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

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.

GeoComply Solutions Inc. supports the proposed rule but argues that it is insufficient because it does not explicitly require PPSIs to account for location-obfuscating technologies like VPNs. The company advocates for the inclusion of prescriptive language requiring multi-source geolocation technology (GPS, Wi-Fi, and cellular data) to ensure effective sanctions compliance and AML/CFT controls.

The Crypto Council for Innovation (CCI), a global alliance of digital asset companies, supports the proposed AML/CFT and sanctions compliance framework for permitted payment stablecoin issuers. They advocate for a risk-based approach and request specific clarifications regarding secondary market obligations, technical limitations of smart contracts, and the need for a "safe harbor" for good-faith blocking actions.

XSOC CORP, a pre-commercial technology provider developing transaction authorization and compliance infrastructure, supports the proposed rule's objectives and its technology-neutral approach. The company argues that the final rule should explicitly recognize proactive, cryptographic pre-authorization enforcement as a valid method for meeting technical capability requirements, alongside traditional reactive controls. They also advocate for an outcome-based effectiveness standard, recognition of cryptographic records as compliance evidence, and the inclusion of post-quantum cryptographic migration requirements.

Paradigm Operations LP and the Hyperliquid Policy Center support the proposed rule but urge FinCEN and OFAC to clarify that obligations (such as SAR filings, KYC, and lawful orders) should not apply to secondary market activities or downstream protocol developers. They specifically advocate for excluding smart contract interactions on the secondary market from sanctions liability and request safe harbor protections for voluntary reporting by developers.

The Conference of State Bank Supervisors (CSBS) supports the proposal to require stablecoin issuers to have the technical capability to block and freeze transactions in both primary and secondary markets. However, they oppose the mandatory notice and consultation process between federal regulators and FinCEN, arguing it would create inefficiencies and supervisory divergence, and instead recommend an optional consultation process.

World Evolution Enterprise PBC, a public benefit corporation, supports the proposed rulemaking but requests that the final rules include a distinct regulatory classification for asset-backed natural capital instruments. They argue that their specific instrument (the Exo-Terran Credit) should be distinguished from payment stablecoins to avoid being subject to a regulatory regime designed for a different class of asset.

The Global Blockchain Business Council (GBBC) supports the proposed AML/CFT and sanctions compliance requirements for payment stablecoin issuers. They advocate for a risk-based, technology-neutral framework that preserves flexibility for different business models while ensuring effective controls like Travel Rule data exchange and smart contract-based monitoring.

The Settlement Integrity Institute, a standards development organization, supports the joint rulemaking by providing a methodology for evaluating the effectiveness of AML/CFT and sanctions compliance programs. They argue that the agencies should recognize independent methodology layers to provide clear, recertifiable standards for assessing program effectiveness and best practices without foreclosing regulatory authority.

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.