THE CLARITY ACT WILL VOTE TOMORROW AND THE “TECHNICAL MELODY” OF UNITED STATES ENCRYPTION REGULATION IS IN PLACE

I. Legal processes and the evolution of institutions to verify the facts

THE LEGISLATIVE PATH OF H.R. 3633 IS AS FOLLOWS:

1. Sejm phase:17 July 2025, Sejm294:134THE RESULTS OF THE VOTING WERE ADOPTED IN THEIR ORIGINAL VERSION, ESTABLISHING THE PROTOTYPE OF THE DIVISION OF SEC AND CFTC FUNCTIONS。

2. Senate game:Following its transfer to the Senate on 18 September 2025, the bill had been deadlocked by the impact of the stabilization currency on traditional banking reserves。

3. Revision of consensus:On 12 January 2026, Tim Scott, Chairman of the Senate Banking Commission, issued an updated version following consultations between the two parties。

4. Key nodes:tomorrow, 15 january, at 10 a.m., the committee “ mark ” voting will determine whether the amendment is legally qualified to vote in the senate as a whole。

Institutional observation:the revision of the senate, compared to the original version of the chamber of deputies, further strengthened the certification procedures for “ the permit to pay the stability currency ” the issuer ' s criminal liability constraints and the refinement of “ the chain maturity of blocks ” and the certification process。

II. KYA Technological hard-bargaining: Article 205 “ mature block chain ” criteria for determination

The bill Sec. 205 is the &ldquao of the whole bill; the logical anchor &rdquao; and it replaces the controversial Hauway test with measurable indicators。

1. 20% Control red line penetration analysis

It is proposed that the revised draft would provide that, in order for a system to obtain &ldquao under the jurisdiction of the CTC; digital &rdquao, it must be proved that it met the following power distribution indicators within the last 12 months:

• Governance concentration:Total &ldquao held by issuer, related party and concerted operator; Voting Power & rdquao; not exceeding20%I don't know。

• Code control:No entity owns &ldquao; unilateral competence &rdquao; to substantially alter the logic of the agreement。

Expert view:THIS PROVISION PLACED CONSIDERABLE AUDIT PRESSURE ON THE VASP ASSET BANK. VASP IN PROGRESSKYA (Know Your Assembly)It cannot rely solely on the description of the White Paper, but must have &ldquao; governance penetrating &rdquao; capacity. If the founding team of a Layer 2 agreement or a DeFi application holds key governance powers through multiplesig, even if its token distribution is dispersed, it may legally be classified as “ an immature system ” and thus considered as securities。

2. Independent validation of source code and transaction history

the draft requires a mature system with “ a publicly available source code ” and “ an independently validated complete history ” this means that any private chain that lacks transparency or is of a strong regulatory nature will have extremely difficult access to the mainstream compliance exchange after 2026。

III. Institutionalization of stable currency: Article 512 and the phasing out of audit

Targeted& ldquo; Licensed Payment Stablecoin & rdquo;The Act establishes a regulatory bastion comparable to the traditional banking industry。

1. From “ Attestation ” to “ Exchange ”

Sec. 512(2)(A) makes it clear that the issuer must submit it monthly& ldquo; Exportation & rdquo;Level of financial reporting。

• Rigorous resolution:In the professional audit context, Examination represents the highest level of assurance. It requires auditors to directly penetrate the lower-level assets of the reserve assets (e.g., national debt or cash reserves) rather than merely reconcile the statements provided by the issuer。

2. Loss of criminal immunity of executives

Draft to be introduced18 U.S.C. 1350 (c)The clause requires CEOs and CFOs to authenticate monthly reports. Once a shortage of funds is discovered to be concealed, executives face federal criminal charges. This “ responsibility to man ” mechanism aimed at ending the breakdown of algorithms and falsification of reserves in the area of stabilization currency。

IV. TECHNOLOGICAL LEGALIZATION OF KYT: SECTION 110 AND COMPULSORY INTEGRATION OF THE BANKING SECRECY ACT

The amendments to the Banking Secrecy Act (BSA) 31 U.S.C. 5312 are currently the most substantial of the technical compliance tools & ldquo; legal endorsement & rdquo。

1. & ldquo; proper analytical tool ” legalization

The draft explicitly requires digital commodity brokers and exchanges to use:

“ &herlip; &herlip;Appropriate distributed book analysis tool(Apppropriate Distributed Ledger Analytics) monitors and reports suspicious activities. ”

Substantive resolution of compliance:This expression transforms “ chain analysis software ” from the VASP operating cost item to compliance access item. Failure to integrate analytical tools with federal recognition criteria will be considered to be BSA compliance deficiencies that directly affect the registration status of VASP。

2. Self-trust wallet protection and anti-money-laundering monitoring games

The Act Sec. 105(c) expressly protects the right of individuals in the United States to hold their own wallets and P2P transactions。

• Challenges:The law, on the one hand, prohibits regulatory bodies from restricting individuals from using hardware wallets and, on the other hand, requires VASP to identify illegal movements. This forces the KYT logic to be from “ address label matching &rdquao; evolution to &ldquao;Multi-jump behavioral expansion analysis”. VASP is required to prove, without touching the red line of privacy, that the funds are not being used by illegal Mixers or sanctioned entities。

