Federal Agencies Propose More GENIUS AML/CFT Rules: Customer Identification Program and OCC Conforming Updates
As the AML compliance framework for payment stablecoin issuers continues to take shape under the GENIUS Act, federal regulators proposed another set of rules that will have important implications for compliance program design and implementation. The latest FinCEN, banking agency, and OCC proposals clarify customer identification program (CIP) expectations, reinforce a bank-like approach to AML/CFT compliance, and provide additional insight into the OCC’s supervisory and enforcement posture.
Our latest blog breaks down the proposals, highlights the practical compliance takeaways for stablecoin issuers, and explains what these developments mean for firms preparing for the new federal AML/CFT regime.
Prediction Markets and Insider Trading: Why Organizations Should Update Compliance Policies Now
As prediction markets expand to cover corporate, regulatory, and geopolitical events, organizations face new compliance risks when employees, directors, or other insiders possess nonpublic information that could affect the value of event contracts.
In this post, we examine the first insider trading case involving prediction markets, discuss the government’s position that existing insider trading and antifraud principles apply to these markets, and outline practical steps organizations can take to strengthen their governance frameworks. We also explore why existing insider trading, confidentiality, and code of conduct policies may be insufficient and provide recommendations for updating policies, training, and compliance controls to address this emerging risk area.
Read our analysis of the evolving regulatory landscape and the measures organizations should consider to mitigate legal, reputational, and compliance risks associated with prediction market activity.
Three Potential Benefits, One Powerful Incentive: NDIL’s New Individual Self-Disclosure Program
On May 14, 2026, the U.S. Attorney’s Office for the Northern District of Illinois (NDIL) announced a new Individual Self-Disclosure Program offering qualifying individuals three potential forms of relief in exchange for voluntary self-disclosure and cooperation: letter immunity, a deferred or non-prosecution agreement, or criminal prosecution with substantial sentencing relief. The Program’s express three-tier structure distinguishes it from many other federal self-disclosure programs, which generally focus on the possibility of a non-prosecution or deferred prosecution agreement. To qualify, individuals must provide a complete and truthful proffer, cooperate fully with law enforcement, testify if required, and disgorge any criminal proceeds, among other requirements. This post summarizes the Program’s key features and highlights how it compares to similar self-disclosure initiatives adopted in other jurisdictions.
When “The Devil Made Me Do It” Is Not a Defense: Lessons in AI Governance and Organizational Oversight from an SDNY Decision
As companies increasingly integrate generative and agentic AI into core business functions, a May 7, 2026 decision from the United States District Court for the Southern District of New York1 highlights several fundamental guardrails for corporate legal and compliance departments to consider. Although the case arose in the context of government decision-making, the opinion carries broader implications for any entity that embeds generative AI in its processes.
“Don’t Wait”: DOJ Criminal Division Chief Signals Faster Disclosure Expectations and Uptick in Corporate Enforcement
On May 7, 2026, Assistant Attorney General A. Tysen Duva used his first major speech to the compliance community since DOJ’s March 2026 rollout of its department-wide Corporate Enforcement Policy (CEP) to deliver a clear message: corporate enforcement activity is expected to increase, companies should self-disclose misconduct early—even before completing internal investigations—and robust compliance programs remain central to DOJ’s expectations.
FinCEN, Office of Foreign Assets Control Propose Anti-Money-Laundering Program and Sanctions Requirements for Stablecoin Issuers
The U.S. Department of the Treasury, through the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) (collectively Treasury) issued a joint notice of proposed rulemaking on April 8, 2026, to implement the anti-money-laundering (AML) and sanctions compliance provisions of the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act), establishing a regulatory framework for permitted payment stablecoin issuers (PPSIs), hereinafter collectively “the proposed rule.”[1] The proposed rule does not address the GENIUS Act’s customer identification program (CIP) requirements, which are expected to be the subject of a separate rulemaking.
The New UK Corporate Offence of Failure to Prevent Fraud
The fraud landscape in the UK is changing, and it will become much easier to prosecute organisations for fraudulent offences.
In September 2025, the UK’s new corporate “failure to prevent fraud” offence introduced under the Economic Crime and Corporate Transparency Act 2023 (Act), will come into force. This marks a key step in the UK government’s intention to bring about a corporate-culture shift around fraud prevention, encouraging organisations to take proactive measures to prevent fraud.
