The Corporate Alternative Minimum Tax (CAMT) The Digital Chamber & Digital Power Network’s Opposition

Last Updated: June 4, 2025

What is CAMT?

The Corporate Alternative Minimum Tax (CAMT), created by the Inflation Reduction Act of 2022, sets a 15% minimum tax for large corporations that earn more than $1 billion per year on average. Instead of relying on the traditional tax system, which allows companies to lower their taxable income through deductions and credits, the CAMT is based on the income they report to investors in their financial statements. This new system was designed to ensure that highly profitable companies can’t reduce their tax bills to near-zero using accounting strategies, and that they contribute a baseline amount in federal taxes each year.

How Did CAMT Come to Include Unrealized Crypto Gains?

In December 2023, the Financial Accounting Standards Board (FASB) updated its rules to require companies to report the fair market value of digital assets on their financial statements.

This shift means that unrealized gains and losses must now be reflected in a company’s reported income, even if those assets haven’t been sold. Because CAMT calculations are tied to this financial statement income, these paper gains can now trigger real tax obligations. As a result, companies with significant crypto holdings may find themselves liable for taxes on value they have not yet realized in cash, raising concerns about liquidity, fairness, and unintended consequences for digital asset innovation.

Who is Affected?

The intersection of CAMT and the new accounting standards primarily impacts large corporations with significant digital asset holdings. These companies may face substantial tax bills based on paper gains, without having liquidated the assets to generate cash. This scenario raises concerns about liquidity and financial planning, especially in volatile markets.

Legislative Response

Senators Lummis (R-WY) and Moreno (R-OH) have called on the Treasury to issue guidance that excludes unrealized crypto gains from CAMT calculations. They argue that taxing unrealized gains is inconsistent with traditional tax principles and could hinder innovation in the digital asset space. The senators suggest that the Treasury has the authority to adjust CAMT regulations to prevent unintended consequences and maintain a fair tax environment for U.S. companies.

Conclusion

The application of CAMT to unrealized cryptocurrency gains has sparked debate over tax fairness and economic competitiveness. As the Treasury considers potential adjustments, stakeholders await clarity on how digital assets will be treated under the evolving tax landscape.

The Digital Chamber and Digital Power Network oppose CAMT and urge for its swift repeal.

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

The Digital Chamber Files CFTC Comment Letters on Perpetual Derivatives and 24/7 Trading

On May 21, 2025, The Digital Chamber (TDC) submitted two comprehensive comment letters to the Commodity Futures Trading Commission (CFTC). The filings respond to the Commission’s April 21 requests for comment on (1) the regulatory treatment of perpetual derivatives and (2) the feasibility of 24/7 trading and clearing in CFTC-regulated markets. Together, the letters urge a modern, principles-based approach that embraces innovation while preserving market integrity and customer protection.

1. Perpetual Derivatives: Enabling Modern Risk-Management Tools

Why it matters
Perpetual derivatives—or “perps”—have become the most liquid crypto-linked futures products globally. They allow investors to maintain continuous exposure to an underlying asset without the need to roll contracts every month, mirroring the 24/7 nature of the spot crypto markets.

Key points from TDC’s letter

Recommendation
Working definitionA perp is a margined contract with no fixed expiration, priced to spot via a funding-rate mechanism.
BenefitsEnhances price discovery, offers round-the-clock hedging, and lowers rollover costs for both retail and institutional traders.
Risk controlsMargin limits, funding-rate caps, circuit breakers, and real-time surveillance should be standard.
DisclosuresAdditional language on funding-rate volatility, leverage, and liquidity dynamics is needed in customer risk documents.
Regulatory clarityThe CFTC should clarify whether perps are swaps, futures, or warrant a bespoke classification—especially for DeFi-native implementations.

2. 24/7 Trading & Clearing: Aligning Regulation With Reality

Why it matters
Crypto spot markets operate nonstop. Extending that model to regulated derivatives would level the playing field for U.S. platforms and traders, unlock new liquidity, and reduce weekend “gap risk.”

