TDC Response: FDIC’s Requirements for Stablecoin Issuers

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  

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. 

Stablecoin Rules Must Match How Stablecoins Actually Work 

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. 

TDC CEO Testifies at Senate Banking Hearing Entitled: The Affordability Agenda

Cody Carbone
Chief Executive Officer, The Digital Chamber
U.S. Senate Committee on Banking, Housing, and Urban Affairs
Hearing Entitled: “The Affordability Agenda”
Tuesday, June 23, 2026


Chairman Scott, Ranking Member Warren, and members of the Committee, thank you for the opportunity to testify today.

My name is Cody Carbone, and I serve as Chief Executive Officer of The Digital Chamber, the world’s largest digital asset and blockchain trade association. Founded in 2014, our members include more than 250 companies globally across the digital asset and blockchain ecosystem, including exchanges, custodians, infrastructure providers, banks, developers, investors, and emerging technology companies working to build a safer, more competitive, and more inclusive financial system.

I am here today to offer solutions to the challenge of affordability weighing on Americans. The cost of accessing, moving, saving, and investing money should not be a barrier to any of these basic economic activities. The goal of the digital asset industry is to make it as easy to send money as it is to send an email.

For too long, American consumers and small businesses have been forced to operate on financial rails that are slow, expensive, and often difficult to access. These costs rarely appear as a single line item on a receipt, but they show up everywhere: in the price of groceries, in fees charged to small businesses, in the cost of sending money to family abroad, in the delay between earning a paycheck and being able to use it, and in the thousands of dollars families
must pay to close on a home.

That is the hidden affordability problem digital assets can help solve.

Digital assets and blockchain technology will not, on their own, slow inflation, increase the housing supply or wages, or fix every cost pressure facing Americans. But they can reduce the impact of friction and fees and offer competitive alternatives across the global financial system.

This matters most for households with the least room for error. The Federal Reserve reported in May 2026 that only 63 percent of adults could cover a hypothetical $400 emergency expense using cash, savings, or the equivalent – meaning more than one-third could not do so without borrowing, selling something, or being unable to cover the expense at all. 1The same survey found that 59 percent of adults had at least one major unexpected expense in the prior 12 months, with major vehicle repairs, home or appliance repairs, and major medical expenses among the most common.2

The FDIC’s most recent national household survey found that 4.2 percent of U.S. households – approximately 5.6 million households – were unbanked in 2023, while another 14.2 percent – approximately 19 million households – were underbanked.3 These are the Americans most likely to rely on costly, high-interest stopgap measures such as check cashing, money orders, payday loans, pawn shops, and other nonbank financial services.

Even for banked consumers, delays and fees are real and costly. Consumers paid more than $5.8 billion in overdraft and nonsufficient-fund fees in 2023, even after many institutions reduced those charges from pre-pandemic levels.4 And under Regulation CC, funds from many local checks generally do not have to be made fully available until the second business day after deposit, with only the first $275 generally required to be available by the first business day.5 For a household living paycheck to paycheck, that delay is not an inconvenience. It is a cost.

Digital assets can help lower costs in three areas to directly address the challenge of affordability: cross-border payments, everyday merchant payments, and the transfer and ownership of assets.

First, digital assets can reduce the cost of cross-border money transfers.

The United States is the largest source of remittances in the world. The International Organization for Migration has reported that the United States has consistently been the top remittance-sending country, and World Bank bilateral estimates have placed U.S. outward remittance flows at approximately $200 billion in a recent year.

6Globally, remittances to lowand middle-income countries were estimated to reach $685 billion in 2024 and were forecast by
the World Bank to reach approximately $690 billion in 2025.7

The World Bank’s Remittance Prices Worldwide database reported that the global average cost of sending remittances was 6.36 percent in its latest available report, more than double the international target of 3 percent.8 At that price, a worker sending $200 home may lose more than $12 to fees before the money even reaches the intended recipient. Across hundreds of billions of dollars in global remittances, those fees represent a significant economic loss for working families.

