Blockchain Infrastructure
Blockchain infrastructure forms the backbone of the digital asset ecosystem, enabling cryptographically secure and efficient transactions across dispersed, permissionless networks of participants.
Blockchain systems rely on a dispersed, unaffiliated network of participants – including nodes, validators, miners, and oracle providers – for whom traditional intermediary compliance obligations are structurally inappropriate. Regulations that ignore this reality threaten the viability of decentralized systems, force innovation offshore, and undermine U.S. competitiveness in emerging financial technology.
Activity-Based Regulation
Policies should regulate intermediaries that perform specific financial activities, not neutral infrastructure. Those who actually hold or control customer assets should be subject to financial services regulation; those who merely build or participate in blockchain networks should not.
Technology Neutrality
Regulations must be carefully designed to avoid favoring or penalizing particular technical solutions, consensus mechanisms, or infrastructure architectures.
Protecting the Ecosystem
The unaffiliated network of participants that operate blockchain infrastructure are essential to its security and decentralization. Rules that unduly burden this dispersed network threaten the entire ecosystem.
Developer & Infrastructure Protections
Blockchain Association leads the industry effort to secure statutory protections for software developers and infrastructure providers. Developers who write and publish neutral, non-custodial code have no access to user funds and no relationship with end users. As such, they should not be regulated as financial intermediaries.
Coalition Advocacy
We build and lead broad coalitions to ensure developer and infrastructure protections are treated as necessary pillars of any digital asset framework – not an afterthought. The industry is united behind this principle.
Regulatory Engagement
We engage with agencies, including the SEC, CFTC, and Treasury, to ensure that activity-based regulations targeting financial intermediaries do not inadvertently sweep in infrastructure participants such as nodes, validators, and oracle services that are not properly subject to intermediary-style requirements.
Blockchain Association Comment on SEC’s Proposal of Regulation NMS
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Tokenization is coming, but the US may lose the chance to write its rules
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Blockchain Association Letter to SEC Crypto Task Force on Third-Party Tokenization of Publicly Traded Securities
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