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Anchorage Digital has backed Treasury’s proposed anti-money-laundering and sanctions rules for stablecoin issuers, while asking regulators to clarify how the framework applies once tokens move through secondary markets.
The June 9 comment letter gives FinCEN and OFAC support from a federally chartered crypto bank. It also points to a central issue in stablecoin oversight: how far an issuer’s duties extend after tokens leave direct customer channels.
Primary-Market AML Duties Draw Anchorage Support
Treasury’s proposal would treat permitted payment stablecoin issuers as financial institutions under the Bank Secrecy Act and require them to maintain sanctions compliance programs. The rule is part of the GENIUS Act implementation process.
Anchorage said the proposal draws a workable line by limiting AML monitoring, customer due diligence and suspicious activity reporting to the primary market. That is where issuers handle issuance, redemption and direct customer relationships.
Secondary Transfers Remain Harder to Police
Anchorage said it supports the primary-market approach because secondary-market transfers often happen through wallets, exchanges and smart contracts that the issuer does not control.
In those cases, the issuer may see an address and token movement, but not the person behind the transaction. That makes downstream AML monitoring harder once stablecoins move beyond direct issuer-customer channels.
Sanctions Liability is the Sticking Point
Anchorage’s main concern is sanctions exposure. The firm asked Treasury to confirm that issuers will not face strict liability for failing to independently identify sanctioned users trading stablecoins through secondary-market smart contract activity.
The company said issuers should maintain technical tools to freeze, block, burn or reject tokens when required by law, court order or OFAC designation. Anchorage argued that this is different from forcing issuers to police every downstream wallet on their own.
Risk-Based Sanctions Programs Need Clarity
Anchorage also asked regulators to treat reasonable, risk-based sanctions programs as meeting the rule when an issuer has no practical way to identify a blocked person.
That request is aimed at keeping sanctions duties tied to known identifiers and lawful orders, rather than open-ended surveillance. The firm said issuers need clarity before scaling stablecoins across open blockchain markets where tokens can move through permissionless infrastructure.
Anchorage Seeks One AML Program
Anchorage also wants Treasury to confirm that a firm acting as both a bank and a stablecoin issuer can use one enterprise-wide AML/CFT and sanctions program.
The bank said it has not found a conflict that would make compliance impossible, but asked regulators to avoid duplicate reviews and inconsistent supervisory expectations. It also asked that not every institutional stablecoin customer be treated as a correspondent account.
Final Rule Will Set Issuer Certainty
Anchorage currently issues USAT, USDtb, USDPT, fUSD and USDGO, and says it expects to become a permitted payment stablecoin issuer once the GENIUS framework takes effect.
The final rule will decide how much compliance certainty stablecoin issuers have before expanding dollar tokens across open blockchain markets.