The problem is that cross-border payments often depend on multiple parties, different systems, different time zones, currency conversion, compliance checks, and settlement processes that were not designed for the modern digital economy. GENIUS Act regulated US dollar-backed stablecoins can help reduce that friction.

A payment stablecoin can move value globally, around the clock, over blockchain-based infrastructure. While on-ramps, off-ramps, foreign exchange, compliance, custody, and wallet services may still involve costs, the underlying payment rail tends to be faster, more
transparent, and more efficient than many legacy cross-border systems.

The same problem affects American freelancers, contractors, and small businesses. For example, a designer in South Carolina working for a client in Europe, a software developer in Arizona paid by a company in Asia, or a manufacturer in Ohio paying an overseas supplier all face the same basic problem: global payments are slow and expensive, creating a burden on those working to innovate and grow much-needed jobs in their communities.

That is why business-to-business payments have become a fast-growing real-world use case for stablecoins. McKinsey estimated in February 2026 that B2B stablecoin payments accounted for roughly $226 billion, or about 60 percent of global stablecoin payment volume, and that B2B stablecoin payments had increased 733 percent year over year.9 Artemis, Castle Island Ventures, and Dragonfly similarly found significant growth in stablecoin payment activity, including B2B use cases such as treasury operations and cross-border settlement.10

Businesses are using these tools because the payment rails are secure and fast. Lower-cost cross-border payments make American workers and American businesses more competitive, and all American consumers deserve access to these innovations.


Second, digital assets can put competitive pressure on the cost of everyday payments.


Federal Reserve data show how central card payments have become to everyday commerce. In 2024, credit cards accounted for 35 percent of consumer payments by number, and debit cards accounted for another 30 percent. Cash accounted for 14 percent.11

The cost of accepting card payments is material. In a 2025 report, the Government Accountability Office found that selected federal entities collected approximately $43.6 billion from consumers using credit, debit, and other payment cards in fiscal year 2023 and paid approximately $784 million in related fees. Those fees equaled 1.8 percent of revenue, and interchange fees accounted for nearly 90 percent of the fees paid by those entities.12

Federal Reserve data also show that payment network fees are significant. In 2023, network fees to all parties in debit card transactions increased to $12.95 billion, and acquirers and merchants paid 64.9 percent of those network fees.13

For large businesses, payment acceptance costs are a major operating expense. For small businesses operating on thin margins, they can be especially difficult to absorb. And because payment costs are part of doing business, they can affect prices, margins, wages, investment, and consumer choice.

Blockchain-based payment rails can introduce another option.

A regulated dollar-backed stablecoin can settle faster and often at lower cost than many traditional payment methods. Stripe, for example, lists stablecoin payment acceptance at 1.5 percent of the transaction amount in U.S. dollars, including conversion to fiat, wallet and AML screening, fraud prevention, and gas sponsorship.14 Stripe has also stated that stablecoin transfers typically incur flat network fees, often measured in pennies, and that for certain
businesses, stablecoin payments can cost about half as much as other payment methods.15

Properly regulated dollar-backed stablecoins can allow certain payments to settle faster, with greater transparency, and with a different cost structure than legacy payment systems. They should not replace cards, cash, ACH, wire transfers, or other payment methods. Different payment methods serve different needs, and consumers should be empowered with the best choices possible for their individual needs and preferences.

A cheaper, faster, compliant payment rail can give merchants more choices. It can allow businesses to experiment with lower-cost payment options. It can create pressure for incumbent payment systems to improve. And over time, greater competition in payments can benefit consumers.

It is also consistent with the way American markets work best. When a new rail can move the same dollar more efficiently, the answer should not be to block it. The answer should be to regulate it properly, supervise it effectively, and allow responsible market participants to compete.

That competition matters for small businesses. A family-owned restaurant, a local grocery store, a contractor, a barber shop, or an online seller may not have the bargaining power of a national retailer. Safer, more compliant, lower-cost options position businesses better to compete, invest, hire, and serve their customers.

Consumers benefit when payment systems compete, especially when innovation happens under U.S. rules, rather than in offshore markets where American regulators have less visibility to protect consumers.

