Industry group calls for coordinated federal leadership to promote responsible data sharing and modern technology in combating illicit finance risks

Washington, D.C. (October 16, 2025) – The American Fintech Council (AFC), the premier industry association representing responsible fintech companies and innovative banks, today submitted a comment letter to the U.S. Department of the Treasury in response to its Request for Comment on Innovative Methods to Detect Illicit Activity Involving Digital Assets. In the letter, AFC urges Treasury to promote secure data sharing and the responsible use of artificial intelligence to enhance detection and prevention of illicit financial activity across digital assets.

“The unimpeded movement of data underpins all aspects of the modern financial services industry, especially in combatting illicit activities in the digital assets space,” said Phil Goldfeder, CEO of the American Fintech Council. “Criminals conducting illicit activities take advantage of gaps in the regulatory framework, especially regarding the movement of data, to harm consumers and fund nefarious operations. Therefore, Treasury and the prudential banking regulators must use all available policy levers to ensure the flow of data used to combat these illicit activities remains unimpeded.”

AFC calls on Treasury to ensure that regulatory efforts do not impede the flow of consumer-permissioned data used to identify and prevent illicit activity in the digital asset space. The letter also urged coordination with banking regulators to affirm that federal law preempts state privacy statutes that could hinder fraud detection. Additionally, AFC encouraged Treasury to expand its own use of supervisory technology (suptech) tools and foster industry partnerships that incentivize AI-driven compliance solutions.

“Leveraging AI technology to combat illicit activities in the digital assets space is crucial to meeting the Administration’s goals for improving the financial services ecosystem,” said Ian P. Moloney, SVP and Head of Policy and Regulatory Affairs at AFC. “By promoting the responsible adoption of AI in regtech and suptech tools, Treasury can strengthen both oversight and operational resilience across the financial services industry.”

AFC’s recommendations highlight the importance of federal leadership in promoting data-driven collaboration between government and industry to counter emerging threats in the digital asset space.

A standards-based organization, AFC is the premier trade association representing the largest financial technology (Fintech) companies and innovative banks offering embedded finance solutions. AFC’s mission is to promote a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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