TDC Challenges Illinois Crypto Tax in Court

To address the unfair tax burden that would be imposed under the Digital Asset Tax Act included in the recent Illinois state budget, The Digital Chamber (TDC) filed a lawsuit today in Sangamon County asking the court to halt the last-minute tax provision slipped into the state’s annual spending bill. The suit seeks to stop the tax from adversely affecting TDC’s members, who are already incurring costs trying to comply with the new tax ahead of its expected January 2027 effective date.

The lawsuit argues that no one should be taxed differently because of how ownership is recorded or transferred. Put simply, this tax discriminates against people who transact in digital assets. This tax is universally applied, regardless of whether the investor realizes any gain, or whether ownership is even being transferred. This expansive provision would affect any tech transaction, including potentially AI and cloud-based applications.

β€œToday we are asking the courts to protect consumers and our members and stop this unfair tax in Illinois. Taxes should be carefully considered, not only for the revenue they produce but for the fairness of those being taxed. That was not the case here, as the provision slipped into legislation the night before the bill’s final consideration,” said Cody Carbone, TDC’s CEO.

From here, the court’s rules provide a window for more groups to join this lawsuit. To inquire about joining this fight, contact policy@digitalchamber.org to learn more.

Digital ID: Modernizing Compliance, Cybersecurity, and Consumer PrivacyΒ 

By: Jonathan Rufrano, TDC Policy Director

Today, many identity checks still depend on outdated processes: uploading photos of physical IDs, collecting large amounts of personal information, or relying on fragmented third-party databases. Mobile driver’s licenses (mDLs) and other digital credentials offer a better path. They can allow people to prove who they are or specific facts about themselves without oversharing sensitive information.

NIST’s latest guidance focuses on how mDLs can help banks and other financial institutions verify identity. TDC strongly supports this work because digital identity can strengthen compliance, make cybersecurity more effective, and make it easier to protect consumer privacy.

Why It Matters

Digital ID is a compliance and security upgrade for financial institutions to verify customers more securely while reducing fraud, account takeover risks, and repeated collection of sensitive personal data. When implemented properly, mDLs can use cryptographic signatures, device-based presentation, and selective disclosure to confirm identity information with a high degree of confidence.

Here is why The Digital Chamber recently submitted comments to the National Institute of Standards and Technology’s (NIST) National Cybersecurity Center of Excellence on its mobile driver’s license guidance for financial institutions:

  • Better compliance: Financial institutions need reliable ways to meet Customer Identification Program, Know Your Customer, and Bank Secrecy Act requirements in digital environments.
  • Stronger cybersecurity: Digital credentials can reduce reliance on easily copied documents, passwords, and centralized stores of sensitive data.
  • More consumer privacy: People should not have to share more information than necessary. Digital ID can allow a person to prove a specific attribute, such as age or residency, without exposing an entire identity document.

This issue is urgent. As stablecoins, digital assets, fintech platforms, and mobile-first banking continue to grow in the traditional finance industry, identity systems must keep pace.

TDC’s View

TDC believes privacy-preserving digital identity should become a core part of the future compliance framework. NIST’s work offers technical guidance to help financial institutions understand how to safely use mDLs in real-world onboarding, authentication, and compliance workflows.

But financial institutions also need clear rules from Treasury and FinCEN confirming how digital identity tools can satisfy existing Bank Secrecy Act obligations. Without that clarity, many institutions may hesitate to adopt better technology, even when it improves security and compliance outcomes.

TDC’s response urges policymakers and regulators to recognize that digital ID can support the goals of existing financial crime rules while reducing unnecessary data collection. The right framework can help institutions verify customers, protect consumers, and reduce risk at the same time.

What’s Next

NIST should continue updating its guidance to reflect how digital identity tools work in practice. That includes mobile-only workflows, privacy-preserving verification, user-controlled credentials, and interoperability across identity standards. At the same time, FinCEN needs to provide clear, technology-neutral guidance explaining how financial institutions can use mDLs and other digital credentials to meet BSA and CIP requirements.

Digital identity is ready to play a larger role in financial services. Now, regulators must update the rules so institutions can use it with confidence.

