OCC finalises its GENIUS Act rule: what changed on yield, reserves and redemption

The OCC published its final GENIUS Act rule on 23 October 2026

The Office of the Comptroller of the Currency (OCC) published its final rule implementing the GENIUS Act in the Federal Register on 23 October 2026.1 The rule creates a new 12 CFR part 15 and amends parts 3, 6, 8 and 19.1 It takes effect on 18 January 2027.1

The OCC proposed the rule on 2 March 2026. It received about 328 comments from crypto firms, trade groups, banks, non-profits, academics and individuals.1 Commenters disagreed most on reserve management, the ban on paying yield, redemption and capital.1

Publication also fixed the date the Act starts. The Act takes effect on the earlier of 18 January 2027 or 120 days after a primary federal regulator issues final rules. The OCC rule is the first of those final rules, and 120 days from it falls after 18 January 2027.1

The OCC said it would address Bank Secrecy Act (BSA), anti-money laundering (AML) and sanctions comments in a separate rulemaking.1 It proposed those standards on 24 June 2026.2 Our earlier brief, GENIUS Act: what stablecoin issuers and payment platforms need ready by January 2027, covers those proposals. This brief covers what the final rule itself changed.

Issuers may not pay yield, and the OCC dropped its proposed presumption

Section 4(a)(11) of the Act bans a permitted payment stablecoin issuer from paying yield to holders.1 The final rule restates the ban in § 15.10(c)(4). An issuer may not:

The proposal added a rebuttable presumption. Certain arrangements with affiliates and related third parties would have counted as breaches unless the issuer showed otherwise.1 The OCC removed it. The agency said the presumption could catch permissible arrangements and imply that arrangements outside it were allowed.1

The ban itself stays as wide as the Act. The OCC says an agent paying yield on the issuer’s behalf falls within it, and an issuer that pays another firm to make a payment it cannot make would be evading it.1 The rule treats retail and institutional holders the same and has no de minimis exemption.1 Rewards programmes that predate the Act get no safe harbour: the OCC will assess them like new ones.1 Registered foreign issuers face the same ban under § 15.31(c).1

Reserve and redemption rules changed from the March proposal

The OCC changed these provisions between the March proposal and the final rule:1

The two-business-day redemption limit is unchanged.1 A redemption counts as done once the issuer initiates the outgoing transfer to the customer or the customer’s bank.1 An issuer’s minimum redemption can be no higher than one stablecoin, subject to customer screening and onboarding.1

The final rule also sets when the redemption clock starts. It starts when the issuer receives the order and, where the issuer’s onboarding procedures are reasonably designed not to unduly delay onboarding, once the customer is onboarded.1

Under § 15.12(f), the OCC will not require an issuer to redeem where redeeming would break other applicable law.1 The OCC gives BSA and economic sanctions obligations as its example.1

Issuers may also hold limited amounts of other digital assets as principal, to pay network and customer fees or to test on a ledger.1 Their disclosures must now state that a payment stablecoin is not legal tender, not a deposit and not federally insured.1

Who the OCC rule applies to

A foreign issuer must hold enough reserves in US institutions to meet US customer demand. One route is to attest that US holders hold under 50% of its outstanding issuance value, and to keep reserves in US institutions worth at least 50% of that value. Another is to attest that it holds substantially all its reserves in US institutions, and to hold them there.1 The issuer’s home jurisdiction must not be under comprehensive US sanctions or designated a jurisdiction of primary money laundering concern.1 The OCC will list approved foreign registrations on occ.gov.1

Treasury’s proposal, which closed for comment on 19 October 2026, reads the Act as setting two dates for digital asset service providers. From the effective date, they may not offer a foreign issuer’s coin in the United States unless the issuer can comply with lawful orders. From 18 July 2028, they may offer only coins from permitted issuers or qualifying foreign issuers.4

OCC GENIUS Act rule dates, from proposal to 2028

1. 18 July 2025

   The GENIUS Act becomes law.1

2. 2 March 2026

   The OCC proposes its GENIUS Act rule.1

3. 1 May 2026

   Comments close. The OCC keeps accepting late comments until 1 July 2026.1

4. 22 June 2026

   Five agencies propose a customer identification program for issuers.3

5. 24 June 2026

   The OCC proposes AML and sanctions standards for the issuers it supervises.2

6. 18 August 2026

   Treasury proposes rules on who may issue, offer and sell payment stablecoins.4

7. 23 October 2026

   The OCC publishes its final rule.1

8. 18 January 2027Upcoming

   The Act and the OCC rule take effect.1

9. 18 July 2028Upcoming

   Digital asset service providers may offer only coins from permitted or qualifying foreign issuers in the United States.4

No enforcement under the rule yet, and how the OCC will police the yield ban

The Act takes effect on 18 January 2027. We found no enforcement action under the Act or the OCC rule in our enforcement tracker.

The OCC will review issuers’ arrangements through licence applications and ongoing supervision.1 Where it finds a breach or evasion of the yield ban, it will act and publish guidance.1 It declined to offer a cure period and said it will use enforcement discretion on the facts of each case.1

What to check before 18 January 2027

Onboarding and KYC

• If you redeem directly with an issuer, finish its onboarding now. The two-business-day clock starts only after onboarding.1
• Read each issuer’s published redemption policy. It must state the timeframe, the minimum redemption and when redemption can be extended.1

Transfer monitoring

• Issuers: set an alert for redemption requests above 10% of a brand’s outstanding issuance in 24 hours. The OCC needs notice within 24 hours.1

Investigations

• Record why any redemption was refused or delayed, and which obligation applied. The OCC will not require a redemption that would break BSA or sanctions law.1
• List every stablecoin rewards arrangement you run with or for an issuer. The OCC gave no safe harbour for programmes that predate the Act.1 Take legal advice on each one.

Reporting and counterparties

• For each foreign issuer you support, ask for its OCC registration status and evidence of its US reserves.1
• Read each issuer’s monthly reserve composition report. Issuers must publish it by noon on the last day of each month.1

Questions the OCC rule leaves open

What Cogentic handles, and what your team keeps

When an issuer refuses a redemption, or a rewards arrangement needs review, your team needs the customer, the transfers and the screening results in one place. Cogentic agents gather KYC records, sanctions screening and wallet analytics from the providers you already use into one case. They follow your SOP for each alert type and record every action. Cogentic drafts the report; your team decides and your MLRO signs.