Key points from TDC’s letter

Recommendation
Operational readinessDCMs, SEFs, and DCOs should adopt active-active architecture, cloud-native deployments, and geo-redundant hosting to guarantee uptime.
Automated risk managementReal-time margin checks, auto-liquidation with customer alerts, and continuous collateral valuation are essential for safety.
Updated customer disclosuresRegulation 1.55 risk statements should spell out off-hours volatility, liquidity conditions, and banking-rail constraints.
Modernized rule setCFTC should allow regulated stablecoins or tokenized fiat as acceptable collateral and revisit capital-reporting timelines that assume bank-hour settlement.
Market surveillanceAI/ML-driven tools that detect spoofing and wash trades must run continuously, with standardized data feeds across venues.

These submissions reinforce The Digital Chamber’s core mission: championing a regulatory environment that allows the U.S. to remain the global leader in digital-asset innovation while safeguarding market participants. We look forward to collaborating with the CFTC and other stakeholders to turn these proposals into actionable, forward-looking policy.

CFPB Withdraws Flawed Rule Impacting Self-Hosted Wallets and Blockchain Gaming

The Consumer Financial Protection Bureau recently withdrew its interpretive rule on the Electronic Fund Transfer Act and its related Regulation E that would have brought serious implications to self-hosted wallets and blockchain gaming platforms. 

TDC’s Gaming Workstream, in effort with our partners at the Blockchain Game Alliance, submitted comments to the CFPB in March outlining how the rule, which miscategorized self-hosted wallets as “financial accounts” operated by “financial institutions” was technically incorrect and would place onerous and undue regulatory burdens on self-hosted wallet providers and gaming platforms. If this miscategorization had been implemented, self-hosted wallet providers and blockchain gaming platforms would have been subject to significant KYC requirements and counterparty transaction data collection and reporting practices. 

Self-hosted wallets don’t collect counterparty information, and blockchain gaming platforms — which standardize a “bring your own wallet” approach — do not collect or have access to this data either. In practice, the rule misunderstood how this setup and the technology behind self-custody function and would have applied rules meant specifically for financial intermediaries to non-intermediated technology providers, giving wallet providers and gaming platforms no way to comply. We are pleased to see the CFPB now recognizes this key distinction. 

See the announcement here.

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

TDC Submits Letter of Opposition to IL SB1797 – The Digital Assets Consumer Protection Act (DACPA)

May 9, 2025  

On, May 9, The Digital Chamber formally submitted a letter of opposition to SB 1797, the “Digital Assets Consumer Protection Act (DACPA)”, currently under consideration in Illinois. While we appreciate the intent to provide regulatory clarity and consumer protections, the bill as written would severely hinder innovation, economic growth, and the long-term competitiveness of the blockchain and digital asset industry in the state.

The Chamber’s letter urges lawmakers to reconsider the proposal’s broad and restrictive provisions, which risk pushing cutting-edge businesses and technology development out of Illinois. As the world’s first and largest blockchain trade association, we remain committed to working collaboratively with policymakers to craft forward-thinking legislation that supports responsible innovation and safeguards consumer interests. We hope that the Illinois legislature will consider the unintended externalities of this legislation and modify it for the benefit of Illinoisans. 

Read the full letter here.

About The Digital Chamber

The Digital Chamber is the world’s leading trade association representing blockchain and digital asset businesses. Founded in 2014, the organization has been instrumental in shaping policy, educating lawmakers, and driving regulatory clarity to support the responsible growth of the digital asset industry. For more information, visit www.digitalchamber.org.

Securing America’s Infrastructure: Blockchain Solutions for Cyber and Physical Threats

May 7, 2025  

By: Jean-Philippe Beaudet 

Advanced Persistent Threats (APTs) are covert cyber-attacks where an attacker gains access to a computer network and remains undetected for an extended period of time, either lying in wait to attack at an opportune time in the future or manipulating the network undetected in the background for months or years. 

According to the Joint Cybersecurity Advisory – an international consortium of intelligence and security organizations – the past few years have seen significant nation-state-backed cyber-attacks against the United States:  

  • Chinese-affiliated Volt Typhoon, “has compromised the IT environments of multiple critical infrastructure organizations – primarily in Communications, Energy, Transportation Systems, and Water and Wastewater Systems (WWS) sectors.”1 
  • “Russian state-sponsored APTs have used sophisticated cyber capabilities to target a variety of U.S. and international critical infrastructure organizations, including those in the Defense Industrial Base as well as the Healthcare and Public Health, Energy, Telecommunications, and Government Facilities Sectors.”2 
  • “[Iranian Revolutionary Guard Corps]-affiliated APTs are actively targeting programmable logic controllers (PLCs). These PLCs are commonly used in the WWS Sector and other industries including, but not limited to, energy, food and beverage manufacturing, and healthcare.”3 

Securing critical physical infrastructure and the software it utilizes is a central concern for U.S. national security professionals because these systems underpin every critical service we rely upon for our livelihood and survival. Blockchain technology offers innovative solutions to enhance security, ensure operational integrity, and mitigate risks to these vital assets.  

