Anchorage Digital has publicly backed the US Treasury‘s joint proposal from FinCEN and OFAC aimed at putting into effect the anti-money laundering (AML) and sanctions elements of the GENIUS Act. Submitted on June 9, 2026, the company’s detailed comment letter highlights how these measures strike a practical balance between national security protections and feasible compliance for stablecoin issuers.
The GENIUS Act establishes a comprehensive federal structure for payment stablecoins, with compliance rules expected to play a pivotal role in maintaining the U.S. dollar’s global dominance and positioning America as the premier hub for dollar-pegged stablecoin creation.
Anchorage Digital acknowledges the agencies for aligning the new requirements as closely as possible with the longstanding Bank Secrecy Act framework.
This approach focuses AML-related duties—such as transaction monitoring, customer due diligence, and suspicious activity reports—primarily on the initial issuance or “primary market,” where issuers maintain direct relationships and visibility into counterparties.
In contrast, sanctions compliance extends throughout the entire lifespan of a stablecoin, reflecting the decentralized nature of secondary trading.
According to a blog post from Anchorage Digital Bank (ADB), this division of responsibilities is well-designed because it assigns duties to areas where regulated entities can realistically fulfill them, all while advancing key policy goals around illicit finance prevention.
The letter emphasizes that such a targeted strategy avoids overburdening issuers with impractical expectations in open secondary markets, where they lack full control or insight.
To enhance clarity and effectiveness, Anchorage Digital urges several specific refinements in the final rule.
First, regulators should confirm that issuers will not face strict liability for failing to independently detect sanctioned parties engaging in secondary-market transactions via the issuer’s smart contracts.
Second, a unified, organization-wide AML/CFT and sanctions compliance program should suffice to meet both GENIUS Act mandates and those from an entity’s primary supervisor.
Third, institutional stablecoin clients should not automatically be treated as correspondent accounts, which would trigger more intensive oversight.
These adjustments, ADB argues, would deliver the regulatory predictability essential for institutions to invest confidently in building next-generation payment and settlement systems.
A clear, operational final rule would reinforce U.S. leadership in financial innovation while safeguarding against risks.
Anchorage Digital currently supports a range of stablecoins on behalf of partners, including USAT with Tether, USDtb with Ethena, USDPT with Western Union, fUSD with Falcon Finance, and USDGO with OSL Group.
The firm anticipates qualifying as an authorized payment stablecoin issuer once the full GENIUS Act regime takes hold.
As a federally chartered crypto focused bank in the United States, Anchorage Digital brings extensive expertise to this discussion.
The company provides institutional services in trading, custody, staking, and stablecoin issuance, backed by top-tier investors and operating across multiple global locations with various regulatory licenses.
Industry professionals now generally view this comment letter as a constructive contribution to ongoing rulemaking.
By supporting the proposal’s foundational design while seeking targeted improvements, Anchorage Digital helps shape a regime that promotes responsible growth in stablecoins.
Anchorage Digital has concluded that as the Treasury moves toward finalizing these rules, continued dialogue with stakeholders will be crucial for achieving a framework that bolsters innovation, compliance, and America’s competitive edge in digital finance.