If you have any questions, please reach out toβ€―policy@digitalchamber.org.Β 

Myth vs. Fact: Common Misconceptions About the CLARITY Act

The CLARITY Act has sparked a lot of debate, including concerns that it could shield bad actors, strip the SEC of authority, or pressure banks into adopting blockchain–based technologies. But a closer look tells a different story: the bill is focused on defining regulatory jurisdiction, extending Bank Secrecy Act oversight to digital assets, strengthening consumer protections, and more. We broke down 10 of the biggest myths to help separate facts from fiction. 

Myth #1: The bill undermines law enforcement by inadequately addressing illicit finance and national security risks. 
Fact: In modern finance, the Bank Secrecy Act (BSA) misses the mark to regulate digital assets. The CLARITY Act is needed to fill those gaps. The bill: 

  • directly regulates digital asset intermediaries, issuers, service providers, and other key actors, defining who regulates what at the federal level 
  • establishes clear liability based on activity  
  • empowers federal agencies to create and enforce new digital assets rules and explicitly ties OFAC’s sanction authority to digital assets.  
  • establishes a public–private partnership to monitor and combat illicit finance and leverage private-sector blockchain data and analytics to help law enforcement. 

Myth #2: The CLARITY Act gives software developers immunity from civil or criminal liability. 
Fact: The Blockchain Regulatory Certainty Act clearly notes that if you do not transmit funds, you are not a money transmitter β€” combining BSA’s money transmitter provisions for financial intermediaries and protecting lawful software development and innovation. Entities that control or custody of customer assets remain fully subject to existing financial laws and the additional requirements established under the CLARITY Act. 

This does not modify anti–money laundering laws or limit prosecutions for fraud or sanctions evasion. It aligns with longstanding FinCEN guidance and the White House’s position that non-controlling; noncustodial developers are not money transmitters.  

Myth #3: The CLARITY Act would complicate law enforcement investigation and prosecution efforts. 
Fact: Civil and criminal regulations already apply to digital asset usage, and CLARITY specifically addresses how existing laws apply, enhancing law enforcement’s ability to police digital assets by: 

  • Offering real-time access to transparent and immutable transaction data on blockchains 
  • Creating efficiency for law enforcement to track, trace, and prosecute digital asset crime and follow illicit fund movements to catch bad actors.  
  • Increasing funding and tools needed by law enforcement to combat illicit finance in digital assets through 
  • new FinCEN appropriations (total proposed increase: $150 billion over 5 years): 
  • Funds would target digital assets kiosks to offer clear disclosure requirements and waiting periods for withdrawals  
  • The bill empowers the Treasury Department to make rules to crack down on suspected illicit activity between US and foreign financial institutions. 

Myth #5: The bill forces banks to adopt blockchain–based technologies and weakens the soundness of our financial system.
Fact: The CLARITY Act includes a dedicated title to set permissible activities and broadly allows banks to use distributed ledgers to perform, provide, or deliver anything they are already authorized to do and subject those activities to the same requirements as existing activities.  

  • This gives banks, credit unions, and financial holding companies the freedom to innovate without mandating the adoption of blockchain–based technologies.  
  • This gives consumers the ability to use banks they know and trust to custody their digital assets. 

Myth #6: The CLARITY Act gives decentralized finance (DeFi) a pass from meaningful accountability and oversight. 
Fact: The CLARITY Act applies oversight based on custody, control, and function, ensuring regulated obligations apply to entities that make sense. It directs regulators like FinCEN to clarify AML/CFT rules, preventing misuse of β€œdecentralization” claims to avoid compliance. 

Myth #7: Market structure is only about financial markets. 
Fact: Market structure also has real implications for energy markets. By clarifying Bitcoin and other digital assets’ status as a digital commodity, the CLARITY Act could help attract domestic Bitcoin mining operations and support grid flexibility. 

Myth #8: The CLARITY Act creates a weaker regulatory regime for crypto firms compared to traditional financial institutions because it strips the SEC of critical authority over digital asset markets and investor protections.
Fact: The CLARITY Act defines where digital asset intermediaries fit into regulatory frameworks comparable to traditional finance while clarifying and preserving the SEC’s jurisdiction on customer asset segregation, disclosure requirements, and market integrity rules. Additionally: 

  • Brokers, dealers, exchanges, and custodians are required to register and comply with oversight regimes administered by both the SEC and CFTC.  
  • The SEC’s full authority over securities-related activity is codified and preserved, while the bill establishes clear jurisdictional boundaries between the SEC and CFTC for non-security digital assets. 
  • The bill specifically extends AML and risk controls under the BSA, including transaction monitoring authorities, temporary transaction holds, and formal risk management standards (Section 308). 

