November 25, 2025
Sebastian R. Astrada
Director for Licensing, Midsize, Trust, Credit Card, and Novel Banks
Office of the Comptroller of the Currency
400 7th St., SW
Washington, DC 20219
Via electronic mail: LicensingPublicComments@occ.treas.gov
RE: Public Comment Letter in Opposition to Foris DAX National Trust Bank Charter Application (2025-Charter-343659)
Dear Director Estrada,
The National Community Reinvestment Coalition (“NCRC”) strongly opposes the application by Crypto.com (“Crypto.com”) for a national trust bank charter under the name Foris DAX National Trust Bank (“FDNTB”).
NCRC is a coalition of more than 700 community-based organizations fighting for economic justice. For nearly 30 years, we have worked to create opportunities for people and communities to build and maintain wealth. NCRC members include community reinvestment organizations, community development corporations, local and state government agencies, faith-based institutions, fair housing and civil rights groups, minority and women-owned business associations, and housing counselors from across the nation. NCRC partners with many of the nation’s largest banks to develop Community Benefits Agreements that channel billions of dollars into underserved communities and ensure transparency, accountability, and long-term impact. Our Innovation Council convenes fintech leaders to advance inclusive financial solutions. These partnerships create collaborative spaces where stakeholders share insights, develop strategies, and advance equitable access to financial services.
Granting Crypto.com a national trust bank charter would establish a fiduciary relationship between FDNTB and consumers nationwide, allowing FDNTB to offer custodial services, hold consumer funds, and manage settlements. The OCC must reject Crypto.com’s application for a national trust bank charter due to serious concerns regarding the applicant’s disregard for enforcement, governance, compliance, and consumer protection laws.
1. The OCC does not have authority to issue national trust bank charters to crypto and stablecoin companies.
The OCC charters national banks under the authority of the National Bank Act of 1864, as amended.[1] However, the OCC’s recent consideration of limited purpose national trust charters for stablecoin issuers and other fintech firms exceeds the agency’s authority under the National Bank Act.
FDNTB is not a trust company but is seeking to engage in core banking activities, including facilitating payments and taking deposits, without obtaining deposit insurance or becoming subject to consolidated Federal Reserve supervision: “granting these firms limited-purpose trust charters would blur the statutory boundaries of what constitutes a ‘bank,’ undermine the credibility of the national charter, and heighten systemic risk by allowing them to operate under a lighter regulatory regime.”[2] Despite the GENIUS Act’s clear prohibition on stablecoin interest or yield, crypto companies evade this requirement by rebranding returns as “rewards.” This creates deposit-like products without regulatory safeguards, reshaping our financial system in ways that disproportionately burden vulnerable communities.
The OCC may deny an application if the applicant presents significant supervisory, compliance, or Community Reinvestment Act (CRA) [3] concerns. In its review of applications, the OCC must consider whether its proposed activities are consistent with the purposes of the Federal Deposit Insurance Act, the National Bank Act, and the Home Owners’ Loan Act. As noted above, FDNTB’s proposed activities are not consistent with the purposes of the National Bank Act. The OCC does not have the authority to grant this entity a national trust bank charter.
Furthermore, as discussed below, Crypto.com’s management record and inadequate internal controls fall short of the standards the OCC is required to evaluate when reviewing charter applications for national banks. In reviewing charter applications for national banks, the factors and principles that the OCC must consider include[4]:
- Maintaining a safe and sound banking system;[5]
- Encouraging a national bank to provide fair access to financial services by helping to meet the credit needs of its entire community;[6]
- Ensuring compliance with laws and regulations;[7] and
- Promoting fair treatment of customers, including efficiency and better service.[8]
In addition, federal regulations detail the policy considerations that the OCC accounts for when evaluating an application to establish a national bank. The OCC considers whether the proposed institution:
- Has organizers who are familiar with national banking laws and regulations or Federal savings association laws and regulations, respectively;[9]
- Has competent management, including a board of directors, with ability and experience relevant to the types of services to be provided;[10]
- Has capital that is sufficient to support the projected volume and type of business;[11]
- Can reasonably be expected to achieve and maintain profitability;[12]
- Will be operated in a safe and sound manner;[13] and
- Does not have a title that misrepresents the nature of the institution or the services it offers.[14]
As discussed below, Crypto.com again falls short of the standards and requirements necessary for the operation of a national bank.
