Comment from Paradigm Operations LP and Hyperliquid Policy Center

Summary: Paradigm Operations LP and the Hyperliquid Policy Center support the proposed rule but urge FinCEN and OFAC to clarify that obligations (such as SAR filings, KYC, and lawful orders) should not apply to secondary market activities or downstream protocol developers. They specifically advocate for excluding smart contract interactions on the secondary market from sanctions liability and request safe harbor protections for voluntary reporting by developers.