Comment from VeloxVFX LLC
VeloxVFX LLCSupportBusiness
Summary: VeloxVFX LLC submits a supplemental comment advocating for a clear distinction between non-executing transaction-state representation (informational architecture) and the actual execution of regulated financial functions like AML/CFT enforcement or sanctions compliance. They argue that preserving this distinction supports regulatory effectiveness and audit traceability while avoiding overbroad classification of technological infrastructure as regulated financial activity.
VeloxVFX LLC respectfully submits the attached supplemental public comment in connection with FINCEN-2026-0100 / RIN 1506-AB73.
The attachment addresses non-executing transaction-state representation, secondary-market risk visibility, lawful-order traceability, AML/CFT program effectiveness, sanctions-compliance continuity, and operational-authority separation.
This submission is informational only and does not request or imply agency adoption, endorsement, procurement, operational integration, implementation, institutional reliance, modification of agency authority, or designation of VeloxVFX LLC as a financial institution, PPSI, MSB, payment processor, custodian, issuer, settlement operator, sanctions authority, supervisory authority, or compliance authority.
Respectfully submitted,
Eyad (Ed) G. Haddadin
VeloxVFX LLC
June 7, 2026