Circle Internet Financial has expressed strong support for the Bermuda Monetary Authority's (BMA) initiative to establish a modern, risk-based regulatory framework for payment service providers, aligning with global standards while encouraging innovation. In its feedback to the BMA, Circle highlighted the need for clear definitions and regulatory distinctions among digital wallet providers, payment-handling providers, and payment technology providers, advocating for a technology-neutral and innovation-friendly approach. Circle emphasized the importance of differentiating between custodial and non-custodial wallet solutions and excluding self-to-self transfers from regulatory oversight to promote interoperability. The company views Bermuda's forward-thinking regulatory efforts as a model for balancing innovation with oversight and appreciates the opportunity to help shape a comprehensive framework that could position Bermuda as a leader in regulating modern payment services. Circle remains committed to collaborating with the BMA and supporting global initiatives for safe, inclusive digital finance.