- The group filed comments with FinCEN, OFAC, and FDIC supporting issuer-focused AML, CFT, and sanctions compliance frameworks.
- It argued peer-to-peer stablecoin transfers should not be treated as issuer-intermediated activity under federal rules.
- The association called for harmonized reserve, redemption, and compliance standards to support innovation and consumer protection.
This week, the Blockchain Association filed two comment letters on GENIUS Act stablecoin rulemakings with FinCEN, OFAC, and the FDIC. It outlined recommendations on AML, CFT, and sanctions compliance, focusing on consumer protection and U.S. digital asset leadership. According to the filings, the comments addressed issuer obligations, secondary market transfers, and regulatory coordination across agencies.
FinCEN And OFAC Focus
The Blockchain Association urged FinCEN and OFAC to coordinate closely on stablecoin compliance frameworks. It said obligations should focus on issuer-controlled functions such as issuance, redemption, reserve management, and fiat conversion.
It added that peer-to-peer secondary market transfers should not be treated as issuer-intermediated activity. It submitted separate comment letters addressing FinCEN, OFAC, and FDIC rulemakings on the GENIUS Act framework.
Issuer Based Compliance Framework
The group supported FinCEN and OFAC efforts to build AML, CFT, and sanctions compliance rules under the GENIUS Act. It stressed preventing illicit use of stablecoins and strengthening safeguards against criminal exploitation.
It noted industry readiness to collaborate with regulators to improve monitoring and enforcement mechanisms. It also highlighted blockchain systems differ from traditional intermediary-based financial systems in structure and operations.
It emphasized that payment stablecoin activity should fall under a clear federal regulatory framework established by Congress. It said industry stakeholders are prepared to work with authorities to strengthen safeguards against bad actors.
FDIC Coordination And Reserve Rules
The Blockchain Association called for FDIC coordination through a harmonized, principles-based regulatory approach. It urged workable reserve requirements, flexible redemption rules, and clear definitions across stablecoin regulation.
It cautioned against unnecessary restrictions that could reduce utility, competition, or innovation in stablecoin markets. It stated that getting GENIUS Act implementation right remains essential for ongoing regulatory work.
It also referenced the importance of coordinated implementation across federal agencies involved in stablecoin oversight. It noted the Proposed Rule recognizes blockchain-based systems differ operationally from traditional intermediary financial systems. BA reiterated collaboration with FinCEN, OFAC, and FDIC on effective AML and sanctions enforcement.
