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US lawmakers reiterate concerns about ‘sham’ crypto firm audits to PCAOB

Two U.S. senators cited the collapse of FTX when writing to the PCAOB chair Erica Williams in January, but now suggest improper auditing could have affected three banks as well.

United States Senators Elizabeth Warren and Ron Wyden have cited the recent collapse of three major banks to call on the Public Company Accounting Oversight Board to “rein in” audits of crypto firms.

In a March 21 letter to Public Company Accounting Oversight Board chair Erica Williams, Warren and Wyden reiterated concerns over “shady audits” of crypto companies the pair raised in January, this time referencing the failures of Silvergate Bank, Silicon Valley Bank, and Signature Bank. The two senators requested Williams respond to questions on whether improper audits and proof-of-reserve reports “may have played a direct or indirect role” in the collapse of the banks.

“You have ample authority to establish standards for auditors that require any SEC-registered auditor to only conduct audits of crypto firms that comply with existing standards for audit quality,” said the letter. “Based on the obvious threats to investors and the public interest posed by sham audits, any audits and reviews of crypto firms done by SEC-registered auditors must maintain a high level of scrutiny. Otherwise, these sham audits must be addressed by PCAOB.”

Warren and Wyden suggested that defunct crypto exchange FTX, currently in bankruptcy court for Chapter 11 proceedings, could have impacted the events around Silvergate and Signature, given the firm “received sham financial reviews” by auditors registered with the PCAOB:

“In assessing the risks associated with the FTX’s deposits, as well as those of other crypto-related customers, the banks may have relied on the misleading and faulty financial information provided by proof-of-reserve examinations.”

Related: Crypto firms may turn to ‘shadow banks’ following major collapses — Molly White

The two senators requested Williams provide a staff-level briefing on March 31, and respond to the questions raised by April 4.

Warren, an outspoken critic of many aspects of the digital asset space in Congress, has been pointing to a lack of regulatory oversight as part of the reason behind the failure of the aforementioned banks. On March 15, she requested Federal Reserve chair Jerome Powell recuse himself from any review of regulatory failures leading to the collapse of Silicon Valley Bank.

Magazine: Unstablecoins: Depegging, bank runs and other risks loom

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Congressional privacy proposals could kill scores of blockchain projects

Lawmakers may be on the brink of scaring blockchain projects into moving offshore or causing them to shut down altogether.

With public trust in large tech companies at an all-time low, Congress is once again considering comprehensive data privacy legislation. But the rise of blockchain technologies and the nascent decentralized web mean that these comprehensive proposals are already behind the times. Without major revisions, these legislative proposals risk strangling decentralizing technologies in the cradle. 

The 118th Congress has held many hearings on data privacy, and it is crucial that lawmakers consider how their proposals might impact technological innovation. In order to properly balance conflicts between individuals’ right to control their information and the necessity of innovation, lawmakers should abandon one-size-fits-all proposals in favor of the time-tested, sectoral approach to data privacy.

While there are several comprehensive data privacy bills floating around Capitol Hill, the one that has the most momentum is the American Data Privacy Protection Act (ADPPA). This bill would strictly govern how companies collect, process or transfer user data by requiring companies to minimize data collection and grant consumers the right to opt out of data collection, among other things.

Related: Did regulators intentionally cause a run on banks?

The ADPPA is a well-intentioned piece of legislation designed to give consumers more control over their information. The bill also reflects the desire of many lawmakers to avoid a patchwork approach to data privacy by creating a national standard of comprehensive privacy protections.

Unfortunately, when it comes to data privacy rules, the past is prologue. Similar approaches to comprehensive data privacy protections have failed to account for nascent technologies, such as blockchain networks, significantly chilling innovation. For evidence of this, look no further than the European Union’s General Data Privacy Regulation (GDPR).

In addition to inhibiting investment and innovation in traditional tech industries, the GDPR is wholly incompatible with decentralizing technologies like blockchains that lack centralized controllers. In fact, the European Parliamentary Research Service admitted as much in a 2019 report. One of the biggest incongruities between the GDPR and blockchain technologies is the question of what entity is being regulated.

Among more traditional internet companies, it is relatively easy to determine who is collecting, processing and transferring data because they are usually centralized. In a decentralized system like a blockchain network, that question becomes significantly more difficult to answer. When thousands of computers are operating open-source code to verify public transactions, who or what is collecting, processing or transferring covered data? Like the GDPR, the ADPAA is silent on this question as well as numerous others relating to how decentralized networks would have to comply.

