Author: Neil Humphrey

Stablecoin Rules Must Match How Stablecoins Actually Work 

by Neil Humphrey

The Digital Chamber submitted a comment letter to FinCEN and OFAC regarding their proposed rule on AML/CFT and sanctions compliance program requirements for permitted payment stablecoin issuers. 

Bringing permitted payment stablecoin issuers, or PPSIs, into a clear BSA/AML framework helps consumers feel confident, helps firms do their part to protect the U.S. financial system and support law enforcement. 

At the same time, TDC urged FinCEN and OFAC to clarify the final rule so it reflects how payment stablecoins actually operate. The key point is simple: issuing a payment stablecoin is not the same as intermediating every transaction in which that stablecoin is later used. 

Why It Matters 

Payment stablecoins can strengthen U.S. payments, expand access to dollar-denominated digital value, and support responsible innovation. The current proposed rules could create obligations that no issuer can realistically meet. 

TDC’s letter focuses on several core points: 

  • PPSIs should be responsible for their own direct activities, such as issuance, redemption, custody, hosted wallet services, or other customer-facing services. 
  • PPSIs should not be required to monitor, report on, or serve as the compliance intermediary for all secondary-market activity merely because they issued the stablecoin. 
  • Recordkeeping, Travel Rule, SAR, and sanctions obligations should apply to the entity with the customer relationship, transaction role, custody, control, or legal ability to act. 
  • Blockchain analytics, digital identity, ecosystem monitoring, and AI-enabled tools can improve compliance, but they should not create broad secondary-market surveillance duties for PPSIs. 
  • FinCEN and OFAC should provide clearer guidance on when PPSIs must block, freeze, reject, seize, burn, or otherwise prevent transfers. 
  • Regulators should account for downstream risks to innocent users when stablecoins are frozen, seized, or burned inside decentralized protocols, liquidity pools, automated market makers, or other shared on-chain systems. 

TDC’s Take 

TDC supports strong AML/CFT and sanctions compliance for stablecoin issuers. But compliance obligations must be tied to the role an issuer actually plays. 

When a PPSI directly issues or redeems stablecoins for a customer, it can collect information, screen wallets, use blockchain analytics, conduct due diligence, and maintain records. But once a stablecoin moves through exchanges, custodians, merchants, self-custodied wallets, decentralized protocols, or smart contracts, the issuer often does not know the sender or recipient, does not hold the customer’s assets, and does not control the transaction. 

That distinction matters when regulators require an issuer to freeze, seize, burn, or restrict stablecoins. In a custodial setting, that action may affect a specific account or wallet. In a decentralized liquidity pool or automated market maker, the same action could disrupt pricing, liquidity, collateral, or protocol operations for users with no connection to the enforcement target. 

TDC also urged FinCEN and OFAC to provide safe harbors or mitigating-factor treatment for PPSIs that act in good faith to comply with lawful orders while taking reasonable steps to limit harm to innocent users, liquidity providers, protocol participants, and other third parties. 

Taken together, these stablecoin compliance recommendations will create rules that are both strong and workable. 

What’s Next 

TDC will continue working with regulators and industry to ensure the final rule aligns realistic compliance obligations with customer relationships and asset control. Done right, the rule can support effective enforcement while giving responsible PPSIs the clarity they need to build in the United States. 

TDC Applauds the Committee on Ways and Means for the Balanced Compromise Reflected in H.R. 9175

by Neil Humphrey

June 21, 2026

The Honorable Jason Smith  Chairman, Committee on Ways and Means  U.S. House of Representatives  Washington, DC 20515 The Honorable Richard Neal  Ranking Member, Committee on Ways and Means  U.S. House of Representatives  Washington, DC 20515 

RE: Support for H.R. 9175, the Tax Clarity for Mining and Staking Act, as Introduced 

Dear Chairman Smith and Ranking Member Neal: 

We, the undersigned organizations, write to applaud the Committee on Ways and Means for the balanced compromise reflected in H.R. 9175, the Tax Clarity for Mining and Staking Act, introduced by Representative Mike Carey, and to respectfully urge its passage as introduced. After years of uncertainty about how mining and staking rewards are taxed, the bill provides a durable compromise that innovators can support while addressing concerns raised by some lawmakers. 

