Digital-asset market-structure principles advance targeted and pro-innovation anti-money-laundering measures by extending Bank Secrecy Act (BSA) and International Emergency Economic Powers Act (IEEPA) tools to foreign entities with U.S. touchpoints and adopting examination standards to deter illicit finance

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A small, common-sense package of measures directed at preventing money laundering and sanctions evasion with digital assets should be included. Potential provisions can and should be targeted and pro-innovation. This could include requiring the adoption of examination standards and clarifying that the Bank Secrecy Act and International Emergency Economic Powers Act (IEEPA) extends to entities abroad with U.S. touchpoints. Reforms should also consider the ways digital assets and distributed ledger technology can improve transparency, efficiency, and the detection of illicit activity, including money laundering.
The principles include setting up clear distinctions between digital securities and commodities and a shared regulatory structure that prevents an "all-encompassing" watchdog from emerging; establishing a "small package" of money-laundering protections that are "pro-innovation"; and encouraging the federal regulators to embrace "no-action guidance, sandboxes, safe harbors, coordination and appropriate application requirements."

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