Cybersecurity, Critical Infrastructure and Blockchain Solutions

The Problem: 

U.S. critical infrastructure—like transportation, communication, health, water, and energy—is the backbone of the country’s economy. Yet, it remains increasingly vulnerable to cybersecurity disruptions from adversaries. 

Furthermore, FBI Director Christopher Wray warned earlier this year that “China’s hackers are targeting American civilian critical infrastructure, pre-positioning to cause real-world harmto American citizens and communities in the event of conflict.”1 China is only one of several nation-states undermining U.S. cyber defenses, but Chinese advanced persistent threats (APTs) consistently rank among the most capable and intrusive. In December 2023, U.S. investigators discovered that hackers known as Volt Typhoon, affiliated with the Chinese People’s Liberation Army, had launched cyberattacks against government offices and infrastructure. These attacks aimed to gather intelligence, monitor citizens, and prepare to disable or degrade systems’ performance in future operations targeting the U.S. and its partners. Evidence suggests these APTs may have been active within U.S. networks since 2019. 

Most recently, hackers breached the networks of the largest water utility company in the U.S. that provides drinking and wastewater services to more than 14 million people in 14 states and 18 military installations.2 One can only imagine how our adversaries could exacerbate national emergencies and disasters by degrading these critical systems in times of greatest need and vulnerability. 

The Solution: 

Blockchain technology can help mitigate some of these risks; they are inherently secure, and offer several key advantages that can bolster American cybersecurity capabilities: 

  • Decentralization – Unlike traditionally centralized databases, blockchains operate on a distributed network of nodes. This decentralized architecture eliminates single points of failure, making it significantly more challenging for attackers to disrupt or compromise the entire network. 
  • Immutable Ledgers – Blockchain employs cryptographic hash functions to secure transactions. Each block in the chain contains a hash of the previous block, creating a cryptographic linkage that ensures immutability. This property ensures a permanent, auditable record that is highly resistant to tampering. This is especially important in cybersecurity, where edges and nodes in a network can hold and communicate threat profiles and defensive resources more efficiently than regular, distributed updates pushed out by centralized entities.
  • Enhanced Transparency and Trust – A blockchain is a distributed, shared ledger where all participants can observe and verify transactions, fostering trust and facilitating identification and mitigation of anomalies or fraudulent activity. 
     

What is to be done? 

U.S. allies and adversaries have either developed or are currently developing robust and progressive national blockchain strategies to leverage the high security, high fidelity, and low latency the technology offers. The U.S. government has consistently acknowledged the importance of blockchain technology and the need for policy development to support its secure deployment. For instance, the National Institute of Standards and Technology (NIST) Cybersecurity Framework highlights the importance of incorporating blockchain into cybersecurity strategies.3 Additionally, Executive Order 14028, Improving the Nation’s Cybersecurity, underscores the need for enhanced cybersecurity measures and encourages the exploration of blockchain technologies to strengthen the nation’s cybersecurity posture. 

However, many U.S. policymakers have ignored the seriousness of the threat posed in cyberspace and the possibilities of blockchain to mitigate those threats.  

The Digital Chamber (TDC) recommends that the U.S. government engage the blockchain industry and support its holistic development via an increase in strategic investment and research through agencies like the National Science Foundation, In-Q-Tel, Defense Advanced Research Projects Agency (DARPA), NIST, the Department of Homeland Security, the Department of Defense, and others. 

It is vital for U.S. national security interests to lead in advanced computing and blockchain innovation, to ensure networks are safe, information remains secure, and the U.S. can respond effectively to emerging threats. 

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

The Digital Chamber Announces Strategic Partnership with Stablecoin Standard

The Digital Chamber is excited to announce its strategic partnership with Stablecoin Standard, an organization renowned for its international leadership in promoting transparency, stability, and innovation in the stablecoin ecosystem.  This partnership promotes joint efforts to shape a robust regulatory framework for stablecoins and enhance their adoption across global financial systems. 

The partnership between The Digital Chamber and Stablecoin Standard will focus on several key areas: 

  • Amplifying the Stablecoin Standard’s best practices and frameworks for stablecoin issuance and management. 
  • Engaging with policymakers in the U.S. and abroad to create a balanced regulatory environment. 
  • Educating global stakeholders on the benefits and risks associated with stablecoin use. 

