In this episode of The Crypto Exchange, hosts Ethan Ostroff and Genna Garver are joined by their colleague Pete Jeydel to explore the implications of the GENIUS Act on sanctions, anti-money laundering (AML), and efforts to combat the financing of terrorism within the stablecoin sector. The discussion focuses on the act’s goal to create a regulated ecosystem for payment stablecoin issuers, known as PPSIs, by transitioning offshore activities to U.S. jurisdiction. This strategic shift is anticipated to strengthen the government’s capacity to enforce AML and sanctions compliance.

Despite the framework established by the GENIUS Act, many regulatory specifics remain to be defined, with FinCEN and the Treasury Department tasked with developing detailed rules over the coming years. The episode also sheds light on ongoing legislative efforts, such as the CLARITY Act, aimed at establishing a comprehensive regulatory framework for digital assets. The group underscores the necessity of proactive compliance strategies for stablecoin issuers, given the dynamic regulatory environment and inherent risks associated with digital assets. As the industry awaits further guidance, the conversation highlights the importance of innovative compliance solutions and the role of technology in addressing challenges related to illicit finance.


Transcript: Navigating the GENIUS Maze: Sanctions and AML Adventures in Crypto (PDF)

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Photo of Ethan G. Ostroff Ethan G. Ostroff

Ethan’s practice focuses on financial services litigation and compliance counseling, as well as digital assets and blockchain technology. With a long track record of successful litigation results across the U.S., both bank and non-bank clients rely on him for comprehensive advice throughout their

Ethan’s practice focuses on financial services litigation and compliance counseling, as well as digital assets and blockchain technology. With a long track record of successful litigation results across the U.S., both bank and non-bank clients rely on him for comprehensive advice throughout their business cycle.

Photo of Genna Garver Genna Garver

Genna provides targeted, practical advice to investment advisers and their proprietary private investment funds. She represents institutional investors, funds of funds and family offices in connection with their private fund investments. Genna routinely advises clients on formation and offering matters for both domestic…

Genna provides targeted, practical advice to investment advisers and their proprietary private investment funds. She represents institutional investors, funds of funds and family offices in connection with their private fund investments. Genna routinely advises clients on formation and offering matters for both domestic and offshore funds; SEC and state investment adviser, broker-dealer and private fund regulation; Investment Advisers Act compliance programs, annual reviews and ongoing compliance matters; and regulatory examinations and investigations.

Photo of Peter Jeydel Peter Jeydel

Pete helps clients navigate today’s increasingly complex regulatory and enforcement environment at the intersection of national security, international trade, finance, and technology. He works with clients to identify innovative solutions to business problems arising from these often daunting and highly technical regulations, based

Pete helps clients navigate today’s increasingly complex regulatory and enforcement environment at the intersection of national security, international trade, finance, and technology. He works with clients to identify innovative solutions to business problems arising from these often daunting and highly technical regulations, based on a clear understanding of the government’s expectations and priorities.