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

Proof, a digital identity and transaction security platform, supports the proposed rule and urges FinCEN to explicitly allow permitted payment stablecoin issuers (PPSIs) to use Verifiable Digital Credentials (VDCs) to meet AML/CFT and sanctions requirements. The company argues that VDCs provide a secure, efficient, and privacy-preserving method for identity verification and beneficial ownership checks while maintaining regulatory integrity.

The Global Legal Entity Identifier Foundation (GLEIF) supports the proposed rulemaking and advocates for the integration of the Legal Entity Identifier (LEI) and its verifiable counterpart (vLEI) into the regulatory framework. They argue that using these standardized identifiers will improve transparency, streamline cross-agency coordination, and ensure consistency with international standards like the EU's MiCA regime.

Coin Center, an independent nonprofit research and advocacy center, supports the proposed action but urges regulators to prioritize privacy-preserving digital identity tools and data-minimized compliance. They argue that overcollecting sensitive personal information creates significant cybersecurity and fraud risks and advocate for a clear distinction between regulated customer relationships and broader peer-to-peer secondary-market activity.

The Value Technology Foundation (VTF) supports the proposed rule and recommends that FinCEN and OFAC explicitly recognize biometric and facial recognition technologies as valid tools for AML/CFT and sanctions compliance. They argue that these technologies are essential for linking real-world identities to on-chain activity, combating synthetic identity fraud, and ensuring compliance with lawful orders while remaining consistent with GLBA privacy exceptions.

The Global Legal Entity Identifier Foundation (GLEIF) supports the proposed rulemaking and advocates for the integration of the Legal Entity Identifier (LEI) and its verifiable counterpart (vLEI) into the regulatory framework. They argue that using these standardized identifiers will enhance transparency, streamline cross-agency consultation, and ensure international interoperability with existing standards like the EU's MiCA.

KillChain, Inc. (d/b/a FLINT Network) supports the proposed rule and argues that it must specifically address transactions initiated by autonomous AI agents. They advocate for a "Know Your Agent" (KYA) verification framework that produces cryptographically signed records to provide auditable evidence of compliance for non-human financial actors.