The Blockchain Association submitted a comment letter on August 21 urging federal regulators to limit proposed know-your-customer requirements for permitted payment stablecoin issuers, or PPSIs, to primary-market transactions. The proposal from FinCEN (Financial Crimes Enforcement Network), the Federal Reserve and other federal agencies would establish customer identification program, or CIP, requirements under the GENIUS Act, signed on July 18, 2025 as the first comprehensive U.S. federal framework for payment stablecoins. The Association broadly supports issuer KYC but says obligations should apply only when an explicit contractual relationship exists, such as the direct minting or redemption of stablecoins. It argues issuers should not be responsible for identifying users who acquire stablecoins through decentralized exchanges or smart contracts (self-executing blockchain code). The group also supports zero-knowledge proofs (privacy-preserving identity verification) as a way to satisfy CIP requirements and asks agencies to coordinate their compliance deadlines, including those set for August 2026.