Comment from KillChain, Inc. (d/b/a FLINT Network)
KillChain, Inc. (d/b/a FLINT Network)SupportBusiness
Summary: KillChain, Inc. (d/b/a FLINT Network), a technology provider for AI agent identity and fraud protection, supports the proposed risk-based, technology-neutral CIP framework for stablecoin issuers. They argue that the final rule should explicitly recognize verifiable credentials and signed verification records as valid non-documentary verification methods, particularly to address the unique challenges of non-human agents exercising delegated financial authority.
KillChain, Inc., d/b/a as FLINT Network (flint.network), respectfully submits the attached formal comment in response to the Joint Notice of Proposed Rulemaking regarding the "Permitted Payment Stablecoin Issuer Customer Identification Program" (FinCEN Docket FINCEN-2026-0101; RIN 1506-AB74).
As a technology provider specializing in identity, authorization, and fraud protection infrastructure for autonomous AI agents, FLINT strongly supports the establishment of a risk-based, technology-neutral CIP framework for stablecoin issuers under the GENIUS Act.
Our attached memorandum specifically addresses the critical intersection of digital identity architectures, verifiable credentials, and the rapid expansion of non-human actors possessing delegated financial authority on programmable rails.
The submission includes detailed practitioner insights and adoptable regulatory text focused on:
1) Formally recognizing verifiable credentials and cryptographically signed verification records as valid non-documentary CIP verification methods under 31 CFR 1033.220(a)(2)(ii)(B).
2) Utilizing the NIST Digital Identity Guidelines (SP 800-63) as a calibration benchmark for identity assurance.
3) Defining and regulating accounts opened or operated by autonomous agents executing financial authority delegated by an identified principal, creating a complete Know Your Agent (KYA) security baseline to prevent regulatory arbitrage and runtime identity takeover.
The perspectives in the attached comment are grounded in direct operational experience with federal-scale digital identity systems and the Bank Secrecy Act, authored by FLINT's founder in his private capacity as a practitioner across the U.S. intelligence community, federal law enforcement, and digital identity infrastructure.
We appreciate the opportunity to comment on this historic rulemaking and welcome further technical discussion with the participating Agencies.
Please see the attached PDF for our full analysis and formal recommendations.