GDF welcomed the opportunity to respond to the Senate Banking Committee’s Request for Information on digital asset market structure. We are strongly supportive of efforts by Congress to establish a clear, proportionate, and globally interoperable regulatory framework for digital assets.
We are particularly encouraged by the inclusion of Sections 401 and 404 in the Committee’s discussion draft, which appropriately recognize the importance of international regulatory alignment, mutual recognition pathways, and cross-border experimentation through regulatory sandboxes. We believe that the provisions in 404 on International Cooperation align with the policy direction of the January 2025 Executive Order and subsequent White House statements on preserving U.S. digital asset leadership, protecting economic liberty, and rejecting central bank digital currency (CBDC)-based models as incompatible with U.S. values.
The provisions in 404 also echo key GENIUS Act provisions, particularly Section 3(b)(2), which requires reciprocal arrangements with foreign jurisdictions for foreign stablecoin market access in the United States. Interoperability and global regulatory alignment should not be seen as a constraint on U.S. sovereignty. To the contrary, it is a means of reinforcing it, ensuring that U.S. standards, values, and institutions shape the international rulebook for digital assets. In this context, U.S. leadership is not optional; it is a strategic imperative.
The crypto and digital asset industry cannot scale without global coordination and the United States has a vital leadership role to play in forging reciprocal frameworks with like-minded regulators. In this submission, we have drawn on insights from our global membership and our ongoing regulatory engagement to outline our strong support for a framework that is principle- based, internationally aligned, and fit for the future.