Anchorage Backs GENIUS AML Rules, Seeks Clear Scope

TLDR

• Anchorage submitted a public comment letter supporting Treasury’s GENIUS AML proposal.
• The firm backed classifying stablecoin issuers as financial institutions under the Bank Secrecy Act.
• Anchorage urged clarity on secondary-market sanctions liability tied to smart contract transactions.
• It argued issuers should not face strict liability for unknown sanctioned users on open networks.
• The proposal was issued jointly by FinCEN and the Office of Foreign Assets Control.

Anchorage Digital has backed the US Treasury’s proposed GENIUS AML framework while urging targeted clarifications. The federally chartered crypto bank submitted a public comment letter supporting core compliance provisions. However, it asked regulators to refine secondary-market sanctions exposure and enterprise-wide AML expectations.

Anchorage and GENIUS AML Framework Alignment

Anchorage stated that Treasury’s proposal places AML duties on regulated stablecoin issuers in a workable manner. The firm said the structure balances compliance standards with operational certainty for issuers. It added that clear rules will support payment innovation while maintaining oversight under existing law.

The letter responded to rules issued in April by the Treasury and the Financial Crimes Enforcement Network. The proposal would classify payment stablecoin issuers as financial institutions under the Bank Secrecy Act. As a result, issuers would face AML, customer due diligence, and suspicious activity reporting obligations.

Treasury’s Office of Foreign Assets Control joined FinCEN in issuing the proposed rule. The framework would align stablecoin issuers with US sanctions compliance standards. It would also impose enhanced monitoring and recordkeeping duties across issuer operations.

The firm said such clarity strengthens US leadership in payments and settlement infrastructure. It therefore endorsed the proposal’s general direction while requesting precise adjustments.

Secondary-Market Sanctions and Compliance Scope

Anchorage urged Treasury to clarify liability tied to secondary-market transactions on public blockchains. It argued that issuers should not bear strict liability for unknown sanctioned users. The firm said smart contract interactions may occur without issuer knowledge or direct customer relationships.

Anchorage stated that issuers cannot independently identify all sanctioned actors transacting through open networks. It therefore asked regulators to define limits around secondary-market sanctions exposure. The letter also sought guidance on enterprise-wide AML programs and correspondent account requirements.

The firm requested clarity on how AML obligations apply across affiliated entities. It asked Treasury to outline expectations for correspondent relationships under the proposed framework. According to the letter, defined boundaries would reduce uncertainty for regulated institutions.

Support for the GENIUS AML proposal has varied across the crypto industry. Hyperliquid and Paradigm also submitted a joint comment letter addressing similar concerns. However, they expressed a more critical view of the sanctions perimeter.

The groups argued that OFAC’s draft language extends issuer liability beyond practical visibility. They said the framework treats smart contract use as an ongoing service provision.

They added that the draft could impose sanctions duties without direct user relationships. The comment letter said issuers may lack visibility into parties transacting on secondary markets. Treasury has not yet issued a final rule following the April proposal.

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