Points of Focus

• Anchorage supports the Treasury’s stablecoin rules but wants limits on issuer liability for secondary-market transactions.
• The GENIUS Act’s stablecoin framework must be finalized by July 2026.
• Anchorage said demand for stablecoin issuance has surged since the law was passed.

Anchorage Digital, the only federally chartered crypto bank in the United States, submitted a public comment letter this week backing the Treasury Department’s proposed Anti-Money Laundering (AML) and sanctions compliance framework for the GENIUS Act. The crypto bank also called on regulators to clarify one structural ambiguity that it argues could expose compliant issuers to disproportionate legal risk.

The joint proposed rule, issued by the Financial Crimes Enforcement Network (FinCEN) and the Office of Foreign Assets Control (OFAC) in April, aligns stablecoin issuers with existing AML and sanctions compliance standards and imposes enhanced monitoring and recordkeeping obligations. Anchorage said the framework largely strikes the right balance between compliance and innovation.

Anchorage Digital generally supports the approach @FinCENnews and @USTreasury’s OFAC are taking to implement GENIUS Act’s AML and sanctions provisions.

Our comment letter, submitted today, outlines why.

— Anchorage Digital ⚓️ (@Anchorage) June 10, 2026

Its specific objection concerns secondary-market activity. Anchorage argued that regulated issuers should not face strict liability for failing to independently identify sanctioned users who transact on secondary markets through their smart contracts, a scenario the bank said is operationally outside an issuer’s direct control and should not carry the same compliance burden as primary issuance.

Hyperliquid and Paradigm also filed comment letters raising secondary-market concerns, though both took a more critical view of the proposal overall than Anchorage.

The commercial position behind the compliance argument

The comment letter is not filed from a neutral position. Anchorage has built its entire post-GENIUS Act strategy around being the regulated infrastructure layer for institutional stablecoin issuance.

The firm launched a GENIUS Act-compliant stablecoin fund with State Street in May, partnered with Ethena Labs to bring USDtb onshore under its Office of the Comptroller of the Currency charter, and supports stablecoins including Tether’s USDt (USDT), Ethena’s USDtb, Western Union’s USDPT, and OSL’s USDGO.

Anchorage Digital CEO Nathan McCauley stated at Consensus Miami in May that the company has won every large stablecoin issuance mandate since the GENIUS Act passed, with up to 20 financial institutions and large technology companies currently in its pipeline. Strict secondary-market liability rules would raise the compliance cost of that entire mandate pipeline and create legal exposure that no amount of internal controls can fully eliminate.

Treasury’s framework under Scott Bessent

Treasury Secretary Scott Bessent framed the April proposed rule as strengthening American leadership in digital financial technology while protecting the financial system from national security threats.

The GENIUS Act itself requires stablecoin issuers to maintain 1:1 reserves in US dollars or liquid equivalents such as Treasury bills, with annual audits mandatory for issuers exceeding $50 billion in supply. Final implementation guidelines must be in place by July 2026.