Category: TDC Update

State Spotlight: Gilberto Nazario of Maryland 

by Renuka Rubin

What is driving your state’s approach to digital assets and emerging technology right now?

In Maryland, the conversation around digital assets and emerging technology is being driven by a combination of economic competitiveness, workforce development, and strong grassroots leadership.

Maryland has a unique advantage with its concentration of talent, federal agencies, research institutions, and world-class universities. There is growing recognition that blockchain, digital assets, and AI can create new opportunities for entrepreneurship, investment, and job creation across the state.

A major part of that momentum comes from community-led organizations. Groups like the Maryland Digital Asset Foundation and the Maryland Blockchain Association have played an important role in educating the public, connecting stakeholders, and advancing conversations around responsible innovation. Their grassroots efforts, alongside entrepreneurs, educators, students, and industry leaders, have helped build a stronger ecosystem from the ground up.

There is also a growing focus on workforce development. Maryland is investing in preparing students, veterans, and professionals for careers in emerging technologies, ensuring the state can compete for the jobs and industries of the future.

Maryland’s approach is increasingly centered on collaboration between industry, academia, community organizations, and government. The goal is to foster innovation while ensuring consumer protection and creating economic opportunities for residents across the state.

Who are the key stakeholders you’ve had to bring together to move this work forward?

It all starts with the community. They are the driving force behind this movement. The individuals making phone calls, contacting their elected officials, attending town halls, and sharing their concerns are ultimately what move policy conversations forward.

Beyond grassroots advocates, we’ve brought together a broad coalition of stakeholders that includes entrepreneurs, developers, investors, students, veterans, educators, industry leaders, and policymakers. Organizations such as the Maryland Digital Asset Foundation, Maryland Blockchain Association, Stand With Crypto, the Digital State Network, and other ecosystem partners have played a critical role in fostering collaboration, advancing education, and creating meaningful dialogue around innovation and digital asset policy.

The most successful efforts happen when all of these groups are working together. Innovation does not happen in isolation. It requires builders, policymakers, educators, and community members all having a seat at the table and working toward a shared vision for Maryland’s future.

What advice would you give to other states looking to engage in this space?

Start with education and community.

The most successful ecosystems are built from the ground up, not the top down. Bring together entrepreneurs, developers, students, educators, investors, and policymakers early in the process. Create opportunities for people to learn from one another and have honest conversations about both the opportunities and challenges presented by emerging technologies.

Focus on people before policy. Strong communities create informed advocates, and informed advocates help shape better policy outcomes. Invest in workforce development, support local builders, and make sure innovators have a seat at the table when decisions are being made.

Most importantly, don’t try to do it alone. Partner with local organizations, universities, industry associations, and community leaders who are already doing the work. The states that will lead in digital assets and emerging technology are the ones that embrace collaboration and create environments where innovation can thrive.

If you could implement one pilot program tomorrow, what would it be?

The Baltimore Blockchain Center

If I could launch one pilot program tomorrow, it would be the creation of the Baltimore Blockchain Center, a workforce development and innovation hub designed to help Baltimore residents build the skills, businesses, and opportunities needed to thrive in the digital economy.

The center would bring together universities, community colleges, industry organizations, startups, employers, and community leaders to provide education, mentorship, and hands-on experience in blockchain, artificial intelligence, cybersecurity, and digital infrastructure.

Participants would not just study emerging technologies; they would use them to build real products and solutions that address challenges facing Baltimore businesses, nonprofits, neighborhoods, and government agencies.

What makes this initiative different is its focus on Ownership. Too often, communities are consumers of innovation rather than beneficiaries of it. The Baltimore Blockchain Center would empower residents to become builders, founders, and owners. Participants would have the opportunity to launch companies, develop intellectual property, create community-focused solutions, and generate long-term economic value for themselves and their neighborhoods.

About Gilberto Nazario:

Gilberto Nazario is a combat veteran, community builder, and technology advocate originally from Puerto Rico and now based in the DMV. From boots to blockchain, his career has spanned military service, government technology, and the forefront of digital asset innovation.

As Maryland Chapter President for Stand With Crypto and Founder & CEO of Web3DC, Gilberto works at the intersection of emerging technology, digital asset policy, workforce development, and entrepreneurship. He introduced and helped lead the Web3 and Digital Asset Track for DC Startup & Tech Week, helping build five years of programming that has brought together thousands of entrepreneurs, builders, investors, policymakers, and innovators from across the blockchain ecosystem.

Before entering the Web3 industry, Gilberto served with the 82nd Airborne Division, completing deployments to Iraq and Afghanistan. He later held leadership roles within the Department of Defense, supporting mission-critical technology initiatives from the Pentagon to Army Recruiting Command. His journey from the battlefield to the boardroom, from the Pentagon to the frontlines of crypto, has given him a unique perspective on technology, security, and innovation.

