Letter to FDIC on GENIUS Act implementation emphasizes regulatory alignment, proportional supervision, efficient consultation, and durable confidentiality protections

Washington, D.C. (August 5, 2026) – The American Fintech Council (AFC), the largest industry association representing both responsible fintech companies and innovative banks, submitted a letter to the Federal Deposit Insurance Corporation (FDIC) in response to its Notice of Proposed Rulemaking regarding Bank Secrecy Act (BSA) and sanctions compliance standards for FDIC-supervised permitted payment stablecoin issuers (PPSI’s) pursuant to the GENIUS Act. AFC supports a cohesive federal framework which coordinates FDIC supervisory expectations with applicable Treasury requirements and evaluates compliance according to risk and program effectiveness.

“Effective regulation of the stablecoin ecosystem should protect the financial system against illicit activities while providing regulated entities with sufficiently clear standards to design, implement, and continuously improve sophisticated compliance programs,” said Phil Goldfeder, CEO of the American Fintech Council. “By relying on a coordinated federal framework, the FDIC can prevent duplicative regulatory requirements and allow entities to leverage their enterprise systems to achieve strong compliance outcomes.”

AFC encourages the FDIC to integrate applicable federal Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements into a clear governance and risk management framework that allows PPSI’s to rely on mature enterprise compliance infrastructure. AFC stresses that supervisory expectations should remain technology-neutral and performance-based to encourage the responsible use of evolving tools like blockchain analytics, wallet screening, and transaction tracing.

“Consistent and proportionate supervision and regulation is essential to a healthy digital asset ecosystem,” said Ian P. Moloney, Chief Policy Officer at the American Fintech Council. “A final rule grounded in regulatory coordination, risk-based enforcement, efficient interagency consultation, and durable confidentiality protections would strengthen AML/CFT outcomes and provide PPSI’s with the clarity necessary to build effective programs.”

AFC also calls for enforcement standards that distinguish material program failures from isolated, remediable deficiencies, ensuring that supervisory outcomes remain proportionate to actual risk. Furthermore, AFC advocates for a disciplined and mandatory FinCEN consultation process for significant AML/CFT supervisory actions, paired with narrow information-sharing safeguards that preserve attorney-client privilege, attorney work product protection, and the confidentiality essential for candid supervisory engagement.

A standards-based organization, the American Fintech Council (AFC) is the largest and most diverse trade association representing financial technology (fintech) companies and innovative banks. On behalf of over 150 member companies and partners, AFC promotes a transparent, inclusive, and customer-centric financial system by supporting responsible innovation in financial services and encouraging sound public policy. AFC members foster competition in consumer finance and pioneer products to better serve underserved consumer segments and geographies.

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