Immutable Audit Trails for Infrastructure Monitoring  

Blockchain’s decentralized and immutable ledger provides a secure solution for monitoring physical infrastructure. Every operation, system update, and status change can be permanently recorded on the blockchain, allowing stakeholders to audit infrastructure activity in real-time. This transparency ensures that tampering or malicious attempts to compromise critical systems—whether through physical effects or non-kinetic cyber-intrusions—are instantly detectable. Unauthorized changes or anomalies can trigger immediate alerts, empowering operators to react swiftly to mitigate damage and prevent wider-scale disruptions.  

Securing Operational Technology with Decentralized Control  

Operational Technology (OT) systems, such as those controlling power grids, water treatment facilities, and transportation networks, are critical to our national infrastructure. Centralized OT systems are vulnerable single points of failure, where cyber-attacks or insider threats at one entry point could compromise entire networks. Distributing these nodes through a blockchain network significantly reduces the risk of system compromise. This decentralization adds resilience by making it exceedingly difficult for adversaries to launch successful attacks on large-scale infrastructure.  

Strengthening Supply Chain Integrity  

The physical components of critical infrastructure – from transformers in power grids to sensors in water treatment plants – often pass through complex global supply chains before reaching their destination. Blockchain technology paired with Internet of Things (IoT) monitoring provides end-to-end visibility of each component’s journey, ensuring that only verified, authenticated, and untampered-with materials are used in infrastructure systems. By securely recording every transaction and transfer on an immutable ledger, blockchain greatly diminishes the risk of counterfeit or compromised parts being introduced into critical infrastructure, reducing the ability of adversaries to exploit systemic vulnerabilities.  

Implementation of blockchains in service of protecting our critical infrastructure is perhaps one of the most important and efficacious uses cases to date for the technology and we strongly support research, investment, and implementation of them to safeguard U.S. national security.  

The Digital Chamber will continue to collaborate with policymakers, researchers, and industry leaders to advance the integration of blockchain into our nation’s physical infrastructure, protecting the services and resources our citizens depend on. 

About The Digital Chamber

The Digital Chamber is the world’s leading trade association representing blockchain and digital asset businesses. Founded in 2014, the organization has been instrumental in shaping policy, educating lawmakers, and driving regulatory clarity to support the responsible growth of the digital asset industry. For more information, visit www.digitalchamber.org.

The Stablecoin Pivot & U.S. Dollar Dominance in the Digital Era 

It goes without saying that we are at a pivotal moment for the global payments ecosystem. Emerging technologies presenting seamless, real-time, and transparent digital movement of payments across borders, coupled with new and expanding financial architectures that are increasingly being folded into broader strategic geopolitical shifts and realignment policies, amid heightened competition (with both friendly and adversarial countries) that could jeopardize the U.S. dollar’s pre-eminent global position as the world’s reserve currency are all converging, simultaneously. Capturing the opportunities presented by this convergence are immense; so too are the potential economic and monetary headwinds from failing to prioritize and instill U.S. leadership in the digital payments space race. While the U.S. has been slow to get out of the gate on payment stablecoin policy in comparison to other jurisdictions, the recent advancements of both the STABLE Act and GENIUS Act provide Congress with a unique opportunity to bolster U.S. competitiveness and solidify the dollar’s role in the digital era.  

The bipartisan votes to move both the GENIUS Act and STABLE Act through the Senate Banking Committee and the House Financial Services Committee, respectively, represent a seminal moment for payment stablecoin policy in the U.S. For the first time ever, both committees successfully moved payment stablecoin legislation that provides for a robust federal framework responsive to the next evolution of payments. As committee staff continue to work tirelessly to reconcile both pieces of legislation – legislation that The Digital Chamber has been actively engaged in – it is worth noting that the objectives of both legislative texts are not to simply cater to the demands of industry, but rather to redefine, reimagine, and reinforce U.S. competitiveness and the global role of the U.S. dollar in the digital era. As Rep. Bryan Steil (R-WI) aptly put it: “This legislation is a foundational step towards securing the future of financial payments in the United States and solidifying the dollar’s continued dominance as a world reserve currency.” 