Cody Carbone, President of The Digital Chamber, expressed his enthusiasm about the collaboration: 

“Stablecoins are inherently global, and to drive worldwide adoption of payment stablecoins, we need partners with a deep understanding of international markets. Stablecoin Standard’s proven excellence in navigating complex regulatory landscapes abroad is an invaluable asset. Together, we can ensure that USD-backed stablecoins thrive not just in the U.S. but across global financial systems, bringing stability and efficiency to cross-border transactions.” 

Stablecoin Standard’s leadership also highlighted the importance of this partnership in driving forward-thinking solutions for the stablecoin industry. 

“Stablecoin Standard is thrilled to announce this partnership as we advance our mission to promote responsible innovation. Our collaboration with the Digital Chamber, including active participation in the Stablecoin Working Group, marks a strategic step toward building a resilient and transparent global stablecoin market.” – Beth Haddock, Global Policy Lead for Stablecoin Standard. 

This collaboration underscores The Digital Chamber’s commitment to advancing blockchain technology and digital asset innovation, providing a platform for dialogue between the private sector and regulators.   

How Stablecoins Can Strengthen U.S. Dollar Dominance  

Stablecoins are not just the future of finance—they’re the key to maintaining the U.S. dollar as the world’s leading reserve currency. Once viewed as a tool exclusively for crypto asset trading, stablecoins are redefining global finance by unlocking financial well-being and freedom for a growing, global user base.   

As stablecoin use cases expand beyond facilitating crypto trading to supporting cross-border payments, trade settlement, remittances, payroll, and even enabling access to high-yield financial products—they create new opportunities for users to interact with U.S. dollars, digitally. What was once viewed as a niche financial tool, stablecoins are gradually opening up new, non-crypto-related economic opportunities for users in far-away markets through increased access to dollar-denominated digital payment rails.  

What Are Stablecoins?  

While there is no universally agreed legal or regulatory definition of stablecoin, a ‘stablecoin’ is generally viewed as a type of digital asset that aims to maintain a stable value relative to a specified asset, or a pool or basket of assets. Currently, there are more than $170 billion worth of stablecoins are in circulation today, and a whopping 98 percent of those are linked to the U.S. dollar. Unlike other cryptocurrencies, stablecoins offer price stability, making them an appealing alternative to traditional financial systems. But beyond their importance in protecting crypto asset traders from wild price swings in the underlying cryptocurrency, the utility of stablecoins is increasingly evolving to meet growing demand and preference, particularly from emerging markets, for dollar-denominated financial services.   

Why This Matters  

One of the defining characteristics of stablecoins is their borderless nature. The ability to enable faster, cheaper, and more inclusive financial transactions and services make stablecoins an indispensable tool for the millions of people underserved by traditional financial markets. Given user preference for dollar-denominated financial services, USD-linked stablecoins are a critical tool to extend the global dominance of the U.S. dollar, expand dollar access to new markets, and protect our national security interests at a time of heightened geopolitical instability. As the stablecoin market expands, U.S. policymakers have a unique opportunity to strengthen the dollar’s position on the global stage, extend U.S. financial influence, and protect against the development and scaling of adversarial payment systems.  

The Urgent Need for Stablecoin Policies  

Despite the promise of USD-linked stablecoins, the U.S. has yet to implement a regulatory framework that fully capitalizes on this opportunity. This regulatory gap could leave an open door for other countries to develop their own stablecoin frameworks, potentially diminishing the dollar’s influence in the process.  

Lawmakers must act now to ensure the U.S. remains at the forefront of this digital financial revolution. In our new report, How Stablecoins are Extending U.S. Dollar Dominance: A Policymaker’s Guide to Action, we provide policy recommendations that can help guide U.S. lawmakers in creating a comprehensive framework to secure the dollar’s influence and leadership in the digital age.  

The time for action is now.   


