The American Fintech Council (AFC) has submitted a formal letter to the Federal Deposit Insurance Corporation urging it to adopt a coordinated, risk-based framework for anti-money laundering and counter-terrorism financing compliance as it implements the GENIUS Act’s rules for payment stablecoin issuers.
The letter, dated 5 August 2026, responds to the FDIC’s Notice of Proposed Rulemaking on Bank Secrecy Act and sanctions compliance standards for what the Act designates as permitted payment stablecoin issuers (PPSIs). The AFC, which describes itself as the largest US trade association for fintech firms and innovative banks, represents over 150 member companies and is a regular respondent to federal financial rulemaking.
What the AFC is asking for
The AFC’s core ask is regulatory alignment: it wants the FDIC to integrate its supervisory expectations with the relevant Treasury and Financial Crimes Enforcement Network (FinCEN) requirements rather than layering additional, potentially duplicative obligations on top of existing federal AML/CFT rules. The group argues that PPSIs should be able to rely on enterprise-level compliance infrastructure already built to meet applicable federal standards.
AFC chief executive Phil Goldfeder argued that a coordinated framework serves both the safety objective and the clarity objective. “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,” he said.
The letter also presses for technology neutrality in supervisory expectations, specifically calling out blockchain analytics, wallet screening and transaction tracing as tools that should be permissible within a performance-based framework rather than prescribed or excluded by rule. The AFC further calls for enforcement standards that separate material programme failures from isolated and remediable deficiencies, a distinction that matters considerably to firms that may face novel fact patterns in a still-maturing asset class.
On procedural safeguards, the AFC advocates for a mandatory FinCEN consultation requirement before the FDIC takes significant AML/CFT supervisory action, alongside narrow information-sharing protections preserving attorney-client privilege and attorney work product in supervisory communications.
Regulatory path and market context
The GENIUS Act, passed in 2026, established the first comprehensive federal licensing framework for payment stablecoins in the United States. Its implementation through agency rulemaking is now the central battleground for how strictly the compliance regime will be calibrated. The AFC’s letter reflects a broader industry concern that multiple overlapping supervisory authorities, FDIC for bank-chartered issuers, state regulators for non-bank issuers, FinCEN for BSA obligations and the Office of Foreign Assets Control for sanctions, could produce fragmented and inconsistent demands.
That concern is well-founded by precedent. The compliance layer for digital-asset firms in the US has historically been assembled piecemeal, with firms receiving inconsistent guidance depending on their charter and business model. For stablecoin issuers specifically, where the transaction volumes and counterparty diversity can rival those of mid-tier banks, the cost of duplicative compliance obligations is not trivial.
The AFC’s position mirrors arguments made by European stablecoin issuers engaging with the Markets in Crypto-Assets regulation, where the emphasis on proportionate, risk-based supervision became a recurring lobbying theme during the MiCA technical standards process. Whether the FDIC’s final rule reflects that framing will be a significant signal for how broadly the US intends to compete for regulated stablecoin activity.
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