Because of this Committee’s leadership, Congress has already taken a major step. The GENIUS Act created a federal framework for payment stablecoins, including requirements for reserve backing, public reserve disclosures, supervision, and compliance. That framework can help give consumers, businesses, banks, and regulators greater confidence that payment stablecoins are backed, redeemable, supervised, and compliant.16

Third, digital assets can reduce barriers to owning and transferring assets.

Tokenization is the process of representing ownership, rights, or claims on a blockchain. That can include financial assets, such as funds, bonds, Treasuries, private credit, collateral, and commodities. But it can also include real estate interests, invoices, receivables, warehouse receipts, supply chain records, intellectual property royalties, energy credits, and other records of ownership or entitlement.

That matters because today, too many markets still rely on fragmented, paper records and duplicative processes. One system records ownership. Another verifies documents. Another sends payment instructions. Another clears the transaction. Another settles it. Another reconciles the records after the fact.


Tokenization can help reduce that friction by allowing ownership records, transfer instructions, payment, settlement, and verification to operate through a shared digital infrastructure. That can mean clearer records, faster settlement, stronger auditability, fewer duplicative checks, and lower administrative costs.

This matters across the economy.

For funds and securities, tokenization can make issuance, subscriptions, redemptions, transfer agency functions, and investor recordkeeping more efficient.

For Treasuries and collateral, it can help assets move more efficiently through the financial rules and regulations that support the markets Americans rely on every day.

For small businesses, tokenized invoices and receivables can help verify payment rights, improve recordkeeping, and unlock working capital faster.

For supply chains, tokenized warehouse receipts and inventory records improve transparency and accuracy about who owns what, where it is, and when it changed hands.

And for real estate, tokenization can help modernize one of the most expensive and paperheavy transactions most Americans will ever experience.

When a family buys a home, thousands of dollars can be consumed by the process of transferring ownership, verifying title, moving funds, recording documents, and closing the transaction. Closing costs often range from 2 to 5 percent of the purchase price, not including the down payment.17

On a $350,000 home, which is currently lower than the median U.S. average price, that can mean $7,000 to $17,500 before a family receives the keys.

While those costs pay for important protections, it should concern everyone on this Committee that the largest financial transaction most Americans will ever make still depends on a process that can be fragmented, paper-heavy, duplicative, and expensive.

Homeownership is already hard enough, especially for first-time buyers. Fannie Mae has found that closing costs are a meaningful obstacle for first-time and low-income homebuyers. In an analysis of approximately 1.1 million home purchase loans acquired in 2020, Fannie Mae found that more than 14 percent of low-income first-time homebuyers had closing costs equal to or exceeding their down payment.18

Modernizing record-keeping, including proof of ownership, transferring value, and settling transactions, are a few ways to make life easier for our neighbors through transparency, reducing duplicative verification, improving auditability, and expanding efficient pathways for transferring interests in assets, rights, and records.

Beyond lowering costs, tokenization can be a key to unlocking access to ownership by reducing the cost of entry for large-scale investments.

Fractional ownership, when properly regulated, can allow participation in smaller increments while preserving investor protections, disclosures, custody standards, suitability requirements, transfer restrictions, and market integrity rules.

That expands wealth-building opportunities beyond those with existing wealth. Though not yet operating at a national scale, the potential is easy to see in the efforts made so far to tokenize and offer small shares for investors to buy and hold.
Major financial institutions, asset managers, technology companies, and market participants are already building toward a more efficient model for issuing, owning, transferring, and administering assets, rights, and records. Citi Institute projected in June 2026 that the global tokenized asset market could grow from approximately $17 billion today to $5.5 trillion by 2030.19 McKinsey has estimated that tokenized market capitalization could reach approximately $2 trillion by 2030, excluding cryptocurrencies and stablecoins.20

Those projections are not a guarantee. They show where markets are moving. A critical question that only Congress can answer is whether that activity will happen under U.S. rules, with U.S. regulators serving U.S. consumers and businesses, or whether it will move offshore.