Today, Gilberto works alongside students, veterans, startups, universities, and world-leading organizations to expand access to technology, develop talent pipelines, and create opportunities within the digital economy. He has partnered with several organizations, including the Digital Chamber, as a community partner. He also advises companies on business development, go-to-market strategy, and growth, bringing the integrity that defined his military and public service career to every engagement.

His mission is simple: help people build, connect, and thrive in the industries shaping the future.

TDC Supports CFTC’s Exercise of Emergency Authority to Ensure Market Stability

by Neil Humphrey

The CFTC’s Emergency Order is an important step toward preventing a single state from disrupting nationwide markets and echoes the disjointed regulation-by-enforcement approach the digital assets industry endured just a few short years ago.

Americans should be able to confidently access financial products and services, including prediction markets. We strongly support the CFTC’s work to oversee event-contract markets, protect consumers, and ensure the industry can compete and operate onshore.

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

RE: Support for Senate Floor Consideration of the Clarity Act

by Neil Humphrey

On behalf of the Crypto Council for Innovation, Blockchain Association, and The Digital Chamber, we write to express our strong support for Senate floor consideration of the Digital Asset Market Clarity Act to establish a comprehensive framework for the regulation of digital assets in the United States. Read our full letter here.

  • The Digital Chamber CEO Cody Carbone
  • Crypto Council for Innovation CEO Ji Hun Kim
  • Blockchain Association CEO Summer Mersinger

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

TDC Statement on Clarity Act Draft as Senate Vote Approaches

by Neil Humphrey

Today’s draft is a meaningful step toward the Senate vote on the Clarity Act we’ve been calling for. We look forward to reviewing the latest, and we will provide our members’ feedback on how the bill may still be improved as it moves forward.

Our optimism has never wavered. Through every round of negotiation, we’ve believed that Congress would deliver the market structure framework this industry and everyday consumers need. Now is our best chance for durable market structure law to allow America to be the global leader in digital assets. We’re encouraged, and we’re ready to keep working until the bill reaches the President’s desk.

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

State Spotlight: Anthony Apollo of Wyoming 

by Renuka Rubin

What or who made you interested in the digital assets, blockchain, and emerging technology space?

Through my advisory work at several GSIBs in the wake of the 2008 Global Financial Crisis and subsequent passage of the Dodd-Frank Act, I saw many legacy systems at traditional institutions breaking in real-time. Concurrently, I was introduced to Bitcoin and Ethereum. A unified, immutable, public ledger and the concept of “programmable money” simply made more sense in a digitally connected world. I made the full-time pivot to blockchain work in 2017 and have been building in the space since.

What is driving your state’s approach to digital assets and emerging technology right now?

A desire to fortify Wyoming’s position as the leading state for cryptocurrency, blockchain, and digital asset legislation. Since 2016, over 80 bills on these topics have been proposed, with more than 50 enacted into law. There is also a drive to further embed digital assets into government operations for increased efficiency, reduced costs, and enhanced transparency. This will require a multi-agency effort to prioritize and publicize the initiatives enabled by the state’s permissive regulations.

How do you see digital assets impacting your constituents or local communities directly?

Our agency endeavors to put real dollars back in the pockets of Wyoming’s citizens. Take for example testimony by Joel Schell, Converse County Treasurer. In a recent Commission meeting, Treasurer Schell testified that his office took in $3.4M in tax remittances, but his constituents paid $70,000 in credit card fees to facilitate those payments. Using the Frontier Stable Token would lower these costs to fractions of a cent per transaction.

What advice would you give to other states looking to engage in this space?

Find champions in your legislature and executive branch to support digital asset initiatives for the long-term. Wyoming has been fortunate to have strong and consistent leadership through its Select Committee on Blockchain, Financial Technology, and Digital Innovation Technology – the body responsible for drafting the key topical legislation. Further, Governor Mark Gordon has presided over the majority of bills enacted in Wyoming and currently serves as the Chairman of the Commission.

Where do you see the biggest opportunity for blockchain or digital assets in your state?

In January 2026, Wyoming launched the Frontier Stable Token – the first fiat-backed and fully-reserved stable token to be issued by a public entity in the United States. Dollars received by the Commission for the purchase of “FRNT” are invested in short-duration U.S. Treasuries and repurchases thereof. Both of these instruments bear interest that is collected by the state and swept into Wyoming’s school foundation program on a quarterly basis. We consider FRNT a public good for Wyoming.

About Anthony Apollo:
Anthony Apollo was appointed as the inaugural Executive Director of the WY Stable Token Commission in September 2023. Director Apollo brings his experience in both traditional finance (KPMG, EY) and digital assets (ConsenSys, Rensa) to the development of the first fiat-backed, fully-reserved stable token issued by a public entity in the U.S.

