Category: TDC Update

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 By reducing outdated compliance burdens on financial institutions while maintaining essential reporting to combat illicit finance, this bill ensures that the Treasury Department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 to policy@digitalchamber.org. 

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 to policy@digitalchamber.org. 

In recent years, we have seen an explosion of interest in prediction markets (exchange-traded platforms where participants buy and sell contracts based on the outcome of future events, such as elections, sports, or economic trends). As these markets grow in popularity, they have reached a critical juncture: the need for a clear, durable, and innovation-friendly regulatory framework. 

Today, The Digital Chamber (TDC) is proud to announce our Prediction Markets Working Group, a dedicated initiative designed to emphasize the value of these markets and ensure they have a modern and workable regulatory framework within the U.S. financial system. 

Our launch begins with a formal letter addressed to CFTC Chair Selig. This letter is the first step in what we anticipate will be a sustained, multi-year effort to bring clarity to a historically important yet often misunderstood segment of finance. 

In our letter, we applauded Chair Selig’s recent statements regarding the intent for CFTC staff to provide tailored rulemaking and guidance for this rapidly growing segment of the financial and digital asset industries. For too long, operators in this space have navigated a maze of regulatory ambiguity including unclear overlaps between federal and state regulators. We are urging the CFTC to move beyond “regulation by enforcement” and instead initiate formal rulemaking that reinforces a coherent federal framework. 

Prediction markets are powerful tools for price discovery and information aggregation. By allowing participants to trade on the outcome of future events, these platforms generate high-quality data that can be used by businesses, policymakers, and researchers to manage risk and make informed decisions.

Below, please find TDC’s Prediction Markets Working Group’s initial action-oriented agenda to drive the industry forward: 

• Engaging directly with the CFTC, congressional committees, and key policymakers to clarify the treatment of event contracts under the Commodity Exchange Act. 
• Developing policy principles to distinguish regulated prediction markets from traditional gambling, emphasizing risk management, market integrity, and consumer safeguards. 
• Submitting comment letters and formal policy recommendations addressing self-certification standards, contract design, and listing practices. 
• Publishing legal and economic research explaining the historical role of prediction markets in U.S. financial markets and their public value in price discovery and information aggregation. 
• Building a coalition of market participants and institutional stakeholders to support a durable, innovation-friendly regulatory environment for prediction markets. 
• Participating in litigation through friend-of-the-court briefings to educate courts on the CFTC’s historic regulatory exclusivity on this area of financial regulation. 

We look forward to working with our members, legislators, courts, and the applicable administrative agencies in developing a thoughtful and durable framework for this emerging market segment.  

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

The Digital Chamber (“TDC”) greatly appreciates the White House’s role in convening stakeholders and fostering candid conversations toward a workable resolution to address ongoing issues regarding payment stablecoins in forthcoming market structure legislation. We are also grateful to members and staff of the Senate Banking Committee for their continued hard work and thoughtful engagement on these complex issues. Through these discussions, a “yield and interest prohibition” principles (“the Prohibition Principles”) document was put forth by banking industry advocates.

As the largest and oldest blockchain trade association, with 250+ members spanning traditional financial institutions, crypto-native firms, leading banks, stablecoin issuers, and infrastructure providers, TDC is uniquely positioned to advance a balanced resolution. We offer principles that support payment stablecoins as payment instruments without disrupting the ecosystem or harming established firms.

Principles

Retain Section 404 Exemptions to Avoid Material Ecosystem Disruption

• Section 404 of the Senate Banking Committee’s recent market structure discussion draft prohibits interest or rewards paid for merely holding payment stablecoins, while establishing permissible activities regarding use of payment stablecoins.  
• Without exemptions (E) and (F), for example, the legislation could significantly impair U.S. dollar-denominated stablecoins currently deployed in Decentralized Finance (“DeFi”) protocols and as Liquidity Provider (“LP”) pairs on DeFi exchanges, which pay users in exchange for facilitating liquidity. Eliminating these provisions would severely undermine dollar dominance in the digital asset ecosystem, effectively ceding this area to foreign jurisdictions and risks foreign currencies replacing U.S. dollar denominated stablecoins in these essential portions of the digital asset ecosystem.[1]

Enforcement/Evasion/Representations and Disclosures

• We understand financial institutions’ concerns regarding community banking and main street lending. Assuming exemptions (b)(2)(E) and (b)(2)(F) are retained, we concur that no person shall circumvent a direct or indirect yield prohibition and that firms must make accurate disclosures clarifying that any yield earned is not comparable to interest.[2]

Retain “Deposit Impact” Study

• We support the requirement present in Section 404 of the most recent Banking market structure discussion draft that regulators submit a study two years after enactment examining the benefits of increased payment stablecoin activity and its impact on deposits at insured depository institutions. We are confident such a study will affirm empirical analysis showing that stablecoins complement, rather than disrupt, the traditional banking system.[3]

We have a real window to cement American leadership in digital finance, but that window will not stay open indefinitely. We are committed to working with the White House and key stakeholders to advance durable market structure legislation while protecting and accelerating the innovation already taking root across the country.

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

[1] Further, disallowing payments for LP pairs containing payment stablecoins could introduce new risks, forcing users to commit their liquidity in ways which enhance impermanent loss risks rather than allowing users to pair their assets with a trusted dollar-denominated payment stablecoin. 

[2] Further, The Digital Chamber wholly supports tailored changes to banking laws which support the growth of community banking and local lending such as proposed in the Main Street Capitol Access Act. Community banking is a vital portion of the American economy, and The Digital Chamber believes that blockchain-enabled technologies paired with community banking services and infrastructure will be a boon to the American consumer. 

