PGPZ Community Weekly Policy Memos

paulbrigner · June 22, 2026, 7:04pm

Going forward, PGPZ Community Weekly Policy Memos will be posted to this topic. Join the PGPZ Community to receive these and more timely updates directly to your inbox.

Weekly Policy Memo: June 15, 2026

Hi everyone,

This week’s PGPZ Community policy memo covers the FinCEN AML rulemaking, Illinois crypto tax, and stablecoin customer-identification requirements.

Key Takeaways

Members of Congress wrote to FinCEN, urging it to reduce low-value “defensive reporting,” update decades-old reporting thresholds, and fully support the integration of mature artificial intelligence systems to track illicit actors effectively as part of a recent rulemaking proposal.
New Illinois law, becoming effective Jan. 1, 2027, imposes a first-in-the-nation 0.2% “privilege tax” on all Illinois crypto transactions (exchanges, transfers, and storage).
FinCEN and the federal banking regulators proposed a rule that formally designates U.S. stablecoin issuers as financial institutions under the BSA and requires them to establish, document, and maintain comprehensive Customer Identification Programs. This mandates that stablecoin platforms verify the identities of the individuals and entities utilizing their services for primary market activities, such as direct issuance and redemption.

Action Items

Consider following Members of Congress such as Rep. French Hill and Rep. Warren Davidson on social media and showing support by liking, reposting, and commenting on related announcements and developments.
Illinois residents should consider migrating their crypto to noncustodial wallets before December 31, 2026, to legally move your funds off centralized exchanges and avoid the upcoming 0.2% transaction tax.
Contact your local Illinois lawmakers to push for amendments exempting P2P transfers and noncustodial software.
Interested stakeholders should consider participating in the public comment period to highlight how rigid onboarding mandates for digital asset base pairs might impact user privacy and the technical architecture of decentralized networks.

X Post of the Week

House Financial Services Committee Leadership Urges FinCEN to Reorient AML Rules Toward High-Risk Threats

On June 16, House Financial Services Committee Chairman French Hill (R-AR) and Subcommittee on National Security, Illicit Finance, and International Financial Institutions Chairman Warren Davidson (R-OH) published a letter to Andrea Gacki, Director of the Financial Crimes Enforcement Network (FinCEN), providing formal comments on FinCEN’s Notice of Proposed Rulemaking (NPRM) regarding Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) Programs, highlighting it as a critical opportunity to prioritize risk within Bank Secrecy Act (BSA) implementation. The proposed rule, which implements the GENIUS Act’s anti-money laundering and sanctions compliance program requirements, encourages innovation in payment stablecoins while providing an appropriately tailored regime to mitigate potential illicit finance risks.

The lawmakers stated that current BSA enforcement overemphasizes process over outcomes, penalizing irrelevant technical failures and driving compliance resources into liability mitigation rather than actual risk identification. They urged FinCEN to execute the core tenets of the Anti-Money Laundering Act of 2020 (AMLA), reduce low-value “defensive reporting,” update decades-old reporting thresholds, and fully support the integration of mature artificial intelligence systems to track illicit actors effectively.

Notable Post

Why this matters for Zcash

Financial institutions often rely on reflexive defensive reporting by filing millions of low-value Suspicious Activity Reports (SARs) out of legal caution. Applied to stablecoins, this dynamic creates friction for privacy-enhanced assets, as compliance departments often default to blanket restrictions or disproportionate profiling rather than assessing actual underlying risk. If FinCEN adopts the lawmakers’ recommendation to prioritize high-value intelligence over sheer reporting volume, legitimate privacy-centric interactions could face less automated profiling by financial intermediaries.

Action Item

Consider following Members of Congress such as Rep. French Hill and Rep. Warren Davidson on social media and showing support by liking, reposting, and commenting on related announcements and developments.

Illinois Becomes First U.S. State to Levy Direct Privilege Tax on Cryptocurrency Transactions

On June 16, Illinois Governor J.B. Pritzker signed a sweeping $55.9 billion state budget bill into law. Tucked inside the revenue provisions of this budget is a first-in-the-nation cryptocurrency transaction tax via the Digital Asset Tax Act (DATA).

The law creates a 0.2% “privilege tax” on the value of all “digital asset business activity”— defined broadly as the exchange, transfer, or storage of digital assets. Scheduled to take effect on January 1, 2027, the tax functions like a sales tax passed directly to the consumer. Any business or platform based in Illinois or out-of-state entities facilitating these activities that generates more than $100,000 in annual gross receipts from Illinois residents would legally classified as a “digital asset broker” and required to track, collect, and remit this tax monthly.

Notable Posts

Why this matters for Zcash

This law affects Zcash users in Illinois who use centralized platforms like Coinbase, Kraken, and Gemini, as the platforms will be required to log every purchase, trade, or withdrawal of crypto, including Zcash, and tack on the 0.2% tax, including transfers from a custodial wallet to a noncustodial wallet.
For noncustodial wallets, sending Zcash peer-to-peer directly to another user’s non-custodial wallet means the tax cannot be enforced, as true P2P transfers do not use a centralized intermediary that would meet the “broker” definition. Because noncustodial wallets do not hold funds or collect revenue, it does not trigger the $100,000 broker threshold. However, the law may impact users who use a noncustodial wallet’s internal swap functions, which rely on decentralized backend partners. While a noncustodial wallet interface is just code, the external liquidity providers, DeFi frontends, and market makers that execute the cross-chain swaps would likely be considered to be operating for-profit businesses because they collect fees. If these underlying protocols clear $100,000 in gross receipts from crypto trades originating in Illinois, the state considers them “brokers.” This may result in companies blocking Illinois residents or limiting available features via geofencing.

Action Items

Zcash holders may want to consider moving funds from a centralized platform to a noncustodial wallet to avoid the .2% tax prior to December 31, 2026.
If you are in Illinois, call your local state representative and senator, framing the law’s implementation as a consumer privacy and data security issue. Explain that the law forces platforms to aggressively log and track the financial data of everyday citizens to prove whether they reside in Illinois, potentially creating a honeypot for hackers. Push for a legislative amendment to clearly exempt noncustodial software and peer-to-peer transfers entirely.
Keep a close eye on incoming lawsuits from organizations like the Crypto Council for Innovation (CCI), Blockchain Association, the Digital Chamber, and Coin Center. Interested Community members can support by amplifying their legal findings and donating to defensive legal funds.

FinCEN and Federal Banking Regulators Propose Joint Identity Verification Rules for Stablecoin Issuers

On June 18, the Board of Governors of the Federal Reserve System, FinCEN, the Federal Deposit Insurance Corporation (FDIC), the Office of the Comptroller of the Currency (OCC), and the National Credit Union Administration (NCUA) issued a joint NPRM. The proposal outlines new regulatory provisions for stablecoin issuers under the GENIUS Act.

The proposed rule formally designates “Permitted Payment Stablecoin Issuers” (PPSIs) as financial institutions under the BSA and requires PPSIs to establish, document, and maintain comprehensive Customer Identification Programs (CIP). This mandates that stablecoin platforms verify the identities of the individuals and entities utilizing their services for primary market activities, such as direct issuance and redemption.

Why this matters for Zcash

While this NPRM specifically targets stablecoin issuers, its compliance mandates carry implications if a stablecoin is issued as a Zcash Shielded Asset (ZSA). With respect to the broader Zcash ecosystem:
Implementing strict bank-level CIP requirements at the stablecoin layer means that the stablecoin-to-Zcash exit points would be anchored to verified user identities.
Centralized platforms that support both permitted payment stablecoins and privacy-preserving assets like Zcash will operate under heightened BSA compliance scrutiny. This could lead intermediaries to adjust their internal risk assessments, potentially influencing asset listings, deposit/withdrawal protocols, or compliance auditing for privacy-enhanced transactions.
If stablecoin protocols introduce more rigid compliance and identification features to satisfy federal oversight, decentralized applications and cross-chain bridges utilizing stablecoin liquidity pools to swap into Zcash may experience operational friction, enhanced monitoring, or geographic restrictions.

Action Item

For companies that are part of the Zcash ecosystem, interested stakeholders should consider participating in the public comment period to highlight how rigid onboarding mandates for digital asset base pairs might impact user privacy and the technical architecture of decentralized networks.

paulbrigner · June 28, 2026, 2:45pm

Weekly Policy Memo: Week of June 22, 2026

Originally posted at: Weekly Policy Memo: Week of June 22, 2026 | PGPZ Coalition

This week’s PGPZ Community policy memo covers CBDC prohibition until 2030; Mining and Staking Tax Deferral; Texas makes 180-degree turn on data center and mining policy.

Key Takeaways

The U.S. Senate voted to pass a comprehensive housing affordability package that also bars the Federal Reserve from engineering or issuing a CBDC until 2030.
Digital asset trade associations called on the House Ways and Means Committee, which oversees tax legislation, to pass H.R. 9175, Tax Clarity for Mining and Staking Act, as introduced so that mining and staking rewards are only taxed when realized.
Texas is mandating that data centers fully fund their upfront electric transmission hookup infrastructure.

Action Items

Show support for H.R. 9175 by liking and reposting content on social media. If you are a constituent of a Congressperson who is on the Ways and Means Committee, call their office and tell them you support H.R. 9175 in its current form.
If you are a Zcash miner in Texas, reach out with any feedback on how this will impact your operations.
Encourage your friends to join the PGPZ Community! Reposting PGPZ content and citing our work products also helps increase awareness and helps socialize PGPZ talking points.

X Post of the Week

Bipartisan Housing Legislation Heading to President’s Desk Includes Statutory Retail CBDC Ban Through 2030

The U.S. Senate voted 85–5 to pass H.R.6644, the 21st Century ROAD to Housing Act, a comprehensive housing affordability package, which includes a critical bicameral compromise that bars the Federal Reserve from engineering or issuing a retail Central Bank Digital Currency (CBDC) until at least 2030. The statutory ban reflects deep skepticism towards a Fed-issued CBDC, although administrative windows remain open for wholesale settlement tokenization experiments.

The signing ceremony was initially scheduled for Thursday, June 25, but President Trump postponed it, conditioning the signature on Congress passing H.R. 8281, the Safeguard American Voter Eligibility (SAVE) Act, voter ID legislation. On Monday, June 29, the House Speaker Mike Johnson (R-LA) will send the bill to the White House for signature, with the SAVE Act still working through the Senate. The president will have 10 days (excluding Sundays) to sign the bill or veto it; typically, if the president does not act, the bill would automatically become law. However, since the 10-day window starts Monday and would end on July 10, occurring while the Senate is out of session from June 29-July 10, the bill can fail via pocket veto.

