KillChain, Inc. (d/b/a FLINT)

KillChain, Inc. (d/b/a FLINT Network) respectfully submits the attached comment letter on the Notice of Proposed Rulemaking, Anti-Money Laundering and Countering the Financing of Terrorism Programs, posted April 10, 2026 (Docket ID OCC-2024-0005; FDIC RIN 3064-AF34; NCUA RIN 3133-AG08). FLINT has filed a substantially similar comment with FinCEN on the concurrent rulemaking (Docket No. FINCEN-2026-0034). FLINT Network supports the proposed shift to effectiveness-based AML/CFT program requirements, harmonized with FinCEN's concurrent proposal, and gives favorable consideration to innovative tools, such as artificial intelligence and human oversight, at critical adjudication points. The attached letter identifies one gap the final rule and its examination procedures should address: effectiveness cannot be demonstrated for transactions initiated by autonomous AI agents without a transaction-level verification primitive. Supervised institutions' customers are already delegating payment authority to AI agents across card, ACH, and stablecoin rails, yet the existing compliance stack verifies only the human or legal-entity customer, not the non-human actor executing the transaction, its delegated authority, or its ongoing behavior. The letter describes Know Your Agent (KYA) verification, performed in real time across 6 layers, producing a cryptographically signed, retained verification record as examiner-ready evidence. It recommends that the final rule and examination procedures: (1) confirm favorable consideration extends to transaction-level AI agent verification; (2) recognize signed verification records as documentary evidence of effectiveness, including in FFIEC examination manual updates; (3) treat agent-initiated activity as a distinct risk category; (4) coordinate with FinCEN and NIST agent-identity standards work; and (5) preserve technology-neutral and rail-neutral framing consistent with the GENIUS Act. Point of contact: Joseph Taylor, Founder and CEO, contact@flint.network.