[3] Cong, Lin William, Stablecoins and Banking: Deposit Dynamics, Financial Stability, and Regulatory Design (December 07, 2025), available at https://ssrn.com/abstract=6163266.

By: Jean-Philippe Beaudet 

The complexity and global nature of modern military supply chains create significant vulnerabilities. These are amplified by issues such as the ‘misplacement’ of conventional arms, inefficiencies in internal tracking systems, and the difficulty of securing strategic military assets, evidenced by the Pentagon’s FY2023 inability to account for 63% ($2.4T) of assets. Blockchain technology offers a revolutionary solution to these challenges, providing transparency, immutability, and surety – key factors that can transform how military and defense supply chains are managed and secured.

Blockchain technology can improve military readiness by tracking parts and systems throughout their lifecycles, providing the necessary data fidelity, access, and security to the US Military to maximize asset uptime and minimize cost. Military systems, from aircraft to vehicles, rely on complex supply chains and timely maintenance schedules to remain operational. Blockchain’s decentralized, immutable ledger can securely track the life cycle of each component, ensuring real-time visibility of part availability, condition, and service history. This eliminates bottlenecks and inefficiencies caused by outdated or inaccurate records.

By leveraging blockchain, the military can significantly reduce downtime, as maintenance personnel can instantly verify the authenticity and status of critical components. This ensures that only certified parts are used, reducing the risk of failure in mission-critical systems. Additionally, predictive maintenance algorithms can be integrated with blockchain to automate parts replacement, further increasing uptime and operational readiness.  

This enhanced accountability and streamlined logistics system will keep military assets mission-ready while simultaneously reducing costs associated with repair delays and logistical inefficiencies.

Tracking Conventional Arms: Securing the Flow of Weapons

Conventional Arms Control (CAC) regimes cannot succeed without trust between parties – particularly difficult to maintain when these agreements seek compliance from countries whose interests often diverge from those of the United States. Blockchain technology addresses this critical gap by creating a decentralized, transparent, and immutable record that can monitor compliance with arms agreements. This technology is referred to as zero-trust because no single arbiter (like a particular state in a multilateral agreement) controls the network or has preferential access to data.

Blockchain ensures that all parties have real-time access to verifiable data, reducing the need for intrusive inspections and bilateral suspicion. Internet of Things (IoT) sensors incorporated into blockchain networks monitoring CAC could add a physical component, further augmenting this passive monitoring. Application of these emerging technologies will drastically enhance the United States’ ability to effect durable arms control agreements in the coming decades.

Transparently Tracking Small Arms

By implementing blockchain technology, every shipment of conventional arms could be tracked from production to final delivery. Each transaction in the supply chain would be logged on a tamper-proof ledger, ensuring that any deviation or anomaly in the chain is instantly detectable. If a crate of rifles fails to arrive at its intended destination, for example, the blockchain record can quickly identify where the disruption occurred, providing real-time data that enables corrective action. This enhanced level of transparency would make it significantly harder for adversaries or corrupt actors to divert arms into the black market or to hostile groups.

Moreover, blockchain’s cryptographic security would prevent unauthorized parties from tampering with supply chain data, ensuring that arms shipments are not only tracked but also securely delivered to allied forces. By leveraging this technology, the DoD can prevent costly and dangerous losses of military hardware, while also providing a clear audit trail to ensure accountability.

Addressing the Pentagon’s Audit Failures

Blockchain technology offers an opportunity to improve internal accountability and transparency and with it, citizens’ trust in government. The Pentagon’s long-standing tracking inefficiencies have repeatedly prevented it from passing a comprehensive audit, undermining accountability and operational readiness.  

A decentralized blockchain ledger can record every transaction and asset movement within the Pentagon’s complex supply chains. Whether it’s the procurement of jet fuel, maintenance parts, or sophisticated defense equipment, blockchain would ensure that every transaction is time-stamped, immutable, and visible to authorized personnel. This would eliminate discrepancies in record-keeping, reduce opportunities for waste, fraud, or abuse, and ensure a clear line of sight into how taxpayer dollars are being spent.

Beyond tracking, blockchain technologies can streamline the auditing process itself. The use of smart contracts – self-executing agreements that operate on blockchain – could automate verification and compliance checks, providing auditors with real-time data on how funds are allocated and spent.

The Digital Chamber will continue to collaborate with policymakers, researchers, and industry leaders to advance the integration of blockchain into our nation’s supply-chain management, protecting and monitoring the hardware essential to US national security. The Deploying American Blockchains Act of 2025, introduced by Rep. Kat Cammack (R-FL-3) in the House, and taken up by Sen. Bernie Moreno (R-OH) in the Senate, is exactly the type of legislation needed “to promote the competitiveness of the United States related to the deployment, use, application, and competitiveness of blockchain technology” in military supply chains.  Now is the time for Congress and the defense community to turn these proposals into action and ensure America’s supply chains remain secure.

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

Momentum is building behind the Strategic Bitcoin Reserve (SBR) concept, with states moving ahead on their own legislation as the federal government works to implement the White House Task Force’s recommendations for crypto agency actions released in July 2025. 

As of November 2025, Arizona, New Hampshire, and Texas have enacted SBR legislation. Another nine proposals remain active, while others failed to advance out of committee during the last session. 

These developments reflect growing momentum at the state level: an area TDC’s State Network is closely tracking and supporting through research, coordination, and member engagement. 

For a deeper look at how states are approaching implementation, explore our Digital Power Network team’s recommendations submitted to the Texas Comptroller in October 2025, offering guidance on how to structure and manage a state-level Strategic Bitcoin Reserve. 

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