Why this matters for Zcash

This statutory restriction against CBDC protects digital assets used for payments against a state-monopolized financial infrastructure. By establishing a clear legislative boundary that prevents the federal government from competing with private-sector transactional rails, Congress preserves room for U.S. digital asset payments innovation. A retail CBDC, which would inevitably crowd out alternative forms of payments, would also present privacy risks to users as efforts increase to enable government agencies to engage in financial surveillance. If the bill is not enacted, the CBDC ban will not become effective.

Action Items

No action needed.

Relevant Posts

Digital Asset Coalitions Urge Unaltered Passage of H.R. 9175 to Normalize Mining and Staking Tax Deferral

The Blockchain Association, Crypto Council for Innovation, and the Digital Chamber have called on the House Ways and Means Committee, which oversees tax legislation, to pass H.R. 9175, Tax Clarity for Mining and Staking Act, as introduced. The draft legislation structures the tax treatment of block rewards, providing that mining and staking rewards must only face taxation when assets are sold rather than being assessed as ordinary income immediately upon receipt.

Why this matters for Zcash

This legislation levels the playing field for block rewards with respect to taxation, preventing them from being taxed twice—when the reward is received and again when the asset is sold. Currently, a Zcash mining operation must continually account for and liquidate portions of block rewards to satisfy immediate ordinary income tax obligations upon generation, creating extensive cash-flow complications. Shifting the taxable event to realization dramatically reduces operational costs for distributed infrastructure providers in the United States and makes it easier to use for payments Zcash block rewards that miners earn.

Action item

Show support for this legislation by liking and reposting content on social media. If you are a constituent of a Congressperson who is on the Ways and Means Committee, call their office and tell them you support H.R. 9175 in its current form.

Relevant Posts

Texas Directs Regulators to Enforce Upfront Grid Infrastructure Funding Requirements on Data Centers

Texas Governor Greg Abbott issued an executive directive to the Public Utility Commission and ERCOT, which manages the flow of electric power to ~90% of the state’s electric load, to finalize a joint regulatory memorandum by July 17, mandating that massive computing facilities and digital asset miners fully fund their upfront electric transmission hookup infrastructure. The action seeks to shift grid infrastructure expansion costs away from residential ratepayers, creating a major test case for how distributed mining node operators can utilize their unique load flexibility to protect their underlying network access parameters.

Why this matters for Zcash

This policy takes a 180-degree turn from Texas’ previous position that encouraged data centers to build/relocate to Texas through cheap land, minimal regulatory friction, and tax incentives.

Action Items

If you are a Zcash miner in Texas, reach out with any feedback on how this will impact your operations.

Relevant Posts

House Financial Services Committee Field Hearing Investigates How the CLARITY Act Unlocks Financial Innovation

The House Financial Services Committee announced it will hold a hearing on July 17, entitled “Building the Future of Finance: How the CLARITY Act Unlocks Innovation.”

Why this matters for Zcash

One of the key issues remaining as the Senate looks to finalize the CLARITY Act is around developer protections that are included in the Blockchain Regulatory Certainty Act, which provides that non-custodial developers are not money transmitters. This hearing is an opportunity to advocate for preserving the developer protections that are in the legislation. If the legislation passes in the Senate, it will need to head back to the House for another vote to reconcile the changes.

Action Items

Repost/share content on social media that promotes preserving the developer protections in the CLARITY Act. If you are a constituent of a Congressperson who is on the House Financial Services Committee, call their office and tell them you support the Blockchain Regulatory Certainty Act.

House Financial Services Committee Evaluates Anti-Money Laundering Frameworks in FinCEN Oversight Hearing

The House Financial Services Committee will conduct a full committee oversight hearing on July 21, entitled “Oversight of the Financial Crimes Enforcement Network.” Andrea Gacki, Director of FinCEN, will testify as the sole witness.

Why this matters for Zcash

This hearing is an opportunity for Congress to question the head of FinCEN on current priorities as they relate to digital assets, how FinCEN is thinking about applying the Bank Secrecy Act (BSA) and AML/KYC requirements to stablecoins (which would impact a stablecoin issued as a ZSA), and other topics.

Action Items

No action needed at this time.

paulbrigner · July 3, 2026, 10:46am

Weekly Policy Memo: June 29, 2026

Originally posted at: ** Weekly Policy Memo: June 29, 2026 | PGPZ Community**

This week’s PGPZ Community policy memo covers a PGPZ Progress Update and CLARITY Act Talks and Prospects

Key Takeaways

In its inaugural month, PGPZ successfully established itself as a central policy hub for Zcash, launching key workstreams across critical regulatory areas (such as financial privacy, tax, and AML) and setting up coordinated communication and reporting channels.
The month culminated in a June 30 Kickoff Breakfast at the Blockchain Association, building momentum for upcoming advocacy efforts and events, including the ZODL Summit in Prague (July 8–10).
The CLARITY Act’s prospects for enactment in 2026 have become increasingly uncertain due to a compressed Senate legislative calendar ahead of the August recess.

Action Items

Help us spread awareness by inviting friends and colleagues to join the Community and Coalition.
Call your Senator’s office to advocate for the passage of the CLARITY Act with developer protections preserved.

X Post of the Week

June Monthly Update on PGPZ

PGPZ has successfully completed its first month, establishing itself as a dedicated hub for policymakers, regulators, and industry stakeholders focused on Zcash. This inaugural month was defined by the launch of key coalition workstreams across critical policy areas—including Mining, Tax, Financial Privacy, Market Structure, Developer Policy, AML/Sanctions, Payments/Stablecoins, and State Policy—as well as the establishment of coordinated communication channels, such as Signal groups and the Community and Coalition websites, to ensure a unified voice for the ecosystem. The month culminated in the June 30 Kickoff Breakfast at the Blockchain Association office, setting the stage for future engagement and advocacy efforts.

PGPZ Progress Summary

Here is a summary of PGPZ progress to date:

Launched the PGPZ Community and Coalition Sites
- Developed PGPZ Policy Principles and Messaging
- Created Coalition Workstreams
  - Mining
  - Tax
  - Financial Privacy
  - Market Structure
  - Developer Policy
  - AML and Sanctions
  - Payments and Stablecoins
  - State Policy
Established the Community and Coalition Signal Chat Groups
Published Weekly Policy Memos
- Narrow/targeted weekly policy memos focusing on impact to Zcash ecosystem with action items for grass roots advocacy and engagement.
Published Special Updates
- Report: U.S. Digital Asset Policy H1 2026 recapping policy developments from the first half of 2026, focusing on implications for the Zcash ecosystem.
- Report: FinCEN/OFAC Stablecoin NPRM Comment Letter Summary and Implications for Zcash that focuses on summarizing comment letters that impact the Zcash eco-system (e.g., comments that support or oppose privacy-preserving technologies.
Held the PGPZ Coalition Launch Breakfast
- June 30 Kickoff Breakfast at the Blockchain Association office

Why this matters for Zcash

PGPZ is focused on educating policymakers about Zcash, engaging with industry to respond to legislative and regulatory proposals, and taking a proactive stance towards policy development. This promotes ecosystem growth while defending against potentially harmful laws and policies by engaging with key stakeholders and helping them understand the important role Zcash and privacy play in payments.

Action Items

Help us spread awareness by inviting friends and colleagues to join the Community and Coalition.

Relevant Posts

CLARITY Act Talks Progress, but Prospects Become Murkier

The CLARITY Act’s prospects for enactment in 2026 have become increasingly uncertain due to a compressed Senate legislative calendar ahead of the August recess. Recent developments highlight significant operational, political, and regulatory challenges that collectively decrease the likelihood of the bill becoming law this year.

The White House is actively coordinating with law enforcement agencies to resolve ongoing concerns surrounding Section 604, which relates to developer protections; authorities remain concerned that shielding developers from money-transmitter liability could inadvertently facilitate illicit financial activities, making an administrative compromise necessary for the bill’s advancement.

JPMorganChase has voiced reservations around the CLARITY Act, cautioning lawmakers against stablecoin risks and decentralized finance (DeFi) exemptions, which it says introduces substantial institutional headwinds.

And reports detailing President Trump’s substantial financial returns from digital assets have intensified congressional debate regarding potential conflicts of interest and the oversight of executive ethics within the bill.

Notably, Galaxy has reduced its odds that the CLARITY Act will pass in 2026 from 60% to 50%.

Why this matters for Zcash

The CLARITY Act generally helps the crypto industry, and the Zcash ecosystem, through a deliberate and thoughtful market structure framework that would task the CFTC with oversight over digital commodities. If this does not pass, the SEC and CFTC have released a joint taxonomy that would still protect Zcash from being treated as a security under the federal securities laws. The key piece is around the developer protections that have remained in the bill following the May Senate Banking Committee Markup. The Blockchain Regulatory Certainty Act, which protects developers who do not take custody of funds from being classified as money transmitters under the Bank Secrecy Act framework, is a crucial piece of the CLARITY Act, and without it’s passage, developers would not have a law that protects them from enforcement actions.

Action Items

Call your Senator’s office to advocate for the passage of the CLARITY Act with developer protections preserved.

Relevant Posts

paulbrigner · July 21, 2026, 11:33am

PGPZ Weekly Policy Memo: Week of July 13, 2026

A little delayed (sorry about that), here is this week’s PGPZ Community policy memo covering PGPZ Community tools, CLARITY Act stalled, and tokenized finance coordination.

Key Takeaways

Senior White House officials met with members of the Senate to negotiate the ethics section of the CLARITY Act.
Democrats have stated that they will not support the CLARITY Act without addressing ethics concerns, and this introduces scheduling constraints as the legislative calendar advances, reducing the near-term probability of a floor vote unless further amendments are included to satisfy the dissenting lawmakers.
The Federal Law Enforcement Officers Association (FLEOA) formally endorsed the CLARITY Act, marking the second major law enforcement endorsement following the National Organization of Black Law Enforcement Executives (NOBLE).
Patrick Witt, the White House’s primary liaison for the CLARITY Act, will take a leave of absence starting July 24.
The U.S. Department of the Treasury and the UK’s HM Treasury, working through the Transatlantic Taskforce for Markets of the Future, have released a 10-point roadmap aimed at coordinating the oversight of tokenized assets, stablecoins, and digital financial markets.

Action Items

Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

X Post of the Week

PGPZ Community Updates

We’re excited to announce two new features of the PGPZ Community – the ZEC Shelf, a curated home for useful Zcash websites, tools, research, and references, and the X Monitor, a tool for monitoring the live conversation about Zcash on X. Enjoy!