A ‘foundational step’ that opens the door to a wide variety of opportunities.  

Take, for instance, the opportunity to move the legislative conversation away from merely speaking about past incidents and hypothetical situations to firmly establishing a federal framework that seeks to address the challenges raised by those past incidents and hypothetical situations. Policymakers and regulators have raised, and continue to raise, concerns about the various risks associated with payment stablecoins, including just how ‘stable’ stablecoins really are. Reports from various jurisdictions and multilateral forums further amplify these concerns – which are justifiably raised, given the demise of past stablecoin issuers and the widespread wealth destruction resulting from the associated fallout. But it is disingenuous to the broader policy debate to raise these concerns without also discussing the regulatory regimes already in place – whether at the State level, in international jurisdictions, or through emerging policy frameworks, such as the STABLE Act or the GENIUS Act. Any serious analysis of the risks and challenges stablecoins may pose must weigh them against these existing and developing standards. Establishing a federal framework that can responsibly address such risks and hypotheticals, while establishing robust protections for users, could put an end to merely talking about one side of the equation. 

Furthermore, we cannot ignore the opportunity to create alternative avenues to purchase U.S. debt. As the U.S. Treasury recently highlighted in its October 2024 report to the Treasury Borrowing Advisory Committee, or TBAC, more than $120 billion worth of collateral backing stablecoins currently in circulation are directly invested in U.S. Treasuries (approximately 2.5% of U.S. Treasury bills (T-bills)). Treasury acknowledged in the report that the structural demand for U.S. Treasuries “may increase as the digital asset market cap grows, both as a hedge against downside price volatility and as an ‘on-chain’ safe-haven asset.” Treasury also stated that the continued growth “in stablecoins, assuming the current trend in stablecoin collateral choices continues (or is forced by a regulator), will create structural demand for short-dated U.S. Treasuries − Recommended issuance should on the margin lean to a higher proportion of T-bills.”  

Both legislative texts would require permitted payment stablecoin issuers to hold reserves that would include U.S. Treasuries. A recent report from Standard Chartered, as described in CoinDesk, found that a federal framework “would further legitimize the stablecoin industry” with the bank also estimating that total stablecoin supply could rise from $230 billion today to $2 trillion by year-end 2028. The bank also estimated that the increase in stablecoin issuance would require the additional buying of $1.6 trillion of Treasury bills over the next four years which “would be enough to absorb all the fresh T-bill issuance planned for the rest of Trump’s second term.” Overall, stablecoin issuers may become the second-largest buyers of T-bills after money-market funds, which currently hold around $2.4 trillion in T-bills. An alternative buyer of T-bills is sorely needed when you consider foreign central bank holdings of U.S. Treasuries continue to decline, as The Digital Chamber recently noted. 

In addition to opening up alternative avenues to purchase U.S. debt, the development of a federal framework and the proliferation of US dollar-pegged payment stablecoins globally also presents alternative avenues to access and utilize U.S. dollars, especially in more marginalized communities or developing economies. In its report, Stablecoins: The Emerging Market Story, Castle Island Ventures not only found that the use cases for stablecoins were broadening beyond their primary use case in facilitating crypto transactions, but also that stablecoin activity was decoupling from broader crypto market cycles proving that stablecoin adoption “has moved beyond merely serving crypto users and trading use cases.” The study also found that of the non-trading use cases, currency conversion (to dollars) is the most frequently reported activity, followed by paying for goods, cross-border payments, and paying or receiving a salary. “Overall, 47 percent of respondents indicated that one of their major goals was saving money in dollars, 43 percent mentioned better currency conversion rates, and 39 percent said earning a yield. The findings are clear: non-crypto uses account for a meaningful share of stablecoin usage modes in the countries surveyed.” 

 These findings were also echoed in a recent blog post sponsored by the Payments Forum of the Federal Reserve Bank of Atlanta. Chris Colson writes: 

“While it’s hard to predict whether or not stablecoins will become a universal payment method, the foundation is forming. Once seen as a hedge against crypto volatility, stablecoins are establishing themselves as a new, innovative payment type. These digital currencies are influencing the future of payments such as purchasing a coffee with a gift card purchased with stablecoins or buying a ticket for a movie at a discount.  