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

Advocating for Fair Value: TDC Sends Letter to the International Accounting Standards Board/IFRS Foundation

The Digital Chamber’s Accounting Initiative took a significant step in advocating for clearer financial reporting standards by submitting a formal letter to the International Accounting Standards Board (IASB). Our letter calls for the adoption of Fair Value accounting standards for digital assets, aiming to provide greater transparency and consistency in global financial reporting. With the rapid evolution of the digital economy, it’s crucial that accounting practices reflect the true market dynamics of assets like Bitcoin and Ethereum.

We look forward to engaging with the IASB and other stakeholders to drive this important initiative forward.

Sen. Hagerty Releases Clarity for Payment Stablecoin Act Discussion Draft

We applaud Senator Hagerty for his leadership in introducing the Senate version of the Clarity for Payment Stablecoins Act. With the stablecoin market now reaching a market capitalization of $173.35 billion[1], the absence of a clear regulatory framework has held back its full potential. The Clarity for Payment Stablecoins Act is a crucial step forward, providing the regulatory certainty that will allow USD-backed stablecoins to thrive in a safe, predictable environment –empowering both innovators and consumers.

“Stablecoin regulation is no longer just an option—it’s a necessity that’s been overdue for too long. Federal Reserve Chair Powell, Treasury Secretary Yellen, and Deputy Treasury Secretary Adeyemo, to name a few, have all repeatedly called for Congress to provide clear guidelines, and we’ve reached a point where the lack of action is holding back progress. Senator Hagerty’s bill builds on previous efforts and provides the regulatory clarity that the market has long been waiting for. It’s time to move forward, not with hesitation, but with the urgency that this moment demands. We simply cannot afford to let this slip any further,” said Cody Carbone, President of The Digital Chamber

While there are key differences between this proposal and the House companion legislation, led by House Financial Services Committee Chairman Patrick McHenry, both bills share a key strength: preserving the option for state regulation of stablecoin issuers. This flexibility is vital for fostering innovation without compromising regulatory consistency or consumer protection, providing issuers with the certainty they need to operate under federal or state regulation and ensuring that stablecoins can thrive within a robust regulatory framework.  

The Digital Chamber Condemns SEC’s Overreach in Issuing Wells Notice to OpenSea

The Digital Chamber (TDC) unequivocally condemns the SEC’s latest overreach in issuing a Wells notice to OpenSea. The notice, which alleges that NFTs listed and sold on the platform are securities, represents a significant and troubling expansion of the SEC’s enforcement actions into the digital economy.

TDC has consistently advocated that certain NFTs, particularly those representing consumer products, are not securities nor financial products and should be outside of the SEC’s jurisdiction.[1]

The SEC’s current approach of regulating by enforcement, as evidenced by this Wells Notice, threatens to stifle innovation, disrupt vibrant markets, and undermine the economic opportunities that NFTs provide to creators and entrepreneurs.

We strongly urge the SEC to reconsider this enforcement-driven strategy and instead work collaboratively with Congress to develop clear and fair regulations that support innovation while protecting consumers. It is essential that regulatory efforts foster the growth of emerging technologies and creative industries rather than hinder them.

TDC remains committed to advocating for a regulatory environment that encourages innovation and secures the future of the digital economy without compromising investor protections. For more information on our efforts and the NFT Working Group visit here.


[1] Read our response to Commissioner Peirce and Uyeda following their dissent in the Stoner Cats case here.


The Digital Chamber’s Statement on the Ripple Labs vs. SEC Case Resolution 

The Digital Chamber (TDC) welcomes the conclusion of the long-standing legal battle between Ripple Labs and the U.S. Securities and Exchange Commission (SEC). As amicus curiae in this case, TDC advocated for regulatory clarity for digital asset businesses

Judge Torres has issued her ruling on remedies in the Ripple case with the following outcomes: 

  • $0 disgorgement, as anticipated, due to the lack of demonstrated losses by the SEC. 
  • $125 million in civil penalties for securities violations related to sales to institutions. 
  • An injunction restraining Ripple from further violations of Section 5 of the Securities Act. 

This decision represents a small fraction of the damages initially sought by the SEC and highlights the flaws in the SEC’s regulation by enforcement approach. While this ruling brings some clarity to the market, it underscores the urgent need for Congress to pass comprehensive market structure legislation. 

