Main Points：
- Origins and Catalyst: Triggered by reports that former President Trump earned over $57 million in 2024 through a crypto venture, the COIN Act is designed to curb public official exploitation of digital assets.
- Scope of the Bill: Applies to the President, Vice President, members of Congress, senior executive branch officials, and their immediate family members—covering 180 days before taking office through two years after leaving.
- Key Provisions:
- Ban on issuing, sponsoring, or endorsing any digital asset (memecoins, NFTs, stablecoins).
- Mandatory disclosure of all crypto holdings and transactions in annual financial reports.
- Recusal requirements for conflicts of interest tied to digital assets.
- Quarterly attestations by stablecoin issuers certifying no improper benefits to officials.
- Legislative Context: Coexists with the bipartisan GENIUS Act regulating stablecoins and companion proposals in the House (e.g., TRUMP Act).
- Market and Industry Implications: Could reshape how crypto firms engage policymakers, and may influence stablecoin market growth—projected to expand from around $120 billion today to $2 trillion by 2035 (Figure 1).
- Next Steps: Requires House approval and presidential signature; mandates a GAO review of digital asset ethics laws within one year.
Background: A Crypto Ethics Reckoning
In June 2025, Senator Adam Schiff, joined by several Senate Democrats, introduced the Curbing Officials’ Income and Nondisclosure (COIN) Act to address rising concerns over public officials leveraging their positions for private gain through cryptocurrency activities. The bill was prompted by investigative reports indicating that former President Donald Trump earned $57.35 million in 2024 via his involvement with World Liberty Financial’s USD1 stablecoin. Schiff emphasized that such windfalls “raise serious questions about the use of public office for private enrichment” and underscored the need for robust ethical safeguards.
This initiative follows a series of high-profile incidents, including a White House dinner hosted for top memecoin investors and growing scrutiny of cryptocurrency’s influence on policy decisions. By framing digital assets as a potential vector for corruption and influence-peddling, the COIN Act enters a broader conversation about how emerging technologies intersect with government ethics.
Key Provisions of the COIN Act
1. Broad Ban on Digital-Asset Promotion
The COIN Act would prohibit any covered official—including the President, Vice President, Members of Congress, and senior executive employees, as well as their immediate family members—from issuing, sponsoring, or endorsing any digital asset (whether memecoins, NFTs, or stablecoins). This restriction applies from 180 days before inauguration through two years after departure from office.
2. Enhanced Disclosure Requirements
Under existing ethics laws, public officials must report certain financial holdings. The COIN Act explicitly adds all digital assets and transactions to the list of assets requiring annual disclosure and periodic transaction reporting. Transactions exceeding $1,000 would trigger separate, detailed disclosures—aligning crypto reporting thresholds with those for stocks and bonds.
3. Conflict-of-Interest and Recusal
The legislation clarifies that purchasing, selling, holding, or promoting digital assets constitutes a “financial interest” under federal conflict-of-interest statutes. It requires officials to recuse themselves from any matter in which they or close relatives have a digital-asset stake, strengthening existing recusal frameworks in the Ethics in Government Act of 1978.
4. Quarterly Stablecoin Attestations
To prevent indirect benefits, stablecoin issuers would need to submit quarterly certifications demonstrating that no covered official or family member has received personal gain from the issuer. Failure to attest, or false attestations, could trigger penalties for both the issuer and implicated officials.
5. GAO Review
Finally, the COIN Act instructs the Government Accountability Office (GAO) to review federal ethics laws pertaining to digital assets within one year and issue guidance for future policy updates. This provision aims to ensure that regulatory frameworks evolve alongside rapidly changing blockchain technologies.
Broader Legislative Landscape
The COIN Act joins a wave of congressional activity around cryptocurrency:
- GENIUS Act: Passed by the Senate on June 18, 2025, this bipartisan bill sets regulatory standards for stablecoin issuers—requiring full-dollar or safe-asset backing, consumer protections, and reserve requirements to guard against collapses like Terra–Luna.
- TRUMP Act: Introduced in the House by Rep. Maxine Waters, the Stop Trading, Retention, and Unfair Market Payoffs (TRUMP) in Crypto Act aims specifically to bar Trump’s memecoin and related ventures while echoing similar ban periods of 180 days pre- and two years post-office.
- Ongoing Debates: Critics of the GENIUS Act argue it overlooks conflicts of interest, especially exempting the President and Vice President from its stablecoin restrictions—a gap the COIN Act seeks to fill.
Together, these measures highlight a dual approach: consumer and market safeguards on one hand, and stricter ethical guardrails for those holding public trust on the other.Figure 1. Stablecoin Market: Current vs Projected
(Bar chart showing ~$120 billion market in mid-2025 vs $2 trillion projected by 2035)
Market Implications and Industry Response
For crypto firms, the COIN Act signals that engagement with policymakers—whether through lobbying, partnerships, or marketing—will face new scrutiny. Marketing campaigns targeting “influential figures” in Washington may need to be restructured or shelved. Stablecoin issuers, already adapting to the GENIUS Act’s requirements, now face additional reporting burdens to certify no nexus with covered officials.
Investors should note:
- Heightened regulatory risk may shift capital toward jurisdictions with less stringent oversight, potentially impacting liquidity in US-based crypto markets.
- Conversely, clearer ethical standards could boost institutional confidence, knowing that market integrity is being protected.
Ethics watchdogs like POGO and Public Citizen have lauded the COIN Act as “desperately needed” to prevent corruption, while lobby groups warn of overreach that might stifle legitimate innovation.
Next Steps: Passage and Policy Evolution
The COIN Act must pass the House of Representatives and receive the President’s signature to become law. Assuming its enactment, the GAO review will likely produce recommendations by mid-2026, guiding further refinements. Stakeholders—lawmakers, industry participants, and ethics experts—will be watching closely to see if follow-on legislation addresses:
- Enforcement mechanisms and penalties
- Digital asset expanding definitions (e.g., DeFi tokens, tokenized ETFs)
- Alignment with global anti-corruption standards
As blockchain applications permeate sectors from finance to supply chains, embedding strong ethical guardrails will be crucial to maintaining public trust and fostering sustainable innovation.
Conclusion
The COIN Act represents a landmark effort to protect the integrity of US public offices in the digital-asset era. By pairing comprehensive bans, enhanced disclosures, and conflict-of-interest safeguards with mandated GAO oversight, it closes critical gaps left by earlier legislation like the GENIUS Act. For crypto entrepreneurs and investors, the bill underscores the imperative of ethical engagement with policymakers. As the bill advances through Congress, its outcome will shape not only the ethical landscape of government but also the future trajectory of blockchain innovation in the United States.
