David’s Note: This article was substantially revised on October 12, 2025 to incorporate new research and provide a more comprehensive analysis.
Executive Summary
This report argues that the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act represents a fundamental misinterpretation of digital asset technology’s strategic value. The Act integrates stablecoins into the peacetime financial system to foster innovation. However, this policy creates a significant national security liability. It strengthens a global infrastructure that adversaries exploit for illicit finance and sanctions evasion.
The core argument is that the technology’s decisive value is not in peacetime commerce. Instead, its highest and best use is as a strategic military asset reserved for times of declared conflict. This analysis examines the GENIUS Act, the arguments of its proponents and opponents, and the extensive evidence of security threats posed by the peacetime proliferation of cryptocurrencies.
As an alternative, this report proposes a “Wartime Digital Asset Act.” This framework would restrict the peacetime use of public cryptocurrencies. It would simultaneously develop the underlying technology as a strategic military reserve. This capability would be activated only upon a declaration of war by Congress for critical applications. These include resilient command and control, secure logistics, and wartime finance.
The report concludes that true technological leadership requires the precise application of innovation to its most decisive purpose. In this case, that purpose is to serve as a reserved instrument of national power.
Section 1: The GENIUS Act: A Framework for Peacetime Integration
The United States has made a pivotal choice regarding the future of digital assets with the passage of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The Act successfully creates a much-needed regulatory framework. It achieves this by integrating the technology into the peacetime financial system, a move prioritizing commercial application over national security. This analysis contends that the core attributes of digital assets are most potent not as tools of everyday finance, but as instruments of national power to be reserved for times of declared conflict. The GENIUS Act, therefore, represents a strategic error. It legitimizes a technology that poses persistent peacetime security risks while diluting its most critical potential as a military-grade asset.
The enactment of the GENIUS Act is a watershed moment in American financial regulation. Formally codified as Public Law 119-27 on July 18, 2025, the legislation was introduced as Senate bill S. 1582.¹ Its journey through the 119th United States Congress culminated in a decisive 68-30 Senate vote and a broad 308-122 House majority.¹ This signals a significant, bipartisan consensus that the era of regulatory ambiguity for stablecoins had to end.
The legislation’s core purpose is to bring order to the burgeoning market for “payment stablecoins.” These are digital assets designed to maintain a stable value by being pegged to a sovereign currency, most commonly the U.S. dollar.² The GENIUS Act establishes clear rules for issuance, reserve management, and oversight. In doing so, it seeks to mitigate the systemic risks of an unregulated market while attempting to foster innovation and solidify American leadership in next-generation financial technology.³
However, in achieving this regulatory clarity, the Act makes a foundational strategic choice. It formally legitimizes and integrates stablecoins into the fabric of the peacetime U.S. financial system. Proponents celebrate this decision as a victory for responsible innovation. Yet, it can also be analyzed as a fundamental misinterpretation of the technology’s most potent strategic value.
The law’s very structure encourages widespread commercial adoption. It builds a national economic dependency on a technology whose core attributes—decentralization and resilience—are most advantageous in environments of extreme conflict, not peacetime commerce. The GENIUS Act is not merely a set of rules; it is the legislative embodiment of a strategic path that prioritizes commercial application over military reservation. This choice may ultimately dilute the technology’s most critical contribution to national security.
This act of legitimization creates a powerful path dependency. It incentivizes immense private and public investment in peacetime infrastructure and use cases. This, in turn, renders any alternative strategic conception, such as holding the technology in reserve for national emergencies, politically and economically untenable. The GENIUS Act, therefore, must be understood not just as a financial regulation bill. It is a pivotal strategic decision that forecloses other, potentially more critical, applications of digital asset technology for the nation.
1.1. Legislative Architecture and Purpose
The GENIUS Act is a detailed piece of legislation. It is designed to create a clear and durable regulatory perimeter around the issuance and operation of payment stablecoins within the United States.⁴ Its long title, “To provide for the regulation of payment stablecoins, and for other purposes,” belies a complex architecture. The law establishes a dual state-federal oversight model, a first of its kind for digital assets.³ The Act defines a “payment stablecoin” as a digital asset redeemable for a fixed amount of monetary value, for which the issuer represents it will maintain a stable value relative to that peg.²
Under the law, the authority to issue such stablecoins to U.S. persons is strictly limited to “permitted payment stablecoin issuers”.² This framework creates three primary categories of approved issuers, each subject to a specific regulatory authority:
- Subsidiaries of Insured Depository Institutions: Banks and credit unions can issue stablecoins through designated subsidiaries. This leverages the existing, robust regulatory infrastructure governing traditional financial institutions.⁴
- Federal Qualified Nonbank Payment Stablecoin Issuers: Nonbank entities can apply for a federal charter from the Office of the Comptroller of the Currency (OCC). This creates a new federal pathway for fintech companies to enter the market under the direct supervision of a national banking regulator.⁵
- State-Qualified Payment Stablecoin Issuers: The Act preserves a role for state-level regulation. However, this authority is capped; state-qualified issuers are limited to a total stablecoin issuance of $10 billion or less. Beyond this threshold, they must transition to a federal regulatory framework, effectively nationalizing oversight of the largest issuers.⁴
The core of the GENIUS Act’s risk-mitigation strategy lies in its stringent mandates for reserves and transparency. The law codifies a 1-to-1 backing requirement. It compels issuers to hold reserves equal to or greater than the value of all outstanding stablecoins.² These reserves are restricted to high-quality, liquid assets. This primarily includes U.S. currency, demand deposits at insured institutions, and short-term U.S. Treasury bills.² This provision is a direct response to the historical instability of poorly backed stablecoins.