One thing is certain: the future of payments looks a lot more stable.” 

By opening up alternative avenues to purchase U.S. debt and broadening access to U.S. dollar-linked instruments, dollar dominance has taken hold in the payment stablecoin market with approximately 99 percent of the market referencing the U.S. dollar. As U.S. Treasury Secretary Scott Bessent recently remarked, “As President Trump has directed, we are going to keep the U.S. the dominant reserve currency in the world, and we will use stablecoins to do that.” Other countries – both allies and adversaries – are taking notice, however, which again highlights the need for the U.S. to get engaged through enacting a federal payment stablecoin regime.  

Take, for instance, recent discussions in Europe where officials at the European Central Bank (ECB) are searching for answers to address the growing USD-referenced stablecoin market. Ulrich Bindeil, ECB Director General, Market Infrastructure & Payments, raised concerns about the lack of adoption of euro stablecoins during a European Parliament Economic and Monetary Affairs meeting, before recommending a review of the business case and the role of stablecoins for the international role of the euro, including potential adjustments to the EU’s regulatory framework and central bank rules. Similar concerns were raised by Piero Cipollone, Member of the Executive Board of the ECB, where he noted that recent measures taken by the Trump Administration to promote crypto-assets and US dollar-backed stablecoins “raise concerns for Europe’s financial stability and strategic autonomy.” He added: “They could potentially result not just in further losses of fees and data, but also in euro deposits being moved to the United States and in a further strengthening of the role of the dollar in cross-border payments. At the same time, private businesses are increasingly open to accepting stablecoins for customer payments, which could have far-reaching implications for monetary sovereignty.” 

Or, take recent concerns expressed by a Chinese economic think tank about the proliferation of US dollar stablecoins globally. “Once the US dollar stablecoin links the international credit of the US dollar with the application scenarios of the virtual world more closely, it may greatly consolidate the hegemony of the US dollar,” the article states.  

The STABLE Act and GENIUS Act present the opportunity for the U.S. to leap ahead of the competition and solidify the integrity and role of the US dollar in the digital era. The only question is, is the U.S. willing to lead, or cede? 

The Digital Chamber Backs DOJ’s Restraint on Digital Assets Prosecutions

The Digital Chamber Backs DOJ’s Restraint on Prosecuting Digital Assets Entrepreneurs and Innovators

Washington, D.C., April 14, 2025 – The Digital Chamber wholeheartedly supports the recent decision by the U.S. Department of Justice (DOJ) to refrain from prosecuting entrepreneurs and innovators in the digital assets sector for inadvertent lapses in complying with complex and evolving rules.  Reigning in prosecutors from misusing strict liability standards for failure to register as a money services business marks a significant step forward in fostering a fair and just regulatory environment for the burgeoning digital assets industry. 

The DOJ’s decision aligns closely with the core principles of 18 U.S.C. § 1960. This statute is designed to combat money laundering and other illegal activities by dismantling operations that enable such crimes. Its primary purpose is to equip law enforcement with the tools to target those who intentionally exploit the financial system for illicit gain. However, it was never meant to penalize individuals or entities that are committed to compliance, even in the face of complex and sometimes unclear regulations. 

We are particularly encouraged by the clear directive articulated by Deputy Attorney General Todd Blanche emphasizing that the Department’s investigative and prosecutorial focus within the digital asset space will be squarely aimed at “prosecuting individuals who victimize digital asset investors, or those who use digital assets in furtherance of criminal offenses such as terrorism, narcotics and human trafficking, organized crime, hacking, and cartel and gang financing.” This strategic prioritization underscores a commitment to protecting consumers and national security, aligning law enforcement resources with the most significant threats. 

The Deputy Attorney General’s further guidance that prosecutors should generally refrain from criminalizing regulatory violations, including but not limited to unlicensed money transmitting under 18 U.S.C. § 1960(b)(I)(A) and (B), Bank Secrecy Act violations, unregistered securities or broker-dealer offerings, and other registration infractions under the Commodity Exchange Act, absent clear evidence of the defendant’s knowing and willful violation of such requirements, is appropriate and consistent with the original legislative intent. This exercise of prosecutorial discretion acknowledges the genuine challenges faced by innovators and entrepreneurs navigating a rapidly evolving technological and regulatory landscape. It recognizes that unintentional non-compliance, born from a lack of clarity or genuine misunderstanding of complex rules, should not be equated with deliberate criminal conduct. 

