TrustLogic

July 23, 2026 Chief Counsel's Office Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219 Submitted via regulations.gov Re: Informational Comment on Conforming Amendments to Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance Requirements for Permitted Payment Stablecoin Issuers (91 Fed. Reg. 37,840, June 24, 2026) Dear Sir or Madam: Right now, if a stablecoin issuer decides a specific transaction was fraudulent or violated sanctions rules, the only real tool available is to freeze or claw back funds the recipient already fully owns. That works, but it is legally awkward, because the recipient did legitimately receive full ownership at the time of transfer. Undoing it after the fact looks a great deal like taking someone's property. There is a cleaner way to structure this. Instead of giving the recipient full, unconditional ownership immediately, an issuer can give them a clearly disclosed, revocable right to the funds from the moment of transfer, with everyone involved knowing upfront that the right can be revoked under defined conditions. If regulators later determine a transaction needs to be unwound, nothing is seized. The issuer simply does not finalize a right that was conditional from the start. This comment is not a request or a proposal. It is submitted only to make clear that this kind of structure already exists and is technically workable today. We are glad to walk through it further if that would be useful to the agency's consideration of this rulemaking. This is relevant here because the request for comments is specifically asking how compliance programs should handle situations discovered after a payment has already gone through. Right now, most answers to that question describe freezing or reversing money that someone already fully owns. The structure described above gives the OCC a third option to consider: a way of arranging ownership so that recovering funds later does not require overriding anyone's property rights in the first place, only declining to finalize a right that was disclosed as conditional to begin with. We share it only so it is part of the public record as an available option, not because we believe it should be required. Respectfully submitted, Amy Leigh Pearson Founder, TrustLogic a.pearson@trustlogic.global