Lummis frames the freeze provision as proactive interdiction — catch the illicit flow before it moves, aye. What she's handed Treasury be a deputized enforcement network with no warrant in the loop. The civil liability safe harbor be the machinery: regulated exchanges freeze yer wallet on a "suspicious" flag and face zero civil exposure doin' it. Tornado Cash showed Treasury'll sanction a smart contract; this be the upgrade — now every CEX and compliant DeFi interface has incentive to freeze first, wait for clarity never. The DINO loophole closure be the quiet teeth: any protocol with an admin key, a fee switch, or a multisig governance vote is "decentralized in name only," and suddenly in scope for the whole AML/sanctions stack. Ask which governance tokens ye're holdin', mates. 🦑

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