Passed by the Senate and now headed to the House, the GENIUS Act will require financial institutions to implement AML controls tailored to both the issuance of stablecoins and the pricing of banking services for crypto-related entities such as exchanges, blockchain providers and custodial platforms, among others. Most banks aren’t ready.
On June 17, 2025, the U.S. Senate passed the GENIUS Act—short for Guiding and Establishing National Innovation for U.S. Stablecoins—with a 68–30 bipartisan vote.
The bill targets “payment stablecoins,” which are digital currencies backed by fiat or government securities and designed for payments or settlement. It’s not just a framework; it’s a regulatory milestone. The Act has now moved to the House of Representatives, where it’s widely expected to pass in July.
The Impact
When enacted, the implications will be sweeping:
- All permitted stablecoin issuers will be classified as financial institutions under the BSA
- Issuers must build and operate a full AML program, tailored to crypto risk
- Banks that provide services to crypto exchanges, blockchain providers, custodial services, and other types of crypto-related companies will be required to implement a system of AML controls to monitor, detect, and report suspicious crypto-related transactions.
- Foreign issuers must comply with U.S. AML and sanctions laws—or face designation as “non-compliant,” which would bar them from U.S. markets
- There is a mandate for annual AML compliance certifications and independent audits
What’s Required from Issuers and Banks
To prepare for compliance, both banks and stablecoin issuers need a tailored roadmap. At a minimum, that includes:
- Customer due diligence (CDD) at onboarding
- Identification of customers that pose a higher-than-normal AML risk.
- Enhanced due diligence (EDD) on high-risk customers
- Transaction monitoring customized for crypto-related transactions
- Investigation workflows and suspicious activity reporting (SAR)
- Management reporting frameworks for governance and oversight
- Case management systems that can track end-to-end resolution
- Sanctions screening aligned with OFAC requirements
- Staffing plans that scale with program complexity and volume
Why This Matters Now
The GENIUS Act isn’t just about new regulation—it’s about treating crypto as part of the mainstream financial system. That means accountability. Transparency. And enforceability.
Most issuers, fintechs and financial institutions are still in exploratory or reactive phases of crypto compliance. But the runway is getting shorter.
SolomonEdwards is actively working with financial crimes teams and regulatory leaders to build crypto-ready AML programs.
