Comment from Circle
CircleSupportBusiness
Summary: Circle Internet Group, Inc., a stablecoin issuer and registered Money Services Business, supports FinCEN's shift toward an outcomes-based, risk-focused AML/CFT framework. The company argues that the rule's benefits should be explicitly extended to non-bank financial institutions (like MSBs and stablecoin issuers) and urges the codification of "non-second-guessing" principles for risk-based resource allocation.
Circle Internet Group, Inc. (together with its subsidiaries, “Circle”) respectfully submits these comments in response to the Financial Crimes Enforcement Network’s Notice of Proposed Rulemaking titled “Anti-Money Laundering and Countering the Financing of Terrorism Programs,” published under Docket FINCEN-2026-0034, RIN 1506-AB72.