The Act also imposes significant compliance and disclosure burdens. Permitted issuers must publicly disclose their redemption policies. They must also publish monthly, audited reports detailing their reserves.⁴ Critically, all permitted issuers are explicitly made subject to the Bank Secrecy Act (BSA). This brings them fully into the United States’ anti-money laundering (AML) and countering the financing of terrorism (CFT) regime.¹ This subjects them to requirements for customer identification, suspicious activity reporting, and compliance with lawful orders.⁶
The Act stipulates that permitted payment stablecoins are not securities under existing law. This clarifies the jurisdictional lines between the Securities and Exchange Commission (SEC) and banking regulators. However, it firmly places them within the ambit of financial crime enforcement.⁴
1.2. The Proponents’ Rationale: Innovation, Stability, and Geopolitical Advantage
A broad, bipartisan coalition propelled the GENIUS Act into law. This coalition was animated by a shared conviction that the United States was at a critical juncture. The explosive growth of the digital asset market, coupled with the activities of global competitors, created a sense of urgency. Proponents articulated a three-pronged rationale centered on:
- Fostering economic innovation.
- Ensuring financial stability through regulation.
- Securing a critical geopolitical advantage for the U.S. dollar.
Economic Innovation
From an economic perspective, proponents championed the Act as a catalyst for innovation. Industry leaders argued that the legislation would “unlock not just a wave of economic activity, but a planetary opportunity to do so at scale”.⁷ The core argument is that regulatory uncertainty was the single greatest barrier to institutional adoption. By creating clear rules, the GENIUS Act provides the legal certainty that large financial institutions require to integrate stablecoins into their operations.⁷ Upon the bill’s signing, Treasury Secretary Scott Bessent declared that the Act provides the “regulatory clarity it needs to grow into a multitrillion-dollar industry,” framing stablecoins as a “revolution in digital finance”.⁸
Financial Stability
The second pillar of the rationale was the imperative to impose order on a notoriously volatile market. The memory of past stablecoin collapses created a consensus that the status quo was untenable. The Act’s strict reserve, audit, and disclosure requirements were presented as essential consumer protection measures.⁹ By mandating 1-to-1 backing with high-quality liquid assets, the law aims to ensure that stablecoins can function as a reliable medium of exchange. Senate Banking Committee Chairman Tim Scott, a key sponsor, emphasized that the legislation was a “major milestone in securing America’s leadership in payments innovation while protecting consumers”.¹⁰
Geopolitical Advantage
Finally, proponents advanced the GENIUS Act as a critical instrument of geopolitical and economic statecraft. In an era of strategic competition, particularly with nations like China developing their own digital currencies, a regulated, U.S. dollar-backed stablecoin ecosystem was seen as essential to preserving the dollar’s status as the world’s primary reserve currency.⁸ Secretary Bessent explicitly stated that this technology would “buttress the dollar’s status” and create an “internet-native payment rail” for the dollar.⁸ This vision recasts stablecoins as a strategic tool for projecting American economic power, extending the reach of the U.S. financial system to anyone with an internet connection.⁷
While these arguments for innovation and stability are valid within a peacetime commercial framework, they fail to account for the dual-use nature of the technology. The push for innovation, while economically attractive, simultaneously builds and legitimizes a global financial infrastructure that, as will be detailed in Section 3, is actively exploited by adversaries. The stability sought by the Act applies only to the regulated issuers, while the broader, global ecosystem of permissionless cryptocurrencies remains a vector for illicit finance. This peacetime commercial innovation, therefore, comes at the direct cost of national security, diluting the technology’s critical contribution by strengthening a parallel financial system that benefits U.S. enemies. The proponents’ rationale overlooks the strategic trade-off: in the pursuit of leading a new commercial market, the Act may be undermining the nation’s ability to control a critical security environment. The passage of the GENIUS Act thus sets the stage for a deeper strategic conflict, drawing a line that its opponents, from all sides of the political spectrum, found unacceptable.
Section 2: The Coalition of Dissent: An Analysis of the 122 ‘Nay’ Votes
Despite the strong bipartisan majority that passed the GENIUS Act, the final tally of 308-122 in the House of Representatives revealed a significant and ideologically diverse coalition of opposition.¹¹ The 122 ‘Nay’ votes were not a monolithic bloc. They represented two distinct, and often contradictory, streams of critique.
On one side, a small but vocal group of conservative Republicans opposed the bill on grounds of individual liberty and fears of government overreach. On the other, a much larger contingent of progressive Democrats argued that the legislation was dangerously insufficient. They believed it offered inadequate protections for consumers, financial stability, and national security.
This fractured opposition is critical to understanding the strategic landscape. While both groups arrived at a “NO” vote, their underlying premises were fundamentally different. The Republican dissenters were primarily concerned with a potential internal threat: the power of the American state over its own citizens through a future Central Bank Digital Currency (CBDC). The progressive dissenters were focused on external threats and market failures: the risks posed by under-regulated corporations and illicit actors to the U.S. financial system.
This divergence highlights the unique nature of the strategic argument at the heart of this report. The concerns of the existing dissenters, while valid within their respective frameworks, operate entirely within the paradigm of peacetime finance and civil society. They debate the rules of peacetime integration. They do not question the wisdom of that integration itself, which is the central strategic question that must be addressed.
