GENIUS Act Triggers Treasury Request for Anti-Money Laundering Tech Feedback
The U.S. Treasury Department is soliciting public input until Oct. 17, 2025, on cutting-edge technologies to combat money laundering and sanctions evasion involving digital assets like stablecoins, fulfilling a mandate of the recently enacted GENIUS Act signed by President Trump.
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Published on Aug. 18th across Treasury’s website, the Federal Register, and partner sites like FinCEN and the IRS, this 60-day comment period stems directly from Section 9(a) of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). President Trump signed the landmark legislation into law on July 18, 2025, creating the first comprehensive federal regulatory framework for stablecoin issuers.
These issuers will now be treated as financial institutions under the Bank Secrecy Act, subject to all federal anti-money laundering (AML), sanctions, and customer due diligence laws. This request for comment initiative directly advances the policy goals set forth in Executive Order 14178, “Strengthening American Leadership in Digital Financial Technology,” signed on Jan. 23, 2025. The order prioritizes “supporting the responsible growth and use of digital assets” and establishes a President’s Working Group on Digital Asset Markets.
That group’s July 30th report specifically recommended evaluating digital identity tools and enhancing public-private information sharing to counter illicit finance, providing further context for Treasury’s request. The Treasury Department is calling on individuals, financial institutions, technology firms, and advocacy groups to share practical insights on “innovative or novel methods, techniques, or strategies” regulated entities currently use, or could potentially use, to detect illicit activity within the digital asset ecosystem. The request highlights four specific technological focal points:
- Application Programming Interfaces (APIs): Systems enabling software communication to share compliance data automatically, enforce access controls, and monitor transactions.
- Artificial Intelligence (AI): Machine-based systems analyzing vast datasets, including blockchain transactions, to identify complex illicit financial patterns and networks.
- Digital Identity Verification: Tools establishing and verifying user identity digitally, including portable credentials, which could streamline onboarding and due diligence, potentially even within decentralized finance (DeFi) smart contracts.
- Blockchain Technology and Monitoring: Techniques for observing, tracking, and analyzing transactions on public ledgers, integrating blockchain data with off-chain information to trace illicit flows and identify high-risk actors.
“Financial institutions can leverage these tools to protect the digital asset ecosystem from misuse by illicit actors like drug traffickers, fraudsters, ransomware attackers, terrorist financiers, Iranian regime-linked sanctions evaders, and Democratic People’s Republic of Korea (DPRK) cybercriminals,” the Treasury notice stated. However, it also acknowledged the challenges: “Innovative tools may present new resource burdens… due to costs to acquire and integrate new tools and to building necessary expertise.”
Public feedback will directly inform Treasury research evaluating each technology across seven critical factors mandated by the GENIUS Act: “(a) improvements in the ability of financial institutions to detect illicit activity involving digital assets; (b) costs to regulated financial institutions; (c) the amount and sensitivity of information that is collected or reviewed; (d) privacy risk associated with the information that is collected or reviewed; (e) operational challenges and efficiency considerations; (f) cybersecurity risks; and (g) effectiveness of the methods, techniques, or strategies at mitigating illicit finance.”
Commenters are urged to address specific questions about each technology, including real-world use cases, effectiveness compared to existing tools, risks, benefits, and crucially, “regulatory, legislative, supervisory, or operational obstacles” hindering adoption. Treasury also seeks recommendations on steps the U.S. government could take to facilitate “effective, risk-based adoption.”
All comments must be submitted electronically via the regulations.gov website by 11:59 PM ET on Oct. 17, 2025, and will be publicly viewable. The Treasury explicitly warns: “Do not include any personally identifiable information (such as name, address, or other contact information) or confidential business information that you do not want publicly disclosed. All comments are public records; they are publicly displayed exactly as received.” Comments can be submitted anonymously.
Following the comment period, the Treasury will conduct research, submit a report to the Senate Banking and House Financial Services committees summarizing findings and proposing legislative/regulatory changes, and may issue formal guidance or initiate rulemaking. Julie Lascar, Director of the Office of Strategic Policy, Terrorist Financing and Financial Crimes, is the designated contact ([email protected]). This public call underscores the government’s urgent push to harness innovation for security in the rapidly evolving world of digital finance.
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