Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements

The Defense Credit Union Council (DCUC) supports the proposed rulemaking to implement the GENIUS Act but urges the agencies to ensure requirements are proportional to an institution's size and risk profile. They specifically advocate for avoiding duplicative requirements for credit unions that already have existing compliance frameworks and request a longer implementation period of at least 18-24 months.

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.

Opacity Labs, Inc. supports the proposed rulemaking but urges FinCEN to provide explicit regulatory clarity regarding the use of decentralized, distributed networks for BSA and sanctions compliance. The company argues that the current lack of clarity hinders the adoption of innovative technologies like their "Verified Data Network," which they claim can improve security, efficiency, and real-time risk propagation for permitted payment stablecoin issuers.

Solidus Labs, a provider of risk monitoring and market surveillance infrastructure, supports the proposed AML/CFT and sanctions compliance framework for payment stablecoin issuers. They argue that the final rule should provide greater specificity regarding the need for behavioral and pattern-based monitoring to address the unique risks of permissionless networks and secondary market activity.

The DDCP Foundation, acting as a steward of open-source protocol infrastructure, supports the proposed AML/CFT and sanctions compliance framework while advocating for technical flexibility. They argue that compliance should be achieved through co-signature authority and coordination with financial intermediaries rather than requiring centralized administrative keys that could compromise self-custody privacy and cause unintended "blast radius" freezes on pooled assets.

Andreessen Horowitz (a16z), a venture capital firm, argues that the proposed rule imposes overly broad and impractical requirements on payment stablecoin issuers, particularly regarding secondary market monitoring and the scope of the Sanctions Compliance Program. They advocate for a more tailored approach that clarifies definitions, limits obligations to direct customers, and provides a longer implementation period for new compliance programs.

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.

Digital Asset Holdings, LLC supports the proposed rule and its alignment with the GENIUS Act, emphasizing the need for regulatory flexibility regarding blockchain architecture. The company argues that the rule should focus on risk assessment standards rather than prescribing specific blockchain technologies, allowing stablecoin issuers to maintain financial privacy while meeting AML and sanctions obligations.

Solari, Inc., a publisher of a financial sovereignty and privacy subscription service, supports the proposed AML/CFT and sanctions compliance framework for stablecoin issuers. However, the company urges the Treasury to strengthen the rule by requiring human oversight for all transaction blocks or freezes, establishing robust due process protections to prevent viewpoint-based discrimination, and implementing measures to protect consumer financial privacy on public blockchains.

The Blockchain Association (BA) supports the proposed rule establishing AML/CFT and sanctions compliance requirements for payment stablecoin issuers. While supporting the framework, the organization argues for a results-based compliance test, a liability safe harbor for good-faith actions, and a narrower scope of obligations that focuses on primary market activities rather than secondary market peer-to-peer transfers.