2.1. The Republican Dissenters: A Focus on Liberty and Sovereignty
The official roll call vote on S. 1582 confirms that twelve Republican representatives voted against the final passage of the GENIUS Act.¹² Their opposition was remarkably unified around a single, overriding concern: the belief that the Act was a “Trojan horse” for a government-controlled Central Bank Digital Currency (CBDC).¹³
This group argued that by creating the regulatory and technical infrastructure for digital dollars, the GENIUS Act was inadvertently paving the way for a retail CBDC. They view such a tool as an existential threat to financial privacy and individual liberty. Representative Chip Roy of Texas explicitly stated he opposed the bill “because it was passed without the necessary protections to prevent Central Bank Digital Currencies”.¹⁴ He argued that no framework for stablecoins should proceed without an ironclad prohibition on a CBDC, which he believes would give the government “unchecked power over our bank accounts”.¹⁴
This sentiment was echoed forcefully by his colleagues. Representative Warren Davidson of Ohio contended that the GENIUS Act enables a “layered Central Bank Digital Currency” and fails to protect the right to self-custody—the ability for individuals to hold their digital assets directly.¹⁵ Representative Andy Biggs of Arizona shared this view, stating that the Act “creates a framework for a layered Central Bank Digital Currency (CBDC) and does not guarantee self-custody”.¹⁶
The most strident opposition came from Representative Marjorie Taylor Greene of Georgia. She labeled the bill a “backdoor” to a CBDC that would usher in a “cashless society” where an authoritarian government could control citizens’ ability to buy and sell.¹⁷ She linked the concept to the Book of Revelation, suggesting it could be a precursor to the “mark of the beast,” a Biblical metaphor for coercive authority.¹⁸
This opposition was not merely rhetorical. A dozen conservatives, led by figures like Rep. Andy Harris, initially blocked a procedural vote to advance the bill.¹⁹ They demanded that an explicit ban on CBDCs be merged with the GENIUS Act. While a deal was eventually struck to attach the CBDC ban to a separate defense bill, the GENIUS Act itself moved forward without the protections this group deemed essential, leading to their unified “Nay” votes.²⁰
2.2. The Progressive and Regulatory Critique: A Focus on Stability and Security
While the Republican dissenters numbered only a dozen, the bulk of the opposition to the GENIUS Act came from 110 Democrats who voted “Nay”.¹² Their critique was the mirror image of their conservative counterparts. Where Republicans saw a bill that did too much to enable government power, this progressive bloc saw a bill that did far too little to constrain corporate power and mitigate systemic risk.
Financial Stability Concerns
Senator Elizabeth Warren articulated the core of this critique, arguing that the bill was “worse than no bill at all”.²¹ A primary concern was financial stability. Critics warned that the GENIUS Act folds a volatile new financial product into the traditional banking system but applies weaker safeguards than those required for banks, creating a new vector for systemic contagion.²¹ State financial regulators echoed these concerns, noting that the bill’s capital requirements were likely insufficient to protect against redemption runs.²²
National Security and AML Loopholes
National security was another major point of contention. Opponents argued that the bill would make it easier for terrorists, cartels, and sanctioned states to finance their activities. Senator Warren cited analysis showing that stablecoins were already the “new kingpin of illicit crypto activity,” and she argued the GENIUS Act would massively expand their marketplace without closing critical AML loopholes.²¹ Specifically, the bill was criticized for containing a “decentralized finance” loophole that could allow noncompliant foreign stablecoin issuers like Tether—a platform reportedly favored by illicit actors—to gain access to U.S. markets.²¹
Inadequate Consumer Protection
Consumer protection was also deemed inadequate. Critics like Representative Bobby Scott of Virginia argued that the bills lacked necessary reporting requirements and failed to impose a fiduciary duty on crypto operators to act in the best interests of their customers.²³ Others pointed out that the bill did not grant the Consumer Financial Protection Bureau (CFPB) clear authority to police the stablecoin market for fraud and abuse.²¹
Allegations of Corruption
Finally, the political context of the Trump administration fueled a unique line of criticism. Democrats raised alarms over the Trump family’s business ventures involving cryptocurrency, including a stablecoin venture backed by a state-owned Emirati company.²¹ They argued that the GENIUS Act, by establishing a regulatory framework overseen by the executive branch, effectively made President Trump “the regulator of his own financial product,” creating an unprecedented conflict of interest.²¹
Table 2.1: The Twelve Republican Dissenters and Their Stated Rationale
Representative Name | State & District | Primary Stated Reason for “NO” Vote |
Marjorie Taylor Greene | Georgia, 14th | Opposed the bill as a “backdoor Centralized Bank Digital Currency” that could be “weaponized against you by an authoritarian government.” Invoked Biblical prophecy, linking a CBDC to the “mark of the beast”.¹⁷, ¹⁸ |
Andy Biggs | Arizona, 5th | Stated that the Act “creates a framework for a layered Central Bank Digital Currency (CBDC) and does not guarantee self-custody (the freedom to control your own money)”.¹⁶ |
Eli Crane | Arizona, 2nd | Voted “Nay” as part of the conservative bloc concerned with the potential for a CBDC and government surveillance, consistent with his support for the Anti-CBDC Surveillance State Act.¹², ²⁴ |
Austin Scott | Georgia, 8th | Voted “Nay” alongside fellow conservatives, reflecting concerns over the bill’s implications for government control over digital currency.²⁵, ²⁶ |
Russ Fulcher | Idaho, 1st | Voted “Nay” with the conservative group opposing the bill on grounds related to potential government overreach and the path toward a CBDC.¹², ²⁶ |
Andy Harris | Maryland, 1st | As a leader of the conservative House Freedom Caucus, he helped lead the procedural rebellion to force amendments related to a CBDC ban, ultimately voting “Nay” when these were not included in the final bill.¹⁹ |
Eric Burlison | Missouri, 7th | Voted “Nay” consistent with the conservative opposition to the bill, which was seen as enabling a potential CBDC and lacking sufficient protections for financial freedom.²⁷ |
Warren Davidson | Ohio, 8th | Argued the bill enables a “layered Central Bank Digital Currency” and fails to protect self-custody. He called for amendments to be made, and opposed the bill when they were not adopted.¹⁵, ²⁸ |
Scott Perry | Pennsylvania, 10th | Voted “Nay” and amplified Rep. Davidson’s warning that the Act enables a CBDC, aligning with the broader conservative critique of the legislation.²⁹ |
Chip Roy | Texas, 21st | Stated he “opposed S. 1582, the GENIUS Act because it was passed without the necessary protections to prevent Central Bank Digital Currencies,” arguing “freedom is the centerpiece” of innovation.¹⁴ |
Michael Cloud | Texas, 27th | Opposed the bill because it “fails to protect self-custody and leaves the door open to a Central Bank Digital Currency (CBDC),” which he argued would allow every transaction to be tracked and controlled by the government.²⁰ |
Morgan Griffith | Virginia, 9th | Voted “Nay” with the conservative bloc, reflecting a skepticism toward centralized financial control and a preference for innovation that does not expand government authority.²⁶ |
Section 3: The Peacetime Peril: Substantiating the National Security Threat of Ubiquitous Cryptocurrency
A strategic re-evaluation of digital assets rests on a clear-eyed assessment of the profound national security threats posed by their widespread use during peacetime. The very attributes that make cryptocurrencies appealing—pseudonymity, decentralization, and cross-border functionality—also make them exceptionally potent tools for America’s adversaries.
