Airbnb Payments, Inc.
BusinessSupport
Effectiveness-based standards
Anti-Money Laundering and Countering the Financing of Terrorism Programs
FINCEN-2026-0034-0001Proposed Rule
Comments
79
Awaiting comments
Deadline
Closed on Jun 10, 2026
Closed Jun 10, 2026
Net supportiSupport minus oppose · campaigns included
+92%
+92% excluding campaigns
Document
Details
The document's own metadata, straight from the source system.
- Title
- Anti-Money Laundering and Countering the Financing of Terrorism Programs
- Posted
- Apr 10, 2026
- Comment period
- Apr 10, 2026 – Jun 10, 2026
- FR Doc
- 2026-07033
- CFR
- 31 CFR Parts 1010 1020 1021 1022 1023 1024 1025
Analysis
Overview
What the public is saying — stance, who's commenting, and the issues they raise.
Include campaigns
Stance breakdown
+92%
Net support
Support76Oppose3
Aggregates include form-letter campaigns. Excluding them, net support is +92% across organic comments.
Who commented
Breakdown by commenter type.
Academic
1
Business
34
Individual
5
Trade association
11
Advocacy
28
Comments over time
Weekly arrivals, stacked by stance.
Posted Apr 10, 2026Deadline Jun 10, 2026
Apr 13Apr 27Jun 1Jun 8
Support76Oppose3Other0
Support × commenter type
How each type splits across stance.
Support
Oppose
Other
Business
97%
3%
0%
Advocacy
100%
0%
0%
Trade association
100%
0%
0%
Individual
80%
20%
0%
Academic
0%
100%
0%
Issues raised
The docket's canonical issues. Select one to browse its comments.
Guidance on effectiveness standards37
Effectiveness-based standards36
Clarification of significant failure13
Cross-silo data collaboration and pets7
Third-party aml risk guidance6
Use of verifiable digital credentials5
Redundant ctr reporting requirements4
Reliability of identity determination4
Effective supervisory control requirement3
Scope of infrastructure providers2
Position map
Who stands where on each issue?
Every non-silent position is backed by an excerpt from the comment.
Issues shown
Uncheck an issue to choose another.
| Organization | Effectiveness-based standards | Guidance on effectiveness standards | Clarification of significant failure | Redundant ctr reporting requirements | Biometric technology recognition |
|---|---|---|---|---|---|
Airbnb Payments, Inc. BusinessSupport Airbnb Payments, Inc. | · | · | · | · | |
America's Credit Unions AdvocacySupport America’s Credit Unions supports FinCEN’s proposed modernization of AML/CFT programs, specifically praising the shift to | · | · | |||
American Gaming Association AdvocacySupport The American Gaming Association (AGA) supports the proposed AML/CFT program rule revisions, welcoming the focus on innov | · | · | · | ||
Conference of State Bank Supervisors (CSBS) Trade associationSupport The Conference of State Bank Supervisors (CSBS), a nationwide organization of state banking and financial regulators, su | · | · | · | · | |
Cooperative Credit Union Association AdvocacySupport The Cooperative Credit Union Association, Inc., a state trade association representing approximately 200 credit unions, | · | · | · | · | |
Crypto Council for Innovation AdvocacySupport The Crypto Council for Innovation (CCI), a global alliance of digital asset companies, supports the proposed rule to mod | · | · | |||
Defense Credit Union Council AdvocacySupport The Defense Credit Union Council (DCUC) supports the proposed rule's emphasis on risk-based supervision, program effecti | · | · | · | ||
Elliptic Inc. BusinessSupport Elliptic Inc., a blockchain analytics provider, supports the proposed shift toward an effectiveness-based AML/CFT framew | · | · | |||
Foundation for Defense of Democracies AdvocacySupport The Foundation for Defense of Democracies (FDD) supports the proposed rule's shift toward an effectiveness-based AML/CFT | · | · | |||
GFIA (Global Federation of Insurance Associations) Trade associationSupport The Global Federation of Insurance Associations (GFIA) supports the proposed reforms to the Bank Secrecy Act, specifical | · | · | · | · | |
HSBC BusinessSupport HSBC, a global financial institution, supports the proposed AML/CFT program rules and applauds the efforts to align them | · | · | · | · | |
