BSA / AML/CFT — FinCEN/OFAC Joint NPR (April 8, 2026) — Key Provisions for PPSI Compliance
Primary vs Secondary Market: SARs required for primary market activity only; NOT required for secondary-market smart contract transactions where PPSI is only involved via smart contract. Block/Freeze/Reject Capability: PPSIs must have technology to block, freeze, and reject transactions on both primary and secondary markets when required by lawful orders. Blockchain analytics explicitly recognized as compliance tool. Strict Liability: OFAC sanctions violations carry strict-liability civil penalties — PPSI liable even without knowledge. Risk Assessment: Must be updated whenever smart contract functionality changes or token deployed on new blockchain. Enforcement Standard: FinCEN unlikely to pursue enforcement absent evidence of significant or systemic program failure for established programs.