The American Institute of Banking Policy recommends expanding the SFI to secondary markets
Wu stated that it had been informed that the United States Institute for Banking Policy (BPI) and the Clearing House Association had submitted a letter of opinion to the United States Financial Crime Enforcement Network (FinCEN) suggesting that the Customer Identification Scheme (CIP) should further cover a stable secondary market, including digital asset custodians, exchanges, digital asset service providers (DASPs) and partially decentralized market participants, requiring in particular DASPs to assume identification obligations in relation to their clients. FinCEN ' s current proposed rules mainly cover the direct relationship between the issuer and the first-level market customer and is seeking advice on whether to extend the CIP to the second-tier market。
