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11/29/2023

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at the 2023 Blockchain Association’s Policy Summit | …

Remarks by Deputy Secretary of the Treasury Wally Adeyemo at
the 2023 Blockchain Association’s Policy Summit
November 29, 2023

As Prepared for Delivery
Thank you to Kristin for the introduction. Itʼs nice to be here with all of you.
Innovation, as you all know better than most, is at the core of Americaʼs economic success.
We are the most important economy in the world in large part due to the ingenuity of our
entrepreneurs. From airplanes and the internet to cars and smart phones, rapid technological
transformations that have reshaped how we live our lives as well as the ways we think about
commerce. And we donʼt shy away from change. A constant American advantage for centuries
has been not only our capacity to embrace change but to also encourage it.
Many of you in this room are at the forefront of such change. It may be easy to lose sight of
the scale of that change when you are immersed in the day to day, but over the last several
years, the digital asset industry has grown at an exponential rate.
According to the O ice of Financial Research, in 2021 alone, companies reported more than 2
billion transactions totaling $1.4 trillion in virtual currency transactions. Thatʼs about four
times as many transactions and seven times the volume of the previous year. Thatʼs why more
than a year ago, at the Consensus conference in Austin, Texas, I spoke about the tremendous
opportunity digital assets present to promote innovation that helps us reimagine commerce.
But I also made clear the importance of industry proactively taking steps to prevent digital
assets from being used by transnational criminal organizations, terrorists, and rogue states. I
hoped the digital asset industry would take up this call to partner with government, design
new tools, and pursue new ways to protect digital assets from being abused.
While some have heeded our calls and taken steps to prevent illicit activity, the lack of action
by too many firms—both large and small—represents a clear and present risk to our national
security.

INNOVAT ION W IT HIN T HE LAW
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Today I would like to focus on the steps we must now take in order to prevent bad actors
from using the digital asset ecosystem for illicit activity. I want to directly address those
within the digital asset industry who believe they are above the law, those that willfully turn a
blind eye to the law, and those that promote assets and services that aid criminals, terrorists,
and rogue states.
My message is simple: We will find you and hold you accountable.
This is exactly what happened to Binance, the largest virtual currency exchange in the world.
Over several years, Binance allowed itself to be used by the perpetrators of child sexual abuse,
illegal narcotics tra icking, and terrorism, across more than 100,000 transactions. Groups like
Hamas, Al Qaeda, and ISIS conducted these transactions.
In response to this egregious activity, Treasury announced our largest enforcement action in
history, with a total settlement amount of over $4 billion. Equally important, we are placing a
monitor within Binance that will have access to their systems, transactions, and accounts in
order to ensure the largest virtual currency exchange in the world is no longer a permissive
environment for illicit proceeds.
But our challenge extends beyond exchanges to other parts of the digital asset ecosystem.
Earlier today, we sanctioned Sinbad.io (Sinbad), a virtual currency mixer that serves as a key
money-laundering tool for a cyber hacking group sponsored by North Korea. Sinbad processed
millions of dollarsʼ worth of virtual currency from cyber hacks and enabled cybercriminals to
mask illicit transactions.
Last month, Treasury announced a set of rulemakings intended to increase the transparency
of mixers, making it harder for criminals and terrorists to use them to hide the source,
destination, and amount of transactions. As we develop these rules, we have requested input
from stakeholders in order to make sure we prevent illicit finance while permitting responsible
innovation.
This action and others to cut other money-laundering mixers—like Tornado Cash—o from
the U.S. financial system demonstrate that De-Fi services and platforms are not above the
law. Taking steps like these to reduce the abuse of these types of services is not only in the
governmentʼs interest; it is in the interest of those that seek to build an innovative industry
that is on the right side of the law.

T HE GROW ING DIGITAL ASSET ILLICIT F INANCE RISK
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Itʼs important that we continue tackle this problem today, so that virtual currencies do not
grow into a larger illicit finance threat. As we take steps to prevent terrorists, transnational
criminals, and rogue states from using the traditional financial system, we cannot let them
find a new outlet in virtual currencies. There are a number of reasons bad actors turn to virtual
currencies, but I would like to highlight two of them.
First, illicit actors have always taken advantage of new technology. We saw this in the last
decade when ISIS used social media to revolutionize jihadist recruitment. It mastered a new
platform to spread its hate faster than social media companies or governments could impose
appropriate safeguards. Addressing the challenge required establishing strategic partnerships
between governments and social media platforms, which remain ongoing to this day.
Second, we know that risk tends to migrate to places where global regulation and
enforcement are less well developed. As rogue states and terrorist groups find it harder to
use the traditional financial system to move money, it is logical they would turn to less
regulated ways to move assets. This is exactly what we are seeing states like North Korea
and groups like Hamas do already.
The North Korean regime already accrues a great deal of its resources from cyber-criminal
activity, including stealing virtual currency. Its preferred means of moving its ill-gotten gains is
through the digital asset ecosystem rather than the traditional financial system. Our concern
is that as Hamas is dislodged from Gaza and no longer able to extort and tax innocent
Palestinians, it will increasingly use the digital asset ecosystem.
These are just a couple of examples of the risks we face today. A digital asset ecosystem that
lacks a shared commitment to preventing illicit finance provides ample opportunity for groups,
like North Korea and Hamas to move resources in ways that are intended to undermine our
e orts to stop them.

