The Blockchain Association has filed a comment letter supporting the joint proposed rules from multiple U.S. federal agencies for stablecoin issuers under the GENIUS Act, the landmark framework signed into law in 2025.
The letter, submitted to the Treasury’s Financial Crimes Enforcement Network, the Office of the Comptroller of the Currency, the Federal Reserve, the FDIC, and the National Credit Union Administration, responds to proposed customer identification program requirements for permitted payment stablecoin issuers. The comment period closed on August 21.
Limited Customer ID Scope
The Blockchain Association’s core position is that customer identification requirements should be limited to direct issuer-customer transactions in the primary market. Under this framework, everyday peer-to-peer transactions on secondary markets would fall outside stablecoin issuers’ CIP obligations.
BA also strongly supports the proposal’s decision to limit CIP obligations to primary-market relationships in which a PPSI interacts directly with a customer, rather than attempting to impose customer-identification obligations across downstream secondary-market activity.
Call for Clearer Definitions
Beyond the scope of CIP obligations, the Association also called for clearer definitions of terms such as account, customer, and digital asset service provider. It recommended excluding one-off redemptions and activities unrelated to stablecoins from the CIP framework.
The group further urged federal agencies to avoid duplicative compliance requirements and to clearly state that stablecoin issuers should have flexibility in verifying client information. It also suggested coordinating the effective date of the proposed CIP rules with separate but related anti-money laundering rules under the GENIUS Act.
Implementation Context
The GENIUS Act, formally the Guiding and Establishing National Innovation for U.S. Stablecoins Act, was signed into law in 2025. It establishes who can issue payment stablecoins, what those tokens must be backed by, and how holders can redeem them. Treasury published its initial request for comment in August 2025, and a second round of public comment was opened in September of that year.
The proposed rules now under consideration represent the latest step in implementing the law’s requirements for payment stablecoin issuers to maintain effective customer identification programs. The Blockchain Association wrote in its filing that the GENIUS Act created a landmark framework for payment stablecoins.
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