Comment from Blockchain Association
Blockchain AssociationSupportAdvocacy
Summary: The Blockchain Association (BA) supports the proposed rule establishing AML/CFT and sanctions compliance requirements for payment stablecoin issuers. While supporting the framework, the organization argues for a results-based compliance test, a liability safe harbor for good-faith actions, and a narrower scope of obligations that focuses on primary market activities rather than secondary market peer-to-peer transfers.
Attached please find the written submission of the Blockchain Association ("BA"). BA appreciates the opportunity to provide comments on the Proposed Rule issued by FinCEN and OFAC jointly.