The licensing matrix

Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance – Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins).

Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM)

MiCA CASP Authorisation granted by the Austrian Financial Market Authority (FMA)

Finanzmarktaufsicht (FMA) Österreich

Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers.

Central Bank of Bahrain (CBB)

MiCA CASP authorisation under Article 63 MiCA, given domestic legal effect by the Belgian Act of 11 December 2025 (published in the Belgian Official Gazette 24 December 2025, entered into force 3 January 2026). Before this Act, MiCA was directly applicable EU law but Belgium lacked a domestic supervisory/sanctioning framework, creating a practical gap.

FSMA (Financial Services and Markets Authority) is the competent authority for CASPs that are not credit institutions or stockbroking firms, this covers the great majority of pure-play exchanges and custodians and includes both prudential and conduct-of-business supervision under Article 63. The National Bank of Belgium (NBB) takes the prudential lead where the CASP is (or is part of) a credit institution.

Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision).

Bermuda Monetary Authority (BMA)

VASP registration under the Virtual Assets Service Providers Act, 2022 (in force 1 February 2023). Three categories: (1) General VASP registration (e.g. transfer/brokerage/advisory services not falling into the other two categories), (2) Virtual Assets Custody Service registration, (3) Virtual Assets Exchange registration. Entities can hold multiple categories if they pay the applicable fee for each. ICO/ITO token issuance alone does not require registration if no other regulated virtual asset service is provided (per FSC Circular 43/2025 FAQ).

British Virgin Islands Financial Services Commission (BVI FSC)

MiCA CASP licence under the national Markets in Crypto-Assets Act (BG MiCA Act), adopted 20 June 2025, in force 8 July 2025.

Financial Supervision Commission (FSC) for most CASPs; Bulgarian National Bank (BNB) supervises e-money token issuers separately.

Dual-track regime. Securities: registration as a Crypto Asset Trading Platform (CTP), since 6 August 2024 this requires full 'Investment Dealer' registration plus Canadian Investment Regulatory Organization (CIRO) Dealer Member status (the previous temporary 'restricted dealer' registration and Pre-Registration Undertaking (PRU) route are both closed to new entrants). AML/CFT: registration as a Money Services Business (MSB) or Foreign MSB (FMSB) with FINTRAC under the Proceeds of Crime (Money Laundering) and Terrorist Financing Act (PCMLTFA).

Three bodies: Canadian Securities Administrators (CSA), umbrella of provincial/territorial securities regulators (e.g. Ontario Securities Commission, OSC) setting policy; Canadian Investment Regulatory Organization (CIRO), the national self-regulatory organization CTPs must join as Dealer Members; FINTRAC (Financial Transactions and Reports Analysis Centre of Canada), federal AML/CTF regulator for MSB/FMSB registration.

Two-tier regime under the Virtual Asset (Service Providers) Act (VASP Act, as amended). Phase 1 (in force since 2020): VASP Registration, required for virtual asset services generally that are not custody or trading-platform operation; AML/CFT-focused, lighter touch. Phase 2 (in force since 1 April 2025): VASP Licence, mandatory for entities operating a virtual asset custody service or a virtual asset trading platform; registration is no longer available for these two activity categories. A narrow waiver from registration/licensing is available for entities already licensed under another Cayman regulatory law.

Cayman Islands Monetary Authority (CIMA)

MiCA CASP authorisation under Regulation (EU) 2023/1114, implemented nationally via Croatia's MiCA Implementation Act (passed 27 July 2024, in force alongside EU MiCA from 30 December 2024).

HANFA (Croatian Financial Services Supervisory Agency); HNB (Croatian National Bank) supervises ART/EMT issuers.

MiCA CASP Authorisation granted by CySEC; existing Cyprus Investment Firms (CIFs) can extend their licence to cover crypto-asset services under a simplified process

Cyprus Securities and Exchange Commission (CySEC) - sole National Competent Authority for MiCA in Cyprus

MiCA CASP authorisation under EU Regulation 2023/1114, with the Czech National Bank (CNB) designated as the domestic competent authority. The CNB accepts applications in English, which practitioners cite as a distinguishing feature versus other Member States.

Česká národní banka (Czech National Bank, CNB), sole competent authority for both authorisation and ongoing supervision of CASPs in Czechia.

MiCA CASP authorisation under Regulation (EU) 2023/1114, with Finanstilsynet designated as competent authority under Danish implementing provisions.

Finanstilsynet (Danish Financial Supervisory Authority)

Digital Asset Service Provider (DASP) licence, locally 'Proveedor de Servicios de Activos Digitales' (PSAD), plus a separate Digital Asset Issuer / stablecoin issuer authorization, both under the Ley de Emisión de Activos Digitales (LEAD, enacted January 2023). DASP covers exchanges, custodians, wallet providers, brokers, OTC desks and token issuers under Article 19 of the law; issuers of digital assets/stablecoins register separately with CNAD.

Comisión Nacional de Activos Digitales (CNAD), National Digital Assets Commission, the sole competent authority for licensing, supervision and enforcement of digital asset issuers and service providers in El Salvador, created under LEAD (2023).

MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024.

Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority)

MiCA CASP authorisation (Articles 60-62), replacing Finland's prior national virtual-currency-provider registration regime (in force since 2019).

Finanssivalvonta (FIN-FSA, Finnish Financial Supervisory Authority)

MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services.

AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team.

