Three Rulemakings, Two Dead Clocks: What a Permitted Stablecoin Issuer Must Actually Build

The compliance layer for permitted payment stablecoin issuers is not a single document, but a stack of three distinct rulemakings. None of these instruments are final. The first, a joint proposed rule from FinCEN and OFAC regarding AML/CFT and sanctions compliance, drew 89 comments on the rule’s comment docket before its window closed on June 9, 2026. The second, a joint proposal on customer identification from FinCEN, the OCC, the Federal Reserve, the FDIC, and the NCUA, closed its comment period on August 21, 2026.