Comment Letters by Agency
- DEF & SPI Response to FinCEN and OFAC NPRM (June 2026)
- Treasury GENIUS Act Implementation ANPRM (November 2025)
- DEF Treasury GENIUS Act Illicit Finance RFC Response (DEF, Paradigm, SPI) (October 2025)
- DEF Treasury GENIUS ACT Illicit Finance RFC Response (DEF Only) (October 2025)
- Response to FinCEN re. its NPRM “Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern” (January 2024)
- DEF Response to Comment Request for Digital Asset Proceeds From Broker Transactions (June 2024)
- DEF Response to Comment Request for Digital Asset Proceeds From Broker Transactions Second Notice published pursuant to the Paperwork Reduction Act (November 2024)
- Response to IRS on the Proposed “Broker” Rulemaking (November 2023)
- Response to U.S. Treasury’s Request for Comment on Digital Asset Innovation (August 2022)
All Comment Letters
- DEF & SPI Response to FinCEN and OFAC NPRM (June 2026)
- DEF & SPI Response to OCC NPRM on GENIUS Act Implementation (May 2026)
- DEF Response to CFPB EFTA Proposed Rulemaking (May 2025)
- DEF Response to CFTC for Input Regarding the Recommendations from the President’s Working Group on Digital Asset Markets (November 2025)
- DEF Response to Comment Request for Digital Asset Proceeds From Broker Transactions (June 2024)
- DEF Response to Comment Request for Digital Asset Proceeds From Broker Transactions Second Notice published pursuant to the Paperwork Reduction Act (November 2024)
- DEF Response to Request for Public Comment on Proposed Rule Regarding Financial Data Transparency Act Joint Data Standards (October 2024)
- DEF Treasury GENIUS ACT Illicit Finance RFC Response (DEF Only) (October 2025)
- DEF Treasury GENIUS Act Illicit Finance RFC Response (DEF, Paradigm, SPI) (October 2025)
- First Response to SEC’s Proposed “Exchange” Rulemaking (April 2022)
- Response to CFPB re. Defining Larger Participants of a Market for General-Use Digital Consumer Payment Applications (January 2024)
- Response to FinCEN re. its NPRM “Proposal of Special Measure Regarding Convertible Virtual Currency Mixing, as a Class of Transactions of Primary Money Laundering Concern” (January 2024)
- Response to IRS on the Proposed “Broker” Rulemaking (November 2023)
- Response to SEC’s “Dealer” Rulemaking (May 2022)
- Response to U.S. Treasury’s Request for Comment on Digital Asset Innovation (August 2022)
- Second Response to SEC’s Proposed “Exchange” Rulemaking (May 2022)
- Third Response to SEC’s Proposed “Exchange” Rulemaking (June 2023)
- Treasury GENIUS Act Implementation ANPRM (November 2025)