Senate CLARITY Act Progress Stalls as Congress and Administration Discuss Ethics Provision

Senior White House officials met with members of the Senate to negotiate the eth-ics section of the CLARITY Act. This specific provision, which restricts the personal cryptocurrency business interests of senior government personnel, remains a primary point of contention, as Senate Democrats have consistently demanded these limits to address potential conflicts of interest. Given the limited floor time available in the Senate, the probability of the bill’s timely advancement depends heavily on achieving an adminis-trative compromise during these sessions. A failure to resolve the ethics dispute will likely delay the legislation past upcoming legislative windows.
Senators Chris Murphy (D-CT), Chris Van Hollen (D-MD), and Jeff Merkley (D-OR) expressed opposition to the CLARITY Act, describing the current framework as a “corrupt bill.” The senators’ pushback highlights frustration with ongoing negotiations regarding including ethics language in the final legislation. This issue complicates the bill’s path through the full Senate, where substantial bipartisan support is necessary for final passage. Democrats have stated that they will not support the legislation without addressing ethics concerns, and this introduces scheduling constraints as the legislative calendar advances, reducing the near-term probability of a floor vote unless further amendments are included to satisfy the dissenting lawmakers.
The Federal Law Enforcement Officers Association (FLEOA) formally endorsed the Digital Asset Market Clarity Act, marking the second major law enforcement endorsement following the National Organization of Black Law Enforcement Exec-utives (NOBLE). Notably, however, the FLEOA endorsement is conditional; the associa-tion requested specific legislative modifications to narrow liability protections for Decen-tralized Finance (DeFi) developers (Section 604), enhance accountability in DeFi sys-tems, and explicitly preserve existing federal investigative authorities. While these en-dorsements bolster the bill’s standing regarding public safety concerns, the requested amendments highlight ongoing institutional pushback against provisions perceived to hinder law enforcement capabilities. Reconciling these specific law enforcement de-mands with industry interests requires delicate administrative compromise, complicating the path to passage before the impending Senate recess.
Patrick Witt, the White House’s primary liaison for the Digital Asset Market Clarity Act, will take a leave of absence starting July 24 for military training. Witt has been a central figure in negotiating complex provisions of the bill, including stablecoin yield and ethics requirements, between industry representatives and lawmakers. His depar-ture occurs just weeks before a critical August 8 Senate recess deadline. Harry Jung, the Deputy Director of the President’s Council of Advisers on Digital Assets, will takeover as the lead. Jung previously served as Chief of Staff to former CFTC Commissioner Car-oline Pham and has been instrumental in the Council’s work. Why it matters for Zcash:
The CLARITY Act would generally help the crypto industry, and the Zcash ecosystem, through a deliberate and thoughtful market structure framework that would task the CFTC with oversight over digital commodities.
Over the past few weeks, the discussion has shifted from maintaining the developer pro-tections in the bill to ethics concerns. If ethics concerns are not addressed to Democrats’ satisfaction, the odds of the bill’s passage decrease given the tight margin in the Senate (53 Republicans and 47 Democrats/Independents).
The window for passing the CLARITY Act in the Senate is also shrinking as the Senate will recess from August 8 to September 14. If the bill is passed in September, it will need to be reconciled with the House–but the timing around this is complicated as September and October will focus heavily on elections, prior to the midterm elections in November. If the legislation does not pass, the SEC and CFTC are working on regulations that would provide more clarity for industry with respect to the application of the federal secu-rities laws.

Action Item

Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

Relevant Posts

U.S., UK Move to Align Rules for Tokenized Finance Across World’s Largest Financial Markets

The U.S. Department of the Treasury and the UK’s HM Treasury, working through the Transat-lantic Taskforce for Markets of the Future, have released a 10-point roadmap aimed at coordi-nating the oversight of tokenized assets, stablecoins, and digital financial markets. Notably, these recommendations do not introduce new statutory rules; instead, they outline a framework for closer cooperation among major regulatory bodies, including the SEC, CFTC, FCA, and the Bank of England. The initiative focuses on exploring common settlement mechanisms and as-sessing whether stablecoins or tokenized funds can be utilized as collateral. While the immedi-ate probability of structural market changes is low due to the non-binding nature of the roadmap, the probability of aligned international supervisory standards and reduced cross-border regula-tory friction over the medium term is significantly enhanced.

Why it matters for Zcash: Coordination between U.S. and UK regulatory agencies signals a long-term shift toward standardized cross-border compliance frameworks that emphasize insti-tutional transparency. As these jurisdictions collaborate to integrate tokenized finance into tradi-tional market infrastructures, a key theme is to harmonize regulatory clarity to support market development for digital assets and tokenization. This could enable more clarity for digital assets, including Zcash, in the UK, and globally, as the U.S. and UK begin to collaborate on regulatory oversight.

Action Item

No action item.

Relevant Posts

paulbrigner · July 25, 2026, 3:17pm

PGPZ Weekly Policy Memo: Week of July 20, 2026

Originally posted at Weekly Policy Memo: July 20, 2026 | PGPZ Community

This week’s PGPZ Community policy memo covers CLARITY Act draft released, ethics provisions challenged, and more. Join the PGPZ Community for regular Zcash related policy updates.

Key Takeaways

Senate Republicans released a draft of the CLARITY Act that consolidates language from the Banking and Agriculture contains a new section on ethics to satisfy Democratic concerns.
Senate Democrats are not satisfied with the ethics provision based on anticipated challenges with enforcement (the DOJ would be responsible for enforcing the ethics provisions against the president and other covered government officials.
Republican and White House opposition to direct state attorney general actions, what Democrats are pushing for, appears to be a significant constraint, although alternative mechanisms involving enforcement against intermediaries remain under discussion.
Patrick Witt will continue in his role as Executive Director of the President’s Council of Advisers on Digital Assets.
The Digital Chamber, a digital asset trade association, sued the State of Illinois over its digital-asset tax provision that will take effect next year.

Action Items

Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.
Illinois residents should call their local state representative and senator, framing the law’s implementation as a consumer privacy and data security issue. Explain that the law forces platforms to aggressively log and track the financial data of everyday citizens to prove whether they reside in Illinois, creating a massive honeypot for hackers. Push for a legislative amendment to clearly exempt noncustodial software and peer-to-peer transfers entirely.
Monitor the lawsuit for any request for preliminary injunctive relief, the State of Illinois’ response, and clarification regarding the precise transactions and service providers covered by the tax. The court’s treatment of the Internet Tax Freedom Act claim will be particularly relevant to whether similar digital-asset taxes may be adopted by other states

X Post of the Week

Senate CLARITY Act Negotiations Remain Constrained by Ethics and Scheduling Disputes

Senate Republicans released a draft of the Digital Asset Market Clarity Act (CLARITY Act) that consolidates language from the Banking and Agriculture Committee, containing a new section on ethics to satisfy Democratic concerns.
A group of Senate Democrats participating in the negotiations concluded in a joint statement that the consolidated draft does not adequately address ethics restrictions, consumer protection, illicit finance, conflicts of interest, or market integrity. Their position is significant because the Senate is expected to require 60 votes to invoke cloture, which limits debate and overcomes a filibuster so the chamber can move toward a final vote. The statement does not end negotiations, but it demonstrates that the current text lacks a reliable bipartisan coalition and therefore lowers the probability of immediate floor action.
Senator Cynthia Lummis (R-WY) characterized release of the consolidated draft as an important procedural milestone, while acknowledging that the text remains negotiable. Republican and White House opposition to direct state attorney general actions appears to be a significant constraint, although alternative mechanisms involving enforcement against intermediaries remain under discussion. The consolidated draft improves procedural readiness but does not establish the votes necessary for passage.
The White House argues that President Trump has accepted broad restrictions on the issuance or sponsorship of digital assets by senior government officials. The proposed provision would authorize civil penalties and federal enforcement, but it would principally rely on the Department of Justice. It would not provide direct enforcement authority to state attorneys general, and it would expire in January 2029, at the end of the current administration. The parties have therefore moved beyond whether an ethics provision should exist and are now disputing its enforceability and durability.
Relatedly, President’s Council of Advisers on Digital Assets Executive Director Patrick Witt deferred National Guard legal training so that he could continue serving as the administration’s principal negotiator during the expected Senate debate. His continued participation preserves institutional knowledge and reduces the risk of disruption at a sensitive stage. This is a modest positive development for negotiations, but it does not independently resolve disagreements over ethics enforcement, illicit finance, consumer protection, or the Senate schedule. The news comes as Harry Jung, the Council’s Deputy Director, announced he is leaving the administration.

Why this matters for Zcash

The CLARITY Act would generally help the crypto industry, and the Zcash ecosystem, through a deliberate and thoughtful market structure framework that would task the CFTC with oversight over digital commodities.
If ethics concerns are not addressed to Democrats’ satisfaction prior to August recess, the odds of the bill’s passage decrease significantly given the shrinking legislative window in August and the anticipated shift to high-priority legislative items such as funding packages. As a reminder, the timing around this vote is complicated because Congress will be heavily focused on the upcoming midterm elections in September and October.

Action Item

Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

Relevant Post

Crypto Industry Group Challenges Illinois Digital Asset Tax

The Digital Chamber, a digital asset trade association, sued the State of Illinois over its digital-asset tax provision that was enacted as part of the state budget shortly before the conclusion of the legislative session. The lawsuit seeks to prevent Illinois from enforcing the tax. The Digital Chamber contends that the statute violates the uniformity and due-process clauses of the Illinois Constitution, the Commerce Clause of the U.S. Constitution, and the federal Internet Tax Freedom Act.

The complaint’s central argument is that the tax distinguishes between transactions based on the technology used to record or process them. According to the filing, the statute does not differentiate between profitable and unprofitable transactions, realized and unrealized gains, or transfers that do and do not change ownership. Instead, it allegedly distinguishes between traditional financial infrastructure and blockchain infrastructure.

The Digital Chamber further argues that this distinction conflicts with the Internet Tax Freedom Act, which limits discriminatory state and local taxation of electronic commerce. The complaint maintains that federal law generally distinguishes assets according to their legal or economic characteristics rather than the technology used to record ownership.

Why this matters for Zcash

This law affects Zcash users in Illinois who use centralized platforms like Coinbase, Kraken, and Gemini, as the platforms will be required to log every purchase, trade, or withdrawal of crypto, including Zcash, and tack on the 0.2% tax, including transfers from a custodial wallet to a noncustodial wallet.
The law may impact users who use a noncustodial wallet’s internal swap functions, which rely on decentralized backend partners. While peer-to-peer transactions via noncustodial wallets would not be subject to the tax, the external liquidity providers, DeFi frontends, and market makers that execute the cross-chain swaps would likely be operating for-profit businesses because they collect fees. If these underlying protocols clear $100,000 in gross receipts from crypto trades originating in Illinois, the state will consider them “brokers.” This may result in companies blocking Illinois residents or limiting available features via geofencing.