The European Union’s response to such incongruity in the GDPR is that innovators should build technologies that comply with the law in spite of the fact that doing so is practically impossible. This burdensome requirement has helped lead to a dearth of technological innovation across Europe. The same is likely to happen here if the United States were to implement the ADPPA as written. Many blockchain projects would move offshore or shut down altogether, taking with them enormous potential for economic growth and innovation.

Fortunately, there is an alternative approach that the U.S. could take that could simultaneously limit the problems of a patchwork approach to data privacy law and allow flexibility for innovative technologies. The answer is to break up comprehensive data privacy proposals into nuanced, sector-specific bills. For example, Congress could pass legislation laying out data privacy rules targeted specifically at e-commerce sites and social media services or even update existing laws like the Children’s Online Privacy Protection Act that governs data collection for minors rather than make omnibus, one-size-fits-all rules.

Related: Lawmakers should check the SEC’s wartime consigliere with legislation

Historically, this is the approach that the U.S. has taken to data privacy in other industries. From laws about financial information to healthcare information, policymakers have traditionally created data privacy rules that are narrowly tailored to specific contexts. The Health Insurance Portability and Accountability Act, for example, governs the flow of healthcare information, while the Gramm-Leach-Bliley Act was designed to protect consumers’ financial privacy. These rules almost always preempt state-level rules and are generally more politically palatable than sweeping one-size-fits-all legislation.

Through a sectoral approach to data privacy legislation, lawmakers can create rules tailored to different contexts that harmonize with blockchain technologies. If lawmakers believe that a sectoral approach does not go far enough toward protecting consumers’ information, then they should at least draft comprehensive data privacy legislation in a way that won’t harm innovation and force innovators offshore. After all, there’s a reason most of the best and brightest technologists choose to live, work and build in the United States. It would be foolish to push them and their innovations away with short-sighted legislation.

Luke Hogg is a policy manager at the nonprofit Lincoln Network in Washington, D.C., where he focuses on the intersection of emerging technologies and public policy.

The views, thoughts and opinions expressed here are the authors’ alone and do not necessarily reflect or represent the views and opinions of Cointelegraph.

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In the aftermath of banks’ horrorshow: Law Decoded, March 13–20.

A week after the twinning collapse of Silicon Valley Bank (SVB) and Signature Bank, and the trouble at Credit Suisse, the dust is slowly settling down.

A week after the twinning collapse of Silicon Valley Bank (SVB) and Signature Bank, and the trouble at Credit Suisse, the dust is slowly settling down. SVB Financial Group has filed a voluntary petition for a court-supervised reorganization under Chapter 11 in the United States Bankruptcy Court. The company is no longer affiliated with Silicon Valley Bank, which operates under the jurisdiction of the Federal Deposit Insurance Corporation (FDIC) and is not included in the Chapter 11 filing. Meanwhile, the United Kingdom arm of the bank was acquired by HSBC for 1 British pound. 

Congress announced a hearing into the failures of SVB and Signature Bank, which will take place on March 29. FDIC chair Martin Gruenberg and Federal Reserve vice chair for supervision Michael Barr are expected to appear before lawmakers to help them understand the nature of the current crisis.

The Mid-Size Bank Coalition of America (MBCA) asked United States federal regulators to extend insurance on all deposits for the next two years. According to the coalition, extending insurance on “all deposits” would “immediately halt the exodus” of deposits from smaller banks and stabilize the industry. This sounds pretty logical, given that more than 186 U.S. banks are well-positioned for collapse from the economists’ point of view.

Wyoming enacts bill to defend private keys 

Governor Mark Gordon of the U.S. state of Wyoming signed a bill preventing the forced disclosure of private keys to protect the privacy of digital asset owners. ourts in Wyoming will no longer compel individuals to provide access to any private keys that grant access to their digital assets, digital identity or any other interests or rights to which the private key provides. The only exception to this law applies when individuals are required to disclose the ownership or transfer of crypto during any lawful proceeding.

