“The American Fintech Council (AFC) commends the OCC for advancing a thoughtful framework to implement the GENIUS Act’s anti-money laundering (AML), countering the financing of terrorism (CFT), and sanctions compliance requirements for permitted payment stablecoin issuers. As the proposal is finalized, it will be important to establish a coordinated federal supervisory framework that aligns with existing Bank Secrecy Act, FinCEN, and OFAC requirements in order to provide regulatory consistency and strengthen protections against illicit finance.

“The final rule should also provide clear, risk-based supervisory expectations that promote effective compliance, regulatory certainty, and continuous improvement while avoiding unnecessary duplication of existing compliance obligations. Additionally, the framework should remain technology neutral, allowing institutions to deploy the compliance technologies and risk management tools best suited to their business models.

“AFC appreciates the opportunity to provide feedback on the proposed rule and looks forward to continuing to work with the OCC to support a modern regulatory framework that will strengthen the long-term safety of the U.S. payment stablecoin market.”

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