This is not a discussion of the regulatory treatment of cryptocurrencies, although it makes passing mention of a number of regulatory initiatives. The report is primarily an overview of the uses of cryptocurrencies to make payments for various types of criminal activities, and of the efforts of enforcement and regulatory authorities to stop such payments.

In view of the criticism, both explicit and implicit, that , Chair Clayton is making a good effort to sell its benefits and to forestall the various states from going their own way and creating their own diverse regulations regarding the obligations that broker-dealers and advisers have to their clients.

The issuance of CBDC is inevitable. Once a financially strong country takes the leap, competitive economies will be forced to follow. One can reasonably predict that there will be a flight to the currencies that are perceived as the safest, with a dramatic impact on the ability of some countries and companies to borrow in their domestic currency.

This is a significant proposal. The costs and difficulties of SEC broker-dealer registrations are simply too much for individuals who may engage in a chance finding or for small firms that may put local businesses together with investors. It is also legally significant (as one may reasonably suspect that violations of the broker-dealer registration requirement are fairly common, at least for small local businesses seeking to raise money). Further, the SEC does not itself remotely have the…