TDC Challenges Illinois Crypto Tax in Court

by Neil Humphrey

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.

“Today 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.

TDC Response: FDIC’s Requirements for Stablecoin Issuers

by Megan Thorpe

The FDIC has the opportunity to create a strong framework for payment stablecoins, as long as the agency’s rules remain faithful to the language and intent of the GENIUS Act. Our core message in The Digital Chamber’s cautionary feedback to the FDIC is simple: do not add requirements Congress did not include, create inconsistent standards across regulators, or turn the stablecoin framework into a broader bank-style capital, deposit-allocation, or anti-innovation regime. You can read our full letter of recommendations HERE, but below are a few of the notable recommendations from our submission:  

A quick summary of several key points the FDIC should address: 

  1. The FDIC should harmonize its definitions and regulatory standards. 
  • The Office of the Comptroller of the Currency (OCC), Federal Reserve, and National Credit Union Administration (NCUA) should ensure that similarly situated issuers are not treated differently based solely on their primary regulator. 
  • Similarly, complex issues around tokenized deposits, deposit tokens, and the boundary between bank deposits and payment stablecoins must be addressed through harmonized rules and guidance across regulators, rather than resolved indirectly through this FDIC proposal. 
  1. We recommended changes to several definitions: 
  • The FDIC’s proposed definition of “insured depository institution” may be too narrow and could unintentionally exclude certain federally supervised banking institutions, including certain U.S. branches of foreign banks, from serving as reserve counterparties.  
  • Additionally, we recommended refining the definitions for “eligible financial institution,” “public distributed ledger,” “smart contract,” and “payment stablecoin holder.”  
  1. Expanding issuer obligations to downstream stablecoin holders with no direct relationship to the issuer did not make sense. As such, we emphasized that regulatory obligations should correlate with direct customer relationships, and that downstream users should be protected through disclosures, redemption rights, and reserve requirements. 
  1. We urged the FDIC to allow stablecoin issuers to engage in activities related to issuance, redemption, reserve management, custody, smart contract deployment, blockchain infrastructure, cross-chain functionality, and operational risk management. 
  1. Our response supported reserve identification, traceability, segregation, audits, and redemption protections that make sense.  
  • However, we noted that mandating a single legal structure, custody model, Simplified Payment Verification (SPV), or reserve management approach that does not align with that recommendation. This will give issuers flexibility to meet statutory requirements through different legally effective structures. 
  1. Finally, we noted that adding capital-like reserve buffers, standardized haircuts, automatic liquidation requirements, or rigid caps beyond the GENIUS Act was concerning. The statute already establishes a strict reserve framework, and additional requirements could reduce liquidity and limit competition. 
     

Overall, the strong supervision, full-reserve backing, redemption rights, transparency, and risk management in the NPRM all form a sensible implementation proposal aligned with Congressional intent. Our repeated stance in our response letter is that inconsistent treatment across agencies and requirements that would undermine the competitive and innovative framework Congress intended in passing the GENIUS Act should not be a part of the final version of the FDIC rules. 

Read our full response here.

One Year of the GENIUS Act  

by Megan Thorpe

One year ago, on July 18, 2025, President Trump signed the GENIUS Act into law, transforming how stablecoins (digital assets pegged to the U.S. dollar) are regulated in the U.S.  The law established a clear federal framework for stablecoins and became part of history as the first major piece of crypto legislation ever signed into law in the U.S.  

The GENIUS Act requires stablecoin issuers to maintain 1:1 reserves in safe assets such as U.S. dollars and short-term Treasuries, publish monthly reports, and comply with anti-money laundering rules. The trust that comes with knowing there is strong federal oversight for stablecoins has been a key unlock to the growth of the asset class. 

The Results 

When the rules became clear, people began building. Major companies took notice almost immediately; Visa, Mastercard, J.P. Morgan, and more integrated or announced stablecoin payment products following the law’s passage. 

  • The global stablecoin market has reached $315 billion in market capitalization in 2026, more than 50% growth from the $206 billion market cap at the beginning of 2025.  
  • Annual global transaction volume surged to nearly $35 trillion in 2025, a figure that rivals major credit card networks.  
  • Real-world stablecoin payments, including businesses paying suppliers, families sending money home, people buying goods, and more, have doubled in a single year to $390 billion. 

Beyond our Borders 

The ripple effect from Washington went global; regulators everywhere watched the U.S. draw clear lines and started drawing their own. 

