Tokens offer an incredible expansion of the way we think of assets by digitizing those assets and offering ways to transfer them in a secure, transparent, and efficient way.


The way in which digital tokens operate is complex and can maintain multiple characteristics – from an investment contract, to a consumable necessary for utilizing a digital platform, to a form of payment or exchange.

This complexity poses a challenge to regulators who attempt to apply legacy regulatory frameworks for securities, commodities, currencies, or perhaps something else. Likewise, innovators are challenged to build viable business models without knowing which regulatory framework will apply. The current financial regulatory framework in the United States is highly complex and fragmented. Often businesses in this industry are regulated at the federal level by FinCEN, the SEC, the CFTC, and others, as well as on the state level, as money transmitters. This decades-old system creates compliance challenges when addressing numerous regulators and exams, for example.

Having an uncertain regulatory environment is a significant impediment to investment and innovation in the blockchain industry, scuttling projects before they begin or forcing them offshore to more established and clear regulatory systems.


The Chamber is working with policymakers to establish the variety of law potentially applicable to this space.

We educate on developments pertaining to the classification of digital tokens, help the industry develop guidelines in significant areas, and advocate where necessary to achieve a predictable legal environment. Part of the Chamber’s strategy involves developing key relationships with stakeholders such as the SEC, CFTC, and Congress.


Formed the Token Alliance to develop a series of tools and resources for industry and policymakers to make informed decisions when engaging in the token economy.

The Token Alliance has issued a series of reports to facilitate the development of token businesses as well as minimize incidents of fraud and promote compliance.

Published guidelines for digital tokens intended as utility tokens that are not intended to be regulated by the SEC and CFTC – providing legal context and reinforcing our pro-compliance stance by detailing the legal landscapes governing digital tokens in the United States, Canada, United Kingdom, Australia, and Gibraltar. The Chamber also provided an economic perspective on the industry with an analysis of market trends.

More recently, the Chamber expanded on those initial resources to balance out the conversation around utility tokens to discuss the rules, regulations, and resulting considerations for those who wish to issue or trade tokens that are or otherwise represent securities.

Published guidelines around cyber security, consumer protection, and anti-money laundering – along with an updated market analysis.

Engaged with Members of Congress and their staff and the agencies to develop workable solutions for industry.

Convened industry stakeholders to discuss challenges when engaging in this regulated marketplace, whether in a traditional banking context, or as a custodian, service provider or customer to coalesce around proposed solutions.