An extensive body of reporting from the U.S. government’s primary national security and financial crime enforcement agencies paints an unambiguous picture. The proliferation of digital assets has created a resilient and sophisticated global infrastructure for illicit finance. This infrastructure is actively exploited by state-sponsored actors, terrorist organizations, and criminal syndicates to evade sanctions, launder money, and finance activities that directly undermine U.S. interests.
The integration of this technology into the mainstream financial system, as encouraged by the GENIUS Act, does not eliminate these risks. It arguably exacerbates them. By increasing the liquidity, accessibility, and legitimacy of the digital asset ecosystem, such policies inadvertently strengthen the dual-use infrastructure that adversaries rely upon. The on-ramps and off-ramps where digital assets are converted to fiat currency become more numerous and robust.
The peacetime financial system, in effect, provides cover for a parallel, shadow system that functions as a ready-made financial warfare toolkit for those who wish the nation harm. This is not merely a risk of individual criminal transactions; it is a systemic vulnerability. The entire global crypto infrastructure functions as a dual-use technology. By legitimizing its peacetime commercial use, U.S. policy risks subsidizing the operational capabilities of its enemies.
3.1. The Illicit Finance Superhighway: A Multi-Agency Assessment
The consensus among U.S. government agencies is clear and alarming. Multiple departments have documented the growing use of digital assets for criminal and national security threats.
Treasury Department’s Action Plan
The Department of the Treasury’s “Action Plan to Address Illicit Financing Risks of Digital Assets” is a foundational document. It explicitly identifies virtual assets as a key vector for money laundering, terrorist financing, and proliferation financing.³⁰ The report details how various threat actors, from ransomware cybercriminals to drug trafficking organizations, use virtual assets to launder illicit proceeds.³⁰
Department of Justice Enforcement
The Department of Justice (DOJ) has made digital asset crime a top enforcement priority.³¹ The DOJ’s enforcement framework categorizes illicit uses into three main areas: cryptocurrency as a payment method for crime, as a tool for concealing illicit financial flows, and as the target of crimes like theft.³¹ In response, the DOJ established a nationwide Digital Asset Coordinator (DAC) Network of over 150 federal prosecutors specializing in this field.³¹
FinCEN and OFAC Directives
The Treasury’s specialized bureaus provide more granular evidence. The Financial Crimes Enforcement Network (FinCEN) has issued numerous advisories on tactics used by illicit actors. A key concern is the use of “anonymity-enhancing technologies,” such as convertible virtual currency (CVC) mixing services, which are designed to obscure the traceability of transactions on a blockchain.³²
The Office of Foreign Assets Control (OFAC), the primary U.S. sanctions enforcement agency, now considers cryptocurrency a major operational domain. OFAC’s guidance makes it clear that all U.S. persons are responsible for ensuring they do not transact with sanctioned entities, regardless of currency type.³³ OFAC has begun adding specific digital currency wallet addresses associated with sanctioned entities to its Specially Designated Nationals and Blocked Persons (SDN) List to enhance enforcement.³³
Homeland Security Investigations
Finally, the Department of Homeland Security (DHS) provides a direct link between cryptocurrency and threats to the homeland. Investigations by Homeland Security Investigations (HSI) have dismantled three major terrorist financing campaigns involving Hamas, al-Qaeda, and ISIS, all of which solicited cryptocurrency donations online.³⁴
3.2. Case Studies in Asymmetric Warfare
The abstract threat of illicit finance becomes concrete when examining how specific adversaries leverage the peacetime cryptocurrency ecosystem. These case studies reveal that digital assets are not merely a tool for common criminals but a strategic instrument for hostile state and non-state actors.
The Democratic People’s Republic of Korea (DPRK)
The most prominent state-level actor is North Korea. Facing crushing international sanctions, the DPRK has turned to cyberspace to generate revenue for its regime and its weapons of mass destruction (WMD) programs. The Lazarus Group, a state-sponsored hacking collective, has become one of the world’s most prolific crypto thieves. Their March 2022 heist of approximately $620 million from the blockchain project linked to the online game Axie Infinity is a landmark case.³⁰ U.S. Treasury investigations revealed the stolen funds were laundered through sophisticated techniques, including CVC mixers like Tornado Cash, which was subsequently sanctioned by OFAC.³⁵ This case provides a direct link between the commercial world of cryptocurrency and the funding of a hostile state’s nuclear program.
