GBBC USA Response to FinCEN and OFAC Request for Comment – Permitted Payment Stablecoin Issuer AML/CFT and Sanctions Compliance Requirements

GBBC USA has submitted our response to Financial Crimes Enforcement Network (FinCEN) and Office of Foreign Assets Control (OFAC)’s Request for Comment on Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism Program and Sanctions Compliance Program Requirements. The proposed rule implements provisions of the GENIUS Act relating to Bank Secrecy Act treatment, AML/CFT obligations, and sanctions compliance requirements for permitted payment stablecoin issuers.

GBBC USA supports a clear, risk-based, and technology-neutral framework that advances financial integrity and national security while preserving the efficiency, programmability, and global interoperability of payment stablecoins. Our response recommends flexible compliance programs based on each issuer’s business model, technical architecture, customer relationships, and actual risk profile.

Key recommendations include product-specific treatment under the Money Services Business (MSB) framework; functional definitions for payment stablecoins and related activity; technology-neutral implementation of lawful-order obligations; and recognition of layered compliance controls, including institution-layer controls, contract-layer controls, Travel Rule data exchange, blockchain analytics, and information sharing. GBBC USA also encourages FinCEN and OFAC to consider the broader economic impact of regulatory design, including effects on financial innovation, financial inclusion, cross-border payment efficiency, competition, transaction costs, U.S. financial competitiveness, and the role of the U.S. dollar in the digital economy.

GBBC USA appreciates the opportunity to contribute and stands ready to support further engagement as FinCEN and OFAC develop AML/CFT and sanctions compliance requirements for permitted payment stablecoin issuers.

Read the full response here.