The US spends roughly $26 billion a year on anti-money laundering compliance across its financial institutions. The recovery rate on criminal proceeds? Less than 1%. Coin Center wants regulators to keep that track record in mind before extending the same framework to stablecoin issuers.
The crypto policy nonprofit submitted comments to the US Treasury on October 20, 2025, laying out its position on how AML obligations should apply to permitted payment stablecoin issuers, or PPSIs, under the GENIUS Act. The core argument: issuers should only be responsible for know-your-customer and AML compliance at the point where stablecoins are issued or redeemed, not when users send tokens to each other on public blockchains.
What the GENIUS Act actually does
Signed into law on July 18, 2025, the GENIUS Act created the first federal regulatory framework specifically for payment stablecoins. Among its many provisions, the legislation directs the Financial Crimes Enforcement Network, better known as FinCEN, to consider PPSIs as financial institutions under the Bank Secrecy Act.
That designation carries weight. Being classified as a BSA financial institution means stablecoin issuers would potentially need to implement the same kinds of compliance programs that banks and money services businesses already maintain. Think suspicious activity reports, customer identification programs, and transaction monitoring systems.