2. Crypto.com’s history of enforcement actions and litigation creates significant supervisory and compliance concerns, and shows a disregard for regulatory compliance, consumer protection, governance, and risk management.
A history of public enforcement actions and litigation matters raises fundamental questions about the character and fitness of Crypto.com’s leadership and their ability to implement adequate internal controls and risk management measures. These actions raise doubts about Crypto.com’s ability, or willingness, to invest in the creation of adequate internal controls and risk management systems that are necessary for the operation of a national trust bank. Below are details of recent actions against Crypto.com or its affiliates, which demonstrate a reckless disregard for regulatory compliance and consumer protection.
2.1. Dutch Central Bank Enforcement for Prolonged AML/CTF Violations
In October 2023, the Dutch Central Bank (DNB) fined Foris DAX MT Limited, Crypto.com’s EU operating entity, €2.85 million for providing crypto-asset services in the Netherlands for over two years without required registration under the Dutch Anti-Money Laundering and Anti-Terrorist Financing Act. DNB deemed the violation “very severe” due to its duration, the volume of Dutch customers served, and the competitive advantage gained by avoiding supervisory fees and compliance obligations. Critically, operating outside the AML/CTF framework meant the firm failed to report unusual transactions to the Financial Intelligence Unit, heightening the risk of undetected money laundering or terrorist financing.[15]
This enforcement action reveals significant deficiencies in the firm’s governance, risk, and compliance structure, as well as a willingness to operate at scale in regulated jurisdictions without securing mandatory AML authorization. Such conduct is fundamentally incompatible with the prudential standards expected of a national trust bank. The OCC should view this record as evidence that the company’s compliance culture and internal controls remain inadequate for a federally supervised fiduciary institution.
2.2. Illinois Biometric Privacy Class Action Settlement
In 2024, Foris DAX, Inc. (d/b/a Crypto.com) settled a class action under the Illinois Biometric Information Privacy Act (BIPA) for $1.72 million. Plaintiffs alleged the company collected and stored facial geometry from identity-verification scans without providing required written disclosures or obtaining informed consent. The settlement covers Illinois residents (or users of Illinois identification or phone numbers) who created accounts between August 2018 and June 2024.[16]
While the settlement includes no admission of liability, it raises serious concerns about Crypto.com’s handling of biometric data—among the most protected categories of personal information. The allegations suggest material gaps in privacy governance, transparency practices, and data security compliance. These deficiencies call into question the firm’s readiness to meet the robust information safeguarding obligations and stringent federal privacy standards required of a national trust bank.
2.3. Texas Department of Banking Consent Order for Unlicensed Money Transmission
On May 5, 2025, the Texas Banking Commissioner issued a consent order against Foris DAX, Inc., concluding the company conducted money transmission activities in Texas without a required state license. Foris DAX agreed to pay an administrative penalty of $87,108.63. Despite standard no-admit-nor-deny language, the action constitutes a final, public determination by a U.S. financial regulator that the firm engaged in regulated activity without authorization.[17]
The Texas enforcement implicates core competencies the OCC expects of any prospective national trust bank: proper money-transmission controls, robust licensing and compliance procedures, and the ability to manage consumer-facing financial services within legal frameworks. Operating in a major U.S. jurisdiction without required licensure demonstrates a pattern of regulatory noncompliance and suggests deficiencies in navigating multi-state financial services obligations—directly relevant to the OCC’s assessment of the applicant’s fitness, managerial expertise, and compliance risk.