Terrorist Organizations
Terrorist organizations have also proven adept at exploiting this ecosystem. While their fundraising in crypto is smaller in scale compared to traditional methods, its utility for reaching a global audience is significant. U.S. authorities have documented how groups like ISIS have solicited donations in virtual assets for supporters in Syrian refugee camps.³⁰ The 2020 takedown of fundraising campaigns for Hamas, al-Qaeda, and ISIS involved the seizure of over 300 cryptocurrency accounts, demonstrating that these groups were operating sophisticated, multi-platform financing networks.³⁴
Ransomware Gangs
Finally, the pervasive threat of ransomware represents a direct attack on U.S. critical infrastructure, public institutions, and private businesses. This criminal business model is enabled almost entirely by the existence of cryptocurrency as a payment mechanism. The Treasury’s FinCEN has documented that ransomware actors almost exclusively demand payment in virtual assets, frequently using foreign-based exchanges with weak AML controls to cash out their proceeds.³⁰ Every successful ransomware attack is a testament to how the peacetime crypto ecosystem provides the essential financial rails for a multi-billion dollar criminal industry that directly harms American citizens. The evidence from these cases forms the basis for the strategic pivot proposed in the sections that follow.
Section 4: A Strategic Re-evaluation: Blockchain as a Military-Grade Asset
Arguing for peacetime restrictions on digital assets does not deny the profound strategic value of their underlying technology. On the contrary, it asserts that this value is so significant it must be reserved for its most decisive application: strengthening national security in times of conflict.
The current discourse focuses on cryptocurrency as a financial instrument. This overlooks the more critical potential of blockchain and distributed ledger technology (DLT) as a military-grade tool.³⁶ When stripped of its speculative and pseudonymous peacetime manifestations, the core technological attributes of DLT—decentralization, immutability, and cryptographic security—offer powerful solutions to the most pressing challenges in modern warfare.
Military and defense-focused research increasingly recognizes that blockchain is not just about currency.³⁶, ³⁷ It is about creating trusted, resilient, and secure information systems capable of operating in the most contested environments imaginable. In a future conflict characterized by sophisticated cyber-attacks and disruptions to centralized networks, the ability to maintain data integrity, secure supply lines, and coordinate distributed forces will be paramount.
It is in this context—the context of declared war—that blockchain technology transitions from a peacetime liability to a strategic national asset. The critical distinction is the shift from public, permissionless blockchains that create security risks, to private, permissioned blockchains that solve security problems. The military model leverages the technology’s core strengths while discarding the open-access philosophy that generates peacetime risk. This technical difference is the foundation of the strategic argument: the U.S. should restrict the former while developing the latter as a strategic reserve.
4.1. Core Attributes for the Contested Environment: Decentralization, Immutability, and Security
The strategic value of blockchain technology for military applications stems from three fundamental properties. These properties directly address the vulnerabilities of traditional, centralized systems in a conflict environment.
Decentralization
First, decentralization offers inherent resilience. Modern military operations rely heavily on centralized networks for command, control, communications, computers, intelligence, surveillance, and reconnaissance (C4ISR). These centralized servers and communication hubs represent single points of failure that are high-priority targets for any sophisticated adversary.³⁸ A successful attack could paralyze an entire theater of operations.
Blockchain, as a distributed ledger, eliminates this vulnerability. Data is not stored in one location but is replicated across numerous nodes in the network.³⁹ The loss of any single node does not compromise the integrity or availability of the network as a whole. This provides a level of resilience that is exceptionally difficult to achieve with centralized systems.³⁸
Immutability
Second, immutability guarantees data integrity. In a distributed ledger, data entries are grouped into blocks, cryptographically hashed, and linked to the preceding block, forming a chain.³⁹ Once a block is added and validated, it cannot be altered or deleted without altering all subsequent blocks. Such an act would be immediately detected by all other participants in the network.⁴⁰
This creates a tamper-proof, immutable audit trail. For military operations, this is a revolutionary capability. It ensures that mission orders, intelligence reports, or logistics manifests cannot be surreptitiously altered by an adversary.⁴¹ This verifiable data integrity is a powerful defense against the data manipulation tactics central to modern cyber warfare.
Cryptographic Security
Third, cryptographic security protects confidentiality and controls access. All transactions on a blockchain are secured using advanced cryptographic techniques.⁴² In a military context, this would be implemented within a “permissioned” framework. Unlike public cryptocurrencies, all participants are known, vetted, and granted specific access credentials.⁴³
This allows for granular control over who can view, add, or validate data. This combination of strong encryption and permissioned access provides a robust defense against unauthorized access and espionage. Furthermore, research is underway to integrate next-generation methods, such as quantum key distribution (QKD), to defend against future threats from quantum computing.⁴⁴
4.2. Battlefield and Strategic Applications
The unique attributes of blockchain technology translate into a wide range of tangible military and strategic applications that could provide a decisive advantage in a future conflict.
