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.

On September 27, 2025, the United Nations reimposed sanctions and other restrictions based on Iran’s continuing “significant non-performance” of its nuclear commitments. Today, September 29, following the UN resolution, the European Union formally reimposed a broad range of sanctions on Iran, citing the same “significant non-performance” of its nuclear commitments under the Joint Comprehensive Plan of Action (JCPOA). These actions follow the invocation of the JCPOA’s snapback mechanism by the E3 (France, Germany, and the United Kingdom) on August 28, 2025, and mark a major shift in the international legal and commercial landscape for entities engaged with Iran.