2.4. Litigation Over Fraud Monitoring and Detection Failures
Beyond formal regulatory enforcement, Foris DAX faces ongoing litigation alleging material deficiencies in platform security and user protections. In Lee v. Foris DAX, Inc. (N.D. Cal., No. 24-cv-06194), filed on August 30, 2024, the plaintiff alleges that scammers were able to gain access to an elderly user’s account, convert his assets into cryptocurrency, and drain the funds through the Crypto.com platform. The complaint asserts that Foris DAX failed to implement adequate fraud prevention and transaction monitoring controls that would have detected the suspicious activity. The plaintiff further contends that the company ignored several warning signs and allowed the unauthorized transfers to proceed, resulting in significant financial harm.[18]
Separately, plaintiff-side firms have brought arbitration claims on behalf of multiple accountholders, alleging inadequate security controls, identity verification processes, and fraud prevention systems that led to unauthorized access and asset theft.[19]
While these are civil disputes rather than regulatory actions, they indicate persistent consumer-protection and security vulnerabilities across Crypto.com’s service offerings. They raise concerns about whether Foris DAX has implemented sufficiently rigorous operational, cybersecurity, and transaction monitoring controls—mandatory for a national trust institution that must safeguard customer assets and ensure secure, equitable access to financial services. These cases highlight ongoing risk management gaps relevant to the OCC’s safety and soundness evaluation.
3. Granting a national trust bank charter to Crypto.com would enable regulatory arbitrage that harms communities and consumers.
A national trust charter would provide Crypto.com with the reputational benefits, enhanced market credibility, and federal regulatory status of a banking institution while allowing it to avoid many of the fundamental obligations that justify such privileges. This arrangement would create dangerous imbalances in four areas: community investment responsibilities, consumer protection standards, regulatory oversight and accountability, and systemic risk management. Any form of national bank charter is a privilege, accompanied by obligations to communities and consumers. Approving Crypto.com’s application would create a two-tier system where digital asset firms receive comparable federal status without comparable public obligations, undermining the integrity of the entire chartering framework.
The US has a well-established legal and regulatory framework that governs banks and banking activities. This framework exists to ensure strong consumer protections, including transparency around fees and privacy; rigorous anti-money laundering (AML) and counter-terrorism financing requirements; fraud prevention and reporting obligations; deposit insurance to protect consumers’ funds; and the overall safety and soundness of the U.S. financial system. Issuing national trust bank charters to crypto and stablecoin companies would enable regulatory arbitrage, weaken public trust, and expose consumers and markets to unnecessary risk.
3.1. Lost Reinvestment to Communities and the Need for Community Development Obligations
National trust banks are not subject to Community Reinvestment Act (CRA) requirements, meaning Crypto.com – an entity that proposed to engage in some traditional banking services such as taking and holding consumer deposits – would gain the prestige and benefits of a federal charter without any obligation to serve low- and moderate-income communities or meet local credit needs. Traditional banks must demonstrate how they reinvest deposits back into their communities—Crypto.com would face no such requirement. Crypto.com’s involvement in stablecoin issuance means a trust charter would legitimize diverting potentially billions of dollars from community bank deposits into stablecoins held by an entity with no corresponding community reinvestment obligation. This diversion of capital away from entities with a community reinvestment obligation represents a fundamental departure from the principle that federally chartered institutions should serve public purposes, not merely private profit.
The CRA states that banks which benefit from federal deposit insurance have an obligation to meet the credit needs of entire communities, meaning that banks cannot solely serve the wealthiest customers. They must serve the needs of low- and moderate-income households as well. Stablecoin issuers should be held to CRA-like standards as they will also rely on a supervisory regime that assures consumers that stablecoins are sound ways to store money.
Until stablecoin legislation requires stablecoin issuers to reinvest a portion of their proceeds into community development projects in underserved communities, no stablecoin issuer should receive any form of bank charter.
Traditional deposit insurance is a form of public subsidy to the banking industry in exchange for which banks accept obligations to serve the public interest. Granting trust bank charters to stablecoin firms will grant the patina of legitimacy to cryptocurrency issuers and the same obligations to serve the public should apply to stablecoin issuance.
