Comment from Andreessen Horowitz (a16z)

Summary: Andreessen Horowitz (a16z), a venture capital firm and registered investment adviser, supports the Proposed Rule's shift toward a risk-based AML/CFT framework and its protections for using innovative technologies like AI. However, they argue the rule needs more specific guidance on how these principles apply to investment advisers, particularly regarding suspicious activity reporting, customer due diligence, and the extension of supervisory protections to non-bank entities.