Comment from KillChain, Inc.

KillChain, Inc. (d/b/a FLINT Network) respectfully submits the attached comment letter on the Notice of Proposed Rulemaking, Anti-Money Laundering and Countering the Financing of Terrorism Programs, 91 FR 18704 (April 10, 2026), Docket No. FINCEN-2026-0034, RIN 1506-AB72. FLINT Network supports the proposed shift from process-based to effectiveness-based AML/CFT program requirements, including the favorable consideration of innovative tools such as artificial intelligence and the requirement for human oversight at critical adjudication points. The attached letter identifies one gap the final rule should address: effectiveness cannot be demonstrated for transactions initiated by autonomous AI agents without a transaction-level verification primitive. Agents are now being granted delegated spending authority across card, ACH, and stablecoin rails, yet the existing compliance stack verifies only the human or legal-entity customer, not the non-human actor executing the transaction, its delegated authority, or its ongoing behavior. The letter describes Know Your Agent (KYA) verification, performed in real time across 6 layers (principal identity, agent identity, wallet provenance, authorization scope, environment identity, and cross-merchant reputation), producing a cryptographically signed, retained verification record as examiner-ready evidence. It recommends that the final rule: (1) confirm favorable consideration extends to transaction-level AI agent verification; (2) recognize signed verification records as documentary evidence of effectiveness for agent-initiated transactions; (3) treat agent-initiated activity as a distinct risk category; (4) coordinate with NIST agent-identity standards work; and (5) preserve technology-neutral and rail-neutral framing consistent with the GENIUS Act perimeter. Full discussion, commenter background, and recommendations are in the attached letter. Point of contact: Joseph Taylor, Founder and CEO, contact@flint.network.