Action Items

If you are in Illinois, call your local state representative and senator, framing the law’s implementation as a consumer privacy and data security issue. Explain that the law forces platforms to aggressively log and track the financial data of everyday citizens to prove whether they reside in Illinois, creating a massive honeypot for hackers. Push for a legislative amendment to clearly exempt noncustodial software and peer-to-peer transfers entirely.
Monitor the case for any request for preliminary injunctive relief, the State of Illinois’ response, and clarification regarding the precise transactions and service providers covered by the tax. The court’s treatment of the Internet Tax Freedom Act claim will be particularly relevant to whether similar digital-asset taxes may be adopted by other states.

Relevant Post

gilmore · July 25, 2026, 5:55pm

Hey Paul, I noticed something on the PGPZ community site while going through signup on mobile. Is there a support channel or someone I should message directly about it?

paulbrigner · August 1, 2026, 1:20pm

Weekly Policy Memo: Week of July 27, 2026

Originally posted at: Weekly Policy Memo: July 27, 2026 | PGPZ Community

This week’s PGPZ Community policy memo covers PGPZ July Monthly Update, Statements on state activity, PGPZ CLARITY Act Coalition Letter, and CLARITY Act Updates.

Key Takeaways

July marked PGPZ’s transition from initial organizational development toward sustained public education, policy monitoring, and direct advocacy. PGPZ expanded that foundation through new community resources and interventions concerning federal market structure, financial-crime oversight, state taxation, and electricity policy.
Senators Thom Tillis (R-NC) and Ruben Gallego (D-AZ) submitted revised CLARITY Act ethics provisions to the White House.
Banking interests are seeking a stronger prohibition on stablecoin yield-like products, while cryptocurrency companies oppose restrictions that could encompass rewards programs. This dispute adds uncertainty to the coalition needed to begin and complete floor consideration.

Action Items

Help us spread awareness by inviting friends and colleagues to join the Community and Coalition.
We’re in the home stretch! Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

X Post of the Week

July Monthly Update on PGPZ

July marked PGPZ’s transition from initial organizational development toward sustained public education, policy monitoring, and direct advocacy. PGPZ expanded that foundation through new community resources and interventions concerning federal market structure, financial-crime oversight, state taxation, and electricity policy.

PGPZ launched or substantially updated four public-facing resources:

ZEC Shelf: A centralized collection of educational and policy resources, including materials explaining how Zcash works. The feature is intended to make reliable background information easier for community members, policymakers, and external stakeholders to locate.

X Monitor: A monitoring tool through which Community and Coalition members can follow Zcash-related posts on X and identify emerging policy discussions, misconceptions, and opportunities for engagement.

Topic Briefings: FAQ-style collections of curated questions and answers intended to provide accessible and consistent explanations of recurring Zcash and public-policy issues.

Community Page Refresh: The PGPZ Community homepage was updated to improve access to policy materials, monitoring tools, briefings, and opportunities for participation.

These developments principally improve PGPZ’s organizational and communications capacity. They do not themselves change public policy, but they provide infrastructure for faster issue identification, more consistent public explanations, and more informed participation by Community and Coalition members.

We prepared and published statements for the record in connection with the House Financial Services July 17 CLARITY Act hearing and the July 21 FinCEN oversight hearing. The submissions represent a step beyond general policy commentary by directing Zcash-specific perspectives toward formal congressional oversight and legislative discussions.

PGPZ and participants from across the Zcash ecosystem prepared for submission a coalition letter to Senate Majority Leader John Thune and Democratic Leader Charles Schumer supporting H.R. 3633, the Digital Asset Market Clarity Act of 2025. The letter urged the Senate to bring the legislation to the floor while preserving its treatment of network tokens and the developer protections contained in the Blockchain Regulatory Certainty Act.

We issued a statement opposing the Illinois Digital Asset Tax Act enacted as part of the state’s fiscal year 2027 budget legislation. According to the statement, the Act taxes covered exchanges, transfers, and storage activity based on the value of the digital assets involved rather than on whether a user realizes income or profit. PGPZ argued that the structure could apply repeatedly across related activities, including a transfer from a custodial platform to a noncustodial wallet.

We also published a statement opposing a one-size-fits-all approach to large electricity loads in Texas. The statement addressed Texas Senate Bill 6, related Public Utility Commission of Texas proceedings, and a proposed change to the state’s transmission-cost methodology and large-load tariffs. It argued that these policies should distinguish between conventional data centers and cryptocurrency-mining facilities capable of rapid and reliable curtailment.

Why this matters for Zcash

July’s work expanded PGPZ’s ability to address several distinct policy channels affecting the Zcash ecosystem.

The website updates provide practical infrastructure for educating policymakers and community members, identifying emerging narratives, and coordinating accurate responses. These tools may be particularly useful when questions involve technically complex subjects such as shielded transactions, selective disclosure, viewing keys, self-custody, developer control, or proof-of-work mining.
The Statements and Coalition letter demonstrate PGPZ’s advocacy efforts to share the Zcash ecosystem’s perspectives and provide recommendations to federal and state government organizations to achieve their objectives while supporting financial privacy and Zcash stakeholders.
Collectively, these developments show a progression from the institution-building described in the June memo toward direct advocacy, ecosystem coordination, and production of reusable policy resources. They do not establish favorable legislative or regulatory outcomes, but they improve PGPZ’s capacity to participate in the proceedings that will determine those outcomes.

Action Item

Help us spread awareness by inviting friends and colleagues to join the Community and Coalition.

Senate CLARITY Act Negotiations Continue as Congress Tackles Remaining Issues

Senators Thom Tillis (R-NC) and Ruben Gallego (D-AZ) submitted revised ethics provisions to the White House. The proposal would change the enforcement mechanism for a prohibition on federal officials issuing or sponsoring tokens by allowing state authorities, rather than the U.S. Attorney General, to enforce the restriction, though this mechanism has yet to be revealed publicly. The bipartisan counteroffer modestly improves the possibility of resolving a significant objection raised by Senate Democrats, but there is no reported confirmation that the White House accepted it, that the language has been finalized, or that it secured additional votes.
Banking interests are seeking a stronger prohibition on stablecoin yield-like products, while cryptocurrency companies oppose restrictions that could encompass rewards programs. A bank-supported amendment that did not receive a committee vote could potentially be raised on the Senate floor. This dispute adds uncertainty to the coalition needed to begin and complete floor consideration.

Why this matters for Zcash

For Zcash, the principal significance is whether resolution of the ethics dispute permits the CLARITY Act to advance. If the dispute remains unresolved, the Senate may not reach substantive provisions that could affect ZEC, exchanges, developers, wallets, or other ecosystem participants. The enforcement design may also affect the political durability of the overall package. If lawmakers consider the ethics mechanism credible, more senators may be willing to support the bill. If they consider state enforcement insufficient, fragmented, or legally uncertain, the proposal may fail to resolve the underlying objection. The supplied sources do not establish which assessment is more likely to prevail.
The practical effect is consequently procedural rather than operational. A successful compromise could remove one barrier to Senate consideration of legislation that may ultimately affect Zcash. It does not itself change the legal treatment of ZEC or the operation of the Zcash protocol.

Action Item

We’re in the home stretch! Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

Relevant Post

divijpandya · August 12, 2026, 8:08pm

Hi all,

I’m working with Paul to stand up and operationalize PGPZ.

For the past few months, we’ve been working to formulate and advance pro-Zcash policy and advocacy positions. So far, we’ve been publishing weekly updates that focus exclusively on public policy issues that are relevant to the Zcash ecosystem. We cover relevant news items, explain why this matters for Zcash, and provide actionable steps for interested individuals to engage in grass roots advocacy. The most recent policy memo is available below and on the PGPZ Community page. It covers the CLARITY Act timeline in the Senate (we’re now looking at a Senate vote in September when the session resumes after August recess) and recent primaries for pro-crypto candidates backed by Fairshake PAC and its affiliates. Our weekly policy memos can be viewed here, where you can also check out our special updates.

Additional resources can be found here.

We also have a powerful X monitor that allows users to explore Zcash-related conversations on X through focused posts, concise summaries, and activity trends organized for the PGPZ community.

Last week, we launched the PGPZ X account and LinkedIn page.

We would very much appreciate it if members of the community can help support us by following, liking, and reposting content to promote PGPZ and help raise its profile.

Please don’t hesitate to reach out with any questions or feedback.

Best,
Div

X Post of the Week:

Senate Won’t Vote on Crypto Clarity Act Before Its Summer Break

Senate Majority Leader John Thune (R-SD) confirmed the Senate will not vote on the Digital Asset Market Clarity (CLARITY) Act before August recess, ending efforts to begin floor consideration before lawmakers leave Washington. The Senate is scheduled to return September 14, leaving roughly three weeks of legislative activity before the chamber becomes increasingly focused on the November midterm elections. The delay reflects both unresolved bipartisan disagreements over the legislation and competition from other Senate priorities, including government funding and nominations. Sen. Thune has indicated that the CLARITY Act will be taken up when the Senate returns, so the bill remains viable. However, losing the August window significantly reduces the probability of enactment in 2026 as the Senate must still needs 60 votes to invoke cloture on the bill, and, if it passes, the House and Senate will need to resolve differences between the two versions of the legislation.

Why this matters for Zcash: Delaying consideration until September means Zcash ecosystem stakeholders should expect the existing regulatory framework to remain operative for longer. It also makes the remaining negotiations particularly important given that provisions concerning illicit finance, decentralized technology and developer liability have greater direct relevance to Zcash than the stablecoin-rewards dispute that has received much of the political attention so far this year.

Action Item: Call your senators’ offices to advocate for the passage of the CLARITY Act with developer protections preserved and join the PGPZ Coalition Market Structure Working Group.

Relevant Post:

Crypto’s Campaign Efforts See Rare Loss, but Crypto Roster in Congress Likely to Grow

The digital asset industry’s Fairshake PAC suffered an uncommon electoral setback when Rep. Shri Thanedar (D-MI), a CLARITY Act co-sponsor, lost his Democratic primary despite more than $2 million in industry-supported spending. The result was offset by victories for five other Fairshake-backed candidates in Michigan and Washington, including lawmakers who have supported digital asset legislation. The broader pattern remains favorable to the industry’s effort to increase the number of lawmakers receptive to digital asset policy, although the result regarding Rep. Thanedar’s race demonstrates that campaign spending does not necessarily determine electoral outcomes. With the CLARITY Act now delayed and other issues, such as digital asset taxation, remaining before Congress, the composition of the next Congress is becoming increasingly relevant to the durability of federal digital asset public policy.