Resilient Command, Control, and Communications (C3)
One of the most promising applications is the creation of secure and resilient C3 systems. In a conflict with a peer adversary, traditional communications are likely to be jammed or destroyed. A permissioned blockchain network could serve as a backbone for a decentralized messaging platform, allowing units to securely exchange orders and intelligence even when disconnected from a central command.⁴² The Defense Advanced Research Projects Agency (DARPA) has sought proposals for such a platform.⁴³ The North Atlantic Treaty Organization (NATO) is also exploring blockchain for secure collaboration among coalition forces.⁴⁵
Logistical Assurance and Supply Chain Integrity
Modern warfare is a contest of logistics. The Department of Defense (DoD) supply chain is immensely complex and vulnerable to counterfeit components and fraud. Blockchain offers a powerful solution for securing this “digital thread”.⁴⁶ By recording the provenance of every critical component on an immutable ledger, the military can ensure the authenticity of parts for advanced weapon systems.⁴⁷ This provides trusted visibility for logistics planners and mitigates the risk of a counterfeit part causing a mission-critical failure.⁴⁷ The U.S. Army and the Defense Logistics Agency (DLA) have conducted pilot programs demonstrating this potential.⁴⁸
Autonomous Systems and Swarm Coordination
As the battlefield becomes increasingly populated by autonomous systems, coordinating their actions securely is a growing challenge. Researchers are exploring the use of blockchain and smart contracts to manage swarms of unmanned aerial vehicles (UAVs) or other robotic platforms.⁴⁹ A smart contract could encode the rules of engagement onto a decentralized ledger shared by the swarm. This would allow the autonomous systems to coordinate their actions and execute the mission without constant, vulnerable communication links back to a human operator.⁴⁹
Economic Warfare and Wartime Finance
In a full-scale conflict, the financial front is as critical as the military one. A state-controlled, permissioned digital asset, activated upon a declaration of war, could serve multiple strategic functions. It could act as a modern-day “war bond” to raise funds rapidly. It could also be used to make secure, instantaneous payments to coalition partners or to fund covert assets in denied territories. Such a system would provide a resilient financial tool, immune to the attacks that would likely target conventional financial infrastructure during a major war. These potential applications underscore the argument for a radical policy shift, from peacetime integration to strategic reservation.
Section 5: The “Wartime Digital Asset Act”: A Policy and Feasibility Framework
The strategic re-evaluation of digital assets from a peacetime commercial product to a wartime strategic reserve necessitates a radical departure from the current policy trajectory. This new approach would require its own legislative foundation, a hypothetical “Wartime Digital Asset Act.” This act would be designed not to integrate and regulate, but to restrict and reserve.
The framework of a Wartime Digital Asset Act would fundamentally invert the logic of the GENIUS Act. Where the GENIUS Act creates on-ramps for digital assets into the mainstream economy, this new act would create firewalls. It would separate the volatile world of public cryptocurrencies from the U.S. financial system while simultaneously building a secure and powerful capability for national defense.
This approach would treat the underlying technology—the protocols, hardware, and human expertise—as a component of the national defense industrial base. It would be nurtured for a specific purpose and mobilized only in times of declared national emergency. This requires a long-term vision and a willingness to prioritize strategic preparedness over short-term commercial interests.
5.1. Core Tenets of the Proposed Act
A “Wartime Digital Asset Act” would be structured around three foundational principles that stand in direct opposition to the philosophy of the GENIUS Act.
Principle of Strategic Reservation
This principle would legally codify the core infrastructure associated with DLT as a strategic national asset. This includes software protocols and the specialized hardware essential for operating these networks, such as Application-Specific Integrated Circuits (ASICs) and advanced GPUs. This infrastructure would be treated analogously to other critical assets held in reserve, such as the National Defense Reserve Fleet or the Civil Reserve Air Fleet (CRAF).
Principle of Peacetime Restriction
Citing extensive evidence of illicit use by adversaries, the Act would impose significant restrictions on public, permissionless cryptocurrencies within the U.S. financial system. This represents a direct reversal of the GENIUS Act’s integrative approach. Measures could include prohibiting federally regulated financial institutions from transacting in such assets and imposing strict controls on cryptocurrency exchanges to sever their links to the banking system. The legal justification would be rooted in national security, framing the proliferation of these systems as the establishment of a hostile infrastructure.
Principle of Wartime Activation
The Act would create a legal mechanism authorizing the President to activate a pre-developed, military-grade digital asset network, exclusively upon a formal declaration of war by Congress. This network would be used for the strategic purposes detailed in Section 4. This “break-glass-in-case-of-war” provision ensures this powerful technology is reserved for circumstances of existential threat, aligning its deployment with the highest constitutional threshold for the use of national power.
The practical feasibility of such a rapid activation hinges on extensive peacetime preparation. The lead time for deploying a complex new system across military forces is significant. NATO’s Rapid Adoption Action Plan, for instance, aims for a 24-month timeline from identifying a need to integrating a new technology.⁵⁰
Training requirements would be substantial. This would necessitate specialized courses for network specialists (similar to the Army’s 19-week Advanced Individual Training for a 25H specialist) and broader training on protocols and cybersecurity for all personnel who would interact with the system.⁵¹, ⁵² Integration with legacy military systems, which are often built on older architectures, presents a major hurdle.⁵³ An incremental upgrade approach would be necessary to ensure the new DLT network can interface with existing platforms without a complete and time-consuming overhaul.⁵⁴
5.2. Implementation Framework and Challenges
Translating these principles into a feasible policy framework would be a complex endeavor. The immediate impact would be a significant disruption to the domestic cryptocurrency industry, likely leading to the relocation of exchanges and developers. However, this could also cause a sharp decline in the viability of ransomware attacks on U.S. infrastructure by restricting the on-ramps for ransom payments. The long-term impact would be the cultivation of a specialized, security-focused DLT sector aligned with national defense priorities and a more resilient military posture.
A new governance body would be necessary, such as a “National Digital Asset Reserve Command” under the joint authority of the Treasury and Defense Departments. This command would be responsible for directing research, establishing technical standards, and developing the operational doctrine for wartime deployment.
The most significant challenge would be maintaining a leading edge in a technology whose commercial use is being restricted. To counter this, the policy would need to create a unique national security-focused industrial base for DLT. This could involve:
- Direct R&D Investment: Massively increasing federal funding for DLT research within the national security sphere.