Crypto and blockchain networks have the potential to integrate with and replace legacy systems across nearly every industry, delivering drastic improvements in speed, cost, and efficiency. However, these networks function only because participants choose to play a key role in validating transactions. Proof-of-stake and proof-of-work are the primary validation mechanisms in use today, with over $1.7 trillion in assets secured through these methods.1 It is critical that Congress provide legislative clarity in the tax code to ensure that those networks can be secured by Americans in America. 

Since Bitcoin’s inception in 2009, stakers and miners have lacked clarity in the tax code regarding the timing, sourcing, and character of the tokens they create through network validation. Recent developments make Congressional action even more urgent. In 2014, the IRS issued Notice 2014-21 stating that miners are required to include the fair market value of mined Bitcoin in gross income as of the date it was mined.2 In 2023, the IRS published Revenue Ruling 2023-14, setting forth the IRS’s position that validation rewards are stakers’ immediately taxable income.3 

3 Internal Revenue Service, Revenue Ruling 2023-14, 2023-33 Internal Revenue Bulletin 407 (August 14, 2023), https://www.irs.gov/pub/irs-drop/rr-23-14.pdf 2 Internal Revenue Service, Notice 2014-21, 2014-16 I.R.B. 938 (March 25, 2014), https://www.irs.gov/pub/irs-drop/n-14-21.pdf 1 See CoinGecko, Top Proof of Stake (PoS) Coins by Market Cap, https://www.coingecko.com/en/categories/proof-of-stake-pos (last visited June 18, 2026); and CoinGecko, Top Proof of Work (PoW) Coins by Market Cap, https://www.coingecko.com/en/categories/proof-of-work-pow (last visited June 18, 2026). 1 

Members of Congress have repeatedly flagged the problems this guidance creates. In November 2025, Senator Todd Young wrote to Treasury Secretary and Acting IRS Commissioner Scott Bessent, urging the IRS to reevaluate the ruling’s treatment of staking rewards, and the following month, Representative Carey led eighteen of his colleagues in a second letter pressing for updated guidance before the 2026 tax year began.4 Taxation at the time of creation results in myriad issues, including issues of dominion and control, taxation of phantom income, and liquidity concerns. Moreover, the guidance offers little analysis and conspicuously avoids key factual and legal considerations, casting doubt on its application to stakers and miners. Far from resolving the issue, this IRS guidance has further contributed to ongoing uncertainty, making prompt action by Congress all the more important. 

H.R. 9175 crafts a novel approach to the new technological and economic realities posed by proof-of-stake and proof-of-work blockchains, inspired by the century-old treatment of newly created property. The language reflects a hard-won compromise, with meaningful concessions on both character and timing to secure broad, bipartisan support. It does not provide unlimited deferral or full parity with all forms of self-created property; instead, it ensures income is recognized while avoiding immediate taxation before taxpayers can monetize the asset. That balance answers the central concern that the bill could create an unwarranted windfall. It also delivers something that years of administrative guidance have failed to provide: a clear, administrable rule that taxpayers can follow without ambiguity, and the IRS can enforce without having to chase recognition events across millions of wallets every time blocks are created on multiple chains. 

This is the needle H.R. 9175 threads to make sound policy. It ensures income is ultimately recognized while sparing taxpayers a tax on gains they may not yet be able to monetize. When a taxpayer owes tax on assets they cannot yet monetize, the practical result is forced selling: liquidating holdings simply to fund the tax bill, not because the taxpayer chose to exit the position. Moreover, H.R. 9175 ensures that taxpayers pay an amount in line with the income they realize at sale, unlike alternative proposals that could leave a taxpayer with a tax bill far higher than the amount they actually realize. 

The administrative costs of this approach are equally unjustifiable for taxpayers and the IRS alike. The Joint Committee on Taxation has scored the proposed amendment’s five-year cap and found that it yields negligible revenue while imposing a significant compliance burden on taxpayers, their advisors, and the IRS.5 For taxpayers and their advisors, it means tracking cost basis and computing gain on a mandatory five-year cycle across potentially millions of wallets, regardless of whether a sale has occurred. For the IRS, it means designing, staffing, and enforcing an entirely new class of recognition events—triggered not by a transaction but by the passage of time—across an asset class that already strains existing audit and reporting infrastructure. Piling that burden onto a provision that raises little meaningful revenue is poor tax policy by any measure. H.R. 9175, as introduced, achieves the same revenue goal—full recognition at sale or death—at a fraction of the administrative cost. 

