Comment from Crypto Council for Innovation (CCI)
Crypto Council for InnovationSupportAdvocacy
Summary: The Crypto Council for Innovation (CCI), a global alliance of digital asset companies, supports the proposed AML/CFT and sanctions compliance framework for permitted payment stablecoin issuers. They advocate for a risk-based approach and request specific clarifications regarding secondary market obligations, technical limitations of smart contracts, and the need for a "safe harbor" for good-faith blocking actions.
The Crypto Council for Innovation (“CCI”) appreciates the opportunity to submit comments on the Notice of Proposed Rulemaking on Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements (“Proposed Rule” or “NPRM”).
CCI is a global alliance of leading companies across the digital asset ecosystem, including stablecoin issuers, financial institutions, technology providers, and investors, with a mission to advance the responsible regulation of digital assets and demonstrate their transformational potential. CCI believes that achieving the shared goals of market integrity, consumer protection, and national security requires informed, evidence-based policy developed through constructive engagement with regulators. To that end, CCI respectfully offers the following comments and recommendations.