Board of Governors of the Federal Reserve System

I support the issuance of this proposal, which would impose customer identification program (CIP) requirements on Board-supervised payment stablecoin issuers that are similar to CIP requirements imposed on Board-supervised banks. I remain concerned, however, that the GENIUS Act regulatory framework does not do enough so far to address the risks of illicit finance conducted through secondary market transactions in payment stablecoins. While some digital asset service providers are subject to anti-money laundering and anti-terrorist financing requirements in their home jurisdiction, it is far too easy for bad actors to evade these restrictions and operate without detection when transacting in digital assets. I will carefully review comments in response to the proposal's questions regarding whether any portions of the CIP rule should be extended to secondary market activity. I will also be assessing whether overall implementation of the GENIUS Act regulatory framework beyond just the CIP rule would result in adequate protection against the use of stablecoins in illicit finance.