TRM Labs submitted a comment to FinCEN and OFAC on the joint proposed rule for AML/CFT and sanctions compliance under the GENIUS Act for permitted payment stablecoin issuers. The core argument is that stablecoins represent a compliance opportunity due to their transparent, traceable, and programmable nature on public blockchains, offering enforcement capabilities superior to traditional finance. According to TRM data, less than 0.5% of stablecoin transactions were illicit in 2025, and sanctions-related activity dropped 60% year-over-year. Key technological advantages include permanent on-chain audit trails, AI-powered intelligence tools that compress investigative time, real-time alert systems like the Beacon Network linking law enforcement with institutions covering 85% of centralized crypto volume, and freeze-burn-reissue authority. TRM emphasizes that freeze-burn-reissue is the most powerful enforcement tool but lacks clear legal standards for reissuance of clean value to victims, urging the final rule to expand provisions for this capability. The April 2026 freeze of $344.2 million in USDT linked to Iran's Central Bank and the T3 Financial Crime Unit's $450 million in freezes across 23 jurisdictions demonstrate operational scale.

Key facts

• Less than 0.5% of stablecoin transactions were illicit in 2025.
• Sanctions-related stablecoin activity fell 60% year-over-year.
• TRM advocates freeze-burn-reissue with clear reissuance standards.
• April 2026 freeze of $344.2M USDT linked to Iran's Central Bank.
• T3 Financial Crime Unit froze $450M across 23 jurisdictions.