Manhattan, NYC | December 8, 2025 — The Stablecoin Standards Authority (SSA) today announced the submission of a Petition for Regulatory Action to the U.S. Department of the Treasury (including FinCEN), the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency (OCC), the Federal Deposit Insurance Corporation (FDIC), and the National Credit Union Administration (NCUA).
SSA’s petition, filed under the Administrative Procedure Act, the Bank Secrecy Act (BSA), and the GENIUS Act, calls for coordinated federal action to ensure that the emerging U.S. payment stablecoin framework is implemented consistently and credibly across issuers and the settlement infrastructure on which payment stablecoins depend.
The Stablecoin Standards Authority (SSA) is an independent standards platform within the Federal Money Services Business Association (FedMSB) dedicated to strengthening the reliability, governance, and transparency of U.S. dollar–denominated stablecoins. SSA is designed to support stablecoin issuers, money services businesses (MSBs), financial institutions, and technology providers with a clear, professionally vetted framework for operating across payments, remittances, settlements, and emerging decentralized finance (DeFi) use cases.
A Petition Focused on a Coherent, Risk-Based U.S. Stablecoin Perimeter
With the GENIUS Act now enacted as federal law, SSA’s petition underscores the importance of implementing a federal stablecoin regime that supports responsible innovation, preserves competitive neutrality, and strengthens both prudential soundness and financial integrity.
SSA notes that recent public commitments by federal prudential and financial integrity authorities—alongside broader supervisory reforms—emphasize:
- a shift away from process-driven oversight toward core, material risks;
- clearer space for banks and credit unions to support responsible innovation within a defined regulatory perimeter; and
- a risk-based approach that avoids vague “reputational risk” rationales for politicized or arbitrary “debanking.”
The petition states that these principles should be applied consistently to stablecoins with a material U.S. nexus.
Key Concerns Addressed in the Petition
SSA’s petition identifies two interrelated risks to the credibility and effectiveness of the GENIUS framework:
1) Large Offshore U.S. Dollar–Referenced Stablecoin Arrangements
SSA argues that continued inaction toward large, offshore, U.S. dollar–referenced stablecoin arrangements, and in particular USDT and its related issuing entities (collectively, the “USDT Issuer”), is difficult to reconcile with the goals of GENIUS and the BSA.
The petition’s core premise is stated plainly:
- No private issuer should be permitted to operate a globally circulating, dollar-branded quasi-bank—holding large pools of dollar-denominated assets, promising par-value redemption, and intermediating cross-border flows—outside meaningful U.S. prudential supervision and BSA/AML and sanctions oversight.
2) Settlement-Layer Anonymity
SSA also identifies a structural implementation gap: the absence of a federally standardized requirement to identify and supervise the settlement-layer nodes that validate, sequence, settle, or route payment stablecoin transactions.
To address this gap, SSA calls for rulemaking to establish On-chain Node KYC and a federally administered Node Registry for payment stablecoin settlement infrastructure with a material U.S. nexus.
CIFB Doctrine Provides Strategic Context
The petition situates its recommendations within the strategic doctrine articulated by FedMSB in its white paper, “U.S. National Digital Currency Sovereignty Centennial Strategy,” which introduces:
CIFB — Clearing Illegal Financial Black Markets
As the white paper states:
“To legitimate and globalize this doctrine, we introduce CIFB—Clearing Illegal Financial Black Markets—as the strategic banner for international alignment and domestic enforcement. CIFB is to digital finance what counterterrorism was to post-9/11 geopolitics: a moral, strategic, and operational doctrine. This is not about suppressing innovation—it is about removing the underworld reefs on which lawful innovation may run aground.”
SSA’s petition applies this doctrine to large offshore dollar-referenced stablecoin arrangements and to the settlement-layer risks that may facilitate illegal financial black markets.
Requested Actions
SSA respectfully requests that Treasury, FinCEN, the Federal Reserve, the OCC, the FDIC, and the NCUA take coordinated action to:
- Affirm the scope and application of GENIUS and the BSA to dollar-referenced stablecoin activities with a material U.S. nexus.
- Reflect these principles in upcoming GENIUS implementation rules, including clear criteria for permitted and registered foreign issuer status and guidance on exposures to non-permitted arrangements.
- Conduct a coordinated, cross-border review of the USDT Issuer, focusing on reserves, governance, financial-integrity controls, and potential spillover channels.
- Issue a FinCEN advisory and interagency guidance treating USDT and similarly situated arrangements as high-risk instruments for AML/CFT and sanctions purposes.
- Maintain a public, interagency registry of licensed and approved payment stablecoin issuers under the GENIUS framework.
- Establish On-chain Node KYC and a federally administered Node Registry to ensure settlement infrastructures for payment stablecoins with a material U.S. nexus are regulated, identifiable, and subject to continuous supervisory visibility.
SSA Statement
“SSA’s petition is designed to support a safe, credible, and competitive U.S. stablecoin ecosystem,” said Peter Tang, member of the SSA Steering Board. “We support GENIUS implementation that provides clarity for responsible innovation while ensuring that large, offshore, dollar-referenced stablecoin arrangements with substantial U.S. nexus do not remain outside meaningful prudential, BSA/AML, and sanctions oversight. We also believe the effectiveness of the GENIUS perimeter depends on addressing settlement-layer anonymity through On-chain Node KYC and a federally administered Node Registry.”
About the Stablecoin Standards Authority (SSA)
The Stablecoin Standards Authority (SSA) is an independent standards platform within the Federal Money Services Business Association (FedMSB) dedicated to strengthening the reliability, governance, and transparency of U.S. dollar–denominated stablecoins.
SSA’s mission is to develop evidence-based technical, compliance, governance, and transparency standards for U.S. dollar stablecoins; promote interoperability, sound risk management, and market integrity in the evolving digital-dollar ecosystem; and serve as a neutral forum for collaboration on best practices, education, and voluntary certification. SSA is not a regulatory agency and does not exercise supervisory or enforcement powers; it complements formal licensing and public-sector frameworks by providing implementation-level guidance for market participants.
For the full petition text, please refer to: