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

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.

America’s Credit Unions supports the proposed modernized BSA and sanctions framework for stablecoin issuers but requests further clarification on operational gaps. They specifically seek guidance on the delineation of responsibilities between parent credit unions and their stablecoin subsidiaries, as well as illustrative examples of non-prescriptive controls for blockchain forensics and KYC.

TRM Labs, a blockchain intelligence company, supports the proposed rule but advocates for specific enhancements to maximize the technology's effectiveness. They argue the final rule should explicitly codify standards for the "freeze-burn-reissue" pipeline, recognize stablecoin financial intelligence units (FIUs), and provide safe harbor protections for risk-based compliance actions.

Chainalysis, Inc. supports the proposed rulemaking under the GENIUS Act, viewing it as a necessary step to establish national standards for stablecoin AML/CFT and sanctions compliance. The company argues that the final rule should specifically recognize continuous, automated blockchain analytics as a foundational compliance tool and establish clear data quality standards to differentiate between deterministic structural claims and probabilistic intelligence.