StableKYC · Know Your Customer
The GENIUS Act created a new compliance category. PPSIs need customer identification programs that work across pseudonymous rails, secondary markets, and decentralized exchanges. The infrastructure doesn't exist yet. We're building it.
Visual Architecture
Where customer identification mechanisms embed in the five-layer Stablecoin Stack. Base leads at L3 with code-enforced identity gates. TRON shows the gap.
The Compliance Gap
Why it matters: The GENIUS Act §104 creates customer identification obligations specifically for Permitted Payment Stablecoin Issuers — a category that didn't exist before July 2025.
| Dimension | Before | After |
|---|---|---|
| AML/KYC | Inconsistent | Full BSA mandatory |
| Secondary Markets | Unaddressed | §104(h) CIP required |
| Travel Rule | Debated | $3K threshold formalized |
| Issuer Class | Undefined | PPSI designation |
| Deadline | None | July 2026 |
Identity Infrastructure
The PYMNTS editorial framing is "this is a problem." StableKYC provides the framework: three distinct identity approaches, each mapped to developer infrastructure.
How it works: KYC provider issues an on-chain attestation (EAS) proving the address holder completed identity verification.
How it works: W3C Verifiable Credential (VC) proves KYC completion. Holder presents the VC to any PPSI; PPSI verifies the cryptographic signature without re-collecting data.
How it works: ZK circuit proves customer meets CIP requirements (age, jurisdiction, sanctions clearance) without revealing any personal data.
GENIUS Act §104
What to know: Section 104 of the GENIUS Act (S.394, signed July 18, 2025) establishes a Customer Identification Program specific to Permitted Payment Stablecoin Issuers. Two requirements are entirely new — they address secondary market acquisition, the gap Governor Barr flagged.
| Section | Requirement | Category | Severity |
|---|---|---|---|
| §104(a)(1) | Verify identity of each customer at account opening | Customer ID | Critical |
| §104(a)(2) | Collect name, DOB, address, and ID number | Customer ID | Critical |
| §104(b) | Screen all customers against OFAC SDN list + ongoing rescreening | Sanctions | Critical |
| §104(c) | Identify and verify beneficial owners (25%+ / control) | Beneficial Ownership | High |
| §104(d) | Transaction monitoring + risk-trigger customer info updates | Ongoing Monitoring | Critical |
| §104(e) | File SARs for transactions >$5K with suspicious indicators | SAR Filing | Critical |
| §104(f) | Retain CIP records for 5 years after account closure | Recordkeeping | High |
| §104(g) | Transmit originator/beneficiary info for transfers >$3K | Travel Rule | High |
| §104(h) | Identify customers acquiring stablecoins via secondary markets | Secondary Market NEW | Critical |
| §104(h)(2) | Risk assessment for P2P and DEX-sourced stablecoin holdings | Secondary Market NEW | High |
Live Proof-of-Concept Demos
Each demo calls real APIs and on-chain data. Full Cloudflare Worker source included — copy, deploy, and extend.
Query Base mainnet for Coinbase-attested KYC status. Proves an address holder completed identity verification without exposing PII — the on-chain CIP gate PPSIs need for secondary market compliance.
Verify a W3C KYCAMLAttestation credential issued by Circle. The portable identity layer — a customer proves KYC completion to any PPSI without re-submitting documents.
Self-assess your CIP readiness against all 12 GENIUS Act §104 requirements. Outputs a gap matrix with severity ratings — the diagnostic tool that makes the compliance vacuum visible.
The Identity Triad
Three sites, three checkpoint types, one S2 Identity stage. Each maps to a distinct compliance function within the Stablecoin Sequence.
Platform Ecosystem