Stablecoin adoption has been particularly transformative in Latin America. As detailed in Latin America’s Surge in the Global Race to Adopt Stablecoins, the region has become a global leader in stablecoin usage, driven by people seeking to protect their savings from inflation, send remittances cheaply, and access dollar-denominated accounts without a U.S. bank. This effectively turns the citizens in those countries into buyers of U.S. Treasuries and depositors into U.S. bank accounts. The GENIUS Act’s clear framework accelerated this by giving international users and issuers confidence that dollar-backed stablecoins were built on solid ground. 

  • Australia introduced stablecoin legislation in late 2025 and adopted it in April 2026, treating stablecoins as regulated payment products and requiring compliance with standard Australian Securities and Investments Commission (ASIC) regulations. 
  • The EU’s MiCA regulation paved the way for licensed euro-backed stablecoins; Decta’s 2025 report noting that monthly transaction volume rose 899% after MiCA’s rollout. 
  • The Asia-Pacific region is racing to be a hub for regulated digital finance, with frameworks such as Hong Kong’s Project Ensemble, South Korea’s Capital Markets and Electronic Securities Acts, Singapore’s Project Guardian, and more. 
  • Stablecoins now account for roughly 43% of all crypto transaction volume in Sub-Saharan Africa, where people use dollar-pegged digital assets to protect their savings from local-currency inflation. 
  • The Bank of England in the UK revised its pound sterling stablecoin proposal, eliminating a £200,000 limit on individual holders and raising the issuance cap to £40 billion.  

The Takeaway 

Clear rules don’t slow innovation down. They speed it up. Before the GENIUS Act, banks and institutions often wouldn’t touch stablecoins for fear that investments would be lost to shifting regulatory winds. And developers couldn’t build products if they didn’t know whether those products were legal. 

When the U.S. defined the rules of the road, the market responded, and that’s exactly why finishing the job with a market structure bill like the Clarity Act matters now. The GENIUS Act addressed the questions surrounding stablecoins, but the U.S. has yet to clearly define where Bitcoin, Ethereum, and thousands of other digital assets fit within our regulatory system.  

We are closer than ever to market structure rules of the road. The House passed a version of a market structure bill last year. The Senate Banking Committee advanced its portion of the bill in May 2026, just months after the Senate Agriculture Committee passed its portion of the bill. Negotiations are actively blending those bills, so the full Senate can continue pushing the bill towards the President’s desk. 

One year in, the lesson of the GENIUS Act is clear: America leads when it sets standards. The world follows when we do. Now is the time to build on that momentum and set the standard for market structure 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. 

Prediction Market Monday: More Than One Simple Market

by Simi Awe

Most people think of prediction markets as simple yes-or-no predictions on whether an event will occur. In reality, these markets are far more complex. They include a variety of contract types, market designs, and even different forms of currency. Below, we break down the main types of prediction markets and explain their purposes.

Contract Types

There are three main types of contracts: binary, index, and spread. Binary contracts are the most common and well-known. For these contracts, traders make yes or no trades on their predicted outcome of an event. This contract can help to show the probability of an event occurring based on market expectations. For index contracts, the payout varies continuously based on the value of a numerical outcome. A common example is the percentage of votes Trump receives in the presidential election. Index contracts show the market’s expectation of the value, mean, of the event with investors split into buckets of potential outcomes. Lastly, spread contracts are binary contracts where a person can invest in a specific event outcome both occurring and exceeding a certain threshold and the cutoff. The profit or loss would deviate based on how close the trader got to the actual outcome. An example of this type of contract is that President Trump will win 66% of the popular vote. Spread contracts show the market’s expectation of the median. This contract type rewards the forecasting accuracy of a trader over mere direction.

Market Design

The type of market design used by a prediction market impacts the liquidity, distributions of winnings, and capital choices. Continuous double-action design is similar to the stock market, as it matches buyers and sellers when the bid and asking price align. The market maintains a ledger to catalog the trades to ensure all contracts are correctly paid out. This style of market is conducive to high-activity markets with frequent trading and allows people to move in and out of investment positions based on the current market price. This peer-to-peer style can often be supplemented by automatic market makers, who can act as counterparties to both sides of trades, while making money by arbitraging different market values and taking fees on spreads. This approach helps provide liquidity in markets where there are not enough buyers or sellers at a given time, ensuring that participants can virtually always find a willing buyer or seller at around the then-current market prices. Pari-mutuel payouts occur when all investments are pooled together into one pot and then are divided out amongst the winners in proportion to the size of their investment.

Currency

The most common type of currency used in prediction markets is real currency, defined as actual assets or money. It is typically used because it incentivizes traders to make accurate predictions. More recently, some markets have begun using platform-specific tokens or coins, where payouts or incentives are awarded based on the number of tokens earned. There are advantages to using platform-specific tokens over real currency, as they lower the barrier to entry and can increase participation and liquidity.

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

Stablecoin Rules Must Match How Stablecoins Actually Work 

by Megan Thorpe

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.