iKinetiq Innovation Solutions, LLC BusinessSupport Stuart Brock, President of iKinetiq Innovation Solutions, supports the proposed rules' shift toward an effectiveness-bas | · | · | · | ||
Illinois Credit Union League Trade associationSupport The Illinois Credit Union League (ICUL), a trade association representing Illinois credit unions, supports the proposed | · | · | |||
Independent Community Bankers of America (ICBA ) Trade associationSupport The Independent Community Bankers of America (ICBA) supports the proposed modernization of AML/CFT programs, particularl | · | · | |||
Institute of International Bankers Trade associationSupport The Institute of International Bankers (IIB) supports the proposed rule to modernize the Bank Secrecy Act framework, pra | · | · | |||
Investment Company Institute Trade associationSupport The Investment Company Institute (ICI), an association representing the asset management industry, supports FinCEN's eff | · | · | |||
Kharon BusinessSupport Kharon, a risk intelligence company, supports the proposed AML/CFT rule because it allows financial institutions to shif | · | · | · | · | |
Main Street Foundation Center for Regulatory Analysis and Engagement AdvocacySupport The Main Street Foundation’s Center for Regulatory Analysis and Engagement (CRAE) supports the modernization of AML/CFT | · | · | |||
Moody's BusinessSupport Moody’s Corporation, a provider of data and analytical tools for financial institutions, supports FinCEN’s proposal to m | · | · | · | ||
Nasdaq Verafin BusinessSupport Nasdaq Verafin, a global technology company providing financial crime management solutions, supports the proposed rule's | · | · | |||
NICE Actimize BusinessSupport Ted Sausen, representing NICE Actimize, supports the proposed AML/CFT program reforms as a welcome shift toward an effec | · | · | · | · | |
Ocean Systems Inc. BusinessSupport Ocean Systems, Inc., a financial technology company providing BSA/AML compliance software, supports the proposed rule's | · | · | · | ||
OTC Markets Group BusinessSupport OTC Markets Group supports the modernization of AML/CFT programs but requests that FinCEN clarify that "utility ATSs" sh | · | · | · | · | · |
Proof.com BusinessSupport Proof, a digital identity and transaction security platform, supports the proposed rule and encourages FinCEN to explici | · | · | · | · | · |
Section 2, Inc. BusinessSupport Section 2 Inc., a financial crime intelligence firm, supports the proposed transition to an "outcome-driven standard of | · | · | · | · | |
Stripe BusinessSupport Stripe, a money service business and licensed money transmitter, strongly supports the proposed rule's shift toward an o | · | · | |||
The Wolfsberg Group AdvocacySupport The Wolfsberg Group supports the proposed rule as a critical step toward modernizing the U.S. | · | · | · | ||
Third Party Payment Processors Association (TPPPA) AdvocacySupport The Third Party Payment Processors Association (TPPPA) supports the proposed updates to the BSA and AML/CFT programs, sp | · | · | · | · | · |
Tokenpods BusinessSupport Tokenpods, Inc., a compliance technology company, expresses strong support for the proposed shift toward an outcomes-bas | · | · | · | ||
Value Technology Foundation AdvocacySupport The Value Technology Foundation, a non-profit organization, supports the modernization of AML/CFT programs and recommend | · | · | · | · |
America's Credit Unions
AdvocacySupport
Effectiveness-based standards
Guidance on effectiveness standards
Redundant ctr reporting requirements
American Gaming Association
AdvocacySupport
Effectiveness-based standards
Redundant ctr reporting requirements
Conference of State Bank Supervisors (CSBS)
Trade associationSupport
Effectiveness-based standards
Cooperative Credit Union Association
AdvocacySupport
Clarification of significant failure
Crypto Council for Innovation
AdvocacySupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Defense Credit Union Council
AdvocacySupport
Effectiveness-based standards
Guidance on effectiveness standards
Elliptic Inc.