Myth #9: The CLARITY Act would leave consumers with fewer protections in digital asset markets. 
Fact: CLARITY strengthens consumer protections by requiring digital asset platforms to meet core safeguards common in traditional finance, including clear disclosures, fair dealing, and protection of customer funds.  

The bill requires customer asset segregation and enforceable operating standards, directly addressing risks like commingling and platform failures. The bill adds fraud detection and intervention tools to the BSA, such as transaction monitoring and temporary holds. 

Myth #10: The CLARITY Act is unnecessary. Existing securities and commodities laws provide sufficient authority. 
Fact: Existing securities and commodities laws are muddy and antiquated. 

  • The CLARITY Act creates certainty for firms, regulators, and consumers, filling in gaps by defining when a digital asset falls under SEC or CFTC jurisdiction.  
  • The bill creates tailored, enforceable requirements for digital asset intermediaries while extending BSA anti-money laundering and risk controls. 

Read our full breakdown here.

If you have any questions, please reach out toβ€―press@digitalchamber.org. 

60-Day GENIUS Act Sprint: TDC Responds to OCC

This Digital Chamber is excited to announce that we recently submitted four comprehensive responses to the Office of the Comptroller of the Currency’s (OCC) proposed rulemaking for the implementation of the GENIUS Act.

When sweeping legislation like the GENIUS Act transitions from statutory text to enforceable rules, the details matter immensely. The OCC’s rulemaking process will likely dictate the operational realities, compliance frameworks, and strategic landscapes of the digital asset industry for years to come.

When the OCC released its proposed rulemaking, it spanned almost 400 pages of dense and complex regulatory framework. Within those pages, the regulators posed 211 specific, highly technical questions to the public. We had less than 60 days to digest the text, analyze its implications, gather consensus, and draft our responses.

Over 20 TDC member companies and law firms stepped up to the plate, dedicating their time and insights to this massive undertaking,Β submittingΒ over 100 pages ofΒ responsive material. Our coalition tackled the proposal head-on, providing thoughtful, detailed, and substantive feedback on almost all of the 211 questions presented by the OCC.

This achievement would have been impossible without the minds that guided us. A special thank you to the teams at Perkins Coie, Clifford Chance, and Morgan Lewis. These teams worked tirelessly around the clock to coordinate responses, synthesize diverse viewpoints from our member companies, and craft rigorously researched arguments. Their dedication, unparalleled expertise, and sheer hard work were the engines that drove this initiative across the finish line.

Together, we have not only met a massive regulatory challenge, but we have also actively shaped the future of the GENIUS Act. Thank you all for your unwavering commitment and exceptional work.

TDC Responses to OCC Rulemaking Proposal:

GROUP 1: Questions 1-24 (Definitions), 100-108 (Redemption), and 198-211 (General)

GROUP 2: Questions 25 -34 (Activities), 35 – 39 (Interest and Yield Prohibitions) and 174, 182 & 197 (Capital Requirements and OCC Assessments)

GROUP 3: Questions 44-99 (Reserve Assets) and 109-128 (Risk Management)

GROUP 4: Questions 129-137 (Audits, Reports, and Supervision), 149-166 (Custody) and 167-176 (Applications)

If you have any questions, please reach out toβ€―policy@digitalchamber.org.

Key White House AI Framework & Google Quantum Takeaways

In the final two weeks of March 2026, two significant documentsΒ were released: theΒ White House’s National Policy Framework for Artificial IntelligenceΒ andΒ aΒ new white paper from Google Quantum AIΒ on quantum vulnerabilities in blockchain cryptography. Below are our key takeaways from each, with links to the fullΒ TDCΒ analyses at the bottom.Β 

White House National Policy Framework for Artificial Intelligence 

On March 20, 2026, the White House released its National Policy Framework for Artificial Intelligence β€“ legislative recommendations to Congress spanning seven subject areas, from child protection and intellectual property to workforce development and federal preemption of state AI laws. It carries no binding legal force, but represents the Administration’s preferences for where it wants Congress to go on AI. 

