VeloxVFX LLC, an independent architecture-oriented company, supports the OCC's rulemaking on stablecoin AML/CFT and sanctions compliance. They recommend a "lifecycle-separated state representation" framework to ensure clarity in reserve traceability, redemption access, and supervisory boundaries without creating duplicative obligations.

The commenter proposes that the regulatory framework for stablecoins should require unique, persistent, and privacy-preserving identifiers for each individual monetary unit to ensure auditable one-to-one backing. They also advocate for a multi-key signature framework involving supervisory or custodian signatures to certify that stablecoins meet specific regulatory and reserve standards.