On-Chain and Off-Chain: Closing the Stablecoin Compliance Gap

Stablecoins are becoming payments infrastructure, and the compliance frameworks built around them are still catching up to what that means in practice. This session brings together practitioners from Rain, Ribbit Capital and TRM Labs to work through the Genius Act, on-chain versus off-chain compliance and what real-time transaction screening actually requires.

Key takeaways

  • Your position in the stablecoin architecture determines your obligations: Issuers, custodians, processors and non-custodial providers each face different freeze, seize and screening requirements. Knowing your role technically is the starting point.

  • Freeze and seize decisions need a policy before an incident: Drift Protocol showed two legitimate but different approaches. Compliance teams need a documented playbook before they face a live situation.

  • On-chain and off-chain compliance are both required: Blockchain analytics tells you about the wallet. Traditional KYC tells you about the person behind it. No single tool bridges both, and effective programs use them together.

  • Pre-transaction screening is now table stakes: Unlike ACH, blockchain transactions are largely irreversible. The compliance window is before the transaction executes, not after.

  • Attribution on-chain is sometimes probabilistic, not deterministic: Compliance decisions based on blockchain data need to account for confidence levels in that data, not treat all attribution as fact.

  • Technology-neutral regulation puts the burden on institutions to demonstrate effectiveness: Overly prescriptive rules create evasion vectors. The expectation is that programs show they understand the risk and that controls are commensurate with it.

Meet the Speakers

Lesley Chavkin

Head of Global Public Policy

Ribbit Capital

Lesley leads public policy at Ribbit Capital, a VC firm investing in fintechs and crypto. She is also a non-resident fellow at the Atlantic Council. Before Ribbit, Lesley served in senior roles at Paxos and Stellar and served in the US Department of Treasury.

Tom Armstrong

Head of Compliance Advisory

TRM Labs

Tom leads TRM’s Compliance Advisory function where he works closely with banks, crypto businesses and regulators on industry best practices for digital asset compliance. Prior to TRM, Tom spent over nine years at Goldman Sachs where he held senior AML roles.

Tyler Nielsen

Head of OFAC and Sanctions Compliance

Rain

Tyler leads sanctions compliance strategy at Rain, a stablecoin infrastructure company. Before Rain, Tyler founded SET Global, a consultancy advising banks and fintechs on fincrime compliance. He previously held multiple roles in the US government around sanctions design, implementation and impact.

Peter Piatetsky

CEO and Co-Founder

Castellum.AI

Peter leads strategy, growth and product at Castellum.AI, working closely with clients to implement risk-aligned solutions. Prior to co-founding Castellum.AI, Peter served at the US Treasury Department.

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