The most consequential provision is Section VII. If enacted, federal preemption would establish a single national AI standard, overriding the fragmented state-level regimes building in Colorado, California, Texas, Illinois, and elsewhere. States could not impose AI-specific disclosure mandates, impact assessments, or liability regimes beyond the federal floor β€“ a significant simplification for companies currently navigating conflicting requirements, though several states are likely to contest it in court. 

Also notable: Section V directs Congress not to create any new AI-specific regulatory body. Oversight would flow through existing regulators β€“ SEC, CFTC, FinCEN β€“ rather than a new agency, which has meaningful implications for digital asset companies whose AI tools already operate under financial regulatory frameworks. 

OurΒ full section-by-section analysisΒ covers all seven provisions and their implications for blockchain and digital asset companies.Β 

Google Quantum AI: Quantum Vulnerabilities in Blockchain Cryptography 

On March 30, 2026, a team at Google Quantum AI β€“ with collaborators from UC Berkeley, Stanford, and the Ethereum Foundation β€“ published revised estimates of the quantum computing resources needed to break Bitcoin and Ethereum’s cryptography. 

The core finding: using Shor’s Algorithm against the elliptic curve underlying both networks, the attack can be carried out with fewer than 500,000 physical qubits and completed in roughly nine minutes β€“ within Bitcoin’s ten-minute block window. That is approximately 20 times fewer resources than prior published estimates. Companies like Google and IBM are actively building hardware in this range. 

The exposure is substantial. Roughly 6.9 million BTC are currently in quantum-vulnerable address formats, including approximately 2.3 million in dormant wallets inactive for five or more years. Ethereum’s attack surface is broader, spanning its account model, smart contract admin keys, Proof-of-Stake validator signatures, and Layer 2 infrastructure. The paper also raises the policy question of what governments should do about dormant quantum-vulnerable assets before a capable quantum computer arrives β€“ and concludes the window for orderly post-quantum migration is narrowing faster than previously understood. 

Our full summaryΒ covers the attack scenarios, dormant asset governance options, and implications for exchanges, custodians, and institutional holders.Β 

From the AIQ Working GroupΒ 

The AIQ working group is continuing to track hardware developments at Google, IBM, IonQ, and others, alongside the White House Framework’s impact on Congress. More updates to follow. 

Read the Full White House AI Framework Analysis here.

Read the Full Google AI Quantum Report Summary here.

If you have any questions, please reach out toβ€―policy@digitalchamber.org

TDC DeFi Policy Principles

Non-Custodial DeFi Policy Principles 

  1. Regulatory Obligations Should Follow Custody or ControlΒ 
    • Financial regulatory obligations should apply to entities that custody user assets or exercise discretionary control over transactions on behalf of users.Β 
  1. Non-Custodial Developers Are Not Money TransmittersΒ 
    • Developers who do not hold or control users’ digital assets should not beΒ subject to financial regulationsΒ simply for building, publishing, orΒ maintainingΒ open-source DeFiΒ software.Β 
  1. Permissionless Protocols Are Infrastructure, Not IntermediariesΒ 
    • Open source, permissionless protocolsΒ areΒ coreΒ digital infrastructure, and should be treated as such.Β Β Classifying these protocolsΒ asΒ financial intermediaries,Β whetherΒ as money transmitters, money services businesses, or other financial institutions, fundamentally mischaracterizes what they are and how they function.Β 
  1. Software Maintenance Does Not Create Financial Intermediary StatusΒ 
    • Financial regulators should clarify thatΒ maintaining, upgrading, or debugging non-custodial protocols, liquidity pools, smart contracts,Β oracles,Β or similar infrastructure does not make an individual or organization a financial intermediary.Β 
  1. Developer Protections Apply Across the Protocol LifecycleΒ 
    • Legal protections for open-source protocol development should extend to the full lifecycle of decentralized systems, including deployment, upgrades, security improvements, and ongoing maintenance.Β 
  1. Law Should Distinguish Between Digital Assets and Smart Contract SoftwareΒ 
    • Regulatory frameworks should clearly differentiate between digital assets, which function as property, and open-source smart contracts, which are software infrastructureΒ (not property).Β 
  1. Developers Are Not Liable for Third-Party Use of Open InfrastructureΒ 
    • Developers who create open-source software tools should not face civil or criminal liability solely for the independent actions of third parties who use those tools.Β 