Regulators are now implementing the GENIUS Act through rules governing issuer supervision, reserve standards, custodial and safekeeping requirements, Bank Secrecy Act obligations, sanctions compliance, and customer identification requirements.21

The GENIUS Act was a major bipartisan accomplishment. It showed that Congress can create clear rules for digital assets that support innovation, protect consumers, and give regulators the tools they need.

And we recognize the heavy lifting this committee has continued to do to ensure consumers, innovators, and regulators can build onshore with confidence.

On May 14, 2026, this Committee advanced the Digital Asset Market Clarity Act by a bipartisan vote of 15 to 9.22 That vote matters because market structure is the foundation for responsible digital asset innovation, and because digital asset regulation should not be partisan.

A clear market structure framework will define who the primary regulator is for what kind of token, what disclosures are required, how intermediaries must operate, how customer assets are protected, and how illicit activity is policed.

This matters for affordability because uncertainty carries a real cost. Muddy, antiquated regulations push responsible companies to divert resources from product development to legal and compliance, and cause banks and regulated financial institutions to hesitate to engage in emerging and more efficient products. Consumers are left with fewer regulated options, and regulators are forced to oversee a market without clear statutory tools.

The better approach is clear, durable law: a framework that defines regulatory authority, and gives innovators commonsense rules and obligations to ensure consumers can confidently participate in the market and have long-term protections.

Digital assets are not a silver bullet for affordability, but they are a practical tool for reducing financial friction.

Digital assets can help lower those costs, but only if Congress provides the clarity needed to build responsibly.

The Digital Chamber and our members are committed to supporting fair, responsible regulation. We support strong consumer protections with clear rules for market participants and innovators. Such a framework encourages and supports innovation in the United States.

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

Latin America’s Surge in the Global Race to Adopt Stablecoins

The GENIUS Act established the first federal framework for stablecoin issuance in the U.S. in July 2025. In the year since, stablecoin transfer volume has reached roughly $4.5T in Q1 2026. Latin American countries are seeing that success and are working to establish regulations that will likely fuel more crypto adoption in traditional finance in the region. Notably: 

  • Brazil was among the first Latin American countries to adopt such regulations through its “Virtual Assets Law.”  
  • Bolivia reversed its decade-long crypto ban in June 2024. 
  • Argentina introduced mandatory exchange registration in 2025, and many more frameworks are being developed in these markets.  

As adoption and regulation of stablecoins have pushed Latin America’s crypto market into more commercial use cases, 71% of Latin American institutions have already begun using stablecoins for cross-border payments, the highest regional adoption rate globally. Additionally, on-chain crypto volume in the region rose 60% year-over-year in 2025, driven largely by stablecoins.  

While the drivers of adoption differ, the common effect is that in 2025, there was $324 billion in stablecoin transaction volume across LATAM, representing an 89% year-over-year surge. In Brazil, currently over 90% of all crypto flows are stablecoin-related, and over 60% in Argentina. Hotels, restaurants, and tourism businesses are also beginning to accept stablecoin payments directly from international visitors, saving both businesses and tourists millions previously lost to exchange rates and credit card fees

Business-to-business (B2B) stablecoin volumes grew 30x globally in the past two years, and Latin American businesses, banks, and fintechs have been among the first to widely adopt stablecoins.  

  • Mizuho research reports that remittance fees via stablecoins in the US-Mexico corridor are now under 1%, a major improvement for consumers compared to the 5% to 7% average fees charged by traditional money transfer services.  
  • Across the $142 billion that U.S. individuals sent to Latin America in 2025, if conducted through low-cost stablecoin infrastructure, this could result in $6.1-8.9 billion in consumer savings. 

As regulations become clearer and adoption continues to grow, stablecoins are likely to play an increasingly important role in payments, savings, and cross-border transfers throughout Latin America.  

TDC Forums: The Place to Meet and Learn 

In a world filled with noise, decision makers’ greatest resource is time. TDC Forums are time well spent for these key leaders, and our next engagements in New York City and Chicago are filling up fast. 
 
