On September 19, 2025, the U.S. Department of the Treasury (Treasury) issued an Advance Notice of Proposed Rulemaking (ANPRM) to solicit public comment on questions relating to the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. Through this ANPRM, Treasury sought feedback on a wide range of potential regulatory issues, including clarity around issuance and marketing restrictions, compliance with the Bank Secrecy Act (BSA) obligations, anti-money laundering (AML) and sanctions enforcement, coordination between state and federal oversight, foreign regulatory comparability, and tax implications.

Last month, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) order providing exemptive relief for covered investment advisers from certain anti-money laundering and combating the financing of terrorism  program and other Bank Secrecy Act-related reporting, recordkeeping and information-sharing obligations (IA AML Rule) until January 1, 2028. The IA AML Rule, published by FinCEN as a final rule on September 4, 2024, is currently set to become effective on January 1, 2026. 
On September 22, 2025, FinCEN published a notice of proposed rulemaking to amend the IA AML Rule to delay its effective date by two years, from January 1, 2026 to January 1, 2028.

Last year in September, we published an alert about the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) final rule, which would have imposed certain anti-money laundering and combating the financing of terrorism (AML/CFT) program and other Bank Secrecy Act-related obligations on investment advisers (IA AML Rule) effective January 1, 2026.