Intermediated (Institutional) DeFi Policy Principles 

  1. Intermediaries Bear Compliance Obligations When Using DeFiΒ 
    • Financial intermediaries and custodians that access DeFi protocols on behalf of clients should remain responsible for regulatory compliance obligations.Β 
    • Developers who build orΒ maintainΒ relatedΒ smart contract software should not be treated as financial intermediaries solely for creating the underlying code.Β 
  1. Regulatory Obligations Follow Institutional ControlΒ 
    • Maintaining or upgrading decentralized infrastructure should not trigger financial intermediary status, though regulatory and data protection obligations should apply when such systems are created, owned, andΒ operatedΒ by financial institutions.Β 
    1. Protect Proprietary Financial Software and Assign Responsibility Accordingly
      • When financial infrastructure is built using proprietary code or intellectual propertyβ€”such as smart contracts, liquidity pools, vaults, algorithms, or AI agentsβ€”it should not be treated as open-source software.
      • Entities that control or deploy such proprietary systems should bear regulatory obligations proportionate to the financial activities those systems perform on behalf of users.Β 
      1. Institutional Use of DeFi Supports Fiduciary ObligationsΒ 
        • Digital asset institutions have the fiduciary obligation to act in the best interest of their clients.
        • Institutions should therefore not be excluded from leveraging DeFiΒ vaults,Β protocolsΒ and platformsΒ to perform their duty of best execution.Β 

          If you have any questions, please reach out toβ€―policy@digitalchamber.org

          AI Agent Identity & Security Standards

          Jean-Philippe Beaudet & Jonathan Rufrano

          Why We Filed 

          Over the past several weeks, TDC’s AI + Quantum and Compliance & Cybersecurity Working Groups led the preparation and submission of two formal public comments to the National Institute of Standards and Technology (NIST). Both filings respond to government requests for industry input on how AI agent systems should be identified, authenticated, authorized, and secured β€“ questions that sit squarely at the intersection of our members’ work. 

          As autonomous agents gain the ability to execute financial transactions, access proprietary data, call APIs, and interact with other agents, the rules governing their identity and authority will shape the architecture of the systems your organizations are building right now. TDC’s goal in filing is to ensure that those rules are informed by the technical reality our members navigate daily and to establish TDC as a credible, expert voice in a policy space that will define AI deployment for years to come. 

          What We Responded To 

          Filing 1: NIST CAISI – Security Considerations for AI Agents (March 2026) 

          The Center for AI Standards and Innovation (CAISI) requested information on security threats, risks, and practices affecting AI agent systems across the full deployment lifecycle. TDC’s response drew on members’ hands-on experience in financial services, digital asset custody, blockchain security infrastructure, and agentic commerce. 

          Filing 2: NIST NCCoE β€“ Software and AI Agent Identity and Authorization (April 2026)

          The National Cybersecurity Center of Excellence (NCCoE) proposed a new project exploring how software and AI agents should be identified and authorized, initially scoped to enterprise deployments. TDC’s response addressed six question categories spanning use cases, existing standards, identification, authentication, authorization, auditing, and prompt injection defense. 

          Our High-Level Recommendations 

          Core principle: Build from existing standards rather than creating parallel AI-specific frameworks from scratch. The building blocks already existβ€”they need to be extended, not reinvented. 

