FinCEN and OFAC regulations, if truly able to leverage the transparency of public ledgers, could make compliance costs for stablecoin issuers lower than those of traditional banks— the key is for regulators to recognize this technological logic, rather than rigidly applying old frameworks.

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.