Comment from Circle represents two identical comments
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Summary: Circle Internet Group, Inc., a global stablecoin issuer, supports the development of AML/CFT requirements for payment stablecoin issuers but argues against certain proposed "reject" obligations and overbroad definitions. They advocate for a risk-calibrated approach that distinguishes between primary market relationships and secondary market transactions while ensuring technical feasibility for "burn" and "freeze" capabilities.
Circle Internet Group, Inc. (together with its subsidiaries, “Circle”) respectfully submits these comments in response to the Joint Notice of Proposed Rulemaking (the “NPRM”) issued by the Financial Crimes Enforcement Network (“FinCEN”) and the Office of Foreign Assets Control (“OFAC”). The NPRM proposes anti-money laundering/countering the financing of terrorism (“AML/CFT”) program requirements for Permitted Payment Stablecoin Issuers (“PPSIs”) and requires PPSIs to maintain effective sanctions compliance programs, pursuant to the Guiding and Establishing National Innovation for U.S. Stablecoins Act (the “GENIUS Act”).