TL;DR
- The Blockchain Association submitted a comment letter supporting proposed rules by federal agencies for stablecoin issuers under the GENIUS Act.
- The group supports limiting customer identification requirements to direct transactions in the primary market, excluding peer-to-peer operations in secondary markets.
- The association also called for clearer definitions of key terms and coordination between CIP rules and the anti-money laundering rules to be implemented under the GENIUS Act.
The Blockchain Association submitted a formal comment letter to a group of U.S. federal agencies in support of the proposed rules for stablecoin issuers under the GENIUS Act, the payment stablecoin legislation enacted last year.
The letter was submitted on Friday, August 22, in response to the joint proposal developed by the Treasury’s Financial Crimes Enforcement Network (FinCEN), the Office of the Comptroller of the Currency (OCC), the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA). The comment period has already closed.
The GENIUS Act establishes who may issue payment stablecoins, what backing those tokens must hold, and how holders may redeem them. Among its requirements, the law requires permitted payment stablecoin issuers —referred to as PPSIs— to maintain an effective customer identification program (CIP).
The Blockchain Association Addresses Secondary Market Boundaries
In its letter, the Blockchain Association supported limiting CIP obligations to direct transactions between issuer and customer in the primary market. Under this criterion, everyday peer-to-peer transactions in secondary markets would fall outside the scope of those requirements. This approach prevents issuers from having to assume identification responsibilities over activities entirely beyond their operational control, a technical distinction crucial to the ecosystem’s viability.
Clear Definitions and Workable Rules
The Blockchain Association also urged agencies to establish more precise definitions of terms such as “account“, “customer“, and “digital asset service provider“. Among its recommendations, it proposed excluding from scope one-time redemptions and activities unrelated to stablecoins. It also called for avoiding duplicative compliance requirements and ensuring that issuers retain a strong degree of flexibility in their identity verification methods.
The association further requested that agencies coordinate the effective date of the CIP rules with the anti-money laundering rules to be implemented in parallel under the same law. “The GENIUS Act created a landmark framework for payment stablecoins,” the Blockchain Association wrote on its X account. “Implementation must preserve its goals: strong safeguards, workable rules, and room for continued innovation.”
