The Bank Policy Institute and The Clearing House Association submitted a joint comment letter on the FDIC’s proposal establishing BSA and sanctions compliance standards for FDIC-supervised permitted payment stablecoin issuers under the GENIUS Act. The Associations support requiring FDIC-supervised PPSIs to comply with the AML/CFT, sanctions, and customer identification requirements established by FinCEN and OFAC, emphasizing that consistent requirements across federal regulators are important to reduce regulatory divergence and arbitrage.

The letter also supports the proposed FinCEN consultation framework for significant AML/CFT supervisory and enforcement actions, but recommends that consultation apply uniformly without an asset threshold or optional carveout, and that the FDIC coordinate with the other federal stablecoin regulators on common definitions and standards. It further urges equal supervisory treatment of all PPSIs, including bank-affiliated and standalone issuers, and generally supports limiting significant AML/CFT actions to significant or systemic program failures while allowing heightened supervisory attention during a new issuer’s initial operating period. To read the full letter, click here.