Crypto Times Logo Black
Google News Follow Banner
  • News
    • Market
    • Bitcoin
    • Ethereum
    • Altcoins
    • Regulations & Policies
    • Price Analysis
    • DeFi News
    • Blockchain News
    • Industry
  • Exclusive
    ExclusiveShow More
    Hunter Biden’s $LAPTOP Post-Mortem: What Went Wrong With the Token Launch
    Elon Musk and SpaceX composite image with the Indian flag and Bitcoin
    India vs Elon Musk: Starlink’s Global Wall of Bans, and the Crypto Thread Running Through It
    Physical gold Bitcoin (BTC) token standing in front of the US Capitol Building and the American flag
    Why Are U.S. Government Wallets Still Routing Seized Crypto to Coinbase?
    Charlie Lee, creator of Litecoin, standing in front of a blue Litecoin corporate logo wall
    Litecoin Turns 15: Original Bitcointalk Records Show How Charlie Lee Launched LTC in 2011
    Elon Musk with folded arms flanked by a giant Bitcoin coin, Tesla electric car, and SpaceX rocket launch
    Elon Musk’s Tesla and SpaceX Still Hold Over 30,000 Bitcoin: Why Is He Not Selling?
  • Opinion
    OpinionShow More
    Donald Trump speaking at a presidential podium with the White House and U.S. Capitol building in the background.
    Trump Just Declared the Super Intelligence Era in the “Unites States.” So Who Controls It?
    Comparison of Bybit 12-hour, Bitget 85-hour, and WazirX 463-day response timers
    Bitget, Bybit Paid in Hours; WazirX Lost Least in Hacks at $235M, Held Users Hostage for 463 Days
    Jackson Hole 2026: Crypto Is No Longer Outside the Fed’s Door
    Jackson Hole 2026: Crypto Is No Longer Outside the Fed’s Door
    The Architecture of Trust Same Routes, New Risks in Global Tokenisation
    The Architecture of Trust: Same Routes, New Risks in Global Tokenisation
    The Architecture of Trust What 4,000 Years of Trade Teach Us About RWA Tokenisation
    The Architecture of Trust: What 4,000 Years of Trade Teach Us About RWA Tokenisation
  • Learn
    • Explained
    • How To
    • Insights
  • IndicesNew
    • India USDT Premium Index
    • India USDC Premium Index
  • Videos
  • More
    • About Us
    • Our Authors
    • Contact Us
    • Editorial Policy
    • Daily Crypto Puzzles
The Crypto TimesThe Crypto Times
  • All News
  • Market
  • Bitcoin
  • Ethereum
  • Altcoins
  • Regulations & Policies
  • Blockchain
  • DeFi
  • Industry
  • Exclusive
  • Opinion
Search
  • News
    • Market
    • Bitcoin
    • Ethereum
    • Altcoins
    • Regulations & Policies
    • Price Analysis
    • Blockchain
    • DeFi
    • Industry
    • Exclusive
    • Opinion
  • Learn
    • Explained
    • How To
    • Insights
  • IndicesNew
    • India USDT Premium Index
    • India USDC Premium Index
  • Quick Links
    • About Us
    • Our Authors
    • Contact Us
    • Editorial Policy
    • AI Policy
    • Sponsored & Advertorial Policy
    • Daily Crypto Puzzles
  • Videos
  • Glossary
Follow US
© 2026 By Crypto Times. All Rights Reserved.
Regulations & Policies

Blockchain Association Says Proposed Stablecoin ID Rules Go Beyond the GENIUS Act

The letter also asks the agencies to permit zero-knowledge proofs for identity verification and to align the rule's compliance clock with a separate AML rulemaking.

Written By Dhara Chavda
Edited by Divya Mistry
Published 2026-08-25·Updated 2 months ago
Make The Crypto Times preferred on GoogleGoogle
Blockchain Association sign next to a printed legislative bill titled "GENIUS ACT" with an American flag in the background
AI Summary
Show
If agencies limit CIP to primary markets, stablecoin issuers may avoid costly secondary‑market compliance, shaping industry standards.
Adopting zero‑knowledge proofs could set a privacy‑focused precedent for future digital‑asset identity verification.
Aligning compliance dates with FinCEN/OFAC rules may synchronize AML enforcement, accelerating nationwide stablecoin regulatory rollout.

The Blockchain Association told five federal agencies in a 15-page comment letter that customer identification requirements for stablecoin issuers should remain confined to primary-market relationships, arguing that extending them to secondary-market transfers exceeds what the GENIUS Act authorizes.

