The OpenID Foundation has submitted a comprehensive response to the US Department of the Treasury's Request for Comment on "Innovative Methods to Detect Illicit Activity Involving Digital Assets" (TREAS-DO-2025-0070-0001), issued under the GENIUS Act.

As a technical standards body with deep expertise in APIs and digital identity, the OpenID Foundation welcomes the opportunity to show how mature, globally adopted open standards can help achieve the GENIUS Act's objectives, particularly balancing law enforcement capability with privacy preservation.

Outlined in its response, the Foundation’s approach focuses on addressing the root causes of financial cybercrime, such as preventing bad actors from gaining access to financial systems in the first place… rather than tracking illicit activity after it occurs. OpenID Foundation standards achieve this by creating secure, interoperable frameworks that protect both traditional finance and digital asset ecosystems. 

Already trusted by billions worldwide

The response highlights several of the OpenID Foundation’s specifications that are already protecting systems operating at internet scale:

• OpenID for Verifiable Credential Presentation (OpenID4VP) has been adopted by 38 jurisdictions and is actively used by 1.3 million Americans for digital identity verification.
• FAPI 2.0 is already securing billions of open banking and open data transactions globally.
• The Shared Signals Framework is enabling real-time risk signal sharing across ecosystems. 
• OpenID Connect is securing over three billion daily logins worldwide.

The OpenID Foundation's response also advocates for the use of partially anonymous, partially unlinkable authentication under ISO/IEC 29191. This approach keeps personally identifiable information private during routine transactions, but allows designated authorities like FinCEN to re-identify users under due process when investigating crimes. These are standards that deliver on the balance the GENIUS Act seeks to achieve.

Broader engagement

Executive Director of the OpenID Foundation, Gail Hodges, said: "This submission is part of our broader engagement with policymakers in the US and abroad on digital identity and financial innovation. The US is well placed to demonstrate how smart policies can leverage standards and conformance to deliver secure, interoperable identity infrastructure for a rapidly evolving financial sector.” 

The full letter and supporting documents can be found here: Letter OIDF comment on TREAS-DO-2025-0070-0001.

About the OpenID Foundation

The OpenID Foundation (OIDF) is a global open standards body committed to helping people assert their identity wherever they choose. Founded in 2007, we are a community of technical experts leading the creation of open identity standards that are secure, interoperable, and privacy preserving. The Foundation’s OpenID Connect standard is now used by billions of people across millions of applications. In the last five years, the Financial Grade API has become the standard of choice for Open Banking and Open Data implementations, allowing people to access and share data across entities. Today, the OpenID Foundation’s standards are the connective tissue to enable people to assert their identity and access their data at scale, the scale of the internet, enabling “networks of networks” to interoperate globally. Individuals, companies, governments and non-profits are encouraged to join or participate. Find out more at openid.net.