Though built for a specific locality, the events are globally focused. With limited seating, the conversations remain small but inclusive in these half-day convenings. TDC Forums are in the works for other key international cities and build on The Digital Chamber’s reputation for sophisticated policy engagement and industry-shaping collaboration between the digital assets industry, global financial leaders, and policymakers. 
 
Rather than simply including another panel, the events are built for engagement. Whether in a group setting or one-on-one, the opportunities at TDC Forums are designed to ensure meaningful connections can grow high-impact ideas. 
 
TDC Members are invited to join the events at no cost. Non-members can join for a nominal fee. Each Forum is also open to the public and meant to diversify voices engaging in key policy issue discussions. TDC Forums are another way TDC is helping the broader industry shape the future of the digital economy across the globe. 

To learn more about the latest cities playing host to a TDC Forum and sponsorship opportunities, click here.

Insider Trading and Prediction Markets; Blockchain Transparency Drives Enforcement  

Recently, insider trading allegations related to prediction markets have been dominating headlines. One of the recent headline grabbers includes allegations a U.S. military official committed fraud and misuse of classified information. The soldier allegedly used classified intelligence related to U.S. military action in Venezuela to place a series of trades on Polymarket’s offshore platform, generating over $400,000 in personal profit. He has been charged with multiple criminal offenses, and the CFTC has also filed a lawsuit against him for civil damages. 

According to the criminal indictment, to bypass the offshore platform’s restrictions against use by U.S. individuals, it is alleged the individual accessed the platform through foreign accounts and attempted to conceal his activity by moving funds through offshore accounts. However, the activity was quickly discovered despite alleged attempts to conceal because the trades at issue were executed through public and immutable blockchain technologies. The suspicious timing and size of the trades were rapidly spotted by the public and quickly uncovered in media reports, leading to a federal investigation and the resulting criminal and civil charges. Since everyone could see the suspicious trading activity, accountability was as transparent as the blockchain ledger. 

As the call for prediction markets regulation bubbles at the state and federal level, this example illuminates a number of key policy discussion points: 

• Transparency: Blockchain-based technologies and platform monitoring appear to have contributed to identifying unusual trading patterns, which were later investigated by authorities.  

• Existing rules: This case represents one of the first major criminal prosecutions and civil enforcement actions for insider trading involving prediction markets. The case suggests that existing fraud, commodities, and misuse-of-information statutes can be applied to conduct on prediction markets.   

• Jurisdictional complexity: U.S. law prohibits certain event contracts, such as those involving war, which is why the individual allegedly had to use workarounds to trade on offshore markets. This highlights that U.S. regulations prohibiting event contracts on things like war and terrorism are still in full force, but the borderless nature of prediction markets and digital assets complicate who and how bad actors are brought to justice.  

• Regulatory scrutiny of prediction markets: The case and similar recent civil enforcement actions are heating up policy discussions around how prediction markets and insider trading with sensitive information on those markets should be regulated. Even though the trades happened on an offshore platform, U.S. authorities can still enforce the law. If someone in the U.S. tries to bypass restrictions to access those markets, they can be held accountable if they break U.S. law.  

Though existing laws already prohibit the insider trading alleged in this matter, clearly tying those existing rules to emerging technology like prediction markets in cases like this is necessary to ensure law enforcement can fairly police online trading activity. As with so many emerging technology products, there is a clear need for consistent regulatory frameworks that address misuse without stifling innovation. 


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

Arizona Sets the Standard: Digital Asset Reserves Next Act

By Anastasia Dellaccio, Executive Director, Digital Chamber State Network

 The states that move early and with intention will attract capital, talent, and infrastructure that underpins the next generation of financial systems. 

Arizona has advanced one of the most comprehensive state-level digital asset reserve frameworks in the country. The legislature recently passed SB 1649 and SB 1042, sending them to Governor Katie Hobbs’ desk, but whether they will be signed into law still remains uncertain.  

