Osman Sonmez
Osman SonmezSupportIndividual
Summary: Osman Sonmez, an attorney and CEO of Sonmez Consulting LLC, supports the general framework of the proposed rule but suggests clarifying how sanctions compliance deficiencies will be treated. He argues that "effective" AML/CFT programs should be based on risk reasoning rather than just list-matching and advocates for maintaining the consultation process for all issuer sizes.
I respectfully submit the attached comment in my personal capacity regarding Docket ID OCC-2026-0463; RIN 1557-AF55, “Permitted Payment Stablecoin Issuer Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Risk Management.”
My comment addresses the OCC’s Questions 8, 9, and 10. It focuses on the treatment of sanctions-compliance deficiencies within the proposed supervisory framework, the meaning of an “effective AML/CFT program” for payment stablecoin issuers, and the need for the FinCEN consultation process to remain available across issuer sizes.
Thank you for the opportunity to submit this comment.
Respectfully submitted,
Osman Sonmez
Attorney at Law, Istanbul Bar Association
CEO, Sonmez Consulting LLC
Irvine, California