Anchorage Digital, a federally chartered digital asset bank, submitted a public comment letter on June 10 addressing the U.S. Treasury’s proposed anti-money-laundering (AML) rules under the GENIUS Act, explicitly voicing support for uniform compliance standards for regulated stablecoin issuers. At the same time, Anchorage raised a key demand: regulators must clarify the boundaries of an issuer’s sanctions-compliance responsibility in the secondary market — that is, after tokens leave the issuer and circulate freely across exchanges, wallets, and card networks. This marks the first time a major custodian has publicly weighed in on “how far compliance responsibility extends” now that the GENIUS Act has entered its implementation-rulemaking phase.
Editorial Take: What This Actually Means for USDT Card Users
Bottom line first — this is a comment letter, not a rule already in effect, so nothing about the card in your wallet changes within the next 7 days. But it signals a tightening direction: scrutiny of “where the coin came from” is being pushed deeper into the transaction chain.
The core dispute over secondary-market liability is this: when a USDT token passes through five layers of transfers from a sanctioned address before ultimately being deposited into your virtual card account, should the issuer — must the issuer, is the issuer even able to — trace that path? Anchorage wants regulators to draw a clear line on “how far back tracing responsibility goes.” If regulators ultimately adopt a rule that issuers are responsible for traceable secondary-market flows, downstream card providers — especially those with clearing relationships tied to compliant custodians — would be forced to move on-chain source screening earlier, to the deposit stage itself.
Across different user scenarios:
- Users of compliant exchange cards (Coinbase Card, Bybit Card) likely won’t feel anything within 30 days, but within a 90-day window, expect a higher chance of being asked to explain the source of USDT deposits — especially funds coming from mixers, P2P OTC trades, or newly generated addresses.
- Users of Asia-Pacific-routed virtual cards (MPCard Asia Elite) are less directly exposed in the short term, since their clearing isn’t directly tied to the U.S. Treasury’s GENIUS framework — but if USDT issuers themselves tighten policy, the impact spreads industry-wide.
This isn’t a call to panic — it’s a reminder that “clean on-chain fund provenance” is shifting from a nice-to-have to a baseline requirement.
Historical Comparison: Not the Same as USDC’s 2023 Depeg
Many will link this news to USDC’s brief depeg in March 2023 tied to Silicon Valley Bank risk — but the direction here is actually the opposite. That 2023 episode was a reserve-asset trust crisis, focused on “is there money backing this coin.” This discussion around GENIUS Act AML rules is a circulation-side compliance issue, focused on “whose hands has this coin passed through.”
A closer parallel is OFAC’s sanctioning of Tornado Cash in August 2022. That episode raised exactly the same question: how does protocol-level sanctions liability propagate down to downstream compliant entities. The result was that many exchanges began freezing funds flagged for “contact with a sanctioned address” as a risk-control measure, catching some compliant users’ funds in the crossfire. Anchorage’s letter is essentially saying: don’t let the 2022-style chaos of “unlimited liability propagation, blanket downstream freezes” repeat itself — please write the boundaries clearly before the rule takes shape.
Similarity: both involve the tension of sanctions compliance propagating downstream. Difference: this time there’s a statutory basis in the GENIUS Act, and a custodian is proactively pushing for clear standards before the rule takes final form, rather than reacting after the fact.
Regulatory Impact: Clearly Compliant, Gray Zone, and Clearly Prohibited
The GENIUS Act is the U.S. federal framework for payment stablecoins, and once its accompanying AML rules take effect, they will directly bind stablecoin issuers operating in the U.S. or serving U.S. users. Breaking it down:
- Clearly compliant: USDT/USDC usage through a licensed issuer, with full KYC completed and traceable fund sources.
- Gray zone: funds that have passed through multiple layers of secondary-market transfers — exactly the area Anchorage wants clarified, with no current rule on “how many layers back” tracing should go.
- Clearly high-risk: funds transferred directly from sanctioned addresses or mixing services.
U.S. users should pay close attention to how this develops — see our U.S. compliance guide for details. Hong Kong and Singapore, which operate under their own stablecoin regimes, are less directly bound by GENIUS, but policy spillover at the issuer level is hard to avoid entirely — see the differing regulatory paths in our Hong Kong compliance guide and Singapore compliance guide.
Key Milestones Worth Watching
- Public comment period deadline: Treasury rules typically carry a 30–60 day comment window — watch whether other issuers besides Anchorage (Circle, Tether-affiliated entities) weigh in.
- Final wording on “secondary-market liability boundaries”: whether language appears on “traceable layer limits” or a “good-faith holder exemption” will determine the compliance burden on downstream card providers.
- Deposit-terms updates from mainstream exchange cards: watch whether Coinbase, Bybit, and others revise their USDT deposit source-disclosure requirements over the coming quarter.
- USDT issuer policy response: whether Tether adjusts its compliance disclosures in response to tightening U.S. regulation.
Editorial Recommendations
- If you currently hold any USDT virtual card: no action is needed right now. This is still the comment stage — the rule is not yet in effect.
- If you routinely deposit to your card account from P2P, OTC, or frequently newly-created addresses: start keeping clear records of fund provenance (transaction screenshots, source platform) from now on — this is the lowest-cost protection against any future compliance tightening.
- U.S. users planning to apply for a compliant exchange card: applying now is fine, but confirm deposit terms again after the comment-period deadline noted above, to avoid process changes once the rule takes effect.
- Users who prefer solutions with independent clearing rails not directly tied to U.S. GENIUS clearing: our MPCard review and 5 Cards Worth Watching in 2026 may be useful references — but note that issuer-level policy spillover is industry-wide, and no single card is fully immune from top-level stablecoin regulation.
Detailed regulatory background is available on the Treasury’s official website and in the original Cointelegraph report. We’ll update this article as the rule advances to its next stage.