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Binance-Voyager deal to proceed without holdings

The United States District Court for the Southern District of New York declined the U.S. government’s reasonings for halting the acquisition of bankrupt brokerage company Voyager Digital by Binance.US. According to Judge Michael Wiles, any protractions with the deal will harm the interests of Voyager’s former clients, who are waiting for the return of their funds. Thus, Wiles realleges his prior approval of Voyager Digital’s Chapter 11 bankruptcy plan, which suggests selling billions of dollars in assets to Binance.US to regain liquidity to pay back customers.

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Euro Parliament approves Data Act

The European Parliament passed the Data Act, intended to “boost innovation by removing barriers obstructing access to industrial data.” The legislation established rules for fairly sharing data generated by “connected products or related services,” such as the Internet of Things and “industrial machines.” The act also granted smart contracts equal protection compared with other forms of contract, which is bad for the industry, as it would undermine immutability guarantees. 

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Congress announces March 29 hearing into failures of SVB and Signature Bank

According to the House Financial Services Committee, it expects to hold multiple hearings on “getting to the bottom” of the banks’ failures.

Representatives from the Federal Deposit Insurance Corporation and Federal Reserve will be testifying before the United States House Financial Services Commission in a newly announced hearing investigating the collapse of two major banks.

In a March 17 notice, Representatives Maxine Waters and Patrick McHenry — the ranking member and chair of the committee, respectively — said U.S. lawmakers would listen to testimony from federal financial regulators “in response to the failures of Silicon Valley Bank and Signature Bank” in a March 29 hearing. FDIC chair Martin Gruenberg and Fed Vice Chair for Supervision Michael Barr are expected to appear before Congress.

“The House Financial Services Committee is committed to getting to the bottom of the failures of Silicon Valley Bank and Signature Bank,” said Waters and McHenry. “This hearing will allow us to begin to understand why and how these banks failed.”

On March 10, Silicon Valley Bank shuttered following a bank run among major depositors, but the government stepped in to announce most uninsured depositors — those with more than $250,000 — would be covered. In contrast, reports suggested Signature Bank had no issues with solvency at the time of its closure on March 12, but New York regulators stepped in, giving the FDIC control of the firm’s insurance process.

Barr will be releasing a report on the Fed’s supervision and regulation of Silicon Valley Bank. The Department of Justice and Securities and Exchange Commission have also reportedly announced their own probes into some of the bank’s executives selling stock in the weeks leading up to the closure.

Related: US lawmaker suggests Signature’s collapse was tied to instability of crypto

Some lawmakers have pointed to exposure to crypto firms as potential culprits in the downfall of the banks, while advocates in the space have argued that government officials were looking to “de-bank” crypto and blockchain companies. The House Financial Services Committee says it expects to hold multiple hearings on the issue.

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US lawmaker suggests Signature’s collapse was tied to instability of crypto

Senator Michael Bennet said crypto was not “even as stable as the marijuana industry,” questioning Signature Bank’s ability to service digital asset firms but not dispensaries.

Michael Bennet, a United States senator representing the state of Colorado, has suggested that banks associated with crypto firms did not make “prudentially sound” decisions.

Speaking at a March 16 hearing of the Senate Finance Committee, Bennet brought up the recent closure of the crypto-friendly Signature Bank with lawmakers and Treasury Secretary Janet Yellen in a discussion of U.S. President Joe Biden’s FY 2024 budget. The Colorado senator drew a comparison between the relationship of banks and crypto companies to that of institutions and marijuana dispensaries — a legal service in many U.S. states that is “frozen out of the financial system”.

“Signature Bank failed and almost a fifth of its deposits came from crypto,” said Bennet. “They’re not allowed to do anything with marijuana, but apparently they can lay 20% of this on crypto — a notoriously unstable [...] thing that nobody here even understands and where the value of the assets can soar and collapse.”

Senator Michael Bennet addressing the Senate Finance Committee on March 16

According to Bennet, crypto was not “even as stable as the marijuana industry,” implying it may have been a factor in the collapse of Signature Bank. However, Signature board member and former U.S. Representative Barney Frank said there was no issue regarding Signature’s solvency at the time the New York Department of Financial Services took control of the bank on March 12.

Related: California cannabis producer adopts blockchain to track its weed

The failure of Signature Bank, Silicon Valley Bank and Silvergate Bank and their ties to crypto firms have been part of discussions among industry experts, regulators, and lawmakers addressing the potential impact on the U.S. financial system. Many in the crypto and blockchain space have argued that government officials were looking to “de-bank” crypto companies, which could have far-reaching implications.