The Digital Chamber also welcomes the Justice Department’s active participation in President Trump’s Working Group on Digital Asset Markets, established by Executive Order 14178. The designation of senior legal experts to this vital body underscores the DOJ’s commitment to engaging proactively in the development of a clear and effective regulatory framework for digital assets. This collaboration between policymakers, regulators, and industry stakeholders will be crucial for fostering a balanced and sustainable ecosystem. 

The Digital Chamber also applauds Acting Commodity Futures Trading Commission (CFTC) Chairman Caroline Pham’s statement lauding the DOJ’s policy of ending the practice of regulation by prosecution that has targeted the digital asset industry in recent years and directing CFTC staff to comply with the President’s executive orders and Administration policy, consistent with DOJ’s digital assets enforcement priorities and charging considerations. As Acting Chairman Pham noted in her statement, “[F]or far too long, lawfare from multiple federal agencies against innovators in the digital asset space has created unfairness and uncertainty that has undermined trust in the regulatory process and impeded American competitiveness.” 

The Digital Chamber firmly believes that clarity, education, and open dialogue are essential for the responsible growth of the digital asset industry. The DOJ’s recent decision reflects these principles and provides a crucial foundation for building a regulatory environment that encourages innovation while safeguarding the integrity of the financial system. We commend the Department for its thoughtful approach and look forward to continued collaboration to ensure the United States remains a leader in the digital asset revolution. 

____________________________________________________________________________________ 

Kristopher Klaich 
Director of Policy, The Digital Chamber 

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

TDC Market Structure Principles

The Digital Chamber’s Core Market Structure Principles

Updated with Member Feedback [March 2025]

Below are The Digital Chamber (TDC)’s core market structure principles—the foundational tenets that should guide digital asset legislation. While legislative text will be broader in scope, these principles reflect the consensus of our membership, the largest and most diverse in the United States, spanning key industry stakeholders.

  1. Provide robust consumer protections, including transparent and timely disclosures and pathways for recourse.
  2. The Commodity Futures Trading Commission (CFTC) should be recognized as the primary regulator for digital asset markets (outside capital raising activities or representing equity or debt interests traditionally recognized as securities).
  3. Fungible digital assets should be presumed commodities by default unless they meet a specific, narrowly defined set of criteria establishing them as securities or other. 
  4. Rulemaking for the spot market for digital asset commodities should fall to the CFTC. Regulatory frameworks for digital asset intermediaries should leverage existing registration categories rather than create new, duplicative, or burdensome regimes.
  5. For digital assets that are securities, the SEC shall use its exemptive authority to implement exemptive relief under: 
    • Section 28 of the Securities Act of 1933,  
    • Section 36 of the Securities and Exchange Act of 1934,  
    • Section 6(c) of the Investment Company Act of 1940, and  
    • Section 206A of the Investment Advisers Act of 1940– to harmonize its rules for the protection of investors and facilitation of capital formation.  

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

TDC Responds to CFPB’s Proposed Regulation E Interpretation

TDC Responds to CFPB’s Proposed Regulation E Interpretation on Self-Hosted Wallets and Blockchain Gaming

As part of its Gaming Workstream and partnership with the Blockchain Game Alliance, The Digital Chamber has submitted a formal comment letter to the Consumer Financial Protection Bureau (CFPB) regarding its proposed interpretation of Regulation E as applied to blockchain gaming platforms and self-hosted digital asset wallets. The rule interpretation sought to classify wallets and gaming platforms as financial institutions subject to the Electronic Fund Transfer Act (EFTA) and its corresponding Regulation E compliance requirements. While we commend the CFPB’s commitment to strengthening consumer protection, we explain that applying Regulation E to these technologies is technically infeasible and risks undermining innovation in the blockchain space. 

