Compliance Prompt for GENIUS Act Stablecoin CIP Routing

Luna, map our active stablecoin wallet and ledger architecture against the joint Customer Identification Program (CIP) proposal issued under the GENIUS Act, then design a tailored risk-based compliance routing flow. The flow must satisfy federal watchlist cross-comparison and record-keeping requirements without degrading our ledger performance budget.

INPUT, the user will paste:
- Active wallet and ledger architecture, with the verification stages each transaction touches (signup, deposit, on-chain transfer, withdrawal, counterparty change)
- Current CIP and watchlist screening logic, including which lists are wired, the refresh interval, and the record-retention period
- Per-stage latency and throughput budget on the ledger (p95 settlement target, any hard caps, peak transaction rate)
- The joint-proposal CIP sections the firm has already reviewed
- Any open Treasury, FinCEN, or Federal Reserve advisories the firm is tracking

OUTPUT, return the following structured response:

1. CIP REQUIREMENT MAP
For each CIP control the joint proposal sets:
- The control (one-sentence summary with the joint-proposal section reference)
- Current firm-level coverage (covered, partial, gap)
- Evidence of coverage, or the evidence-absence reason

2. RISK-BASED ROUTING DESIGN
- The tiered routing flow from signup through ledger settlement, with each stage and its assigned risk tier (low, elevated, high)
- The specific watchlist cross-comparison check placed at each stage and tier, and whether it runs inline or asynchronously
- The record-keeping write placed at each stage and the fields it captures
- The escalation path when a tier promotes mid-transaction (low to elevated or high)

3. LEDGER-PERFORMANCE IMPACT ANALYSIS
- Per-stage latency delta the proposed flow adds, measured against the supplied budget
- Which checks breach a hard cap inline and the asynchronous or pre-computed alternative for each
- Projected throughput at peak under the new flow and the headroom remaining

4. RECORD-KEEPING AND AUDIT-TRAIL SPEC
- The record-keeping schema the firm should retain to satisfy the CIP record requirement (identity fields, screening result, decision rationale, timestamps)
- The retention window and the cryptographic-receipt format for each screened event
- How records and alerts route from Luna to the human investigation team for a Treasury, FinCEN, or Federal Reserve inquiry

Be specific. Cite the joint-proposal section references where you can. Where the firm's input is insufficient to assess a control or a latency impact, flag the question instead of guessing.