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US lawmaker accuses FDIC of using banking instability to attack crypto

The collapse of Signature Bank, Silicon Valley Bank, and Silvergate Bank has had many in the space reeling — but is the U.S. government trying to "choke off digital assets”?

Tom Emmer, Majority Whip of the United States House of Representatives, has reiterated concerns that the federal government is “weaponizing” concerns around the banking industry to go after crypto.

In a March 15 letter, Emmer called on Federal Deposit Insurance Corporation chair Martin Gruenberg to answer questions as to whether the government corporation has specifically instructed banks not to provide services to crypto firms, or suggested doing so may be an “onerous” task. The Minnesota Representative cited claims from Signature Bank board member and former U.S. Representative Barney Frank, who reportedly called the FDIC moving against Signature as a “strong anti-crypto message” rather than based on concerns about the bank’s solvency.

“These actions to weaponize recent instability in the banking sector, catalyzed by catastrophic government spending and unprecedented interest rate hikes, are deeply inappropriate and could lead to broader financial instability,” said Emmer.

Emmer also targeted the Biden administration, accusing policymakers of attempting to “choke off digital assets” from the U.S. financial system. The Minnesota Representative has made similar claims prior to the collapse of Silicon Valley Bank and Signature Bank, in addition to speculating the U.S. government could “easily weaponize” a central bank digital currency as a surveillance tool.

Related: Signature Bank and former executives sued by shareholders for alleged fraud

For many in the space, the recent banking crisis began with Silvergate’s parent company announcing on March 8 it would “wind down operations” for the crypto bank. Silicon Valley Bank followed on March 10 with its own failure after a run on deposits. USD Coin (USDC) issuer Circle reported $3.3 billion of its reserves in the bank, causing the stablecoin to temporarily depeg from the dollar.

Some lawmakers and those in the space have suggested the shutdown of Signature Bank could have been a targeted move by government officials against crypto, as Barney Frank reported were “there was no insolvency based on the fundamentals" at the time. The New York State Department of Financial Services reportedly said on March 14 that its closing the bank had “nothing to do with crypto”, citing the firm’s failure to provide “reliable and consistent data” to the regulator.

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State caps or federal regulation: What’s next for political crypto donations

The industry isn’t having the best of its moments now, but the topic of campaign donations in crypto remains a relatively safe space for innovation.

On Jan. 25, the Committee on Elections introduced a bill to the Kansas House of Representatives aimed at capping political donations via crypto at $100. Regardless of the success of this legislative initiative, the state of Kanzas won’t be the first jurisdiction to target anonymous donations. From authoritarian nations like Russia or China to electoral democracies like Ireland or Canada, one can find recent attempts to ban crypto donations to politicians all around the globe. 

The opponents of crypto may have a strong point — it’s hard to imagine a healthy democracy where large sums of untraceable money are flowing between candidates. But the problem of “dark money” and tools to dispense it around the political system existed way before pseudonymous crypto assets arrived. The industry isn’t having the best of its moments now, but the topic of campaign donations in crypto remains a relatively safe space for innovation. Could it change by the next electoral cycle?

The 2014 rule and a $6,600 cap

The first time the United States Federal Election Commission (FEC), the independent authority responsible for enforcing election law, approached the topic of crypto donations was in 2014. Back then, digital assets weren’t nearly as big of an issue, and the price of one Bitcoin (BTC) lay around the $300 mark. Perhaps that is why the FEC took the new problem light-heartedly. It acknowledged the option to donate in Bitcoin (and Bitcoin only) but qualified it under the category of “in-kind contributions” along with such non-monetary campaign activities as giving a free consultation or a concert performance.

Despite the apparent inclusion, Bitcoin donations have been deemed to remain non-anonymous and capped at the same mark as direct cash donations. There is a basic limit of such donations that grows along with the inflation from one electoral cycle to another — by 2024, it will stand at $3,300 for the primary and the same amount for the general election. The status of “in-kind contribution” also prevented campaigners from spending received Bitcoin directly — they have to “liquidate” it and then deposit the money into their accounts.