SB 1649 establishes a Digital Assets Strategic Reserve Fund managed by the State Treasurer, seeded with seized and forfeited digital assets at no new cost to taxpayers. The Treasurer is authorized to hold, invest, and where appropriate, lend those assets to generate returns. The bill proposes this effort be governed by a “cryptocurrency fair value” framework that evaluates assets on measurable criteria like market capitalization, network activity, and ecosystem development.  

SB 1042 would complement the reserve by enabling Arizona to diversify a small portion of public funds beyond traditional assets into high-potential digital assets. 

Why This Matters for Arizona’s Fiscal Future

As state debts and unfunded pension liabilities grow, governments face mounting pressure to protect long-term purchasing power without burdening taxpayers. Traditional portfolios have a mix of bonds, cash, and Treasuries. Digital assets offer states a new diversification opportunity, and Arizona’s framework is designed to capture that upside responsibly.

The digital asset industry has grown from roughly $10 billion in total market capitalization a decade ago to between $2 and $3 trillion today and shown increasing stability alongside sustained growth. Critically, SB 1649’s weighted, metrics-based framework for determining eligible assets means Arizona is not relying on a concentrated position on any single token. It is building a diversified digital asset allocation governed by principled, measurable criteria. That is the same discipline we expect from any well-managed public fund, now applied to an asset class most state treasuries haven’t yet had the tools to access.

Good Policy Built Right

Passing the legislation is step one. Implementation is the bigger challenge, and Arizona has the opportunity to set an example for state governments across the country

Diversify thoughtfully within the framework. SB 1649’s fair value framework was designed to allow Arizona to invest across a diversified mix of assets rather than concentrating exposure in a single token. As the Treasurer’s office operationalizes the fund, it should establish clear, repeatable processes for evaluating asset eligibility, reviewing portfolio composition regularly, and resisting any pressure to treat the fund as a single-asset vehicle. Diversification across digital assets with different use cases, network characteristics, and market dynamics is what transforms this reserve from a novelty into a durable fiscal tool.

Go beyond periodic attestation and build out the full reserve stack. As Arizona moves into the next phase of digital asset innovation, it should anchor its framework in transparency and durability. Across unclaimed assets, strategic reserves, and state stablecoin regulation, Arizona should aim for the ceiling in its digital asset administration. Traditional monthly audits show what was true at a single point in time, while programmatic, on-chain proof of reserves can show what is true continuously, every block, every second. But proof of reserves is only the foundation. Proof of composition provides transparency into the makeup of reserve assets to guard against concentration and tail risk, while proof of solvency can continuously demonstrate that total assets exceed liabilities.

Together, these layers distinguish a durable financial system from a compliance checkbox. This framework is ultimately about more than compliance; it’s about building enduring financial infrastructure and services that strengthen Arizona’s long-term fiscal stability. This also offers assurance to regulators that they can cover their bases by leveraging technology to hedge against risk.

Use the custodial flexibility the bill provides. SB 1649’s amended language recognizes secure custody solutions as qualified custodians, and the bill preserves the Treasurer’s ability to self-custody assets directly using technology providers. This is a wise choice, as it is typically more cost-effective, secure, and less exposed to third-party risk than relying exclusively on institutional custodians.

The Bigger Picture

Arizona’s move is not just about reserves. It is a signal. A signal that states are beginning to treat digital assets as a strategic asset class, a legitimate investment opportunity, and a clear message to innovators that Arizona is open for business.

The Digital Chamber State Network stands ready to help ensure what comes next matches the ambition of what has just been achieved.

Maryland Leads the Way: Turning Digital Asset Policy into Progress 

By Anastasia Dellaccio, Executive Director, Digital Chamber State Network | Jacqui Cooper, CEO, Maryland Blockchain Association 

At its best, digital asset policy is not only about markets or technology. It is about expanding access, strengthening protections, and creating real opportunities. For Maryland communities, from the unbanked to students, to entrepreneurs and workers across the state, they are seeing the benefits of clarity, coordination, and bipartisan action in their legislature to ensure that opportunities for jobs and innovation can flourish in their state. 

