Comment from America's Credit Unions (ACU)

America's Credit UnionsSupportAdvocacy
Summary: America’s Credit Unions supports the proposed modernized BSA and sanctions framework for stablecoin issuers but requests further clarification on operational gaps. They specifically seek guidance on the delineation of responsibilities between parent credit unions and their stablecoin subsidiaries, as well as illustrative examples of non-prescriptive controls for blockchain forensics and KYC.
See Attached.

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