5 Joint Committee on Taxation, Digital Asset Taxation (JCX-18-26) (June 8, 2026), https://waysandmeans.house.gov/wp-content/uploads/2026/06/JCT-Description.pdf 4 Letter from Sen. Todd Young to Scott Bessent, Sec’y of the Treasury & Acting Comm’r, Internal Revenue Serv. (Nov. 18, 2025), https://assets.bwbx.io/documents/users/iqjWHBFdfxIU/rrJFjBE.kMNI/v0; Letter from Mike Carey et al. to Scott Bessent, Acting Comm’r, Internal Revenue Serv. (Dec. 18, 2025), https://carey.house.gov/wp-content/uploads/2025/12/Rep.-Carey-IRS-Crypto-Tax-Staking-Letter.pdf 2 

We urge the Committee to preserve the balance reflected in H.R. 9175 and pass the bill as introduced. Reopening the compromise already struck in this legislation would risk reviving the very problems the bill resolves and stalling a bipartisan result that is finally within reach. Getting this right keeps blockchain validation and the innovation it supports built here in the United States. We are grateful for the Committee’s leadership and the hard work of staffand Members, and we stand ready to be a resource as the bill advances. 

Respectfully, 

For any inquires, please contact TDC at press@digitalchamber.org.

Latin America’s Surge in the Global Race to Adopt Stablecoins

by Neil Humphrey

The GENIUS Act established the first federal framework for stablecoin issuance in the U.S. in July 2025. In the year since, stablecoin transfer volume has reached roughly $4.5T in Q1 2026. Latin American countries are seeing that success and are working to establish regulations that will likely fuel more crypto adoption in traditional finance in the region. Notably: 

  • Brazil was among the first Latin American countries to adopt such regulations through its “Virtual Assets Law.”  
  • Bolivia reversed its decade-long crypto ban in June 2024. 
  • Argentina introduced mandatory exchange registration in 2025, and many more frameworks are being developed in these markets.  

As adoption and regulation of stablecoins have pushed Latin America’s crypto market into more commercial use cases, 71% of Latin American institutions have already begun using stablecoins for cross-border payments, the highest regional adoption rate globally. Additionally, on-chain crypto volume in the region rose 60% year-over-year in 2025, driven largely by stablecoins.  

While the drivers of adoption differ, the common effect is that in 2025, there was $324 billion in stablecoin transaction volume across LATAM, representing an 89% year-over-year surge. In Brazil, currently over 90% of all crypto flows are stablecoin-related, and over 60% in Argentina. Hotels, restaurants, and tourism businesses are also beginning to accept stablecoin payments directly from international visitors, saving both businesses and tourists millions previously lost to exchange rates and credit card fees. 

Business-to-business (B2B) stablecoin volumes grew 30x globally in the past two years, and Latin American businesses, banks, and fintechs have been among the first to widely adopt stablecoins.  

  • Mizuho research reports that remittance fees via stablecoins in the US-Mexico corridor are now under 1%, a major improvement for consumers compared to the 5% to 7% average fees charged by traditional money transfer services.  
  • Across the $142 billion that U.S. individuals sent to Latin America in 2025, if conducted through low-cost stablecoin infrastructure, this could result in $6.1-8.9 billion in consumer savings. 

As regulations become clearer and adoption continues to grow, stablecoins are likely to play an increasingly important role in payments, savings, and cross-border transfers throughout Latin America.  

The Digital Chamber Statement on ICBA’s Digital Asset Campaign

by Neil Humphrey

ICBA’s campaign isn’t about protecting Main Street, it’s about shielding an outdated model from competition. The ‘free pass’ claim is flatly false: our industry is fighting for clear federal rules through the Clarity Act, while ICBA is fighting to keep Americans locked out of innovation.

Clear rules of the road will protect consumers and establish a transparent, fair way for crypto to be a choice for the 70 million Americans who own crypto.

For any inquires, please contact TDC at press@digitalchamber.org.

TDC Forums: The Place to Meet and Learn 

by Neil Humphrey

In a world filled with noise, decision makers’ greatest resource is time. TDC Forums are time well spent for these key leaders, and our next engagements in New York City and Chicago are filling up fast. 
 