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Foundation for Defense of Democracies
AdvocacySupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
GFIA (Global Federation of Insurance Associations)
Trade associationSupport
Effectiveness-based standards
HSBC
BusinessSupport
Guidance on effectiveness standards
iKinetiq Innovation Solutions, LLC
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Illinois Credit Union League
Trade associationSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Independent Community Bankers of America (ICBA )
Trade associationSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Institute of International Bankers
Trade associationSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Investment Company Institute
Trade associationSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Kharon
BusinessSupport
Effectiveness-based standards
Main Street Foundation Center for Regulatory Analysis and Engagement
AdvocacySupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
Moody's
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Nasdaq Verafin
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Clarification of significant failure
NICE Actimize
BusinessSupport
Effectiveness-based standards
Ocean Systems Inc.
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
OTC Markets Group
BusinessSupport
Proof.com
BusinessSupport
Section 2, Inc.
BusinessSupport
Effectiveness-based standards
Stripe
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Redundant ctr reporting requirements
The Wolfsberg Group
AdvocacySupport
Effectiveness-based standards
Clarification of significant failure
Third Party Payment Processors Association (TPPPA)
AdvocacySupport
Tokenpods
BusinessSupport
Effectiveness-based standards
Guidance on effectiveness standards
Value Technology Foundation
AdvocacySupport
Biometric technology recognition
4 organization-typed comments could not be identified.
Comments
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
Filter:
- Jun 9, 2026EnveilSupportBusiness📎 Attachment
Enveil, a Privacy Enhancing Technology (PET) solution provider, supports the modernization of AML/CFT programs and advocates for the integration of PETs to enable secure, cross-silo data collaboration. The company argues that regulators should provide clearer incentives, standardization, and funding for operational pilots to help financial institutions share data across boundaries without compromising privacy or security.
Read comment → - Jun 9, 2026Section 2, Inc.SupportBusiness📎 Attachment
Section 2 Inc., a financial crime intelligence firm, supports the proposed transition to an "outcome-driven standard of effectiveness" for AML/CFT programs. They argue for specific refinements, including allowing automated configuration updates for national priorities, clarifying that network-based behavioral analytics qualify as "reasonably designed," and ensuring that the "establishment" prong of the rule evaluates structural adequacy against criminal network typologies.
Read comment → - Jun 9, 2026Coin CenterSupportAdvocacy📎 Attachment
Coin Center, a nonprofit research and advocacy center, supports the modernization of AML/CFT programs but argues that current practices of over-collecting sensitive personal information create significant cybersecurity and fraud risks. They urge FinCEN to recognize and encourage privacy-preserving digital identity tools, such as portable credentials and attribute-based proofs, as effective alternatives to traditional data collection.
Read comment → - Jun 9, 2026HSBCSupportBusiness📎 Attachment
HSBC, a global financial institution, supports the proposed AML/CFT program rules and applauds the efforts to align them with the AML Act. The bank argues for specific modifications to the final rule that would explicitly encourage the use of innovative technologies, recognize participation in public-private information-sharing partnerships, and allow firms to prioritize resources toward higher-risk activities without fear of regulatory reprisal for not detecting lower-risk activity.
Read comment → - Jun 9, 2026NICE ActimizeSupportBusiness📎 Attachment
Ted Sausen, representing NICE Actimize, supports the proposed AML/CFT program reforms as a welcome shift toward an effectiveness-based regulatory framework. The commenter argues that FinCEN should further strengthen the proposal by explicitly promoting advanced analytics and AI, and by expanding interbank information sharing beyond current Section 314(b) limitations to include behavioral risk signals and a clear safe harbor.
Read comment → - Jun 9, 2026Global Blockchain Business CouncilSupportAdvocacy📎 Attachment
The Global Blockchain Business Council (GBBC) USA supports FinCEN's proposed rule to modernize AML/CFT programs, praising its risk-based approach and the distinction between establishing and maintaining programs. They argue for further clarifications on "effectiveness" and "materiality" to ensure the rule supports innovation in digital assets while focusing on high-impact threats.
Read comment → - Jun 8, 2026SOLO FINANCE INC.SupportBusiness📎 Attachment
SOLO FINANCE INC., a company operating an inter-bank trust network and consumer reporting agency, supports the proposed AML/CFT rule. They argue that the rule should focus on effectiveness-based evaluation and clear, research-backed standards to create a level playing field and prevent illicit finance.
Read comment →