Comment from DDCP Foundation, Inc.

Summary: The DDCP Foundation, a nonprofit steward of open-source protocol infrastructure, supports the proposed rule's risk-based framework and its endorsement of innovative technologies like blockchain analytics. They argue that AML/CFT compliance obligations should remain with "Financial Intermediary-layer" entities (like exchanges and custodians) rather than with open-source infrastructure stewards who do not hold customer assets or conduct regulated activities.