Comment from Stripe
StripeSupportBusiness
Summary: Stripe, a money service business and licensed money transmitter, strongly supports the proposed rule's shift toward an outcomes-focused, risk-based AML/CFT compliance framework. They argue that the new approach better aligns with technological innovation and request that FinCEN extend specific enforcement protections and clear definitions of "significant or systemic failure" to non-bank financial institutions like MSBs.
See attached file(s)