My Comment Letter on the FinCEN/OFAC Stablecoin Rule

This week I submitted a comment letter on the joint FinCEN/OFAC proposed rule implementing the GENIUS Act’s anti-money-laundering (AML), suspicious-activity-reporting (SAR), and OFAC sanctions-compliance requirements for permitted payment stablecoin issuers.

The letter addresses the threat vectors I believe create real legal exposure—for issuers, for custodians, and for individuals who sign off on filings. If you’re building in the stablecoin sector, today would be a good day to subscribe to my newsletter on Substack.