Without applying community development obligations to stablecoin issuers, communities will lose billions of dollars of needed community and economic development projects and initiatives. In 2023 alone, banks originated over $127 billion in loans that meet the CRA’s definition of community development for LMI communities and households.[20] In addition, ensuring community development conditions are being met by nonbank or national trust bank issuers would also allow for a more level playing field between banks, especially community banks, and nonbank or national trust bank issuers.
3.2. Threat of Consumer Harm
As noted in several comment letters submitted earlier this year by NCRC, granting a national trust bank charter to cryptocurrency and stablecoin companies threatens to harm consumers on multiple levels.
Consumers using stablecoins issued by a “national trust bank” would not have protections that federally insured deposits offer; however, the trust bank charter will confer the appearance of regulatory legitimacy and safety, which is likely to mislead and confuse consumers. This perception gap increases public exposure to financial loss while allowing Crypto.com to benefit from the reputational privileges of the federal banking system without offering the core protections that actual banks provide.
In addition, a stablecoin issuer taking consumer deposits under a national trust bank charter would not be subject to the OCC’s National Bank Charges regulation, which requires full-service banks to consider key consumer protection principles when setting fees. A federal trust charter would also preempt state-level money transmitter licenses and consumer protection laws that would currently apply to Crypto.com’s operations in many jurisdictions. This federal preemption could weaken consumer protections that states have enacted specifically for digital asset activities. Trust banks aren’t FDIC-insured, but the “national bank” label could mislead consumers into expecting federal protection, creating moral hazard and exposing them to avoidable harm.
3.3. Lost Regulatory Oversight and Accountability: Stablecoin issuers should not be permitted to use a federal trust bank charter to avoid state-level consumer protections.
Traditional banks that maintain community reinvestment programs, robust compliance infrastructure, and comprehensive consumer protections would face a competitive disadvantage against Crypto.com operating under a lighter trust charter while enjoying comparable market credibility. Non-depository fintech companies are subject to state-level registration and regulatory oversight requirements. Granting a national trust bank charter to stablecoin issuers enables regulatory arbitrage that would allow Crypto.com to gain federal banking status while avoiding the obligations and safeguards that justify such privileges, and while avoiding state-level supervision.
The OCC should not permit Crypto.com to use a trust charter as a regulatory shortcut to avoid federal and state-level oversight while lacking the responsibilities and protections of insured banking institutions. The resulting competitive distortion could trigger a race to the bottom, incentivizing other institutions to seek similar arrangements. Moreover, granting federal banking status to an entity with Crypto.com’s unsettled risk profile, particularly one involved in stablecoin issuance that could scale to trillions of dollars, introduces systemic risk without corresponding safeguards, deposit insurance, or resolution mechanisms that protect depositors when traditional banks fail.
4. Risks to Safety and Soundness
Despite the passage of the GENIUS Act, federal regulators have yet to finalize this law’s implement regulations, which will be critical to establish clear rules for stablecoins, leaving critical issues of backing, redemption, and oversight in regulatory limbo. Even after the GENIUS Act and its implementing regulations all go into effect, which could take several years, legal scholar Art Wilmarth warns that “By placing the federal government’s seal of approval on uninsured and weakly-regulated nonbank stablecoins, the GENIUS Act would greatly increase the likelihood that future runs on stablecoins would trigger systemic financial crises and require costly government bailouts.”[21]
Granting Crypto.com a trust bank charter before a comprehensive regulatory framework is in place would expose both consumers and the broader financial system to poorly understood risks. FDNTB’s proposed banking operations would create an unprecedented moral hazard by extending the federal safety net to a company whose core business involves highly volatile digital assets. Stablecoin issuers operating through platforms like Crypto.com’s open-issuance infrastructure pursue profit-driven business models that are uniquely susceptible to destabilizing runs in the absence of rigorous reserve, redemption, and risk-management standards.[22]
Historically, in the United States, bright lines have existed to separate banking from commerce. The separation of banking and commerce is critical to maintaining the safety and soundness of our financial system. The national trust bank charter is a problematic contradiction to that principle.
