1) The report places a strong emphasis on blocking tools, but these mechanisms are already integrated into most popular stablecoins. At the same time, there are no clear requirements within the Travel Rule directly addressed to stablecoin issuers.

2) The best practices section looks quite strange; essentially, it’s just a collection of market-wide practices without any new logic.

3) The report itself states:

“FATF standards do not require jurisdictions to implement regulatory regimes for stablecoins that go beyond those already applied to virtual asset service providers (VASP).”

In other words, no new requirements are being introduced for stablecoins.

4) Meanwhile, real issues remain unaddressed: the inability to quickly and properly submit requests through law enforcement agencies in many jurisdictions.

5) Why not discuss creating a system where the time between law enforcement’s request to the issuer and the blocking of funds takes hours, not months, when the money has long been withdrawn?

In the end, the report is written carefully and technically competently, but essentially quite empty.

It’s a bit disappointing how little time was spent.