Exposing Hidden AML Policy Gaps in the Age of Stablecoins and Crypto Regulation

As digital assets move from the fringes of finance into the regulated mainstream, firms face a familiar but increasingly dangerous challenge: policies that appear robust on paper yet fall short when measured against evolving regulatory expectations.

The GENIUS Act marks a turning point for Stablecoins and digital-asset regulation in the US. While the Act provides long-awaited clarity around issuance standards, reserve requirements, and Anti-Money Laundering (AML) obligations, it also exposes a critical weakness across banks, financial institutions, and crypto-native firms alike. Legacy AML policies were not designed for blockchain-based activity.

At Sia, we see this gap repeatedly. And increasingly, it is not the absence of controls that creates risk, but the misalignment between regulatory specificity and language policy.

Most AML programs were built for traditional financial products. Even where firms have implemented sophisticated transaction monitoring tools, blockchain analytics, or freezing mechanisms, the formal policy framework often lags operational reality.

The GENIUS Act raises the bar by introducing explicit, testable expectations around: 

• Stablecoin issuance and redemption
• Reserve backing and public disclosures
• AML responsibilities for issuers and non-issuers
• Reporting obligations to multiple regulators 

Yet many AML policies remain high-level, technology-agnostic, and insufficiently granular, creating hidden compliance gaps that are difficult to detect through manual review alone.

One of the most persistent challenges firms face is translating regulatory language into operationally meaningful requirements.

The GENIUS Act does not simply ask whether controls exist. It implicitly asks: 

• Who is accountable?
• What specific actions must occur?
• When must they be triggered?
• How must evidence be produced for regulators?

This level of specificity is often missing from existing policies, even when controls exist in practice.

To address this challenge, Sia developed RegMatcher, an AI-enabled regulatory review tool that deconstructs regulations into discrete, testable obligations and maps them directly to a firm’s policy language.

Rather than relying on subjective interpretation, RegMatcher evaluates coverage across five critical dimensions: 

• Ownership: are accountable roles and signatories clearly defined?
• Scope: do policies explicitly address digital assets and Stablecoins?
• Procedural detail: are triggers, timelines, and escalation paths articulated?
• Governance alignment: do policies reflect regulator-facing expectations?
• Completeness: are requirements fully met, partially met, or missing? 

This approach consistently uncovers gaps that are invisible in traditional policy reviews. 

Sia also has an end-to-end approach to GENIUS Act readiness, by supporting clients throughout the regulatory change lifecycle with deep regulatory expertise and advanced tooling: 

• Regulatory interpretation and firm categorization (issuer vs. non-issuer)
• Impact assessment across policies, processes, controls, and data
• AI-driven policy gap analysis using RegMatcher
• Implementation, testing, and operationalization
• Ongoing monitoring, reporting, and audit readiness 

Our experience shows that firms who address policy alignment early move faster, respond more confidently to regulators, and avoid costly remediation later.

The GENIUS Act is unlikely to be the last major digital-asset regulation. As the regulatory environment continues to evolve, firms need scalable, repeatable ways to assess whether their governance frameworks keep pace. 

In the age of digital assets, compliance risk is no longer just about what you do, it’s about how clearly you can prove it.

AI-enabled regulatory mapping is becoming a strategic necessity, not a nice-to-have. And for firms navigating the future of Stablecoins and crypto regulation, closing hidden policy gaps is the foundation for sustainable growth.