V. Legislative recommendations and industry conclusions

ON THE BASIS OF A READING OF THE H.R. 3633 DRAFT SENATE AMENDMENTS, WE DRAW THE FOLLOWING CONCLUSIONS:

1. Jurisdiction Prejudice:The determination of the nature of the asset was made from “ the qualitative narrative ” the overall shift to “ the quantitative feature ” VASP must establish an automated compliance review process based on the Sec. 205 standard。

2. Compliance infrastructure upgrade:Entities with basic KYC capabilities alone will not be able to meet the mandatory requirements of Article 110. Establishment of technology to identify “ cross-chain jump &rdquao; and &ldquao; attribution analysis &rdquao; and imminent infrastructure。

3. Compatibility of self-administered rights:VASP must revisit its self-custody wallet strategy to ensure that its wind-control logic enables real-time interception of high-risk assets while meeting Sec.105(c) protection of citizens ' rights。

VI. Practical application of technical aids: for example, TrustIn

In the H.R. 3633 & ldquo; Quantitative Regulation & rdquo; in the new order, technical tools play a central role in bridging the gap between legal provisions and defecation. Although the bill has not yet been finalized, its establishment & ldquo; technical compliance & rdquo; the direction is clear。

In response to the provisions of the ActTrustInAS A FOUNDATION BUILDING FOR COMPLIANCE ON THE STABLE CURRENCY CHAIN, VASP CAN BE PROVIDED WITH THE FOLLOWING TECHNICAL SUPPORT OF PRACTICAL VALUE:

1. Entity-related penetrating (KYA Pro) for Sec. 205

The Act for “ the mature system ” and the establishment of a 20% quantitative red line of control, which requires VASP to have the ability to identify “ associated entity ” and in-depth auditing。

• Technical Match_Other OrganiserKYA ProModule provides configurable3-5-9 Layer multi-layer penetration analysisI don't know. Through its “ white box ” engines, compliance teams can penetrate surface addresses and dig deeper into physical connections behind different addresses. This will assist the VASP to accurately assess the actual governance concentration of the assets to be launched and determine whether it triggers the &ldquao in the Act; the issuer and related party holding shares should not exceed 20% &rdquao; and the red line, thus providing conclusive evidence of the physical relevance of the CFTC maturity certification。

2. Dynamic Defence of Reserve Address for Sec. 512

The Act requires a stable currency issuer to conduct monthly & ldquo; Examination & rdquo; and audit and criminal accountability for executives, making it necessary for VASP to maintain real-time vigilance at the bottom of the risk of the deposit。

• Technical Match_Other OrganiserMonitoring (continuous risk radar)Module provision24/7 Dynamic defenceI don't know. Using its “ anti-pollution ” mechanism, VASP can perform continuous risk scanning of the central reserve address associated with the stable currency. The system will provide real-time warning of risks and isolate them once they are monitored for interaction with the sanctioned entity at the reserve address. This not only compensates for the &ldquo of the monthly audit report; the &rdquo of the window of time; the &ldquo, which is better passed; the white box ” and the clear audit trail for VASP, which is recorded in response to the requirements of the Act for compliance records。

3. Complex chain restoration for Sec. 110

The Act imposes requirements for the use of “ appropriate analytical tools ” to monitor suspicious activities (SAR), especially in the context of the active P2P and self-custody wallets, the accuracy of chain tracking is crucial。

• Technical Match: For Bill vs. “ distributed book analysis capability ” statutory requirements, by TrustInTraceForceThe module demonstrates core competitiveness. The module focuses onCross-coin protocol and cross-chain technologyThe complex financial chains that can be seen to be restored, in particular the data-intelligence blind areas in Asia and the Middle East, have been filled. Through TraceForce case snapshots and teamwork, VASP is able to provide efficient forensic evidence of P2P-filled funds protected by Act Sec. 105(c) to ensure that money-laundering risks are identified with evidence of suspicious activities that meet federal law enforcement standards。

Concluding remarks

H.R. 3633 IS NOT THE FINAL VERSION OF THE REGULATION OF DIGITAL ASSETS, BUT IT HAS ESTABLISHED A CLEAR TECHNICAL MELODY FOR 2026:Legal status of decentralised quantitative monitoring, stabilization currency penetrating audits and chain analysis tools。

REPORT STATEMENT: THIS REPORT IS BASED ON DRAFT LEGISLATION AND PROPOSED AMENDMENTS MADE PUBLIC BY 14 JANUARY 2026. AS THE BILL IS STILL UNDER CONSIDERATION, THE FINAL TEXT MAY BE FINE-TUNED ALONG WITH THE VOTING PROCESS. THE TECHNOLOGY APPLICATIONS REFERRED TO IN THIS STUDY ARE INTENDED ONLY FOR VASP COMPLIANCE PURPOSES AND DO NOT CONSTITUTE OFFICIAL ENDORSEMENT OF COOPERATION OR LEGAL ADVICE。

Trustin & mdash; — Intellectual risk, far-reaching, protective area compliance。

• References:https://www.congress.gov/bill/119th-congress/house-bill/3633/text