GBBC USA: Response to FinCEN Request for Comment on Permitted Payment Stablecoin Issuer Customer Identification Program

GBBC has responded to the joint FinCEN, OCC, Federal Reserve, FDIC, and NCUA proposed rule on customer identification program requirements for permitted payment stablecoin issuers (PPSIs). Our response supports a risk-based and technology-neutral framework that reflects how payment stablecoins operate while maintaining strong customer identification and financial integrity standards.

Our response focuses on:

🔹 Limiting CIP requirements to direct customer or account relationships rather than automatically extending them to secondary-market activity

🔹 Maintaining clear, function-based definitions of “account,” “customer,” and digital asset service provider

🔹 Allowing PPSIs to use digital identity, verifiable credentials, and other innovative verification technologies where they satisfy applicable CIP requirements

These recommendations are intended to support effective customer identification while preserving flexibility for evolving payment of stablecoin business models and technologies.

Read GBBC’s full response here.