Though built for a specific locality, the events are globally focused. With limited seating, the conversations remain small but inclusive in these half-day convenings. TDC Forums are in the works for other key international cities and build on The Digital Chamber’s reputation for sophisticated policy engagement and industry-shaping collaboration between the digital assets industry, global financial leaders, and policymakers. 
 
Rather than simply including another panel, the events are built for engagement. Whether in a group setting or one-on-one, the opportunities at TDC Forums are designed to ensure meaningful connections can grow high-impact ideas. 
 
TDC Members are invited to join the events at no cost. Non-members can join for a nominal fee. Each Forum is also open to the public and meant to diversify voices engaging in key policy issue discussions. TDC Forums are another way TDC is helping the broader industry shape the future of the digital economy across the globe. 

To learn more about the latest cities playing host to a TDC Forum and sponsorship opportunities, click here.

Insider Trading and Prediction Markets; Blockchain Transparency Drives Enforcement  

by Neil Humphrey

Recently, insider trading allegations related to prediction markets have been dominating headlines. One of the recent headline grabbers includes allegations a U.S. military official committed fraud and misuse of classified information. The soldier allegedly used classified intelligence related to U.S. military action in Venezuela to place a series of trades on Polymarket’s offshore platform, generating over $400,000 in personal profit. He has been charged with multiple criminal offenses, and the CFTC has also filed a lawsuit against him for civil damages. 

According to the criminal indictment, to bypass the offshore platform’s restrictions against use by U.S. individuals, it is alleged the individual accessed the platform through foreign accounts and attempted to conceal his activity by moving funds through offshore accounts. However, the activity was quickly discovered despite alleged attempts to conceal because the trades at issue were executed through public and immutable blockchain technologies. The suspicious timing and size of the trades were rapidly spotted by the public and quickly uncovered in media reports, leading to a federal investigation and the resulting criminal and civil charges. Since everyone could see the suspicious trading activity, accountability was as transparent as the blockchain ledger. 

As the call for prediction markets regulation bubbles at the state and federal level, this example illuminates a number of key policy discussion points: 

• Transparency: Blockchain-based technologies and platform monitoring appear to have contributed to identifying unusual trading patterns, which were later investigated by authorities.  

• Existing rules: This case represents one of the first major criminal prosecutions and civil enforcement actions for insider trading involving prediction markets. The case suggests that existing fraud, commodities, and misuse-of-information statutes can be applied to conduct on prediction markets.   

• Jurisdictional complexity: U.S. law prohibits certain event contracts, such as those involving war, which is why the individual allegedly had to use workarounds to trade on offshore markets. This highlights that U.S. regulations prohibiting event contracts on things like war and terrorism are still in full force, but the borderless nature of prediction markets and digital assets complicate who and how bad actors are brought to justice.  

• Regulatory scrutiny of prediction markets: The case and similar recent civil enforcement actions are heating up policy discussions around how prediction markets and insider trading with sensitive information on those markets should be regulated. Even though the trades happened on an offshore platform, U.S. authorities can still enforce the law. If someone in the U.S. tries to bypass restrictions to access those markets, they can be held accountable if they break U.S. law.  

Though existing laws already prohibit the insider trading alleged in this matter, clearly tying those existing rules to emerging technology like prediction markets in cases like this is necessary to ensure law enforcement can fairly police online trading activity. As with so many emerging technology products, there is a clear need for consistent regulatory frameworks that address misuse without stifling innovation. 


If you have any questions, please reach out to policy@digitalchamber.org. 

TDC’s State Network: Lawmakers, Industry Leaders Convene for New York State Blockchain Day

by Neil Humphrey

Washington, DC (May 27, 2026) — Industry leaders, technology advocates, and policymakers will gather today at the Legislative Office Building for New York State Blockchain Day. The education event will focus on the growing role of blockchain technology in government modernization, economic development, consumer protection, and energy innovation.

Hosted by the BSV Association, The Digital Chamber’s State Network, and the NYS Blockchain Council, the event will demonstrate to lawmakers about blockchain technology and emerging digital asset applications from industry experts that could strengthen New York’s economy and modernize public services.