As Governor Wes Moore recently underscored at The Digital Chamber’s DC Blockchain Summit, “Innovative technologies like blockchain must work for everyone, including underbanked communities.” Maryland is not just embracing that vision. It is putting it into action.  

The 2026 legislative session will be remembered in Maryland as the year digital asset policy moved from conversation to commitment. As the 2026 legislative session draws to a close, the state has clearly asserted that Maryland is open for business. Lawmakers advanced a cohesive, bipartisan set of policies designed to move blockchain technology from theory into real-world applications and, on a broader scale, have positioned the state to compete for digital assets jobs by embracing responsible innovation. 

Building the Legal Foundation 

The 2026 legislative session will be remembered in Maryland as the year digital asset policy moved from conversation to commitment. 

At the heart of this session, progress is SB 154, which modernizes Maryland’s commercial code to recognize controllable electronic records. Though not flashy, this foundational move aligns UCC Article 12 and considers adopting provisions for Controllable Electronic Records. Simply stated, Maryland has modernized its commercial law to recognize and protect digital assets with the same rigor as traditional physical property. For consumers and businesses, this means digital assets are just like other asset classes, which can be owned, transferred, financed, and secured with distinct legal clarity. 

Putting Blockchain to Work 

Maryland is equally focused on harnessing blockchain technology for tangible public value. SB 168 / HB 810 is now headed to the Governor’s desk and means the state will actively study evaluating recording real property titles on blockchain-based systems. By piloting blockchain-based title verification, the state is making a concrete investment in modern technology that will reduce fraud, streamline transactions, and shine a light on systems traditionally burdened by inefficiency and opacity.  

Playing the Long Game 

Maryland’s work is smart and likely to be successful because it is built on a foundation of technical expertise. 

SB 376 / HB 470 establishes a Digital Asset and Blockchain Technology Task Force, creating a standing engine for the state to continue to lead in policy development. This task force will offer a low-risk, low-cost, and transparent path to policymaking, while enabling lawmakers to build internal expertise, compare approaches taken by peer states, and assess real-world use cases. By doing this work before committing public resources or adopting specific rules, Maryland is more likely to continue their practical and bipartisan regulatory efforts. 

Meanwhile, SB 662 / HB 1355, the Maryland Stablecoin Act, is advancing a clear, credible framework for payment stablecoins, providing the consumer protections and banking standards necessary for digital dollars to flourish in the state’s economy. Although this legislation needs some improvement, primarily around reserves and a few other standards, it does a good job at adhering closely to the federal law, the GENIUS Act, and creating nimble efforts to adapt to future industry needs. 

Next Opportunities 

Not every blockchain legislative effort in Maryland advanced this session, and that matters too. 

Unfortunately, SB 759 / HB 859, which addressed staking and broader financial innovation, did not advance out of committee. Marylanders deserve access to staking-as-a-service offerings, as described in this legislation. The industry’s coalition has engaged in educating policymakers around this topic, and staking legislation remains a top priority as it signals a long-term commitment to sophisticated financial technology.  

The Maryland Blockchain Association calls these education efforts its “Lighthouse” strategy and will continue to push for clarity that attracts serious players and builds a real, durable digital assets innovation ecosystem. 

The next opportunity is the Maryland BlockchAIn Bootcamp & Workforce Expo, will be held from July 13–17, 2026, at Capitol Technology University. The Expo will gather consumers, students, businesses, state leaders, and the new cohort of The Blockchain Legal Institute’s Business of Blockchain Interns to demonstrate real-world applications for blockchain technology. A Replicable Blueprint 

Groups that share Maryland’s ambition are beginning to take root in other states. Together, The Digital Chamber’s State Network and the Maryland Blockchain Association have partnered to help increase awareness of the facts around blockchain.  

We commend the Maryland lawmakers who drove this progress, including Delegate Boafo, Senator Watson, Delegate Amprey, Senator Hayes, and Senator West. Their leadership reflects exactly the kind of policymaking this moment demands, grounded not just in innovation, but in impact. We look forward to our continued work with them to ensure that Maryland continues to prioritize the values of privacy, freedom, and innovation that Marylanders deserve. 