What the Proposal Does

The joint rule, published at 91 Fed. Reg. 37,234 on June 22, implements the GENIUS Act’s requirement that permitted payment stablecoin issuers maintain a customer identification program. It was issued by FinCEN, the OCC, the Federal Reserve Board, the FDIC, and the NCUA and would take effect 12 months after a final rule is issued. The proposal arrived one month before the statutory rulemaking deadline, following the same compliance track as earlier illicit-finance rulemakings.

1/ On Friday, Blockchain Association filed comments on federal agencies’ proposed customer identification requirements for permitted payment stablecoin issuers under the GENIUS Act.

We support the goal of preventing illicit use of digital assets, and support the proposal’s core… pic.twitter.com/ED0CifzEqE

— Blockchain Association (@BlockchainAssn) August 24, 2026

The letter, signed by Blockchain Association Chief Executive Summer K. Mersinger, was addressed to FinCEN Acting Director Jenna Casanova, Comptroller Jonathan V. Gould, and the chairmen of the three remaining agencies.

The Secondary-Market Question

The agencies asked commenters directly whether CIP obligations should extend to secondary-market activity. As proposed, they do not: obligations attach only where an issuer interacts directly with a customer through issuance, redemption, conversion, or custody.

The Blockchain Association’s argument runs on two tracks. On statute, it points to the GENIUS Act’s text at 12 U.S.C. § 5903(a)(5)(A)(v), which requires issuers to verify the identities of account holders with the issuer—language the group reads as foreclosing obligations over transfers of already-circulating stablecoins.

In practice, the letter describes what an issuer can observe during a peer-to-peer transfer: a sending wallet signs and broadcasts a transaction, validators confirm it, and settlement occurs without the issuer’s involvement or knowledge. The issuer’s smart contract executes non-discretionary code, does not identify the parties, and provides no pre-settlement approval function.

Paradigm and Hyperliquid raised the same objection in June, warning that treating smart contract interactions as issuer services would hold issuers responsible for transfers they cannot see clearly or realistically stop.

The group’s strongest support comes from the agencies themselves. The preamble states that smart contract interaction does not currently give an issuer the information needed to verify an identity and describes the resulting obligations as “nearly impossible” in scope.

Two Carve-Outs to the Definition of an Account

The proposal defines an account by reference to a formal relationship between issuer and customer, an approach borrowed from existing CIP rules for banks, broker-dealers, and futures intermediaries. The Blockchain Association supports that structure while asking for four exclusions, which fall into two pairs.

The first pair concerns relationships the group says should not count as accounts at all. One-off redemptions from non-account holders should not create an account, the letter argues, drawing an analogy to check-cashing and money-order purchases, which existing bank rules already exclude. Vendor and service-provider relationships—market data, Oracle services, blockchain infrastructure, analytics—should not qualify either, on the grounds that procurement is not financial intermediation.

Two Asks About Double Coverage

The second pair concerns customers who are already identified under some other regime.

Read literally, the proposal treats provision of digital asset services as creating an account while defining a digital asset service provider broadly enough to cover exchanging, transferring, or holding digital assets. Combined, that would make every exchange customer a CIP account holder of the issuer whenever a single legal entity does both jobs.

The letter notes that those customers already fall under whatever Bank Secrecy Act regime governs exchanges and that the reading produces an asymmetry: identical trading services would carry a general CIP obligation only where the provider also issues a stablecoin. It points to 12 U.S.C. § 5903(a)(7)(B), where Congress contemplated that an issuer might also be a service provider, as evidence the merger was not intended. FinCEN and OFAC’s April proposal already treats issuers as financial institutions under the Bank Secrecy Act.

The fourth ask concerns redemptions submitted through an exchange on a customer’s behalf. The proposal already excludes those who redeem by means other than directly to the issuer. The Blockchain Association wants the final rule to state explicitly that the exchange is the party involved and that this holds even where identifying information about the underlying customer reaches the issuer in the process.

The Bank Comparison

Under the 2003 CIP rule, a bank relying reasonably on another institution’s identity verification is not held responsible if that institution fails. The preamble to this proposal says an issuer remains responsible for its own compliance, which the Blockchain Association reads as leaving issuers exposed where banks are not. The letter says no rational justification exists for the difference and asks that the final rule extend the same protection.

Zero-Knowledge Proofs

The agencies declined to write regulatory text on verifiable credentials and digital identity, preferring to leave the method open, and asked for comment on the approach.

