Circle Submits Comment Letters in Support of Combatting Illicit Finance

Circle Internet Financial has actively engaged with the U.S. Department of the Treasury by submitting comment letters in response to two major rulemakings on anti-money laundering (AML) and countering the financing of terrorism (CFT) programs, aimed at modernizing these frameworks for financial institutions, including stablecoin issuers. Circle supports the comprehensive updates proposed by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC), which will shape the compliance landscape for stablecoins. Emphasizing the role of blockchain-native controls, Circle argues that these tools offer superior traceability and compliance capabilities compared to traditional systems. The company advocates for a risk-based approach that balances financial inclusion with effective compliance, urging regulators to extend modernization benefits beyond banks to other financial entities like money services businesses. Circle's submissions highlight the need for clear, workable rules that accommodate the unique function of payment stablecoins on public blockchains, thereby ensuring that compliance efforts are aligned with actual risks rather than legacy financial models.