We commend our member Ripple for fighting on behalf of the industry in court, setting a precedent that many smaller players could not, and helping to create a more coherent and predictable regulatory environment. 

For more information, please contact: press@digitalchamber.org 


Standing Against SEC Overreach: Defending DeFi Innovation and Financial Inclusion

The Digital Chamber (TDC) strongly opposes the SEC’s latest lawsuit against Consensys, the creator of the MetaMask crypto wallet. This action, targeting DEX routing and staking services, is another troubling example of the SEC’s overreach. 
 
DeFi platforms like MetaMask’s Swaps and Staking democratize finance, providing greater autonomy, efficiency, and access to financial services. They empower the unbanked and underbanked, promoting financial inclusion and accessibility. The SEC’s claim against Consensys misinterprets the technology and stifles progress that could benefit millions.
 
The SEC’s repeated enforcement actions, without clear rules, violate their investor protection mandate and create market uncertainty. With the recent end of Chevron deference, this regulatory ambiguity should not stand. 
 
We stand with Consensys and the wider community in advocating for fair regulation that fosters innovation, protects investors, and promotes financial inclusion. Enough is enough—it’s time for the SEC to stop attacking the digital asset industry and embrace the future of finance.

The Digital Chamber Condemns SEC’s Latest Regulatory Overreach Following Wells Notice to Robinhood Crypto 

Washington, D.C. – The Digital Chamber, the leading trade association representing the digital asset industry, expresses its profound disappointment and concern following the news that Robinhood Crypto (RHC) has received a Wells Notice from the U.S. Securities and Exchange Commission (SEC). This alarming development is yet another instance of the SEC’s unchecked regulatory overreach, coming on the heels of similar notices issued to major industry players like Uniswap and Consensys.

Robinhood’s statement earlier today highlighted their rigorous efforts to comply with SEC regulations, including their attempt to register a special purpose broker-dealer specifically for their crypto operations. Despite these good faith efforts, the SEC has chosen a path that significantly undermines innovation and investor protection in the digital assets space.

The Digital Chamber has consistently argued, through multiple amicus briefs and advocacy initiatives, that the SEC is extending its regulatory reach over the digital asset industry without proper congressional authorization. When Congress is actively deliberating legislation that would define regulatory jurisdictions for digital assets, the SEC’s actions contradict the legislative process.

Moreover, the SEC’s aggressive stance does not align with its stated investor protection mandate. By threatening to stifle a major part of the financial sector through potentially unwarranted enforcement actions, the SEC risks not only alienating innovative enterprises but also undermining the financial autonomy of millions of Americans who participate in the digital economy.

We urge immediate legislative action to address these jurisdictional discrepancies and clarify the regulatory framework governing digital assets. Additionally, SEC Chairman Gary Gensler must be called to testify before Congress to explain the rationale behind the SEC’s continued attempts to stifle an industry pivotal to our economic future.

The Digital Chamber stands ready to support Robinhood Crypto and other affected companies in seeking a resolution that protects their ability to operate and innovate, as well as defending the rights of digital asset users and entrepreneurs nationwide.

For media inquiries, please contact press@digitalchamber.org.


HFSC National Security Subcommittee: Ransomware Hearing

Hearing entitled: Held for Ransom: How Ransomware Endangers Our Financial System 

On April 16, 2024, the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions held a hearing to discuss the critical issue of ransomware and its implications for the security of our financial system.

Witnesses (testimony linked): 

Jacqueline Burns Koven: Head of Cyber Threat Intelligence, Chainalysis 

Daniel Sergile: Senior Consulting Director, Unit 42 by Palo Alto Networks 

Megan Stifel: Chief Strategy Officer, Institute for Security and Technology 

Kemba Eneas Walden: President, Paladin Global Institute 

Hearing Takeaway: 

While digital assets were not the central theme, they emerged as a key topic due to their role in ransomware economics. The hearing delved into ransomware’s operational intricacies, the alarming rise in payment values despite fewer incidents, and the challenge of ransomware as a service (RaaS) operating beyond U.S. jurisdiction. There was a general acknowledgment that ransomware is a national security issue requiring tight regulation, improved public-private cooperation, and resources to help small businesses strengthen their cyber defenses. The discussion highlighted the effectiveness of blockchain analytics in tracing ransom payments and the potential legislative actions to advance the fight against these cyber threats. 

