Most Americans pay attention when Congress passes a law. Far fewer pay attention to what happens next. Once legislation is enacted, federal agencies begin the rulemaking process. Through rulemaking, agencies write the regulations that determine how a law will be interpreted, enforced, and applied in practice. In many cases, the rules have a greater impact on our daily lives than the statute itself.

This is particularly important with the GENIUS Act. While the legislation establishes a federal framework for stablecoins, regulators at the Office of the Comptroller of the Currency (OCC), the Treasury Department, the Financial Crimes Enforcement Network (FinCEN), and the Office of Foreign Assets Control (OFAC) are now writing the rules that will govern how that framework operates. The details of these regulations will determine how stablecoin issuers are supervised, what compliance obligations they face, and how financial surveillance, sanctions enforcement, and transaction monitoring are carried out.

Over the last several weeks, Solari has submitted comments on two separate GENIUS Act rulemakings—one to the OCC and another to Treasury, FinCEN, and OFAC. Our comments focused on the implications of stablecoin infrastructure, regulatory authority, financial surveillance, sanctions compliance, and the potential for programmable restrictions on financial transactions. The goal is to ensure that policymakers fully consider the long-term consequences of the regulatory framework they are building.

You can review Solari's comments here:

• OCC GENIUS Act Rulemaking Comment Letter:
https://ft2freedom.solari.com/wp-content/uploads/2026/05/Solari-Inc-Comment-to-OCC-on-GENIUS-Act-NPRM-1.pdf

• Treasury, FinCEN, and OFAC GENIUS Act Rulemaking Comment Letter:
https://ft2freedom.solari.com/wp-content/uploads/2026/06/Solari-Inc-Comment-to-Treasury-FinCEN-OFAC-on-GENIUS-Act-NPRM.pdf

 As financial systems become increasingly automated, there is growing pressure to rely on algorithms, artificial intelligence, and automated compliance systems to make decisions regarding account restrictions, transaction monitoring, asset freezes, sanctions enforcement, and other financial activities. Solari has urged regulators to ensure that significant actions affecting a person's access to money or financial services remain subject to meaningful human review, clear standards, and accountability. When financial decisions are made by automated systems without transparency or recourse, citizens can find themselves deprived of essential financial services with little ability to understand, challenge, or correct the decision.

Just as importantly, citizens can participate in this process as well. While many people assume that only industry groups, attorneys, or large organizations submit comments, federal agencies are required to accept comments from any member of the public. Well-reasoned comments that raise substantive concerns become part of the official record and must be considered by regulators as they develop final rules.

When a federal agency opens a proposed rule for comment, the process is straightforward:

• Visit Regulations.gov.

• Search for the rulemaking by agency, subject matter, or docket number.

• Click the “Submit a Formal Comment” button.

• Enter your comments directly into the online form or upload a document.

• Submit your comment before the deadline.

You do not need to be an attorney, banker, or policy expert to participate. The most effective comments are specific, respectful, and focused on the substance of the proposal. Agencies are generally required to consider and respond to substantive concerns raised during the comment period. While a single comment may not change a rule, a large number of thoughtful comments can help highlight issues, unintended consequences, and public concerns that regulators might otherwise overlook.

As Congress increasingly delegates authority to federal agencies, rulemaking has become one of the most important battlegrounds in determining how laws are interpreted and enforced. Legislation sets the destination. Rulemaking determines the route. If citizens wait until a final rule is issued, they are often arriving after the most important decisions have already been made.

If we want financial freedom, privacy, due process, and human accountability to remain part of the future financial system, participation cannot stop when a bill passes Congress. Citizens must remain engaged throughout the rulemaking process, where many of the most consequential decisions are ultimately made.

In freedom, 

The Solari Team