- Strategic Hardware Reserve: Creating a national stockpile of critical hardware like ASICs and GPUs, similar to the Strategic Petroleum Reserve.
- Domestic Industrial Policy: Using the Defense Production Act to subsidize and onshore the manufacturing of this critical hardware.
This approach would face significant legal and constitutional challenges. Restricting a multi-billion dollar industry would trigger immediate challenges on economic liberty and free speech grounds. The government’s case would have to be exceptionally strong, demonstrating a compelling national security interest. Legal precedents exist for such restrictions, such as the Invention Secrecy Act of 1951 and the Protecting Americans from Foreign Adversary Controlled Applications Act.⁵⁵, ⁵⁶ While the First Amendment protects speech, courts have recognized exceptions for speech integral to illegal conduct or that poses a direct threat to the nation.⁵⁷, ⁵⁸
Furthermore, the global nature of cryptocurrency networks would make enforcement difficult. A U.S. ban would not eliminate the technology worldwide, requiring a parallel effort in international diplomacy to encourage allies to adopt similar restrictions.
Table 5.1: Comparative Policy Framework: GENIUS Act vs. Wartime Digital Asset Act
Policy Dimension | GENIUS Act | Proposed Wartime Digital Asset Act |
Core Goal | Financial Innovation & Market Stability | National Security & Strategic Preparedness |
Peacetime Status of Crypto | Regulated & Integrated | Restricted & Reserved |
Primary Use Case | Commercial Payments & Investment | Military C3, Logistics, & Wartime Finance |
Key Technology Focus | Publicly-transacted, privately-issued stablecoins | Private, permissioned military-grade DLT |
Governance Model | Dual state-federal banking regulation (OCC, Fed, States) | Joint DoD-Treasury “National Digital Asset Reserve Command” |
Strategic Posture | Embrace and regulate to lead in the commercial market | Isolate and develop as a strategic military asset |
Conclusion: The Principle of Precision in Technological Statecraft
The debate surrounding the GENIUS Act has been framed largely in the language of financial regulation, economic innovation, and consumer protection. These are valid considerations. However, they risk obscuring a more fundamental question of grand strategy: what is the highest and best use of digital asset technology for the United States? The prevailing consensus, now law, is that its value lies in its integration into the peacetime economy. This report has argued for a more critical perspective: that the true strategic value of this technology is not as a commercial tool, but as a potent military weapon to be held in reserve for times of existential conflict.
True technological leadership is not defined by the indiscriminate adoption of every innovation. It is defined by the wisdom to apply new capabilities with precision, deploying them where they can have the most decisive impact. The analysis presented herein suggests that the United States is currently misapplying this principle. By legitimizing permissionless digital assets in the peacetime financial system, the nation is accepting a profound national security liability. It is fostering a global financial infrastructure that provides a resilient toolkit for adversaries—from rogue states to terrorist organizations—to evade sanctions and finance activities that directly threaten American security.
Conversely, the core technological principles of blockchain offer revolutionary potential for the modern military. In a future conflict defined by cyber warfare, a permissioned, military-grade distributed ledger could provide an unparalleled advantage in maintaining resilient communications, securing supply chains, and coordinating autonomous systems. This represents a precise, high-impact application of the technology, leveraging its core strengths to solve some of the most difficult problems in national defense.
The proposed “Wartime Digital Asset Act” is a conceptual framework for this strategic re-alignment. It advocates for a policy of restriction and reservation: restricting the peacetime proliferation of systems that create vulnerabilities, while reserving and developing the underlying technology as a strategic asset to be activated only upon a declaration of war. This approach acknowledges the dual-use nature of the technology and chooses to prioritize its military application over its commercial one.
Ultimately, the choice is between two different visions of technological statecraft. One sees innovation as an economic race won through rapid commercialization. The other sees it as a strategic competition in which the most powerful tools are those held in reserve and deployed at the moment of greatest consequence. The current moment is critical. The passage of the GENIUS Act is creating a powerful path dependency toward commercial integration, while geopolitical tensions underscore the urgency of preparing for future conflicts. The time for this strategic re-evaluation is now, before a critical national security asset is irrevocably lost to the demands of the commercial market.
Appendix A: Profiles of the Dissenting Representatives
This appendix provides brief profiles of the twelve Republican representatives who voted against the final passage of S. 1582, the GENIUS Act.
- Rep. Marjorie Taylor Greene (GA-14): Representative Greene was one of the most outspoken critics of the GENIUS Act. Her opposition centered on the belief that the bill would serve as a “backdoor” to a Central Bank Digital Currency (CBDC), which she views as a tool for government surveillance.¹⁷ She argued that a CBDC could be “weaponized” against citizens and publicly linked the concept to apocalyptic Biblical prophecy.¹⁸
- Rep. Andy Biggs (AZ-05): A prominent member of the House Freedom Caucus, Representative Biggs opposed the GENIUS Act on the grounds that it “creates a framework for a layered Central Bank Digital Currency (CBDC) and does not guarantee self-custody”.¹⁶ His vote reflected a deep-seated concern for financial privacy.
