#BPIUrgesFinCENExpandStablecoinIDRulesToSecondaryMarkets
The rulebook for stablecoins isn't finished yet — and the biggest banks in the country just asked regulators to make it apply somewhere it currently doesn't: decentralized markets.
The Bank Policy Institute, representing major lenders including JPMorgan, Bank of America, Wells Fargo, and Citi, submitted a comment letter to FinCEN arguing that customer identification requirements should extend beyond stablecoin issuers to the secondary market — meaning exchanges, other platforms with direct retail relationships, and what the letter calls "decentralized market participants." The current proposal, part of rulemaking under the GENIUS Act, applies Bank Secrecy Act identity checks primarily to issuers themselves, while explicitly excluding purely secondary-market activity such as smart-contract-only transfers, since FinCEN itself noted that expanding the requirement further would be "practically challenging" given how blockchain transactions work. BPI's position is that most illicit-finance risk actually surfaces after tokens leave an issuer's direct control, making that exclusion a meaningful gap.
This matters because it sits at the center of an unresolved tension in crypto policy: how far identity-verification rules should reach once an asset moves onto open, permissionless infrastructure. If regulators lean toward BPI's view, it could reshape compliance expectations for exchanges and DeFi platforms alike.
Where should the line sit between preventing illicit finance and preserving the open nature of secondary crypto markets?

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