional use of stablecoin payment systems.

The next steps for the rulemaking include the close of the public comment period and any final rule following the April 10 Federal Register publication. Treasury’s approach after reviewing comments, including submissions from organizations such as the AFC, will determine the practical compliance framework for permitted payment stablecoin issuers.