If Crypto.com receives a charter, regulators will have little insight into its corporate parent’s operations even though they have many interdependent relationships – compounding the systemic risks that Crypto.com and stablecoin operations already pose to the US economy.
5. The OCC must place a moratorium on all stablecoin company charter applications until laws and regulations can effectively address safety and soundness concerns and protect consumers against fraud.
The current regulatory framework governing cryptocurrency and stablecoins fails to prevent massive fraud and financial losses. It does not adequately address stablecoin liquidity standards, reserve requirements, or consumer protection, and these gaps have allowed criminal exploitation to flourish.
The digital asset ecosystem has been plagued by fraud, hacking, and cybercrime, with billions of dollars in losses annually. US consumers are already losing billions of dollars a year to fraud, with stablecoins overtaking Bitcoin as the illicit currency of choice for criminals.
According to the FBI’s Internet Crime Complaint Center (IC3) 2024 Internet Crime Report, US consumer losses due to scams are increasing at a startling rate, rising from just under $4 billion in 2020, to over $16 billion in 2024.[23] Cryptocurrency has become the top way that complainants reported financial loss in fraud, accounting for $9.3 billion dollars in losses in 2024 alone.[24] As a group, those over the age of 60 suffered the most losses and submitted the most complaints referencing cryptocurrency.[25] While Bitcoin was the currency of choice for cybercriminals for years, this changed in 2022: a 2025 report shows a seismic shift to stablecoins that now account for 63% of all illicit crypto transactions.[26] In June of this year, the Financial Action Task Force (FATF), a leading global financial crime watchdog, recently called on countries to take stronger action to combat illicit finance in crypto assets, warning that gaps in regulation could have global repercussions.[27]
A related concern involves Crypto.com’s proposed Foris DAX National Trust Bank and its integration into the stablecoin and digital-asset payments ecosystem. Crypto.com is seeking a national trust charter to issue stablecoins, custody digital assets, and manage stablecoin reserves. These activities would place Crypto.com at the center of digital-asset infrastructure that has enabled widespread cryptocurrency-kiosk and wallet-based fraud—a rapidly growing consumer-protection crisis disproportionately harming seniors and vulnerable individuals.
While Crypto.com does not directly operate crypto kiosks or retail exchanges, it has launched stablecoin financial accounts,[28] supports global USDC payments, and is developing custody and settlement rails for crypto platforms, fintech firms, and cross-border remittance providers. Bridge has tested blockchain-based settlement and stablecoin-issuance models, and its trust bank would provide “custody, stablecoin issuance, [and] management of stablecoin reserves,” according to company leadership. These functions create the possibility that Bridge National Trust could become an indirect liquidity, issuance, or settlement provider to cryptocurrency kiosks, payment aggregators, wallet providers, and high-risk exchange networks.
Given Crypto.com’s lack of experience operating a federally supervised financial institution, the OCC should closely scrutinize whether Crypto.com/Bridge possesses adequate anti-money-laundering, sanctions screening, and transaction monitoring controls to detect and respond to transactional patterns characteristic of kiosk-related scams and other crypto-enabled schemes.
Recent federal and state data underscore the scale of this threat posed by stablecoin and crypto-kiosk fraud. The Federal Trade Commission reported that consumers lost over $65 million to Bitcoin ATM scams in the first half of 2024, with a median individual loss of $10,000, and that older adults were several times more likely to be targeted.[29] FinCEN and multiple state attorneys general have documented that kiosks have been used to launder “millions” in criminal proceeds, prompting a wave of new state laws imposing transaction caps, disclosure mandates, refund rights, and operator registration requirements.
Finally, the OCC should also deny all stablecoin company charter applications until the Secretary of the Treasury has finalized rules to implement Section 5(A) of the GENIUS Act. That section of the Act provides that a permitted payment stablecoin issuer shall be treated as a financial institution for purposes of the Bank Secrecy Act, and as such, shall be subject to all federal laws applicable to a financial institution located in the United States relating to economic sanctions, prevention of money laundering, customer identification, and due diligence.