Anastasia Dellaccio, Executive Director for The Digital Chamber State Network, said, “Lawmakers will see firsthand how blockchain technology can reduce administrative costs, eliminate duplicative processes, and bring real transparency to how government serves its constituents. New York’s reputation as a global finance leader will be bolstered by the innovations on display today. The Digital Chamber’s State Network is proud to stand with our partners to ensure policymakers have the tools and knowledge to build a policy environment where that innovation can take root.”

New York State Blockchain Day underscored the importance of connecting policymakers, industry experts, and community stakeholders as the state evaluates how blockchain technology can responsibly support economic growth, government efficiency, and consumer trust.

Today’s interactive demonstrations and discussions with blockchain industry leaders show how blockchain technology can:

  • Enhance transparency and accountability in government
  • Improve cybersecurity and reduce fraud
  • Modernize public infrastructure and digital services
  • Drive economic growth and job creation
  • Strengthen energy market resilience and sustainability initiatives

Organizers are also discussing the benefits of pending legislative proposals in the New York State Legislature, including legislation to modernize public sector recordkeeping and health information systems through blockchain-enabled infrastructure. Additionally, advocates will address proposals that could slow innovation, investment, and technological development in the state, including legislation impacting digital asset mining operations, data center regulation, and emerging blockchain-based financial platforms.

Through a supportive innovation ecosystem that enables blockchain businesses and digital infrastructure companies, companies can grow jobs and scale in New York, while maintaining strong consumer protections and transparency standards.

About New York State Blockchain Day

New York State Blockchain Day is an educational advocacy initiative organized by the BSV Association, the Digital Chamber State Network, and the NYS Blockchain Council to raise awareness among policymakers about blockchain technology and its applications across government, finance, healthcare, energy, and public infrastructure.

ABOUT THE DIGITAL CHAMBER’S STATE NETWORK  

The Digital Chamber’s State Network, a project of The Digital Chamber, is a non-partisan program that establishes a collaborative ecosystem connecting policymakers, regulators, industry, and innovators to advance blockchain adoption and digital asset integration across the United States.  
  
ABOUT THE DIGITAL CHAMBER  

The Digital Chamber is a non-profit organization committed to promoting global blockchain adoption. We envision a fair and inclusive digital and financial ecosystem where everyone has the opportunity to participate. Access to digital assets is not merely a technological advancement but a fundamental human right, crucial for economic and social empowerment. Through targeted education, advocacy, and strategic collaborations with government and industry stakeholders, we drive innovation and shape policies that create a favorable environment for the blockchain technology ecosystem.   

The Digital Chamber’s umbrella includes: CryptoUK, Digital Power Network (DPN), TDC’s Digital State Network, and Treasury Council.  

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For media inquiries, contact press@digitalchamber.org   

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Digital ID: Modernizing Compliance, Cybersecurity, and Consumer Privacy 

by Neil Humphrey

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 to policy@digitalchamber.org. 

TDC Celebrates Senate Banking Committee’s Historic Market Structure Vote

by Neil Humphrey

Today’s advancement of market structure legislation by the Senate Banking Committee puts the United States closer than ever to establishing a durable federal market structure framework for digital assets. After years of regulatory uncertainty, enforcement-driven policymaking, and watching innovation move overseas, Congress is on the precipice of passing legislation that creates clear rules for the digital asset industry. We appreciate the leadership of Chairman Scott, Subcommittee Chairwoman Lummis, members of the Committee, and staff who worked through difficult and complex issues to strengthen the bill and keep it moving closer to final passage.

But this process is not finished. As the Senate works to reconcile the Banking and Agriculture Committees’ respective bills, it is critical that the final framework preserves the strong protections for consumers while ensuring developers, innovators, and responsible companies can build, operate, and thrive in the United States.

For any inquires, please contact TDC at press@digitalchamber.org.

TDC Welcomes Senate Banking Committee’s Bipartisan Market Structure Progress

by Neil Humphrey

The Senate Banking Committee’s updated digital asset market structure draft represents meaningful progress toward a comprehensive federal framework for digital assets. This bill text is the result of months of bipartisan negotiations and reflects industry collaboration to resolve regulatory uncertainty, strengthen consumer and market protections, and provide a workable pathway for responsible innovation under U.S. oversight.

As Committee members and staff work through the markup process on Thursday, The Digital Chamber is looking forward to continued progress toward legislation that can be delivered to the President’s desk this summer.

For any inquires, please contact TDC at press@digitalchamber.org.