Why this matters for Zcash:

A larger congressional bloc receptive to digital assets could improve the long-term environment for federal digital asset legislation, particularly if the CLARITY Act is not enacted before the current Congress expires. For the Zcash ecosystem, however, a generally “pro-crypto” Congress should not automatically be regarded as supportive of financial privacy. Zcash-specific policy priorities, including protection for non-custodial software development, lawful use of shielded transactions, appropriate AML treatment and recognition of privacy-preserving technology, will require separate education and engagement. Consequently, the election results suggest a potentially more receptive policymaking environment, but one in which the Zcash ecosystem will still need to distinguish privacy technology from custodial financial intermediaries and illicit finance concerns.

Action Item:

No action item at this time.

Relevant Post:

divijpandya · August 12, 2026, 8:11pm

Hi @gilmore, sorry we missed this! Happy to chat about the Community site signup process. Best, Div

divijpandya · August 14, 2026, 3:19pm

Hi all, here’s this week’s update.

Originally posted at Weekly Policy Memo: August 10, 2026 | PGPZ Community

This week’s PGPZ Community policy memo covers next week’s CFTC IAC Meeting, how bank lobbying may slow the CLARITY Act, and that the White House plans to convene digital asset and prediction markets leaders next week.

Key Takeaways

The CFTC will convene its inaugural Innovation Advisory Committee next week, in which it will discuss digital asset regulation.
Banking advocacy organizations are using the congressional recess to press Republican senators for tighter restrictions on rewards paid to stablecoin holders, arguing that such programs could draw deposits away from banks and reduce lending capacity.
The White House is expected to convene digital asset and prediction market executives on August 19, one day before the CFTC’s Innovation Advisory Committee meeting.

Action Items

As the CFTC considers rulemakings and requests feedback, let us know if you have any comments or concerns.
Call your senators’ offices to advocate for the passage of the CLARITY Act and join the PGPZ Coalition Market Structure Working Group.

X Post of the Week

CFTC to Explore Crypto Regulation Beyond the CLARITY Act

The Commodity Futures Trading Commission (CFTC) will convene its inaugural Innovation Advisory Committee on August 20 to examine cryptocurrency, artificial intelligence and prediction-market policy. The meeting will consist of three substantive sessions. The first will examine the evolution of digital asset regulation, including state licensing requirements, overlapping jurisdiction, regulation through enforcement, actions available under existing statutory authority and the development of a durable federal market-structure framework. It will also address cybersecurity, operational resilience and digital asset infrastructure. The second session will consider artificial intelligence in trading, compliance, surveillance and risk management, including autonomous financial agents and the intersection between AI and digital assets. The final session will address prediction markets, federal and state jurisdiction, product design, surveillance, manipulation and customer protection. The committee is advisory and the agenda does not provide for a vote on binding rules. The meeting may inform later guidance or rulemaking and help the CFTC prepare for future legislation, but it will not independently advance the CLARITY Act through Congress.

The agenda includes consideration of regulatory actions the CFTC could take under its existing authority to complement future legislation. The meeting reflects an effort to provide incremental administrative clarity after the Senate postponed consideration of the CLARITY Act until after its August recess. Such measures could support implementation planning and clarify selected compliance questions, but they cannot fully establish the statutory division of authority between the CFTC and Securities and Exchange Commission (SEC) or provide the durability of enacted legislation. The SEC initially scheduled a meeting on a tailored offering framework for certain crypto assets for August 14, but Reuters subsequently reported that the SEC postponed that meeting because of a scheduling issue. Administrative work may continue if congressional action remains delayed.

Why it matters for Zcash

CFTC regulation, staff guidance, and no-action letters could improve regulatory predictability for intermediaries offering ZEC-related trading or derivatives products. Note that this would not resolve questions under Treasury and FinCEN authorities concerning shielded transactions, anti-money-laundering controls, self-hosted wallets or noncustodial software. Administrative policy may provide near-term assistance, but statutory protections would remain more durable.

Action Item

As the CFTC considers rulemakings and requests feedback, let us know if you have any comments or concerns.

Relevant Post

Bank Lobbying Adds Republican Pressure to the CLARITY Act Debate

Banking advocacy organizations are using the congressional recess to press Republican senators for tighter restrictions on rewards paid to stablecoin holders, arguing that such programs could draw deposits away from banks and reduce lending capacity. Digital asset companies and their congressional allies contend that an earlier compromise negotiated by Senators Thom Tillis (R-NC) and Angela Alsobrooks (D-MD) adequately addressed passive-balance yield and that broader restrictions would principally protect incumbent financial institutions from competition. Republican supporters of the CLARITY Act expect sufficient party support to begin floor consideration, but bank opposition could still produce defections or demands for additional amendments. The more consequential hurdle remains the need for Democratic votes to reach the Senate’s 60-vote procedural threshold, including an agreement on ethics provisions addressing federal officials’ digital asset interests. Bank lobbying consequently increases drafting and scheduling risk during an already limited September legislative window, but it would not necessarily defeat the bill if Republicans remain largely unified and negotiators secure sufficient Democratic support.

Why this matters for Zcash

The stablecoin rewards dispute does not directly concern ZEC, but it is delaying a broader bill that could determine CFTC spot-market authority, exchange obligations and protections for developers, self-custody and noncustodial activity. Prolonged negotiations therefore extend regulatory uncertainty for ZEC-related listings and services. Any compromise should keep restrictions on stablecoin rewards confined to fiat-referenced payment products. Broad definitions of “rewards” or “yield” should not create unintended uncertainty for unrelated arrangements, including Zcash’s proof-of-work block rewards or exchange programs involving ZEC.

Action Item

Call your senators’ offices to advocate for the passage of the CLARITY Act and join the PGPZ Coalition Market Structure Working Group.

Relevant Post

White House to Host Cryptocurrency and Prediction-Market Executives

The White House is expected to convene digital asset and prediction market executives on August 19, one day before the CFTC’s Innovation Advisory Committee meeting. Traditional financial institutions may also participate, although the guest list, agenda and President Trump’s attendance remained unsettled. The gathering indicates continued Executive Branch engagement with fintech companies while the CLARITY Act awaits Senate consideration in September. Its proximity to the CFTC meeting may allow industry concerns and administrative priorities to be coordinated, but the White House meeting is informal and does not itself constitute rulemaking, legislation or an enforceable policy commitment. Its significance will depend on whether participants identify compromises or regulatory proposals that can subsequently be incorporated into formal legislative or agency processes.

Why this matters for Zcash

The practical significance for Zcash will depend substantially on representation and subject matter. Large exchanges and prediction market firms may prioritize market access, stablecoins and event contracts rather than privacy-preserving digital cash. Unless the meeting produces a formal follow-up process, it creates no immediate change for ZEC users, developers or exchange listings.

Action Item

No action item.

Relevant Post

divijpandya · August 21, 2026, 9:19pm

Hi everyone, here’s this week’s update.

Originally posted at Weekly Policy Memo: August 17, 2026 | PGPZ Community

This week’s PGPZ Community policy memo covers yesterday’s CFTC IAC Meeting and the potential CFTC digital assets rulemaking and the SEC’s notice of proposed rulemaking regarding crypto assets.

Key Takeaways:

The CFTC outlined an extensive regulatory agenda covering digital assets and Chairman Mike Selig stated he has directed staff to prepare a rulemaking if the CLARITY Act is not enacted.
The SEC proposed Regulation Crypto Assets, which would establish two registration exemptions for crypto-related investment contracts and a safe harbor for determining when an asset is no longer subject to an investment contract.

Action Items:

Post and reshare posts that promote the CFTC’s work around digital assets and a potential rulemaking to illustrate support for the agency’s agenda.
Please reach out if you have any questions, comments, or concerns about the SEC NPRM.

X Post of the Week:

CFTC Innovation Advisory Committee Sets a Broad Agenda for Digital Assets, AI, and Prediction Markets

The Commodity Futures Trading Commission’s (CFTC) Innovation Advisory Committee (IAC) convened and outlined an extensive regulatory agenda covering digital assets, artificial intelligence, cybersecurity, and prediction markets. The digital-asset discussion centered on establishing a unified federal framework, improving SEC–CFTC coordination, and distinguishing decentralized protocols and software developers from conventional financial intermediaries, among other things. Participants generally supported advancing agency rulemaking alongside legislation and criticized the cost, inconsistency, and unequal market access associated with state-by-state licensing. Within that broader discussion, Chairman Michael Selig confirmed that the CLARITY Act remains the preferred and most durable means of establishing federal market structure, but directed staff to examine a contingency framework under the CFTC’s existing authority if legislation stalls. Discussions regarding financial privacy arose through competing concerns about data minimization, centralized databases linking identities to holdings, confidential regulatory access, uniform KYC requirements, and the surveillance capabilities of public blockchains. Note, however, that committee recommendations are advisory, and the scope and durability of any CFTC framework would remain constrained by existing statutory authority, interagency jurisdictional questions, and the rulemaking process. Public comments regarding the meeting may be submitted through August 27, 2026.

Why this matters for Zcash:

Zcash was specifically cited by IAC member Tyler Winklevoss during the meeting as an example of a project using advanced AI models to identify vulnerabilities and strengthen network security, as well as a project advancing formal verification. The favorable cybersecurity reference provides a useful basis for presenting Zcash as verifiable and resilient financial infrastructure.

Separately, a CFTC rulemaking on digital assets would help provide more clarity for the industry in the absence of legislation.

Action Item:

Post and reshare posts that promote the CFTC’s work around digital assets and a potential rulemaking to illustrate support for the agency’s agenda.

Relevant Post:

SEC Proposes Registration Exemptions and a Safe Harbor for Crypto-Related Investment Contracts

The Securities and Exchange Commission’s (SEC) released its notice of proposed rulemaking (NPRM) on Regulation Crypto Assets, which would establish two registration exemptions for crypto-related investment contracts and a safe harbor for determining when an asset is no longer subject to an investment contract, among other things. The proposal does not broadly exempt crypto offerings from the federal securities laws. Its principal legal contribution is to distinguish between a crypto asset that is not itself a security and the investment contract that may arise when the asset is offered with promises of essential managerial efforts from which purchasers reasonably expect profits. Building on the SEC’s March 2026 crypto-asset interpretation, the NPRM states that continued work to maintain or improve an already functional network generally need not constitute essential managerial efforts when value instead derives from programmatic operation, market forces, and contributions from multiple participants. The proposal will have a 60-day public-comment period after publication in the Federal Register. If finalized, it could materially improve administrative clarity for crypto capital formation, but it would remain narrower than comprehensive market-structure legislation.