A recent report by the International Consortium of Investigative Journalists (ICIJ) found routine use of brand-name crypto exchanges by money launderers.[30] The ICIJ-led cross-border investigation with 37 media partners in 35 countries reveals how crypto and stablecoin companies provide the tools that criminals exploit to launder the proceeds of scams, theft, and other crimes — while those who’ve lost their savings or livelihoods are left with little hope of justice. The findings raise questions about whether exchanges are doing enough to stop illicit flows, either by freezing funds, closing accounts or carefully monitoring suspicious transactions.
Before the OCC considers granting a charter to any stablecoin issuer, the following rules and regulations implementing provisions of the GENIUS Act must be in place:
- The Federal Reserve Board is authorized to issue regulations related to reserve requirements and liquidity standards for federally regulated stablecoin issuers.[31]
- The Federal Deposit Insurance Corporation may issue rules to ensure that insured depository institutions issuing stablecoins comply with capital and risk management standards.[32]
- The Department of the Treasury is authorized to issue rules on consumer protection, including public disclosures of reserve composition, redemption procedures and prohibited marketing practices.[33]
- The Financial Crimes Enforcement Network is authorized to issue implementing regulations under the Bank Secrecy Act to ensure anti-money laundering and sanctions compliance by stablecoin issuers.[34]
- The Secretary of the Treasury is granted broad authority to issue rules and guidance necessary to carry out the act.[35]
6. The comment period for charter applications must be extended to at least 90 days.
A key feature of the American democratic process is the opportunity for public engagement in the lawmaking process and in the American banking law this means the public’s right to participate by submitting comments on charter applications. A 30-day comment period for national trust applications is simply not sufficient for meaningful public engagement.
We urge the OCC to publicize the nonpublic portions of all stablecoin issuer charter applications (redacting any nonpublic personal information about the proposed entities’ officers or directors). Finally, we request that the OCC extend the comment periods for all such applications to 90 days.
Conclusion
The OCC must reject Crypto.com’s application for a national trust bank charter. Granting a national trust bank charter to Crypto.com would enable regulatory arbitrage, reduce investment into community development, risk significant harm to consumers and communities, and would create systemic risk. Finally, until the GENIUS Act is effective and its implementing regulations are finalized, granting a national trust bank charter to a stablecoin issuer will further fuel illicit finance and fraud that are already wreaking havoc on US consumers.
Thank you for considering this request. If you have any questions about this letter, please contact Jesse Van Tol, NCRC’s Chief Executive Officer, at 202-464-2709 or jvantol@ncrc.org.
Sincerely,
Jesse Van Tol
Chief Executive Officer
NCRC
[1] 12 U.S.C. 1 et seq.
[2] Bank Policy Institute, BPI urges OCC to preserve the integrity of national trust charters. BPI. https://bpi.com/bpi-urges-occ-to-preserve-the-integrity-of-national-trust-charters/
[3] Ibid., 4.
[4] 12 C.F.R. s. 5.20(e).
[5] 12 CFR 5.20(f)(1)(i)
[6] 12 CFR 5.20(f)(1)(ii)
[7] Ibid.
[8] Ibid.
