Notabene Response to PPSI AML/CFT and Sanctions NPRM

Notabene filed its response to FinCEN and OFAC’s joint PPSI AML/CFT and sanctions compliance NPRM, Docket FINCEN-2026-0100. The response supports codified Travel Rule and recordkeeping obligations for permitted payment stablecoin issuers, recommends pre-transaction authorization as the right architecture for block, freeze, reject, and lawful order obligations, and encourages clear rules for secondary market activity, sanctions compliance, and international interoperability.