Circle's recent opinion letter is quite straightforward; on-chain monitoring and smart contract-level restrictions are inherently advantages of crypto-native technology, and regulatory frameworks indeed shouldn't focus solely on banks.

According to Crowdfund Insider, Circle has submitted two comment letters to the U.S. Department of the Treasury in response to the proposed rules for FinCEN's anti-money laundering (AML) and sanctions framework, as well as FinCEN and OFAC's AML/CFT and sanctions compliance rules for licensed payment stablecoin issuers (PPSI) under the GENIUS Act. Circle urges regulators to recognize blockchain-native compliance tools such as on-chain monitoring, smart contract-level address restrictions, transaction graph analysis, and transparency of public ledgers, and states that relevant rules should not be designed solely around banks but should also apply to non-bank entities like stablecoin issuers.