Anchorage Digital Policy Library: Comment Letters & Perspectives

Stablecoins are becoming a core part of how money moves — and the rules for how they're regulated are being written right now. Anchorage Digital, home to America's first federally regulated stablecoin issuer, works directly with the regulators writing those rules. Below is where we're weighing in, in plain terms, and why it matters.

GENIUS Act Implementation

The GENIUS Act is the new federal law governing stablecoins. Regulators are now writing the detailed rules that will implement it, and we're commenting on each one as it comes up.

Customer identification rules (FinCEN) — Submitted August 21, 2026 Regulators proposed rules requiring stablecoin issuers to verify who their customers are, similar to standard bank "know your customer" requirements. Anchorage Digital Bank, N.A. weighed in to help ensure these rules work in practice for how stablecoins operate. 🔗 Read our comment letter

Anti-money laundering & sanctions rules (Treasury/FinCEN/OFAC) — Submitted June 9, 2026 This rule sets out how stablecoin issuers should screen for illicit activity and enforce sanctions. We support the core approach. Regulators smartly focused monitoring obligations on the primary issuance relationship rather than trying to track every downstream trade and asked for a few clarifications so issuers aren't held responsible for things outside their control, like anonymous secondary-market transfers. 🔗 Read our comment letter

Stablecoin issuance rules (OCC) — Submitted May 1, 2026 As the first federally regulated stablecoin issuer, we responded to the OCC's core rulebook for how banks like ours issue stablecoins. Our letter explains how holding reserve assets in separate legal trusts already delivers the safeguards regulators want, and pushes back on rigid one-size-fits-all reserve rules and an automatic seven-day redemption freeze that could actually trigger the kind of run it's meant to prevent.  🔗 Read our comment letter

Getting Fair Access to the Federal Reserve

National Ttrust  banks like Anchorage Digital Bank have historically had a harder path to basic Federal Reserve services than banks with federally insured deposits — even though we're regulated by the same federal agency, under the same laws, and do not lend. Granting national trust banks full access to a fed master account enhances financial stability, levels the playing field, and helps expedite financial systems to evolution to digital assets and blockchains. 

A National Trust Bank Is a National Bank — Submitted July 29, 2026, Federal Reserve The Fed proposed a stripped-down "Payment Account" for banks like ours instead of full account access. We support modernizing access, but pointed out that an account with no ability to move money through the most useful payment rails, tight balance caps, and no interest isn't a real substitute for the account other national banks have had for a century. 🔗 Read our comment letter

Companion letter on interest for Payment Accounts — Submitted July 2026, Federal Reserve A follow-up letter reinforcing many of the points we made in the first letter above to the Federal Reserve.  🔗 Read our comment letter

Executive Perspectives

GENIUS Worked. Now Congress Is Stalling on the Sequel — But China's Not Waiting By Nathan McCauley, Co-Founder & CEO — Washington Examiner, July 18, 2026 One year after GENIUS passed, McCauley argues Congress needs to finish the job with the CLARITY Act and  extend the same clear rules to exchanges, broker-dealers, and custody — or risk falling behind China and Russia.

America Doesn't Need a Second-Class Payments System By Rachel Anderika, Head of Global Operations — CoinDesk, August 12, 2026 Drawing on her experience as a former OCC bank examiner, Anderika makes the case that the Fed's "skinny" account proposal doesn't solve the real problem: banks like ADB still depend on other banks just to move money.

The Dollar's Next Battlefield Isn't a Country. It's Code. By Dustin Palmer, Bank Secrecy Act Officer — The Cipher Brief, August 13, 2026 Palmer argues that as China and Russia build their own state-backed digital currencies, bringing dollar stablecoin activity onshore, under U.S. supervision strengthens America's ability to track and freeze illicit money, not weaken it.