What You Need to Know:

  1. Self-Hosted Wallets and Developers Fall Outside EFTA and Regulation E
    • Self-hosted wallets are not financial accounts, are not controlled by intermediaries, and their developers do not function as financial intermediaries. These wallets simply provide users with tools to access blockchain networks and fall outside the scope of Reg. E. 
  2. CFPB Should Align with FinCEN’s 2019 Guidance
    • FinCEN has already determined that self-hosted wallet providers are not money services businesses (MSBs) under the Bank Secrecy Act. We urge the CFPB to adopt a consistent approach. 
  3. Blockchain Gaming Platforms Do Not Provide Financial Accounts 
    • Web3 gaming platforms provide profile accounts for gameplay, not for asset custody. Players retain full control of their assets through a “bring your own wallet” model, and transactions occur externally via licensed third-party marketplaces and payment processors—not within the game itself. 
  4. Irreversible Blockchain Transactions Preclude EFTA Compliance 
    • Because blockchain transactions are irreversible by design, game publishers cannot reverse, adjust, or cancel them. Applying EFTA’s consumer protections as written would impose impossible obligations. 
  5. Blockchain Enhances Consumer Protection 
    • However, blockchain gaming platforms and self-hosted wallets reduce the risk of asset loss and unauthorized transactions, while empowering users with full control over their assets—even if a game is discontinued. 
  6. NFTs Are Correctly Excluded from the Definition of “Funds” 
    • We support the CFPB’s conclusion that NFTs are not “funds” under Regulation E, as they function more like collectibles or digital goods rather than mediums of exchange. 

We respectfully urge the CFPB to consider these technical realities and avoid imposing infeasible compliance burdens on blockchain gaming platforms and wallet providers. TDC, the Blockchain Game Alliance, and our respective members stand ready to assist the Bureau in advancing responsible innovation while protecting consumers. 

Read the full comment letter here. 

The Digital Chamber Welcomes Shayla Moon as Director of Government Relations

FOR IMMEDIATE RELEASE 
March 31, 2025 
Contact: digitalchamber@transformgroup.com 

Washington, D.C. –  The Digital Chamber (TDC) recently strengthened its advocacy efforts through the addition of Shayla Moon, Director of Government Relations. “We’re thrilled to welcome Shayla Moon as our new Director of Government Relations at the Digital Chamber. Shayla’s incredible experience, deep network, and undeniable talent make her the right leader at the right time. As Washington prepares to move the first-ever digital asset legislation over the finish line, I have full confidence in Shayla’s ability to lead that charge and deliver real results for our members and the broader industry.” – Cody Carbone – CEO of The Digital Chamber. 

“I am excited to join the Digital Chamber team during this transformative period for the blockchain and digital asset industry. Leveraging my experience in legislative affairs and my deep passion for innovation and economic empowerment, I look forward to advancing efforts to engage policymakers and stakeholders on key issues shaping the future of Web3.” – Shayla Moon – Director of Government Relations of The Digital Chamber. 

Shayla Moon is a dedicated advocate for bipartisan collaboration and global competitiveness in today’s rapidly evolving digital economy. As the new Director of Government Relations at the Digital Chamber, she will help to engage policymakers on legislative and regulatory matters that shape the future of blockchain, Web3, and emerging technologies. With a deep background in public affairs, economic development, and trade association leadership, Shayla is committed to fostering an environment where innovation thrives. 

Her career is defined by a strong commitment to bridging political divides and advancing policies that fuel economic growth. Before joining the Digital Chamber, she was Senior Vice President of the Greater Washington Board of Trade, spearheading initiatives that strengthened the region’s business ecosystem. She has also held policy leadership roles at the National Urban League and the U.S. Department of Commerce, where she influenced key legislative efforts on economic policy, housing, and international trade. Throughout her work with trade associations and nonprofits, Shayla has been a consistent champion for solutions that enhance economic resilience and expand opportunities for businesses and communities alike. 

Beyond traditional policy work, Shayla has played an instrumental role in advancing bipartisan initiatives—from supporting nuclear arms reduction through the New START Treaty to advocating for intellectual property protections in collaboration with the Motion Picture Association of America and Creative Future. Her advocacy underscores a steadfast commitment to policies that drive innovation, safeguard economic interests, and promote U.S. leadership in emerging technologies. 

A proud United States Air Force veteran and HBCU graduate, Shayla remains deeply engaged in community service, lending her expertise to nonprofit boards and advocacy organizations. When she’s not shaping the future of blockchain policy, she enjoys gaming, skiing, and adding to her sneaker collection. 

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About The Digital Chamber 
The Digital Chamber is the world’s leading trade association representing blockchain and digital asset innovators. Founded in 2014, the organization has shaped national policy, defended the industry during its most challenging periods, and secured bipartisan support for blockchain innovation. Today, The Digital Chamber is building the future of the digital economy through education, advocacy, and strategic engagement in Washington and around the world. 

Website: www.digitalchamber.org