Comment from Multicoin Capital

Summary: Multicoin Capital Management, an investment adviser, supports the proposed AML/CFT and sanctions compliance framework for stablecoin issuers but urges the agencies to adopt a performance-based, rather than prescriptive, standard for smart-contract controls. They argue that the current proposal risks creating competitive asymmetries that favor bank-affiliated incumbents over standalone fintechs by imposing disproportionate fixed compliance costs.