6/9/26
ICBA Comment Letter - FinCEN-OFAC Proposed Rule RE:PPSIs
ICBA strongly supports a federal illicit-finance framework for PPSIs that is no weaker than the framework applicable to community banks. Community banks already operate under extensive AML/CFT, sanctions, examination, audit, and reporting obligations, and nonbank issuers offering bank-like payment products should not be permitted to compete under materially weaker standards.