Member Opening Statements: 

Vice Chair Elaine (R-CA) opened the hearing on ransomware, emphasizing the critical need for a comprehensive understanding of this growing cyber threat that has not been fully addressed since pandemic-related fraud hearings four years ago. She highlighted the vulnerability of all sectors to ransomware, which extorted over $1B in 2023 alone, and underscored the potential for even a single employee error to result in significant breaches. Kim pointed out the real-world impacts of such attacks in her district and beyond, stressing the ongoing threat and the use of AI by cybercriminals to exploit system vulnerabilities. She also touched upon geopolitical dimensions, noting Iran’s role in cyber operations against the U.S. and its allies. Kim called for enhanced congressional awareness and a unified effort to address the ransomware challenge, appreciating the bipartisan approach to tackling this critical national security issue. 

Ranking Member Joyce Beatty (D-OH) thanked the Chair for their collaborative efforts on financial issues and for convening the hearing on the escalating threat of ransomware, particularly highlighting its impact on small and medium-sized businesses and national security. She noted the dramatic rise in ransomware incidents, with the value of attacks increasing from $102 million in 2018 to $1.1 billion in 2023. Beatty stressed the need for bipartisan congressional action to enhance business preparedness and consumer protection and praised the Biden administration and Treasury agencies like FinCEN and OFAC for their efforts in combating these attacks through legislation and strategic initiatives to trace ransom payments. She emphasized supporting these agencies rather than undermining their efforts and expressed a commitment to collaborating across party lines to address this significant national security challenge. 

Witness Statements: 

Jacqueline Burns Koven from Chainalysis emphasized the pivotal role of blockchain technology in countering ransomware during her testimony. As Head of Cyber Threat Intelligence, she outlined how the tool facilitates tracking and disrupting ransomware operations on the blockchain, aiding policymakers and law enforcement. Koven debunked the myth that cryptocurrency transactions are anonymous, noting they are public and traceable. She cited significant successes such as the FBI’s Colonial Pipeline case, where Chainalysis’ data led to substantial seizures of bitcoin. Despite the increase in ransom demands, she noted a decrease in actual payments, suggesting greater difficulty for attackers to profit. Koven advocated for enhanced support from Congress to empower federal efforts with blockchain intelligence, emphasizing a collaborative, whole-of-government approach to sustain pressure on ransomware actors. 

Daniel Sergile from Palo Alto Networks discussed the evolution of ransomware into a significant operational risk across various sectors, emphasizing the increasing sophistication of extortion tactics, including AI-enhanced attacks. He identified vulnerabilities due to insufficient visibility across digital infrastructures and outdated IT systems, particularly in financial services. Sergile recommended strengthening cybersecurity through actions like enhancing incident response strategies, improving infrastructure visibility, leveraging AI, adopting zero-trust architectures, and prioritizing cloud security. He highlighted the importance of collaboration within cybersecurity forums like JCDC, the Ransomware Task Force, and FS-ISAC to enhance collective defense capabilities. Sergile’s testimony did not specifically mention cryptocurrency. 

Megan Stifel, Chief Strategy Officer at the Institute for Security and Technology highlighted the critical role of cryptocurrency in ransomware economies during her testimony. She discussed the Ransomware Task Force’s efforts, which led to a report with 48 recommendations—12 targeting financial services—stressing the need for strict regulation of the cryptocurrency sector to mitigate ransomware payments through compliance with KYC, AML, and CFT rules. Stifel emphasized that despite efforts following significant ransomware incidents substantial progress is needed, especially in the financial sector where cryptocurrency transactions facilitate these criminal activities. She proposed enhancing sector resilience, ensuring adequate resources for investigating financial abuses, and promoting cybersecurity best practices through collaboration between the government and private sectors. Stifel concluded by expressing readiness to continue addressing these urgent cybersecurity challenges. 

