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.

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.

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