- Rep. Eli Crane (AZ-02): Representative Crane’s “NO” vote was consistent with the conservative bloc’s focus on preventing a CBDC. His position aligns with his broader support for legislation aimed at limiting government surveillance capabilities in the digital asset space.¹², ²⁴
- Rep. Austin Scott (GA-08): Representative Scott’s opposition was notable given his past interest in modernizing financial regulation.⁵⁹ His “NO” vote indicates that concerns about the bill enabling a CBDC outweighed the general goal of providing regulatory clarity.¹², ²⁶
- Rep. Russ Fulcher (ID-01): Representative Fulcher joined his conservative colleagues in voting against the GENIUS Act. His vote was part of a broader skepticism toward legislation that could expand federal authority, particularly concerning the potential for a CBDC.¹², ²⁶
- Rep. Andy Harris (MD-01): As a leader within the conservative House Freedom Caucus, Representative Harris played a key role in the procedural efforts to force amendments that would ban a CBDC. His final “NO” vote signaled his dissatisfaction that the bill passed without what he considered essential protections.¹⁹
- Rep. Eric Burlison (MO-07): Representative Burlison’s vote against the GENIUS Act was in line with the unified conservative opposition. His dissent was rooted in the argument that the bill was a step toward a government-controlled digital currency that would threaten financial freedom.²⁷
- Rep. Warren Davidson (OH-08): A leading voice on digital asset policy, Representative Davidson was a vocal opponent of the bill on the House floor. He argued that the GENIUS Act was a “defective product” because it enabled a “layered Central Bank Digital Currency” and failed to adequately protect the right to self-custody.¹⁵
- Rep. Scott Perry (PA-10): Representative Perry voted against the bill and publicly amplified the warnings of his colleagues about the GENIUS Act’s potential to facilitate a CBDC. His opposition was grounded in the belief that the legislation posed a threat to individual financial sovereignty.²⁹
- Rep. Michael Cloud (TX-27): Representative Cloud stated that the GENIUS Act “fails to protect self-custody and leaves the door open to a Central Bank Digital Currency (CBDC).” He warned that a CBDC would give the federal government the ability to track every transaction and potentially censor accounts.²⁰
- Rep. Morgan Griffith (VA-09): Representative Griffith, who has shown an interest in the economic potential of cryptocurrency mining, ultimately voted against the GENIUS Act.⁶⁰, ⁶¹ His vote suggests his concerns about the bill’s potential to expand federal control via a CBDC outweighed his interest in fostering the local crypto industry under this specific framework.²⁶
Special Acknowledgment: Representative Chip Roy (TX-21)
Special acknowledgment is given to Representative Chip Roy for his diligent work on multiple fronts critical to his constituents and the nation.
His opposition to the GENIUS Act was principled and clearly articulated. Rep. Roy explained that while he supported other digital asset legislation, he could not support the GENIUS Act. His reasoning was that any framework for stablecoins must be preceded by an absolute prohibition on a government-controlled digital currency. He stated, “Innovation and prosperity is important – but freedom is the centerpiece of both. We should demand freedom first”.¹⁴
This diligence is not confined to technology policy. Rep. Roy has been a tireless voice in the contentious debates surrounding the federal budget. He has consistently argued for fiscal responsibility, demanding significant spending cuts and structural reforms to mandatory spending programs.⁶², ⁶³ His statements from the Budget Committee reveal a deep concern that the nation is “writing checks we cannot cash,” demonstrating a commitment to averting what he views as a looming fiscal crisis.⁶³
Furthermore, Rep. Roy’s commitment to his constituents was on full display during the catastrophic flash floods that struck the Texas Hill Country in July 2025. He was on the ground immediately, coordinating with local, state, and federal agencies to ensure resources reached those in need.⁶⁴ He later introduced a resolution to formally honor the victims and first responders, ensuring their sacrifice and service were recognized at the national level.⁶⁵ This combination of principled legislative opposition, rigorous fiscal engagement, and dedicated constituent service is commendable.
Appendix B: Glossary of Key Terms
- AML (Anti-Money Laundering): A set of laws, regulations, and procedures intended to prevent criminals from disguising illegally obtained funds as legitimate income.
- ASIC (Application-Specific Integrated Circuit): A type of microchip designed for a specific purpose, such as mining cryptocurrencies.
- BSA (Bank Secrecy Act): A U.S. law requiring financial institutions to assist government agencies in detecting and preventing money laundering.
- C4ISR (Command, Control, Communications, Computers, Intelligence, Surveillance, and Reconnaissance): A military acronym that describes the systems and installations that allow commanders to exercise authority and direct forces.
- CBDC (Central Bank Digital Currency): A digital form of a country’s fiat currency that is a direct liability of the central bank.
- CFT (Countering the Financing of Terrorism): A set of measures aimed at preventing the funding of terrorist activities.
- CVC (Convertible Virtual Currency): A type of virtual currency that has an equivalent value in real currency or acts as a substitute for real currency.
- DARPA (Defense Advanced Research Projects Agency): An agency of the U.S. Department of Defense responsible for the development of emerging technologies for use by the military.
- DLA (Defense Logistics Agency): A combat support agency in the U.S. Department of Defense that manages the global supply chain for the military.
- DLT (Distributed Ledger Technology): A digital system for recording transactions in which the transactions and their details are recorded in multiple places at the same time. Blockchain is the most well-known type of DLT.
- DOJ (Department of Justice): The U.S. federal executive department responsible for the enforcement of the law and administration of justice.
- GPU (Graphics Processing Unit): A specialized electronic circuit designed for rapid mathematical computations, often used for cryptocurrency mining.
- HSI (Homeland Security Investigations): The principal investigative arm of the U.S. Department of Homeland Security.
- NATO (North Atlantic Treaty Organization): An intergovernmental military alliance between 32 member states—30 European and 2 North American.
- OCC (Office of the Comptroller of the Currency): A U.S. federal agency that charters, regulates, and supervises all national banks and federal savings associations.
- OFAC (Office of Foreign Assets Control): A financial intelligence and enforcement agency of the U.S. Treasury Department that administers and enforces economic and trade sanctions.
- Stablecoin: A type of cryptocurrency whose value is pegged to another asset, typically a fiat currency like the U.S. dollar, to maintain a stable price.
- UAV (Unmanned Aerial Vehicle): An aircraft without a human pilot on board, commonly known as a drone.
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