Comment from Notabene Inc.

Summary: Notabene, Inc., a provider of compliance infrastructure for virtual asset service providers, supports the proposed rule's risk-based framework and its distinction between program design and implementation. The company argues that FinCEN should restore an outcomes-based definition of "effectiveness" from a 2020 ANPRM and formally recognize open compliance infrastructure, such as Travel Rule networks and pre-transaction authorization protocols, as innovative activities that produce demonstrable AML/CFT outputs.