But there is a caveat within the American political system. While the amount of personal donations may be limited, one can always support Political Action Committees (PACs) by donating up to $41,300 yearly. There are also Super PACs, which have no limit whatsoever. Technically, Super PACS cannot make any direct contributions, but they can spend unlimited amounts of funds in marketing support of their candidates independent of their campaigns.

Recent: Ethereum layer-2 solutions may focus less on token incentives in the future

There is at least one successful instance — BitPAC — specifically dedicated to promoting cryptocurrency and blockchain technology. It has accepted donations of Bitcoin, Ether (ETH) and Litecoin (LTC) and used those donations to support U.S. presidential candidates, congressional candidates, Super PACs and grassroots organizations.

The FEC has not issued any major statements on crypto donations since 2014, although Bitcoin’s total capitalization has sky-rocketed since then, not to mention the issuance and adoption of hundreds of other digital currencies.

An example of an itemization schedule for donating cryptocurrency. Source: FEC

There is also a major exception for nonfungible tokens (NFTs). In 2022, the FEC deemed it “permissible” to send NFTs to political campaign contributors without violating rules on corporate contributions. Earlier in 2019, the FEC approved an ERC-20 token issued by Omar Reyes to use in an incentives program for his congressional campaign. The agency decided the tokens to be souvenirs with no monetary value.

Kansas or California?

Over the last decade, the separate states have largely agreed with the FEC’s vague recommendations on crypto donations. It was only South Carolina, North Carolina and Kansas where lawmakers decided firmly against any donations in crypto. Early on, crypto donations started to spread slowly with the help of enthusiastic politicians like Rand Paul, Austin Petersen or Jared Polis.

However, in the 2020s, when every fifth American has dealt with crypto to some degree, and the industry itself became a sort of a problem for global regulators, the mood swung in another direction. In April 2022, Ireland became the first European country to officially prohibit political donations in crypto. As Darragh O’Brien, the Irish minister for Housing, Local Government and Heritage, explained to journalists back then, the law aimed to protect Ireland’s democratic system, “given the escalating threat of cyber warfare targeting free countries.”

This year, Kansas started to discuss political donations in the state legislature. The local House bill no. 2167 sets a cap of $100 for any political candidate in the state’s primary or general election. Moreover, even for donations under $100, the receiver would need to “immediately convert” the crypto into U.S. dollars, not use the crypto for expenditures, and not hold on to the funds.

There is, however, a case for optimism. After four years of a ban, candidates for state and local offices in California are once again allowed to accept donations in cryptocurrency. The ban was lifted by the state’s Fair Political Practices Commission (FPPC) last year after it considered three major strategies regarding crypto donations.

The option with a $100 cap, like in Kansas, was also on the table, but the FPPC decided to go with the original FEC prescription and treat donations in crypto as in-kind contributions. The Golden State joined 12 other states where political donations of digital assets are explicitly allowed.

Crypto donations in 2024

Why, in all those years, when the landscape of the crypto industry has been constantly changing, has the FEC not come up with any significant updates? First of all, 2014’s ruling was finalized only in 2019, so, with all reservations, it is not that ancient, as Martin Dobelle, co-founder and CEO of Engage Labs, told Cointelegraph. He said it “has been a good rule and has allowed crypto political donations to be made successfully.”

Anthony Georgiades, co-founder of Pastel Network, considers the FEC’s pace to be completely in agreement with general crypto regulation in the United States. With crypto still being a very new industry compared to traditional finance, the FEC is most likely unsure of how to monitor crypto donations, making it difficult to enforce any regulations. He further stated that the time for some updates on crypto donations has come, telling Cointelegraph:

“With all the recent turbulence in crypto, regulators now want to ensure there’s more clarity and transparency within the industry, and we’ll be seeing more regulation introduced by the time the next electoral cycle begins.”

Terrence Yang, managing director of Swan Bitcoin, isn’t so optimistic about the chances of getting the updates from the FEC by the next electoral cycle. Speaking to Cointelegraph, he points out the polarized nature of the current political configuration.

“Because of the split Congress, it may be harder than you think to get legislation passed. It’s unlikely any crypto election laws get added to a bill to pass both houses of Congress and get signed by the president,” he said.

Given the turmoil in markets brought about by the crypto winter of 2022, there is always a chance that new crypto donation regulations would not be friendly to the market. But, on the other hand, the area of campaign donations still remains totally free of any public scandals involving crypto.

