Andreessen Horowitz Calls for Limiting Stablecoin Customer Verification to Primary Market

Andreessen Horowitz (a16z) has argued that the customer identification program (CIP) for U.S. stablecoin issuers should be limited to primary market activities that have a direct relationship with the issuers. There is a divide in the crypto industry and banking sector regarding whether secondary market users or transfers between wallets should be considered part of the issuers' customer verification targets. The comment letter submitted on August 21 included case numbers 'FINCEN-2026-0101 / OCC-2026-0331 / RIN 1557-AF53'. Andreessen Horowitz interprets the Bank Secrecy Act (BSA) as requiring customer verification to be linked to 'account opening', arguing that expanding the customer verification target to include secondary market users who do not have a direct account relationship with the issuers lacks legal basis and does not reflect market realities. Furthermore, it stated that the definition of 'account' should be narrowed, and that receiving tokens through third-party transfers or freezing, burning, or seizing tokens under legal orders should not automatically create an account relationship. It also argued that there is no need to onboard one-time payers as account customers. However, it added that this does not mean such transactions are exempt from money transfer rules, travel rules, suspicious transaction reporting, or scrutiny by the Office of Foreign Assets Control (OFAC). Regulators have stated that this rule applies similar customer verification requirements to stablecoin issuers as those for banks and credit unions. The industry is calling for separate technical standards and explicitly allowing mobile IDs, biometric data, and zero-knowledge proofs (ZKP) in the regulations.