June 2026: FIFA, Olivia Rodrigo, Supergirl…and the Month of Stablecoin and AML Rules
Two dates that will matter long after the credits roll, the games are over and the album ends.
(Note - all views are those of Fintech Compliance Chronicles/my personal views and not affiliated with any other organization. And yes that’s Travis Hill (FDIC) and Andrea Gacki (FinCEN) shaking hands on the side there!)
Last time we previewed what was coming up in the month of May from the fintech compliance regulatory world. This time, we’re looking ahead to June - where the FIFA World Cup will start on June 11 with the likely last time we’ll see Cristiano Ronaldo and Lionel Messi both participating together, Olivia Rodrigo drops her 3rd album on June 12, and Toy Story 5 comes out on June 19 along with Supergirl on June 26. Break out your calendars and let’s see what’s coming up:
June 2: Answering Treasury’s State vs Federal Question
What is happening? The comment period closes on June 2 for the Treasury Department’s proposed rule on a component of the GENIUS Act that allows for state regulation of stablecoins. Specifically, the GENIUS Act states that issuers with over $10 billion in outstanding stablecoins issued must be federally regulated, but those with less than $10 billion can stay under state regulation, but only if the state’s rules are “substantially similar” to the federal framework. It is this “substantially similar” phrase that has set off debate and led to this comment period by the Treasury department.
For more on the GENIUS Act, check out this breakdown by Paul Hastings.
Who has commented? 16 comments have been left (although only 10 appear to be available on Regulations.gov). If you ever wonder whether any average person can pop in and drop comments on a groundbreaking legislation like this one, this is a great example that proves anyone absolutely can. Highlights:
Someone clearly used an AI to submit an anonymous comment that reads more like an outline, not really taking an opinion, just highlighting different high level examples of what “substantially similar” could mean and compares possible state approaches to federal approaches.
Another person started off their comment by saying they don’t care for cryptocurrency at all and then goes on to vent about separate issues they are having with Progressive Insurance and Shellpoint Mortgage Servicing, going into great length about how both companies’ websites result in late fees, concluding with the belief that “we need physical cash and paper checks. Period.”
In more serious commentary, the North Carolina Blockchain AI initiative, an advocacy group, offered support for the proposal and used the comment as an opportunity to highlight North Carolina’s progressive crypto legislation dating back to 2020 and indicated that it was going to lobby for the state to create its own version of the GENIUS Act to demonstrate further alignment. This group is not a bunch of random crypto bros shouting out the proposal; a further look at the signatories reveals that this is a newly formed (as of March 2026) lobbying vehicle that includes a former Lt. Governor, a member of the FRB of Richmond’s Business and Consumer Payments Advisory Council and a managing partner of a national law firm.
The American Bankers’ Association contributes to two comments. One has the backing of all 52 state bankers’ associations (including DC and Puerto Rico) and says that June 2 is an impossible deadline to opine on “substantially similar” when the federal framework itself is not final (it will go into effect the earlier of January 2027 or 120 days after the FRB and FDIC finalize their frameworks). The other sees the ABA co-signing with three other groups to argue that a separate June 9 comment period on the next batch of NPRMs makes holistic review impossible. The latter comment also adds an interesting statistic from the International Bancshares Corporation - stablecoins could drive deposit outflows of up to $6.6 trillion, while community banks could lose $1.3 trillion in deposits and $850 billion in reduced lending capacity if yield loopholes aren’t closed (the latter is relevant because affiliates, distribution partners, and rebate programs are often used by issuers to get around the GENIUS Act’s prohibition on them paying interest to holders which could lead to unmonitored systemic risk).
Michael Ravnitzky adds a comment to the mix. He is a federal regulatory attorney, former journalist, private investigator, and one of the most prolific Freedom of Information Act litigants in the country which has put him up against the Department of Energy, SEC, National Archives, and numerous other agencies. Despite his decades of regulatory engagement, here he appears as a private individual and argues against the rule, claiming that the rule is stacked against states primarily because there is no allowance for states to transition to become “substantially similar” among a host of 25 total objections.
Two other comments tout their own products and frameworks to argue for technical enhancements to the proposal, specifically cryptographic interoperability standards (i.e. ensuring there is a way for federally regulated and state regulated issuers to verify each other’s compliance automatically using the same technical format) and the application of a more meaningful equivalence assessment by not just comparing federal and state rigor but also adding a stress-testing layer when analyzing an issuer.
Why does it matter? Treasury has to respond to all of these comments, as they are now officially building blocks of the administrative record. Later on down the road, if someone sues to overturn the rule, a judge will come back and read all of these in deliberating on a final ruling.
June 9: The FDIC, FinCEN and the Future of Stablecoin Compliance
What is happening? Three separate comment periods close on the same day, with two tied to the aforementioned GENIUS Act and one proposing massive changes to what it means for banks to do AML going forward.
From the FDIC side, the NPRM answers the question of how stablecoin issuers should be built. Specifically, it establishes a view on safety and soundness by creating a framework within which future issuers can understand capital requirements, reserve standards, and what happens to the reserves if the issuer fails. It also asks the question as to whether stablecoin reserves should count as deposits and whether holders should get FDIC protection.