ACCOUNTAB ILIT Y
In order to address these challenges, we need a shared commitment. When I talk about
“shared commitment,” I mean the digital asset industry and the government working hand in
hand to cut o illicit actors before they are able to spread roots and for us to create a culture
of accountability.
At Consensus 2022, I explained that our goal is to empower industry participants to do the
right thing by building a responsible, compliant, and accountable digital asset ecosystem.
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That means companies need to be proactive in identifying risks, establishing standards and
protocols to mitigate those risks, and isolating bad actors. A shared commitment requires
action from this industry.
Today, government and the traditional financial sector work in partnership to prevent the
movement of illicit proceeds. We have built a regulatory framework that traditional financial
firms not only adhere to, but help us to implement. These firms have invested in tools,
personnel, and processes that help us identify and capture criminals, terrorists, and others
that seek to move money illegally.
Just this week, the CEO of the American Bankers Association highlighted ongoing work to
design, develop, and pilot a new information sharing exchange, which the ABA will manage,
that focuses on combatting fraud, money laundering, and terrorist financing. This type of
collaboration and proactive e ort amongst industry participants both large and small is
commendable and demonstrates the collective commitment that is necessary to stay ahead
of bad actors.
We need those in the digital asset industry to do the same. You have the capacity to build new
tools that help prevent money laundering while continuing to provide legitimate protections
to individuals. You also have the capacity to cut o firms from your ecosystem that are failing
to take steps to prevent illicit finance.
Without action by your industry, increased movement of illicit proceeds into the digital asset
ecosystem will force us to restrict, restrain, and cut o elements of the digital asset
ecosystem from the broader economy. Our actions over the last year send a clear message:
we will not hesitate to bring to bear tools across government to protect our national
security.

NEW TOOLS
Yesterday, Treasury provided Congress a set of common-sense recommendations to expand
our authorities and broaden our tools and resources to go a er illicit actors in the digital
asset space.
First, we are pursuing the creation of new sanctions tools targeted towards actors in the
digital asset ecosystem that allow terrorist groups and other illicit actors to move their
assets. We are calling on Congress to create a secondary sanction regime that will not only
cut o a firm from the U.S. financial system, but will also expose any firm that continues to do
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business with the sanctioned entity to being cut o from the US financial system. This is a
significant tool we do not request lightly. But we need to do everything in our power to make
sure that groups like Hamas are not able to find safe haven within the digital asset
ecosystem.
Second, we need to update our illicit finance authorities to match the challenges we face
today, including those presented by the evolving digital asset ecosystem. For example, we
cannot rely on statutory definitions that are decades-old to address the illicit finance risks we
face in 2023. We cannot allow dollar-backed stable coin providers outside the United States
to have the privilege of using our currency without the responsibility of putting in place
procedures to prevent terrorists from abusing their platform. And we cannot permit o shore
financial services providers to use jurisdiction-evasion tactics to avoid complying with our
laws. We are working to close these gaps and others.
Finally, in addition to working with Congress, we are committed to working with the Financial
Action Task Force (FATF) to make sure our allies and partners around the world join us in
updating their regulatory approach.
The last time we pursed major reforms to this architecture was a er the terrorist attacks on
9/11. The threat actors and tools at their disposal have changed, but their goals remain the
same. As terrorist and criminals innovate their approach to illicit finance, we need tools to be
able to keep up with them.
These reforms will not only help us curb illicit finances, but they will also level the playing field
for the actors pursuing responsible and beneficial innovation and facilitate sustainable growth
for the industry.
For those in the industry skeptical that the digital asset industry can grow if regulated,
remember that the seat belt and air bag did not squelch Henry Fordʼs innovation. They simply
protected people and helped to foster an environment where the automobile industry could
enjoy sustainable growth. A regulatory environment that stops terrorists, criminal
organizations, and rogue states from using virtual currencies to move their assets can also
help legitimate firms thrive in the long term.
Thank you so much for having me here today. I look forward to the discussion.
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