Blockchain Association Backs Stablecoin Rules Exempting Peer-to-Peer Transfers

Summary

• Blockchain Association supports limiting stablecoin identity checks to direct issuer-customer relationships while excluding ordinary peer-to-peer secondary-market transfers from compliance duties.
• The industry group wants clearer definitions for accounts, customers, and digital asset providers to prevent unnecessary identification and reporting burdens.
• Coordinated deadlines for customer identification and anti-money laundering rules could help issuers build compatible compliance systems.

The Blockchain Association has backed joint federal rules exempting peer-to-peer stablecoin transfers from customer identification requirements imposed on regulated issuers. Its position supports limiting identity checks to transactions between permitted stablecoin issuers and customers who use their services directly.

The association submitted its comment letter before the public consultation period closed on August 21, completing the industry group’s response. FinCEN, the Federal Reserve, the OCC, the FDIC, and the NCUA jointly proposed the identification rules under consideration.

Peer-to-Peer Transfers Should Remain Outside Issuer Obligations

According to the Blockchain Association, verification should apply when customers purchase stablecoins directly or return their tokens through established issuer redemption channels. However, it opposes extending those responsibilities across secondary markets where issuers maintain no direct commercial relationships with individual participants.

Such requirements could force regulated issuers to identify people using independently operated wallets, cryptocurrency exchanges, or decentralized finance platforms. Moreover, issuers may lack the information and operational authority required to monitor every downstream transaction involving their payment stablecoins.

The association argued that broader obligations could create impractical compliance burdens without materially improving oversight of direct customer relationships.

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Clear Definitions and Coordinated Deadlines Remain Important

Beyond secondary-market transfers, the association requested clearer definitions covering an account, customer, and digital asset service provider within regulations. Those definitions could determine whether isolated transactions establish formal commercial relationships requiring an issuer to complete customer identification procedures.

Consequently, the group recommended excluding one-time redemptions and activities unrelated to regular stablecoin issuance, distribution, or customer services. It also urged regulators to prevent overlapping requirements that could force compliant issuers to repeat identical verification and reporting procedures.

Furthermore, stablecoin businesses should retain reasonable flexibility when selecting suitable methods for verifying customer information across different operating structures. The association recommended coordinating these identification rules with separate anti-money-laundering regulations required under the broader GENIUS Act framework.

According to the Blockchain Association on X, implementation should preserve strong safeguards, workable rules, and room for responsible financial innovation. Aligned implementation dates could help issuers develop compatible compliance systems and avoid operational conflicts among closely related federal requirements.

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