From the FinCEN/OFAC side, their NPRM defines who is a stablecoin issuer under the law. Issuers are formally designated as financial institutions under the BSA for the first time, which triggers the full suite of AML obligations including CIP, SARs, and record keeping. It also creates the first explicit legislative requirement to have an OFAC sanctions compliance program, something that was previously strongly expected and based on guidance and enforcement practices alone. The rule leans into smart contract technology that stablecoins can offer and lays out an expectation that sanctions compliance must now go beyond the point of issuance and extend to secondary market transactions.
Lastly, separate from the GENIUS Act, FinCEN proposes an overhaul of BSA compliance for every financial institution by proposing a new model where instead of SARs filed as a default, a risk-based approach would be used to allow institutions to focus on actual threats from bad actors rather than generating paperwork.
Who has commented? Six parties have commented to date on the FDIC proposal, 14 on the FinCEN/OFAC joint proposals, and 21 have commented on the FinCEN risk-based proposal. I’ll use this as an opportunity to say (as you may notice when attempting to access the links yourself) that for whatever reason, the ability to access comments is somewhat limited on regulations.gov - the FDIC uses its own website to house comments on its proposals. On regulations.gov, there seems to be frequent downtime and delayed syncing back to the federal register, with this being the most frequent result I ended up getting:
Which of these has the biggest implications? I’ll underscore the AML/CFT reform rule as having the biggest impact on anyone who works in regulated financial services. We talked a little bit about this last time in the context of the upcoming hearing on BSA modernization, but here’s why this is so important:
It rewrites how all BSA-regulated institutions should do AML compliance - banks, credit unions, MSBs, fintechs, broker-dealers, etc - shifting from “file as many SARs/CTRs as possible and let the regulators review it” to a risk-based, effectiveness model, essentially shifting the burden of judgment and analysis to the institutions themselves.
It ties non-FinCEN examiners’ hands - supervisory regulators at the OCC, FDIC and Fed would have to consult FinCEN before taking major AML/CFT enforcement actions. This dramatically raises the power of FinCEN to be a formal gatekeeper in Fincrime federal regulation.
It directly affects how your program is built, how it will be examined, and what counts as “good enough” across the entire industry. This is not a signal to do less - on the contrary, it will impact who you hire, what you write down, what you actually do day-to-day, and how you’re graded. In terms of hiring, expect fewer pure “checkers” and more analysts, more data and engineering roles embedded in compliance, and upgraded expectations for CAMLO/MLRO roles as it relates to resource allocation and strategy. In terms of documentation, you should expect a living enterprise AML risk assessment that drives control design, policies that justify internal standards/exclusions in risk terms, and procedures that support documented tuning cycles, governance around exceptions/overrides, and more QA/QC around investigations. And lastly, compliance training will need to move away from “here is the SAR form” to “here is how human tracking, sanctions evasion, or fraud actually surface in your line of business.”
Honorable mention/the rest of June:
June 15-19 - FATF Plenary: The Financial Action Task Force is essentially the world’s anti-money-laundering referee. It’s an international body of 40 member countries that sets the global rules for how governments and financial institutions are supposed to detect and stop dirty money, terrorist financing, and sanctions evasion. When FATF says a country is on its “blacklist” or “grey list,” it’s a serious signal to the entire global banking system to treat that country’s transactions with extra scrutiny. Every few months, FATF member countries send their delegates to a plenary, which is a formal meeting where they vote on new standards, approve country evaluations, and set the agenda for the next period. The June 15–19 meeting is important because it’s the last one under Mexico’s leadership before the UK takes over, and it’s expected to finalize new guidance specifically on stablecoins and crypto, directly relevant to everything else happening in May–June 2026.
June 16-17 - FOMC Meeting: The Federal Open Market Committee is the group inside the Federal Reserve that actually votes on interest rates. It’s made up of the Fed’s Board of Governors plus rotating regional Fed presidents. Eight times a year, they meet for two days, review the economy, and vote on whether to raise, cut, or hold interest rates. This is the decision that ripples into every mortgage, car loan, credit card rate, and savings account in the country and is getting extra scrutiny due to rising gas prices and potentially rising unemployment. Every other meeting also includes a dot plot, which is a chart showing where each committee member anonymously expects rates to go over the next few years. The June 16–17 meeting is one of those, and it’s the first one that will likely be run by Kevin Warsh if he’s confirmed as Fed Chair in May. That makes it the first real signal of whether his stated goals of shrinking the balance sheet and cutting rates on his own terms translate into actual policy.
July 1 - DFPI DFAL Deadline: The Digital Financial Assets Law is a California law passed in 2023 that requires any company dealing in crypto assets with California residents to obtain a license from the DFPI, similar to how New York’s BitLicense works. The law gave the industry until July 1, 2026 to either get licensed or have a completed application submitted. July 1 is technically a California deadline, but because California has 40 million residents and roughly a quarter of U.S. blockchain companies are based there, it’s nearly impossible for any serious crypto company to simply walk away from the market. In practice, this state deadline is setting the minimum compliance bar for the entire U.S. crypto industry.
If you’ve read this far, congratulations: you’re now more prepared for June than most of the industry. None of this will trend on X. But in a year or two, when products launch, banks pull back, or regulators act, odds are you’ll be able to trace the story back to the dates and time frames we just walked through. Thanks for joining us, and see you next week.