Comment from Anchorage Digital Bank

Summary: Anchorage Digital Bank, a federally chartered bank and stablecoin issuer, supports the proposed risk-based approach to AML and sanctions compliance for payment stablecoin issuers. The commenter requests specific clarifications to ensure that secondary market sanctions obligations are not interpreted as a strict liability duty to independently identify every blocked person, but rather as a risk-based requirement to maintain technical capabilities and reasonable internal controls.