Why this matters for Zcash:

The proposal’s distinction between a non-security crypto asset and an investment contract involving that asset is potentially significant for the Zcash ecosystem, as it would provide that ZEC is not a security subject to the federal securities laws. Note that although the SEC notified the Zcash Foundation earlier this year that it ended its investigation, rules formally distinguishing digital assets that are part of an investment contract from the contract itself have not yet been implemented. This rulemaking would provide more clarity for the ecosystem.

Action Item:

Please reach out if you have any questions, comments, or concerns about the SEC NPRM.

Relevant Post:

divijpandya · August 31, 2026, 6:13pm

Hi all, here are the previous two updates (Sept. 7 and Sept. 14). Sorry for the delay–will try to get these posted here on Fridays when we publish.

Originally posted at Weekly Policy Memo: September 07, 2026 | PGPZ Community and Weekly Policy Memo: September 14, 2026 | PGPZ Community

Sept. 7 covers the updated CLARITY Act draft released days ahead of the September 15 cloture vote. Sept. 14 covers the CLARITY Act procedural vote failure; House Ways and Means Committee’s advancement of digital asset tax legislation; and the CFTC staff’s no-action letter on passive software providers of access to CFTC-regulated derivatives offered by registered entities.

Week of September 7, 2026

Key Takeaways:

Senate Republicans released an updated, 630-page substitute for the CLARITY Act, days before the Senate is scheduled to vote on whether to invoke cloture on the motion to proceed.
A comparison of the July 22 and September 10 texts shows that the developer provisions were reorganized rather than uniformly expanded or narrowed.
Overall, the September draft provides clearer and, in several respects, stronger protection for pure software development, code publication, infrastructure services, and appropriately limited cybersecurity response.

Action Item:

Call your senators and tell them to pass the CLARITY Act with the developer protections and the Blockchain Regulatory Certainty Act included.

X Post of the Week:

Revised CLARITY Act Text Arrives Before a Pivotal Senate Vote

Senate Republicans released an updated, 630-page substitute for the CLARITY Act, days before the Senate is scheduled to vote on whether to invoke cloture on the motion to proceed, which limits debate and overcomes a filibuster so the chamber can move toward a final vote. The revised text adds decentralized-finance provisions, among other things, but it does not change the White House-supported ethics title or the stablecoin rewards provisions that have contributed to opposition among Democrats and some Republicans. Cloture requires 60 votes, which means that with at least two Republican senators expected to oppose the procedural motion, proponents would need support from at least nine Democrats, several of whom have conditioned their votes on stronger ethics restrictions. Prosecutors’ organizations also continue to object to the Blockchain Regulatory Certainty Act, while negotiations over vertical integration in the Agriculture title remain incomplete. Even if the Senate advances and passes the measure, the House would have to approve the Senate’s revisions, and its shortened September schedule makes action before the post-election session unlikely. The new text improves legislative readiness and resolves some drafting questions, but it does not remove the principal political obstacles; the September 15 vote’s passage therefore remains uncertain. The revised Senate text is publicly available.

Developer Protection-related Changes in the September Draft

A comparison of the July 22 and September 10 texts shows that the developer provisions were reorganized rather than uniformly expanded or narrowed:

Core software and network activity retains broad protection. Developers, publishers, transaction validators, node and oracle operators, providers of computational work or network bandwidth, and publishers of self-custody software generally would not become subject to the Commodity Exchange Act solely because they perform those activities. The phrase “solely based on” is important: the protection attaches to the listed conduct and would not immunize separate custodial, brokerage, dealing, or controlling activity.
Post-deployment decentralized-finance activity receives a narrower safe harbor. The July text generally protected user interfaces, protocol administration, messaging systems, smart-contract liquidity pools, and wallet-related operations from the Commodity Exchange Act as a whole. The September text protects those activities only from the Act’s digital-commodity cash- and spot-market provisions. This change preserves meaningful protection for nonintermediary activity but creates greater potential exposure when a person moves beyond publishing code and actively operates or maintains a trading interface or protocol.
A control-based framework replaces categorical treatment of operational DeFi. A protocol could be treated as a “non-decentralized finance trading protocol” if a person or coordinated group can materially alter its operation, if transactions are not governed solely by transparent pre-established code, or if an operator can restrict or censor use. The CFTC, in consultation with the SEC and Treasury, would establish tailored requirements for controlling persons based on the financial functions they perform. Bank Secrecy Act obligations would attach only to controlling persons required to register and treated as financial institutions under preexisting law. The bill expressly protects First Amendment interests in creating, publishing, and using code; prohibits requiring software or a distributed-ledger system to register in its own capacity; and bars rules that would prohibit launching, deploying, or operating a protocol.
Additional safeguards improve legal predictability. The September text states that the section does not expand CFTC jurisdiction or create a presumption that a person or activity is regulated. It preempts inconsistent state securities, commodities, and digital-asset laws for protected activities, while preserving state anti-money-laundering, antifraud, and anti-manipulation authority, and it applies the safe harbor to conduct occurring before, on, or after enactment. It also generally treats governance participants as separate persons and provides that participation in a security council—or use of a predefined, temporary, rules-based emergency response—does not by itself establish control, provided the response is authorized through publicly disclosed on-chain mechanisms, narrowly limited to a documented cybersecurity incident, and not used for unrelated protocol, governance, or economic changes.
The separate money-transmitter protection remains politically unresolved. Section 20209 concerns civil regulation under the Commodity Exchange Act. The Blockchain Regulatory Certainty Act, in Section 10604, separately provides that a noncontrolling developer or infrastructure provider is not a money transmitter solely because it publishes software, supplies self-custody tools, or supports a distributed ledger. Prosecutors’ groups continue to oppose that provision and that a key Democratic senator has not publicly changed her position. The September revisions to the CFTC safe harbor therefore do not eliminate the principal legislative risk to noncustodial-developer protection.

Why it matters for Zcash:

The core safe harbor’s retention in the September 10 version is helpful for the ecosystem. This is because developing software that shields transactions, validating transactions, operating network infrastructure, or publishing tools that allow users to control their own ZEC would not, by themselves, create Commodity Exchange Act obligations. Federal preemption and retroactive application would also reduce uncertainty arising from conflicting state regulatory theories. These protections remain activity-specific, however, as a person performing custody, brokerage, dealing, transaction execution, or other intermediary functions could still be regulated on the basis of that separate conduct.

The narrower treatment of post-deployment interfaces and operational DeFi activity warrants closer attention for ecosystem stakeholders. A wallet developer or interface operator that also administers trading functions may receive less comprehensive protection than a developer who only writes and publishes software. Accordingly, future CFTC and Treasury rulemakings for persons controlling non-decentralized trading protocols will be important. Those proceedings should distinguish protocol development and privacy-preserving infrastructure from financial intermediation and should not convert Bank Secrecy Act obligations applicable to a controlling intermediary into protocol-level requirements for universal identification, transaction tracing, or modification of shielded transactions.

Action Item:

Call your senators and tell them to pass the CLARITY Act with the developer protections and the Blockchain Regulatory Certainty Act included.

Relevant Post:

Week of September 14, 2026

Key Takeaways:

The Senate voted 49–50 against advancing the Digital Asset Market Clarity (CLARITY) Act, short of the 60 votes required to proceed with debate. In the interim, policy development has already shifted toward the SEC and CFTC, however, their regulatory fixes cannot provide the same statutory durability or resolve all jurisdictional questions.
The House Ways and Means Committee voted 38–5 to advance H.R. 10357, the Digital Asset Tax Certainty Act. The bill would clarify the tax treatment of digital asset transaction fees, accounting, stablecoins, lending, wash sales, mining, staking, and broker reporting. Its de minimis provision is narrower than a general exemption for small purchases.
The CFTC’s Market Participants Division issued Staff Letter No. 26-25, extending to similarly situated passive software providers the no-action position it previously granted to Phantom Technologies.

Action Item:

PGPZ plans to support the Digital Asset Tax Certainty Act and its outcome from the markup. Let us know how this legislation would impact you and whether you’d like to see any changes reflected in the bill.

X Post of the Week:

CLARITY Act Fails Senate Procedural Vote After Last-Minute Negotiations

The Senate voted 49–50 against advancing the Digital Asset Market Clarity (CLARITY) Act, short of the 60 votes required to proceed with debate. The vote followed months of negotiations and a last-minute Democratic counteroffer, but the parties remained divided principally over ethics restrictions for senior federal officials with digital asset interests. Additional opposition concerned stablecoin rewards, state enforcement authority, and the Commodity Future Trading Commission’s (CFTC) treatment of prediction markets. The bill also lost several Republican votes and did not secure a simple majority, making successful reconsideration during the limited post-election session unlikely. A renewed effort remains possible, but enactment before the end of the 119th Congress, which follows a two-year cycle, would require a substantial political reversal; otherwise, market-structure legislation will need to be reintroduced in the next Congress. In the interim, policy development has already shifted toward the SEC and CFTC, however, their regulatory fixes cannot provide the same statutory durability or resolve all jurisdictional questions.

Why it matters for Zcash:

The vote leaves Zcash without the CLARITY Act’s proposed statutory framework for classifying digital assets, allocating spot market authority, and protecting certain noncustodial software activity. The most recent draft would have provided civil regulatory protections for qualifying blockchain developers and service providers, but it did not include the earlier proposed clarification of criminal liability under 18 U.S.C. § 1960. It therefore would not have fully resolved the legal risk facing developers of privacy-preserving, noncustodial software. The vote’s failure means that even its narrower civil protections did not take effect. Agency action may improve conditions for particular products or intermediaries, but it cannot supply a comprehensive or durable developer safe harbor.

Action Item:

No action item.

Relevant Post:

House Committee Advances the Digital Asset Tax Certainty Act

The House Ways and Means Committee voted 38–5 to advance H.R. 10357, the Digital Asset Tax Certainty Act, demonstrating substantial bipartisan support despite the CLARITY Act’s failure. The bill would clarify the tax treatment of digital asset transaction fees, accounting, stablecoins, lending, wash sales, mining, staking, and broker reporting. Its de minimis provision is narrower than a general exemption for small purchases. The Joint Committee on Taxation’s description states that it would generally prevent recognition of gain or loss when digital assets are disposed of to pay qualifying network or transaction fees of no more than $10, beginning after 2027. The measure would also extend certain tax rules applicable to traditional financial assets and clarify the source and ordinary-income character of mining and staking income. Committee approval materially improves the bill’s position, but it must still pass the House and Senate during a short remaining legislative calendar. Enactment this year is therefore uncertain, although the bipartisan vote may give the proposal a stronger basis for renewed consideration if it does not advance before Congress adjourns.