Of course, there was the case of Sam Bankman-Fried and the $40 million he donated to both political parties in the U.S. and tried to return later. But, as with the lobbying efforts of the crypto industry in general, that technically has nothing to do with the topic of campaign donations in crypto. “In fact, there’s a very compelling case that political finance offers a genuine use case for blockchain technology, which can be leveraged to significantly enhance transparency and traceability,” Dobelle stated.

Recent: Next stop Shanghai — Ethereum’s latest milestone approaches

“There’s plenty of reason to be optimistic about the future regulation of crypto donations,” Georgiades believes. It takes time for knowledge to develop and spread to regulators; the example of internet regulation, practically absent in the 1990s, is still fresh.

It’s hard to imagine a flawless implementation of regulations, but over time, the understanding of the technology will grow; regulators will become more adept and recognize where crypto has the potential to impact campaign fundraising and where the risks need to be mitigated.

“It’s just going to take patience and a lot of education to get there,” Georgiades concluded.

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Future of Bitcoin and Crypto Will Be Determined by Congress – Not the Biden Administration, Says House GOP Leader

Future of Bitcoin and Crypto Will Be Determined by Congress – Not the Biden Administration, Says House GOP Leader

A Republican House leader says Congress will shape the future of Bitcoin (BTC) and cryptocurrency in the US – not the White House. House majority whip Tom Emmer is outlining a list of pro-crypto proposals making their way through the House of Representatives that he believes would bring constructive clarity to the emerging industry. And […]

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US senators write to banking regulators about potential crypto discrimination

The four Republican senators sense hints of the Obama administration’s Operation Choke Point that used regulation against disfavored industries.

Four United States Republican senators led by Bill Hagerty have written a letter to the heads of federal banking regulatory agencies, questioning the ideological motivation behind recent regulatory moves in regard to cryptocurrency. They compared the regulators’ policies to the Obama administration’s Operation Choke Point.

The senators addressed Federal Reserve Board Chair Jerome Powell, Federal Deposit Insurance Corporation (FDIC) Chair Marty Gruenberg and Office of the Comptroller of the Currency (OCC) Acting Comptroller Michael Hsu. The March 9 letter said that their agencies, along with the White House, have issued statements on heightened supervision that have resulted in unfortunate consequences for the cryptocurrency sector, such as the closing of crypto firms’ bank accounts.

The senators were referring to the joint statement released by those agencies on Jan. 3 that said in part, “Issuing or holding as principal crypto-assets […] is highly likely to be inconsistent with safe and sound banking practices.” In addition, they pointed to a February Fed policy statement that said, making specific reference to crypto, that “legal permissibility is a necessary, but not sufficient, condition” for banking activity, and the Biden administration’s January “road map” that called for agencies to “ramp up enforcement.”

“This coordinated behavior seems disturbingly reminiscent of Operation Choke Point,” the senators wrote. In that operation, “federal regulators applied pressure on financial institutions to cut off financial services to certain licensed, legally operating industries simply because certain regulators and policymakers disfavored those industries.” They added:

“We are especially worried that overreaching behavior by the banking regulators will inevitably bleed into other legal industries.”

The senators posed a number of questions to the regulators. They asked how their increased supervision will help consumers, whether it is possible for banks to provide services to crypto firms at all under the updated guidance, and whether the agencies plan to release similar guidance for other industries.

Related: Banks under pressure from US authorities to cut ties with crypto firms

With their letter, the senators are joining a conversation in the crypto community concerning the voluntary liquidation of Silvergate Bank. That talk may heat up with the FDIC’s closing of Silicon Valley Bank.

Senators Mike Crapo, Thom Tillis and Steve Daines were co-authors of the letter. Hagerty introduced the Digital Trading Clarity Act in the Senate in October. That act would provide a safe harbor for cryptocurrency exchanges from some Securities and Exchange Commission enforcement actions.

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US House Republicans Blast Biden Administration’s Attack on the Crypto Ecosystem

US House Republicans Blast Biden Administration’s Attack on the Crypto Ecosystem

Republicans in the U.S. House of Representatives are criticizing the White House, saying the Biden administration’s approach to crypto assets threatens the nascent industry. In a new memo addressed to the members of the House Committee on Financial Services, Republicans acknowledge that digital assets are a thriving trillion-dollar market. “Today, the total digital asset market […]

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