Blockchain Association urges exclusion of P2P transfers from stablecoin ID rules

The Blockchain Association has asked five U.S. federal agencies to clarify that the customer‑identification program (CIP) required under the GENIUS Act should apply only to direct relationships between stablecoin issuers and their customers, not to independent peer‑to‑peer (P2P) transactions.

Scope of the proposed CIP

In June 2026 the agencies – FinCEN, OCC, the Federal Reserve, FDIC and NCUA – issued a joint proposal that would require permitted payment stablecoin issuers to adopt a written, risk‑based CIP as part of their anti‑money‑laundering and counter‑terrorist‑financing controls. The rule would obligate issuers to collect a customer’s name, address, date of birth or formation date, and an identification number before opening an account, and to retain records for five years after account closure.

Blockchain Association’s position

The association supports the primary‑market identity checks but argues that the rule should not extend to downstream P2P transfers where the issuer does not intermediate the transaction. It cites the agencies’ own language that merely owning or controlling a stablecoin does not create an account, and that transfers executed solely through a smart contract are considered “secondary‑market activity.”

Key requests from the association

• Clear definitions that limit the CIP to direct issuer‑customer relationships such as issuing, redeeming, converting, repurchasing or custodial services.
• Explicit allowance for digital‑identity tools and interoperable verification methods.
• Protection against duplicate compliance work by permitting issuers to rely on checks performed by other regulated financial institutions, provided the reliance is reasonable, contractually documented and annually certified.

Regulatory timeline

The public comment period closed on August 21, 2026. Regulators will now review the submissions and may adjust definitions of “account,” “customer,” and “digital asset service provider.” Once a final rule is published, issuers would have 12 months to comply. The broader GENIUS Act framework is slated to restrict unlicensed payment stablecoin issuance nationwide on January 18, 2027.