Analysis of FinCEN/OFAC GENIUS Act Stablecoin Rules: Six Key Risk Provisions and Their Impact

A rule is rarely dangerous on the day it is written. It becomes dangerous on the day it is applied—years later, after a bad outcome, by someone reading it with the full benefit of hindsight.

That gap, between what the text says and how it gets used when a matter is examined or charged, is the only thing that has ever

I filed a comment on the FinCEN/OFAC stablecoin rule. This is the report I promised: a provision-by-provision read of where the proposed text creates exposure the drafters may not have intended—and where the people who sign for it are most at risk once it goes live.