Why it matters for Zcash:

If enacted, the fee provision could reduce tax-recordkeeping burdens when ZEC is used to pay qualifying network or transaction fees, but it would not create a general tax exemption for purchases made with ZEC. Zcash miners would be directly affected by the proposed sourcing and ordinary-income rules for validation activity, while ZEC traders could face expanded wash-sale and constructive-sale requirements.

Action Item:

PGPZ plans to support this legislation and its outcome from the markup. Let us know how this legislation would impact you and whether you’d like to see any changes reflected in the bill.

Relevant Post:

CFTC Staff Extends Conditional No-Action Relief to Passive Software Providers

The CFTC’s Market Participants Division issued Staff Letter No. 26-25, extending to similarly situated passive software providers the no-action position it previously granted to Phantom Technologies. Until CFTC rulemaking or guidance becomes effective, division staff will not recommend enforcement for failure to register as an introducing broker, or for relevant personnel to register as associated persons, solely because a qualifying provider supplies or markets software through which users access CFTC-regulated derivatives offered by registered entities. The relief can apply to standalone interfaces or software embedded in self-custodial wallets, and providers may receive transaction-based compensation. However, the staff letter is narrowly conditioned, stating that the provider must remain passive, may not custody assets, generate trading signals, or exercise order-routing or execution discretion, and must satisfy disclosure, marketing, recordkeeping, notice, and other requirements. The provider and participating registrant must also accept joint and several liability for violations connected to the covered activity. Note that the letter is a staff enforcement position rather than a Commission rule, which means it is fact-dependent, temporary, and subject to modification or withdrawal rather than a durable regulation.

Why it matters for Zcash:

The letter provides a useful regulatory distinction between passive software and financial intermediation. A qualifying Zcash wallet could potentially embed access to derivatives offered by registered CFTC entities without the wallet provider becoming an introducing broker solely for that activity, even if the interface is marketed or generates transaction-based fees. The relief does not cover ordinary ZEC transfers, spot-market activity, custody, investment advice, discretionary routing, money-transmission obligations, anti-money-laundering requirements, or criminal liability, and it should not be understood as a general safe harbor for wallet or protocol developers. Its operational conditions, particularly the required undertaking of joint and several liability, may also limit practical reliance. Still, the approach offers a potentially constructive model for future rules that assess software providers according to custody, control, and transaction-specific conduct rather than treating publication of noncustodial software as regulated intermediation.

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No action item.

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Hi everyone, here’s this week’s update.

Originally posted at Weekly Policy Memo: September 21, 2026 | PGPZ Community

This week’s PGPZ Community policy memo covers outgoing SEC Commissioner Hester Peirce’s speech from this past week where she discussed minimizing data collection and leveraging privacy-preserving technologies to support compliance.

Key Takeaways:

SEC Commissioner Hester Peirce argued that federal financial regulation should move away from indiscriminate data collection and toward more targeted, privacy-preserving methods of verification. She questioned whether existing customer identification, transaction monitoring, and reporting requirements create large repositories of personal information without proportionate enforcement benefits, while increasing cybersecurity and confidentiality risks.

Action Item:

No action item.

X Post of the Week:

Commissioner Peirce Calls for Data Minimization and Zero-Knowledge Verification in Financial Regulation

In remarks at SIFMA’s Digital Assets Conference, SEC Commissioner Hester Peirce argued that federal financial regulation should move away from indiscriminate data collection and toward more targeted, privacy-preserving methods of verification. She questioned whether existing customer identification, transaction monitoring, and reporting requirements create large repositories of personal information without proportionate enforcement benefits, while increasing cybersecurity and confidentiality risks. As alternatives, Commissioner Peirce identified attribute-based credentials, third-party identity verification, and zero-knowledge proofs. She also cautioned against introducing intermediaries into permissionless systems principally to create a point of data collection.

Why it matters for Zcash:

The remarks provide direct support for zero-knowledge proofs, reduced duplication of identity records, and data minimization and supports the proposition that regulatory compliance does not require universal disclosure of identity or transaction history. These concepts may strengthen the public policy case for use of selective disclosure and privacy-preserving credentials instead of routine demands for full viewing keys or permanent public surveillance.

Action Item:

No action item.

Relevant Posts:

Shawn · October 2, 2026, 4:02pm

bump this post

divijpandya · October 9, 2026, 6:43pm

Hi everyone, here’s last week’s and this week’s update.

Originally posted at Weekly Policy Memo: September 28, 2026 | PGPZ Community and ** Weekly Policy Memo: October 05, 2026 | PGPZ Community **.

Last week’s PGPZ Community policy memo covers the SEC’s crypto-asset custody rule, tax legislation, separate staff guidance from the SEC and CFTC, Illinois postponing its digital asset tax, Rep. Sean Casten’s (D-IL) bid for the top Democratic member on the House Financial Services Committee, and a new memorandum of understanding between the New York Department of Financial Services and Wyoming Division of Banking.

This week’s policy memo covers the CFTC’s advance notice of proposed rulemaking on crypto asset transactions and crypto asset markets, FinCEN’s withdrawal of its mixer and unhosted wallet proposals, and Fairshake PAC’s identification of 32 House races for political contributions.

Weekly Policy Memo: Week of September 28, 2026

Key Takeaways:

The SEC proposed a rule governing crypto-asset custody by registered investment advisers and regulated funds, including registered investment companies and business development companies. The proposal would permit self-custody under specified circumstances, allow state trust companies to custody client and fund crypto assets, and update requirements concerning financial-statement audits and broker-dealer custodial services.
Sen. Steve Daines (R-MT) introduced the Aligning Digital Assets with Principles of Taxation (ADAPT) Act, pairing targeted tax simplification with restrictions intended to align digital assets with traditional investments. The bill would eliminate gain-or-loss recognition for qualifying regulated dollar-stablecoin purchases of goods and services and for eligible crypto-paid transaction costs totaling $10 or less.
SEC staff issued and updated FAQs addressing crypto-asset classification and investment contracts. The guidance explains that maintenance, security improvements, and development supporting an already functional network need not constitute the essential managerial efforts relevant to the securities law analysis. Separately, CFTC staff updated guidance concerning investment of customer funds in tokenized forms of permitted investments and blockchain-based recordkeeping.
Illinois officials and industry challengers have agreed to seek postponement of the state’s digital asset tax from January 1 to July 1, 2027, subject to court approval.
Rep. Sean Casten (D-IL) has reportedly approached Democratic colleagues about a potential bid for the top Democratic position on the House Financial Services Committee, currently held by Rep. Maxine Waters. Rep. Casten has been a vocal critic of digital assets’ illicit-finance risks. His prior proposals include a temporary prohibition on financial institutions handling mixer-routed funds and the CODE Act, which would explore integrating AML, sanctions, and customer-identification controls into DeFi systems before subsequent FinCEN rulemaking.

New York’s Department of Financial Services and the Wyoming Division of Banking have announced a memorandum coordinating digital asset licensing, examinations, information sharing, and enforcement.

Action Items:

PGPZ may respond to the SEC rulemaking. Reach out if you have any comments in support or in opposition of this proposed rulemaking.
Reach out if you have ideas for additional guidance for SEC and CFTC consideration.

September Monthly Update on PGPZ:

September marked an important step in PGPZ’s organizational development and preparation for sustained advocacy. We formally seated our Board of Directors, advanced operational and compliance work, and developed policy and educational materials to support engagement on financial privacy, privacy-preserving technologies, and developer protections.

September’s substantive policy work included:

· CLARITY Act and developer protections: Analyzing how proposed legislation would affect the Zcash ecosystem, with particular attention to protections for developers of decentralized technology and subsequent legislative developments.

· Texas electricity policy: Explaining why flexible proof-of-work mining should be distinguished from other large electricity users, particularly when facilities can reduce demand during periods of grid stress.

· Weekly policy updates: Continuing to share legislative and regulatory developments and provide opportunities for questions through our Public Policy and Regulatory Developments Q&A thread.

Why it matters for Zcash:

September’s work strengthened PGPZ’s capacity to bring informed, technically grounded perspectives into policymaking. Our governance and operational processes support sustained advocacy, while the proposed ecosystem input process will help ensure that our positions reflect practical experience across the community.

The policy analyses and educational materials provide a foundation for explaining lawful uses of shielded transactions, distinguishing noncustodial software development from financial intermediation, and addressing the treatment of proof-of-work mining. October’s meetings and events will create opportunities to put that work directly before policymakers and their staff.

Action Item:

Help shape our advocacy by sharing policy concerns, technical input, and practical examples of how financial privacy matters to you. Please also invite friends and colleagues to join the PGPZ Community and Coalition.

X Post of the Week:

SEC Proposes Crypto Custody Framework for Investment Advisers and Funds

The Securities and Exchange Commission (SEC) proposed a tailored framework governing crypto-asset custody by registered investment advisers and regulated funds, including registered investment companies and business development companies. The proposal would permit self-custody under specified circumstances, allow state trust companies to custody client and fund crypto assets, and update requirements concerning financial-statement audits and broker-dealer custodial services. The initiative addresses a practical obstacle to institutional participation as custody arrangements designed for traditional securities do not always accommodate digital assets or the availability of custodial services. Comments will be accepted for 60 days following Federal Register publication, and the final framework will depend on the Commission’s consideration of operational risks, investor protections, and public feedback.

Why it matters for Zcash:

Additional custody options could make it easier for advisers and funds to support ZEC, although they would not guarantee product approval or institutional adoption. A key policy question is whether custody safeguards can accommodate shielded assets.

Action Item:

PGPZ may respond to this rulemaking. Reach out if you have any comments in support or in opposition of this proposed rulemaking.

Relevant Post:

Daines Introduces Digital-Asset Tax Bill Combining Payment Relief With Wash-Sale Restrictions

Sen. Steve Daines (R-MT) introduced the Aligning Digital Assets with Principles of Taxation (ADAPT) Act, pairing targeted tax simplification with restrictions intended to align digital assets with traditional investments. The bill would eliminate gain-or-loss recognition for qualifying regulated dollar-stablecoin purchases of goods and services and for eligible crypto-paid transaction costs totaling $10 or less. It would also extend wash-sale and constructive-sale rules to covered digital assets and address lending, investment structures, and other tax questions. Its introduction provides a Senate counterpart to the digital-asset tax legislation recently advanced by the House Ways and Means Committee. However, the proposals differ materially, which means negotiators in the House and Senate must reconcile their scope, effective dates, and treatment of particular transactions.

