CTF Written Submission

Re: AML/KYC Compliance Requirements for Peer-to-Peer Transactions of YLDS

May 16, 2025
  • FCC is not required to perform AML/KYC on counterparties to peer-to-peer transactions involving YLDS, as FCC is not a "financial institution" under the Bank Secrecy Act (BSA) and FinCEN regulations.
  • Even if FCC were subject to BSA/AML requirements, peer-to-peer transaction counterparties are not considered "customers" of FCC under the relevant FinCEN rules applicable to mutual funds.
  • Requiring FCC to perform AML/KYC on peer-to-peer transaction counterparties would impose significant compliance costs and place FCC at a competitive disadvantage compared to other stablecoin issuers.

Last Reviewed or Updated: May 16, 2025