Comment from D.D. Sayfer Information Security Ltd.

Summary: D.D. Sayfer Information Security Ltd., a forensic blockchain-investigations and digital-asset recovery firm, supports the proposed rule but urges three specific clarifications. They argue that the final rule should explicitly confirm that issuers have the technical capability to move identified stablecoins into official custody (via burn-and-reissue), that civil orders qualify as "lawful orders," and that foreign issuers must comply with U.S. lawful orders regarding assets offered to U.S. persons.