Why it matters for Zcash:

Eligible ZEC-denominated transaction fees could benefit from the $10 threshold, but that relief should not be confused with a general small-payment exemption. Proposed wash-sale restrictions would also affect covered ZEC investment transactions, subject to the bill’s exceptions and transition provisions.

Action Item:

No action item at this time.

Relevant Post:

SEC and CFTC Continue Administrative Clarification Following the CLARITY Act Setback

SEC staff issued and updated FAQs addressing crypto-asset classification and investment contracts. The guidance explains that maintenance, security improvements, and development supporting an already functional network need not constitute the essential managerial efforts relevant to the securities law analysis. It also addresses staking receipt tokens, promotional statements, and buybacks; the September 28 buyback clarification expressly requires a functional system without a central party. Note that the FAQs represent staff views, have no legal force, and do not amend existing law. Separately, Commodity Futures Trading Commission (CFTC) staff updated guidance concerning investment of customer funds in tokenized forms of permitted investments and blockchain-based recordkeeping. Together, these actions demonstrate continued administrative work following the Senate’s failed CLARITY Act vote, but do not replace the statutory market-structure framework Congress has yet to enact.

Public Policy Implications for the Zcash Ecosystem

The SEC’s distinction between maintaining a functional network and promising essential managerial efforts is particularly relevant to Zcash’s developers and supporting organizations. It supports the argument that continued technical development should not, by itself, determine securities treatment. Nevertheless, the guidance neither classifies ZEC nor creates a general developer safe harbor. Its analysis remains separate from money-transmission, sanctions, and anti-money-laundering requirements. Zcash stakeholders should therefore distinguish useful securities-law clarification from the broader statutory protections sought for noncustodial software and decentralized infrastructure.

Action Item:

Reach out if you have ideas for additional guidance for SEC and CFTC consideration.

Relevant Post:

Illinois Agrees to Seek a Six-Month Delay of Its Digital-Asset Tax

Illinois officials and industry challengers have agreed to seek postponement of the state’s digital asset tax from January 1 to July 1, 2027, subject to court approval. The 0.2% tax applies to Illinois-based users and the companies that provide services to them and covers specified digital asset activities, including transactions from a hosted wallet to a self-custody wallet, when certain requirements are met. The agreement would allow the parties to focus on the underlying dispute over the tax’s constitutionality and enforceability rather than immediate implementation. Challengers also argue that federal law preempts the measure. The proposed delay is procedural relief, not repeal or a ruling accepting those arguments. If approved, it would reduce near-term compliance pressure while leaving the tax’s ultimate validity unresolved.

Why it matters for Zcash:

A postponement could provide additional preparation time for covered businesses supporting ZEC and reduce immediate pressure to change services or pass compliance costs to customers. It would not resolve the broader concern that taxing transaction activity, rather than realized gains, can increase the cost of using digital assets. For the Zcash ecosystem, the litigation remains relevant to the affordability and availability of custodial services and transfers involving self-custody in Illinois. Stakeholders should not treat the agreement as either a permanent exemption or a final judicial outcome.

Action Item:

No action item at this time.

Relevant Post:

Casten Seeks Support for Potential House Financial Services Leadership Bid

Rep. Sean Casten (D-IL) has reportedly approached Democratic colleagues about a potential bid for the top Democratic position on the House Financial Services Committee, currently held by Rep. Maxine Waters. Rep. Casten has reportedly engaged in preliminary outreach, but has not announced his candidacy for the role. The outcome would depend on internal Democratic decisions, while control of the House would determine whether the position carries the authority of Chair or Ranking member. Rep. Casten has been a vocal critic of digital assets’ illicit-finance risks. His prior proposals include a temporary prohibition on financial institutions handling mixer-routed funds and the CODE Act, which would explore integrating AML, sanctions, and customer-identification controls into DeFi systems before subsequent FinCEN rulemaking. His record suggests that illicit finance and technology-based compliance would be important priorities if he obtained the position, although the leadership discussion itself changes no law.

Why it matters for Zcash:

Rep. Casten’s interest merits attention because his earlier mixer legislation also proposed studying privacy coins and anonymity-enhancing technologies. A leadership role could give those concerns greater influence over hearings, oversight, and legislative negotiations. His potential advancement signals a policy risk to monitor, not a predetermined restriction on Zcash.

Action Item:

No action item at this time.

Relevant Post:

New York and Wyoming Agree to Coordinate Digital-Asset Supervision

New York’s Department of Financial Services and the Wyoming Division of Banking have announced a memorandum coordinating digital asset licensing, examinations, information sharing, and enforcement. Eligible firms operating under one regulator’s oversight for at least three years, without an enforcement action and with sufficiently similar proposed operations, may receive expedited consideration in the other state. The agreement sets a six-month decision target measured from the application or delivery of requested examination information, whichever is later. It does not establish automatic licensing reciprocity or guarantee approval. Each regulator retains its existing legal authority, and the memorandum creates no enforceable rights for applicants. Its practical significance is procedural: reducing duplicated review while improving coordination between two distinct regulatory systems.

Why it matters for Zcash:

More coordinated supervision could reduce expansion costs for regulated businesses supporting ZEC, but the agreement does not itself support ZEC listings or shielding. For Zcash stakeholders, the implementation question is whether coordination reduces repetitive data requests while preserving proportionate, risk-based treatment of privacy-preserving technology.

Action Item:

No action item at this time.

Relevant Post:

Weekly Policy Memo: Week of October 05, 2026

Key Takeaways:

The CFTC opened an early-stage consultation on regulations for retail crypto markets, but agency action leaves important statutory questions unresolved.
FinCEN withdrew its mixing and unhosted wallet proposals. The withdrawals recognize legitimate privacy interests; the Tornado Cash prosecution continues.
Fairshake PAC named 32 House incumbents for support.

Action Item:

Comments on the CFTC ANPRM are due 60 days after publication in the Federal Register. Please reach out if you have any feedback.

X Post of the Week:

CFTC Opens Retail Crypto Consultation as Congress Weighs the Limits of Agency Action

The Commodity Futures Trading Commission (CFTC) issued an advance notice of proposed rulemaking (ANPRM) seeking input on Regulation Crypto Asset Transactions (Reg CTX) and Regulation Crypto Asset Markets (Reg CAM). The framework would use the Commodity Exchange Act’s existing authority over retail commodity transactions offered on a leveraged, margined or financed basis to implement the regulation. It would clarify covered transactions and develop a tailored category of designated contract market registration for digital asset trading.

The initiative advances Chairman Michael Selig’s effort to establish a federal route for covered trading under existing law. It also illustrates the limits identified by House Financial Services Committee Chairman French Hill, who recently argued that SEC and CFTC action cannot provide the durability of the CLARITY Act. The CFTC cannot use this process to require registration of every spot digital assets platform. Accordingly, this provides incremental clarification, but it does not resolve comprehensive spot-market jurisdiction or establish a congressional agreement on market structure.

Why it matters for Zcash:

For exchanges and intermediaries supporting ZEC, the eventual framework could affect market access, custody and transaction delivery. The consultation is also an opportunity to explain how customers obtain control of shielded assets and how regulated intermediaries can verify relevant information without requiring universal public transaction histories. These are policy questions for future rules as opposed to requirements impacting Zcash users today.

Action Item:

Comments are due 60 days after publication in the Federal Register. Please reach out if you have any feedback.

Relevant Post:

FinCEN Withdraws Crypto Reporting Proposals While Tornado Cash Litigation Continues

The Financial Crimes Enforcement Network (FinCEN) announced withdrawal of two proposed reporting regimes: its 2023 proposal concerning international convertible virtual currency mixing and its 2020 proposal concerning certain transactions with unhosted or otherwise covered wallets. The notice withdraws both the proposed special measure and the underlying finding that the identified class of transactions was of primary money-laundering concern. FinCEN acknowledged that its broad approach could burden financial institutions and discourage legitimate activity, including lawful uses of financial privacy. Note that while these proposals have been withdrawn, they still enable Treasury to consider future measures under its existing authority.

Separately, federal prosecutors are continuing to litigate the Tornado Cash case. In an October 5 filing, they cited the appellate decision in the separate Bitcoin Fog case, United States v. Sterlingov, to support their venue arguments concerning Roman Storm.

Why it matters for Zcash:

The withdrawal is particularly relevant to Zcash because the abandoned definition of mixing reached a broad set of transaction techniques, rather than only a named service. FinCEN’s recognition of legitimate privacy interests provides useful support for shielded transactions, self-custody and data minimization. However, it does not establish a general exemption for privacy software or resolve developer liability, such as the Tornado Cash case.

Action Item:

No suggested action item at this time.

Relevant Post:

Fairshake Names 32 House Incumbents for Election Spending

Fairshake PAC announced support for 32 House incumbents, 13 Democrats and 19 Republicans, and plans for substantial independent spending. CoinDesk reports $1 million commitments for each of six lawmakers: Republicans French Hill (R-AR), Bill Huizenga (R-MI), and Bryan Steil (R-WI), and Democrats Steven Horsford (D-NV), Derek Tran (D-CA), and Janelle Bynum (D-OR). The roster includes lawmakers positioned to influence financial-services, tax and agricultural-market legislation.

The effort could affect the next Congress’s composition, but election spending does not secure passage of pending legislation or resolve the Senate’s current disagreements. Its policy significance will depend on election results, committee assignments and lawmakers’ substantive positions.

Why it matters for Zcash:

Support for digital asset legislation does not necessarily establish support for shielded transactions or developer protections, however it creates an environment where lawmakers may be more receptive to learning about these issue areas within broader crypto-related policymaking.

Action Item:

No suggested action item at this time.

Relevant Post:

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Weekly Policy Memo: June 15, 2026

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Notable Post

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Weekly Policy Memo: Week of June 22, 2026

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Weekly Policy Memo: June 29, 2026

Key Takeaways

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X Post of the Week

June Monthly Update on PGPZ

PGPZ Progress Summary

Why this matters for Zcash

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CLARITY Act Talks Progress, but Prospects Become Murkier

Why this matters for Zcash

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PGPZ Weekly Policy Memo: Week of July 13, 2026

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X Post of the Week

PGPZ Community Updates

Senate CLARITY Act Progress Stalls as Congress and Administration Discuss Ethics Provision

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PGPZ Weekly Policy Memo: Week of July 20, 2026

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Weekly Policy Memo: Week of July 27, 2026

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July Monthly Update on PGPZ

Why this matters for Zcash

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Senate CLARITY Act Negotiations Continue as Congress Tackles Remaining Issues

Why this matters for Zcash

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