          Across both filings, TDC advanced four interconnected recommendations: 

          1. Expand the project scope beyond enterprise-only use cases. Consumer-facing and government AI agent deployments introduce identity and authorization risks that enterprise frameworks may not address β€“ and standards that fail to account for all three segments will produce gaps from day one. 
          2. Prioritize adaptation of mature, widely-deployed protocols. Standards like OAuth 2.0, NIST SP 800-63, SPIFFE/SPIRE, W3C Verifiable Credentials, and ISO/IEC 18013 (mDL) already provide robust foundations. The right approach is to extend these β€“ not replace them β€“ to accommodate non-human, autonomous actors.
          3. Treat agent identity and authorization as distinct layers. Authentication establishes who an agent is; authorization determines what it is permitted to do. Conflating these layers is a root cause of current over-permissioning in agentic deployments. 
          4. Design for accountability at scale. EveryΒ agentΒ action should be cryptographically attributable to a verifiable identity, a delegating human principal, and an auditable authorization chain – before those agents are managing financial assets or acting across enterprise systems.

          If you have any questions, please reach out toβ€―policy@digitalchamber.org

          TDC Prediction Markets Working Group Framework for Responsible Prediction Markets

          1.β€―Purposeβ€―Β 

          The Prediction Markets Working Group (β€œPMWG”) supports the responsible development and regulation of CFTC-regulated prediction markets as federally regulated derivatives markets that facilitate price discovery, risk management, and information aggregation. This is an important priority for The Digital Chamber (TDC), as blockchain-enabled technologies will continue to be implemented into various forms of commodities trading, including prediction markets, due to their transparency-enabling features and near instantaneous settlement and trade finality capabilities.   

          2.β€―Core Policy Principlesβ€― 

          TDC advances the following principles to guide our prediction market advocacy work:β€― 

          Deep Industry and Technical Knowledge: Members of the PMWG include former CFTC-staff, regulated designated contract markets (β€œDCM”s), future commission merchants (β€œFCM”s), legal experts, and infrastructure service providers. Our work is focused on bringing a deep technical and legal understanding of how these markets operate and are regulated. We aim to bring advanced subject-matter expertise to our efforts to ensure the regulations covering this growing industry are practical and effective.   

          Federal Regulatory Clarity and Preemption:β€―Where prediction markets operate as CFTC-regulated event contract markets, federal commodities law should provide the exclusive regulatory framework. Regulatory fragmentation undermines market stability and consumer protection. This includes any future developments at the CFTC related to interactions of DCMs with blockchain-enabled technologies like stablecoins, public or DeFi orderbooks, and related technologies as deemed appropriate by federal regulators.  

          Market Integrity and Consumer Protections:β€―The public needs to trust event-contracts are fair for these products to reach their full potential. Event contract markets should maintain robust listing standards, anti-manipulation controls, transparency, margin and capital safeguards, and surveillance mechanisms consistent with derivatives market best practices. 

          Distinction from Gambling Frameworks:β€―Just as futures were once described as β€œgambling on grain” prediction markets face opposition from certain states who view the products as gambling. However, prediction markets structured on DCMs differ meaningfully from traditional gambling models in governance, clearing, capital controls, and risk management. Policy frameworks must reflect those distinctions. 

          Principled Contract Designs:β€―Event contracts should be evaluated under clear, administrable standards that consider economic purpose, susceptibility to manipulation, and alignment with the public interest. 

          U.S. Leadership in Financial Innovation:β€―The United States should lead in establishing modern regulatory frameworks for information markets; ensuring competitiveness while safeguarding systemic integrity. 

          β€― 

          3.β€―Policy Prioritiesβ€―β€― 

          Objective 1: Encourage the CFTC to initiate formal rulemaking specific to prediction markets to reduce ambiguity and promote consistent regulatory treatment 

          Key Results: Submit at least one comprehensive comment letter advocating for tailored rulemaking. Conduct 5+ meetings with senior CFTC staff. Publish a public policy paper outlining model regulatory principles. 

          Objective 2: Clarify the scope of federal authority over CFTC-regulated event contracts and reduce uncertainty created by overlapping state gaming enforcement. 

          Key Results: Publish a federal preemption legal analysis. Develop model federal statutory clarification language, if necessary.  

          Objective 3: Support a coherent national framework through strategic litigation involvement in in state vs. DCM event contract litigation.  

          Key Results:Β File at least oneΒ amicusΒ brief in active litigation involving state regulators and CFTC-regulatedΒ predictionΒ market operators. Produce a public explainer on the legal issues at stake in federal vs. stateΒ jurisdictionΒ disputes.Β Β 

          ObjectiveΒ 4:Β DemonstrateΒ that the industry supports strong market integrity and consumerΒ protections.Β Β 

          Key Results: Publish a Prediction Market Best Practices Framework. Convene 3 roundtables with operators, academics, and compliance experts. Develop recommended disclosure and transparency standards for event contracts.  