The Blockchain Association endorsed that flexibility and named zero-knowledge proofs specifically: a customer supplies cryptographic proof of satisfying identification predicates without transmitting underlying personal data to the issuer. The letter argues such proof can be mathematically sound and auditable and, in some cases, more reliable than checking a customer’s details against a public database.

It also asks that issuers be permitted to obtain taxpayer identification numbers from third-party sources rather than directly from customers, pointing to a July 2025 exemption order the Federal Reserve and FinCEN issued for banks.

State Issuers and Timing

Section 4(c) of the GENIUS Act lets issuers with no more than $10 billion outstanding opt into state regulation where the state regime is substantially similar to the federal framework. The proposal would not permit federally regulated issuers to rely on identity checks performed by state-qualified issuers, a disparity the agencies acknowledged. The letter asks them to revisit that once Treasury finalizes its substantially similar rulemaking.

On timing, the group asks that the compliance date match that of the separate FinCEN and OFAC rulemaking on AML and sanctions programs, published April 10. That proposal supplies definitions this rule depends on, including what constitutes a permitted payment stablecoin issuer. The structural complaint is not new: banking groups argued in April that the GENIUS rulemakings were inextricably tied to an unfinished OCC framework and asked for comment deadlines to be pushed accordingly.

Also Read: GENIUS Deadline Missed, CLARITY Act Stalls on Ethics: USA’s 2 Crypto Laws Stuck

Disclaimer: The information researched and reported by The Crypto Times is for informational purposes only and is not a substitute for professional financial advice. Investing in crypto assets involves significant risk due to market volatility. Always Do Your Own Research (DYOR) and consult with a qualified Financial Advisor before making any investment decisions.

Follow The Crypto Times on Google News to Stay Updated!      Google News

Daily Crypto Puzzles
Tickerdle Tickerdle Crypto Connections Crypto Connections Crypto Crossword Crypto Crossword
TAGGED:BlockchainStablecoin
Share This Article
Whatsapp Whatsapp LinkedIn Telegram Copy Link

Daily Crypto Puzzles

Tickerdle crypto game Tickerdle Crypto Connections game Crypto Connections Crypto Crossword game Crypto Crossword

Latest News

CZ Warns Ledger Users as Mt. Gox Chief Reports Hidden Chip in His Device
CZ Warns Ledger Users as Mt. Gox Chief Reports Hidden Chip in His Device
BTC price
Bitcoin Price Today: BTC Holds Near $82.8K After Volatile Week and $86M Ledger-Linked Losses
Hunter Biden’s $LAPTOP Post-Mortem: What Went Wrong With the Token Launch
Coinbase blue block logo next to a Morgan Stanley black block logo.
Coinbase Stock Surges 5.4% as Morgan Stanley Raises Price Target to $258
Physical NEAR Protocol token coin standing in front of illuminated NEAR Protocol wall signage.
NEAR Says Accounts Support ML-DSA Post-Quantum Signatures

Find Us on Socials

You may also like

Polkadot pink icon and white lettering on a pink and purple gradient background.

DOT Rises Over 6% as Network Launches dotUSD Stablecoin

Alex Mashinsky speaking into a microphone while wearing a Celsius Network hoodie.

Celsius Founder Alex Mashinsky Faces Up to $35M Under NY Settlement

Cantor Fitzgerald and Tether logos side-by-side on a light gradient background.

U.S. Senator Questions Cantor Fitzgerald Over Tether’s Iran-Linked USDT Activity

Official seal of the U.S. Securities and Exchange Commission mounted on a light wood wall

SEC to Discuss Crypto Assets at November 19 National Compliance Seminar

The Crypto Times Logo PNG

News

All News
Market News
Bitcoin News
Ethereum News
Altcoin News
Regulations & Policies
DeFi News
Blockchain News
Industry News

Sections

Exclusive
Opinions
Learn
Insights
Videos
Glossary

India Premium Indices

Stablecoins
USDT
USDC

Play

Daily Crypto Puzzles
Tickerdle
Crypto Connections
Crypto Crossword

Company

About Us
Our Authors
Masthead
Editorial Policy
AI Policy
Advertorial Policy
Contact Us
Career

Follow Us

X-twitter Linkedin Telegram Youtube Instagram
© 2026 The Crypto Times | Protocols And Tokens Pvt Ltd.
DMCA.com Protection Status
  • Terms and Conditions
  • Disclaimer
  • Privacy Policy
  • Cookie policy
Do Not Sell or Share My Personal Information