Comment from KillChain, Inc.

KillChain, Inc. (d/b/a FLINT Network) submits the attached comment letter on the joint FinCEN/OFAC proposed rule implementing GENIUS Act AML/CFT and sanctions compliance requirements for permitted payment stablecoin issuers (PPSIs) [Docket No. FINCEN-2026-0100; RIN 1506-AB73]. FLINT Network supports the proposed rule. We identify a class of transactions PPSIs will encounter at scale before any other BSA financial institution: those initiated by autonomous AI agents operating under delegated financial authority. Stablecoin rails are the native settlement layer for agent commerce, and the compliance stack was built to verify humans. Customer-level diligence cannot demonstrate effective monitoring of transactions the customer did not personally initiate. The letter describes the transaction-level primitive that closes this gap: Know Your Agent (KYA) verification with cryptographically signed, retained verification records. Two provisions of the proposed rule map directly onto it. Pre-execution verification producing an allow, step-up, review, or block determination is a direct technical implementation of the block, freeze, and reject capability required by proposed 31 CFR 1033.240, applied before irreversible settlement. Signed verification records are the demonstrable outputs evincing program effectiveness that proposed 31 CFR 1033.221(d)(2) instructs the Director to credit, including effective use of artificial intelligence. The letter responds to FinCEN Questions 9, 13, 14, 26, 27 through 30, and 36, and OFAC Questions 3 through 6, and offers 5 recommendations, including treating agent-initiated transactions as a distinct risk category, SAR guidance for agent activity, NIST coordination, and alignment with Docket No. FINCEN-2026-0034.