          ObjectiveΒ 5:β€―Educate state regulators and stakeholders on the federal framework governing CFTC-regulated prediction markets and distinguish derivatives markets from traditional gaming.

          Key Results:Β Develop a state policymaker briefing toolkit. Publish a white paper explaining interaction between state gaming laws and federally regulated derivatives markets. Include F&Qs where helpful clearing up.Β 

          If you have any questions, please reach out toβ€―policy@digitalchamber.org

          TDC Applauds the Introduction of H.R. 1799

          The Digital Chamber (TDC) applauds Congressman Barry Loudermilk (GA-11) for introducing H.R. 1799, the Financial Reporting Threshold Modernization Act, which calls for inflation-based updates to thresholds of Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), as required by the Bank Secrecy Act (BSA).

          H.R. 1799 modernizes financial reporting thresholds, updating their regulatory scope to partially reflect inflation. The original CTR transaction reporting threshold of $10,000 was established in 1970 by the BSA and has not been updated for over 55 years. Were this threshold to have tracked inflation, CTRs would only be necessary for transactions above $86,000, today.

          H.R. 1799 updates the CTR threshold to $30,000 and requires a readjustment to accommodate inflation every five years. By reducing outdated compliance burdens on financial institutions while maintaining essential reporting to combat illicit finance, this bill ensures that the Treasury Department and law enforcement continue to receive meaningful financial information.

          In addition to the larger CTR accommodation threshold adjustments, H.R 1799 would modify SAR thresholds as well. It would adjust the current $5,000 threshold for larger financial institutions to $10,000, and both the $1,000 and $2,000 thresholds for Money Services Businesses (MSBs) to $3,000. It would not amend the $0 threshold for insider abuse, terrorist funding, or structural evasion of BSA requirements.

          This bill will assist financial institutions in better allocation of compliance resources and reduce administrative costs for smaller financial institutions, all while ensuring critical AML/CFT provisions are updated for the 21st century. H.R. 1799 encourages responsible financial innovation, aligning regulatory frameworks with the modern economic conditions we find ourselves in today.

          TDC urges Congress to advance Rep. Loudermilk’s bill to continue establishing modern, risk-based regulatory frameworks, ensuring that AML tools remain targeted, proportionate, and effective. TDC appreciates Congress’ commitment to national security, countering the financing of terrorism, and anti-money laundering provisions associated with the SAR regime. 

          If you have any questions, please reach out toβ€―policy@digitalchamber.org

          Why AIQ; Why Now? – TDC Launches AI + Quantum (AIQ) Working Group

          Artificial intelligence (AI) and quantum computing will define the operating environment of the 21st century. They will shape capital allocation and market supervision; data security, privacy, and ownership; how labor, education, and transportation systems are organized; and how nations assess and project power. AI and quantum computing will transform markets whether this industry is ready or not.

          AI is already impacting financial markets. Compliance workflows are being automated. Risk scoring models are being retrained on real-time data streams. Supervisory expectations increasingly assume algorithmic monitoring, anomaly detection, and model governance. AI agents are beginning to transact, audit, and allocate capital autonomously. For digital asset firms, this shift affects everything from market surveillance to custody controls to fraud detection and consumer protection.

          For these reasons, The Digital Chamber (TDC) is launching our Artificial Intelligence + Quantum Working Group (AIQ).

          AIQ’s priorities include:

          • Legislation and standards to promote data neutrality, fidelity, and provenance
          • Industry alignment on quantum-resistance timelines and coordination
          • Agentic commercial and cybersecurity standards and expectations
          • Standards to promote the development of free and open software
          • Contributing to legislative AI frameworks at the State and Federal levels
          • Research into quantum and AI developments and capabilities

          By engaging with congressional and agency staff, TDC will educate on these emerging technologies, support standards that encourage further market viability, and prioritize both shared global benefit and US security as national and international quantum priorities are established. Read our full statement here.

          If you have any questions, please reach out toβ€―policy@digitalchamber.org