FinCEN published a proposed rule on April 7 that would “fundamentally reform” BSA compliance programs for all financial institutions — including stablecoin issuers, who are classified as financial institutions under the GENIUS Act — requiring them to build risk-based AML frameworks focused on actual illicit finance threats rather than prescriptive documentationTreasury Secretary Scott Bessent framed the proposal explicitly as a reduction in compliance burden: the goal is to redirect resources away from lower-risk activities toward higher-risk ones, with enforcement actions reserved only for “significant or systemic failures”Under the new framework, stablecoin issuers must build programs around four core pillars: internal policies and controls including risk assessments, a designated BSA compliance officer located in the US, employee training tailored to the firm’s risk profile, and independent testing of the program’s effectiveness