[9] 12 CFR 5.20(f)(2)(i)(A)
[10] 12 CFR 5.20(f)(2)(i)(B)
[11] 12 CFR 5.20(f)(2)(i)(C)
[12] 12 CFR 5.20(f)(2)(i)(D)
[13] 12 CFR 5.20(f)(2)(i)(E)
[14] 12 CFR 5.20(f)(2)(i)(F)
[15] De Nederlandsche Bank, “Fine for Foris DAX MT Limited (Crypto.com) for having provided crypto services without the required registration until 2 August 2023 in the Netherlands,” March 13, 2024, updated December 3, 2024, https://www.dnb.nl/en/general-news/enforcement-measures-2024/fine-for-foris-dax-mt-limited-crypto-com-for-having-provided-crypto-services-without-the-required-registration-until-2-august-2023-in-the-netherlands/
[16] Agnew v. Foris DAX, Inc., No. 2024-CH-00435 (Cir. Ct. Cook Cnty., Ill.) https://cdn.prod.website-files.com/642f23e5f54b794300ac12a6/668cbeaf4fb3711cf409be18_zLos3la1_UM96k7BXnygnekVC36RyJ2CeHjXypBLDwM.pdf
[17] Texas Department of Banking, Consent Order No. 2025-010 in the Matter of Foris DAX, Inc., Tyler, Texas, May 5 2025, https://www.dob.texas.gov/sites/default/files/files/Laws-Regulations/orders/2025-010.pdf
[18] Jung Min Lee v. Foris DAX, Inc., No. 3:24-cv-06194-WHO (N.D. Cal. filed Aug. 30, 2024), Order Granting FDIC-R and Evans Motions to Dismiss and Granting in Part and Denying in Part Crypto.com Motion to Dismiss, Doc. 115 (N.D. Cal. Sept. 5, 2025), available at https://law.justia.com/cases/federal/district-courts/california/candce/3%3A2024cv06194/435795/115/
[19] [Confidential] v. Foris DAX, Inc. d/b/a Crypto.com,” Silver Miller Law Firm (Active Cases), https://www.silvermillerlaw.com/active_cases/confidential-v-foris-dax-inc-d-b-a-crypto-com/
[20] American Bankers Association, Community Reinvestment Act, accessed November 13, 2025, https://www.aba.com/banking-topics/compliance/acts/community-reinvestment-act
[21] Open Banker, “Congress Must Reject the GENIUS Act and Remove the Dangers Posed by Nonbank Stablecoins” by Art Wilmarth: https://ourfinancialsecurity.org/wp-content/uploads/2025/07/AFR-Factsheet.GENIUS-Acts-Flaws-and-Failures.pdf
[22] Financial Stability Oversight Council, 2024 Annual Report (Washington, DC: U.S. Department of the Treasury, 2024), 8, https://home.treasury.gov/system/files/261/FSOC2024AnnualReport.pdf.
[23] Federal Bureau of Investigation, 2024 Internet Crime Report (Washington, DC: Internet Crime Complaint Center, 2025), 7, https://www.ic3.gov/AnnualReport/Reports/2024_IC3Report.pdf.
[24] Ibid., 3.
[25] Ibid., 35.
[26] Chainalysis, “2025 Crypto Crime Report: Illicit Volumes Portend Record Year as On-Chain Crime Becomes
Increasingly Diverse and Professionalized,” January 15, 2025, https://www.chainalysis.com/blog/2025-crypto-crime-report-introduction/
[27] Reuters, “Global financial crime watchdog calls for action on crypto risks,” June 25, 2025, https://www.reuters.com/sustainability/boards-policy-regulation/global-financial-crime-watchdog-calls-action-crypto-risks-2025-06-26/
[28] Crypto.com, “Introducing Stablecoin Financial Accounts in 101 Countries,” Crypto.com Blog, May 20 2025, https://Crypto.com.com/blog/introducing-stablecoin-financial-accounts?utm_.com
[29] Federal Trade Commission, “New FTC Data Shows Massive Increase in Losses to Bitcoin ATM Scams,” press release, September 3, 2024, https://www.ftc.gov/news-events/news/press-releases/2024/09/new-ftc-data-shows-massive-increase-losses-bitcoin-atm-scams
[30] International Consortium of Investigative Journalists. (n.d.). About Coin Laundry investigation: Cryptocurrency. ICIJ. https://www.icij.org/investigations/coin-laundry/about-coin-laundry-investigation-cryptocurrency/
[31] GENIUS Act, Sec. 4(e)(2), S.1582, 119th Cong.
[32] GENIUS Act, Sec. 4(e)(3), S.1582, 119th Cong.
[33] GENIUS Act, Sec. 6(a)–(c), S.1582, 119th Cong.
[34] GENIUS Act, Sec. 7(b), S.1582, 119th Cong.
[35] GENIUS Act, Sec. 13(a), S.1582, 119th Cong.
