Comment from Steptoe LLP submitted on behalf of our client The Digital Chamber.

Summary: The Digital Chamber, a trade association representing over 250 companies in the digital asset and blockchain industries, expresses strong support for FinCEN's proposed modernization of the Bank Secrecy Act. They advocate for specific clarifications to ensure that neutral infrastructure providers are not unfairly regulated as money transmitters and request that "effectiveness" standards be clearly defined to avoid inconsistent regulatory interpretations.