Kemba Walden of Paladin Global Institute emphasized the sophistication of ransomware attacks and the necessity for a multi-faceted approach to deter and disrupt these threats. Highlighting the Task Force’s work, she spoke about the importance of raising the cost and lowering the profitability of ransomware. Walden identified the critical moments when ransomware criminals are most vulnerable—during the ‘on and off ramps’ of cryptocurrency transactions where fiat currency and crypto are converted— and stressed the need for quick action between financial services and law enforcement to exploit these vulnerabilities. Concluding with a call to action, she urged for the full implementation of policy recommendations, including those that address legislative gaps in combating ransomware and its financial mechanisms. 

Questioning: 

Vice Chair Young Kim opened the questioning by asking Jacqueline Koven what role digital assets play in ransomware attacks and how law enforcement and congress can work to combat ransomware. Koven explained how bad actors are no longer putting their crypto address on display now. This is an Achilles heel for bad actors; once the address is found blockchain analytics can be used to trace everything and “law enforcement is able to understand the entire ransomware supply chain.” 

Responding to another Rep. Kim question, Megan Stifel emphasized AI’s role in ransomware evolution, while Daniel Sergile stressed foundational cyber hygiene for companies. 

Ranking Member Joyce Beatty addressed the vulnerability of small to medium-sized businesses to ransomware due to limited cyber defense resources. Stifel advocated for the use of grant programs, and Walden proposed tax incentives to promote cybersecurity practices among these businesses. 

Rep. Andy Barr (R-KY) highlighted the national security risk posed by the cybersecurity workforce shortage and queried the targeting pattern of ransomware attacks in relation to cybersecurity insurance holders. 

Rep. Maxine Waters (D-CA) discussed the potential effects of banning ransomware payments, with Walden cautioning that such a ban could severely impact small to medium-sized businesses and emphasized the need to fortify cyber defenses for critical infrastructure. 

Rep. Barry Loudermilk (R-GA) emphasized the importance of trust and public-private partnerships in the aftermath of incidents like the Colonial Pipeline disruption. 

Rep. Wiley Nickel (D-NC) echoed Koven’s remarks on the traceability of cryptocurrency in ransomware cases, with Koven underscoring the need for rapid law enforcement action to prevent fund laundering by bad actors that move quickly. Koven also stated that increased training and resources for law enforcement are needed. 

Nickel also asked why there has been a significant increase in ransomware payments. Walden noted a decrease in the number of ransomware payments but an increase in their average dollar value. 

Rep. Roger Williams (R-TX) questioned the evolution of ransomware and the legislative actions needed to keep pace. Sergile illustrated the use of AI in combatting threat actors, and Koven noted the increasing sophistication of ransomware, suggesting a need for involvement from multiple agencies. 

Koven also analogized it to big game hunting as bad actors are increasingly more sophisticated. Koven flagged how nation state actors engaged in ransomware are being used to obfuscate national politically motivated activities like disruption and espionage and the important to involve multiple agencies because of this. 

Rep. Dean Phillips (D-MN) referred to the significant rise in ransom payments and the need for legal and investigative capacity investment. Stifel discussed the shortage of trained investigators, while Walden highlighted the necessity for enhanced government understanding of investigative tools like blockchain analysis. 

Rep. Zach Nunn (R-IA) inquired about the nature of “Ransomware as a Service” and brought up his Public and Private Ransomware Response Coordination Act, which aims to improve threat detection, information sharing, response time, and threat suppression. Stifel described RaaS operators utilizing services outside of U.S. jurisdiction, while Koven highlighted the impact of public-private partnerships citing how their collaborative work with law enforcement has resulted in freezing North Korean funds and the colonial pipeline resolution.  

Rep. Bill Foster (D-IL) continued to push his Digital ID legislation saying implementing Digital ID is the single most useful thing congress could do. This is the same Digital driver’s license idea he pushed for in last year’s July HFSC markup while Sergile replied that the Digital ID proposed may not be infallible.  

Rep. Dan Meuser (R-PA) focused on what makes certain companies targets for ransomware, with Stifel emphasizing the need for more support for small businesses. 

Rep. Monica De La Cruz (R-TX) wrapped up the questioning by supporting the idea of tax incentives for small businesses to enhance their cybersecurity measures, drawing from her personal experience as a business owner.