TDC Launches its State Network: A New Chapter for State-Level Leadership in Digital Asset Policy 

The Digital Chamber (TDC) recently launched our State Network, an initiative designed to unify, strengthen, and elevate digital asset advocacy at the state level. The launch brought together state lawmakers, industry leaders, and partners from across the country to set a shared vision for how states can lead the future of blockchain innovation and responsible policy development.  

The State Network builds on the proven model that has guided our success in Washington. At the federal level, we have seen firsthand that a coordinated and unified advocacy strategy is the most effective way to advance thoughtful digital asset policy. Our biggest wins have come from consistent messaging, aligned priorities, and the full engagement of our member companies. Now, we are applying that same approach to the states, where digital asset legislation is moving fast, and where lawmakers are seeking trusted, technically accurate input as they craft policies that will shape our economic future. 

A High-Energy Launch to Chart the Road Ahead 

The launch event created a dynamic space for lawmakers and innovators to connect directly on the opportunities and challenges shaping state policy. The conversations were highly engaged and fully bipartisan, reflecting a shared recognition that the United States must lead the next era of financial and technological innovation. 

A highlight of the evening was the participation of the Future Caucus, our new strategic partner in bipartisan state engagement. Their leadership underscores a generational commitment to advancing innovation, strengthening public trust, and shaping a forward-looking policy environment for digital assets. Together, TDC and Future Caucus will equip young state lawmakers with the tools and knowledge they need to help modernize financial systems, protect consumers, and promote economic competitiveness. 

Another major announcement from the event was the launch of the State Network Microgrant Program, a new initiative that will provide small grants to support state-level research, innovation pilots, educational programs, and community outreach efforts focused on blockchain and digital asset policy. This program is designed to empower local leaders, university clubs, and state blockchain organizations to develop smart engagement activities that help to educate policy leaders and showcase practical blockchain use cases that have the potential to make government more efficient and transparent. 

Taking the Federal Model and Bringing It to the States 

For over a decade, TDC has demonstrated that unified advocacy delivers results. Our success at the federal level has come from consistent priorities, credible information, and constructive, bipartisan engagement. The State Network applies that same proven model to state legislatures. 

The mission is simple: give policy makers and regulators the tools, expertise, and real-world examples they need to craft smart policy that protects consumers, supports innovation, and strengthens local economies. 

Key pillars of our State Network include: 

  • Advancing and supporting actionable policy campaigns in priority states – including drafting legislation, coordinating testimony, engaging regulators, and mobilizing members to help pass clear, pro-innovation digital asset laws.
  • Showcasing model policy solutions and providing guidance in legislation development and rulemaking related to key issues facing our members like unclaimed-property, advancing DUNA-based government efficiencies, stablecoin implantation, money-transmission rules, and promoting innovation through sandboxes, pilot programs, and more so resources are shared across states where lawmakers often legislate in silos.
  • Providing nonpartisan education and technical guidance.
  • Demoing blockchain applications that showcase member company solutions.
  • Developing strategic policy partnerships with associations and state-level blockchain organizations, university clubs, and like-minded groups.
  • Ensuring industry voices are represented consistently.

Our Work Is Already Underway 

Before the formal launch, our State Network had already begun engaging key constituencies across the country. We have led briefings in Arizona for a group of state reps, briefed the Ohio State Treasurer’s office, presented to the New Hampshire Token Commission, briefed the New York Treasury Managers Association and its affiliates, and there is more to come.  

What Comes Next 

Over the next year, our State Network will roll out a robust slate of programs, including the Microgrant program, as well as a Digital Asset Tour meant to engage policy makers and stakeholders in critical states across the country.  

With this launch, TDC is entering a new chapter of coordinated, strategic, and forward-looking state-level advocacy. We are proud to lead this effort alongside our member companies, and we look forward to building a strong, secure, and innovation-focused digital asset future in partnership with states nationwide.