Overview

• Treasury issued an advance notice of proposed rulemaking and set a public comment deadline of Oct. 20 to gather input before drafting regulations.
• Officials posed dozens of questions covering reserve custody, prohibitions on issuers, AML and sanctions compliance, tax treatment, and comparisons with foreign regimes.
• The notice follows an earlier outreach focused on illicit‑finance risks, underscoring Treasury’s mandate to build enforcement mechanisms alongside consumer protections.
• Industry participants are accelerating compliance builds, though key uncertainties remain on AML program expectations, travel‑rule treatment across wallets and bridges, and the legal definition of “issuer.”
• Rulemaking sits within a wider policy effort that includes the Digital Asset Market Clarity Act, with GENIUS timelines requiring final rules by July 18, 2026, statutory effect Jan. 18, 2027, and full compliance by July 18, 2028.