MiCA CASP authorisation granted by BaFin under national law FinmadiG/KMAG; replaces the legacy KWG crypto-custody business licence, with a simplified transition for existing KWG-licensed firms.

BaFin (Bundesanstalt fur Finanzdienstleistungsaufsicht) with Deutsche Bundesbank involvement; applications go to both. Widely regarded as the EU's most demanding CASP regulator.

GFSC DLT Provider licence under the Financial Services (DLT Providers) Regulations 2020 (in force since 1 Jan 2018), required of any firm using DLT to store or transmit value belonging to others in/from Gibraltar. Principles-based (10 core principles), not a MiCA-style category licence.

Gibraltar Financial Services Commission (GFSC), with a dedicated DLT/innovation team running pre-application engagement; also the AML/CFT supervisor under the Proceeds of Crime Act 2015.

MiCA CASP authorisation under Law 5193/2025 (enacted 11 April 2025), operationalised by HCMC Board Decision 8/1059 of 30 July 2025.

Hellenic Capital Market Commission (HCMC) for CASP authorisation; Bank of Greece for ART/EMT prudential oversight.

Part III VASP Licence under the Lending, Credit and Finance (Bailiwick of Guernsey) Law, 2022 ('LCF Law'). Covers virtual asset exchange, transfer, safekeeping/custody, administration, and issuance/ICO services. This is a genuine substantive licensing regime (not merely AML registration), which came into full effect 1 July 2023 (application window opened 1 February 2023).

Guernsey Financial Services Commission (GFSC).

SFC Virtual Asset Trading Platform (VATP) licence on a dual basis: under the AMLO and, for tokens that are securities, under the SFO (Type 1 dealing + Type 7 automated trading). Stablecoin issuance is separately licensed by the HKMA under the Stablecoins Ordinance (Cap. 656).

SFC regulates VATPs and security-token activity; HKMA regulates stablecoin issuers and banks' VA activities. Staking and intermediary VA activity are covered by joint SFC-HKMA circulars.

MiCA CASP authorisation (Regulation (EU) 2023/1114, Art. 62) under Hungary's Act VII of 2024 on Crypto-Assets, transposing MiCA.

Magyar Nemzeti Bank (MNB) grants the core CASP licence; SZTFH (Supervisory Authority for Regulated Activities) separately runs a national crypto-asset conversion validation-certificate scheme (effective 27 Dec 2025), required in addition to the MNB CASP licence for crypto-fiat/crypto-crypto exchange - a Hungary-specific dual-track layer.

Crypto-Asset Service Provider (CASP) authorisation under MiCA (Regulation (EU) 2023/1114), given domestic legal effect by Act No. 101/2025 on markets for crypto-assets (markadir fyrir syndareignir)

Central Bank of Iceland (Sedlabanki Islands), Financial Supervision (Fjarmalaeftirlitid), the sole competent authority under Act No. 101/2025

Crypto Asset Trader/Exchange licence (Pedagang Aset Keuangan Digital, PAKD) under POJK 27/2024 (as amended by POJK 23/2025), plus related infrastructure licences: Bourse operator (Penyelenggara Bursa Aset Keuangan Digital, CFX), Clearing House, and Custodian. Legal basis: Government Regulation No. 49/2024 (transfer of authority) plus POJK 27/2024 and POJK 23/2025 (December 2025 amendment adding a crypto derivatives framework).

Otoritas Jasa Keuangan (OJK), Financial Services Authority; took over from Bappebti (commodity futures regulator) on 10 Jan 2025 under Government Regulation No. 49/2024. Market infrastructure now spans two bourses (PT Bursa Komoditi Nusantara, CFX, and PT Fortuna Integritas Mandiri, ICEx, licensed 5 Jan 2026), two clearing institutions (PT Kliring Komoditi Indonesia and PT Pranata Karya Solusi, licensed 2 Mar 2026) and two custodians (PT Kustodian Koin Indonesia and PT Arganis Konsultindo Utama, licensed 2 Mar 2026).

MiCA CASP authorisation granted by the Central Bank of Ireland; replaces the legacy VASP registration (CJA 2010, AML). No simplified VASP->CASP conversion - all applicants face the full process.

Central Bank of Ireland (CBI) - sole competent authority; runs an Innovation Hub. Known as a demanding, gatekeeper-style regulator.

No dedicated/bespoke crypto licence exists. Virtual asset/virtual-currency businesses not otherwise regulated must register as a 'Designated Business' with the Isle of Man Financial Services Authority (IOMFSA) under the Designated Businesses (Registration and Oversight) Act 2015 (DBRO Act). This is an AML/CTF registration regime only, it confers no market authorisation, conduct-of-business, or prudential status akin to a licence.

Isle of Man Financial Services Authority (IOMFSA), administering DBRO Act registration (oversight of some professions may be delegated to a recognised delegated oversight body, e.g. legal/accountancy bodies).

MiCA CASP authorisation under EU Regulation 2023/1114, transposed via Legislative Decree 129/2025 and implemented through Consob Resolution 23700/2025. Pre-MiCA VASPs (registered under the OAM register per AML Decree 90/2017) had to convert to full CASP authorisation; transitional regime for existing VASPs was extended to 1 July 2026.

Split regulator model: Consob (Commissione Nazionale per le Società e la Borsa) is the lead competent authority issuing CASP authorisation and supervising conduct-of-business/market integrity; Banca d'Italia is consulted on and supervises prudential aspects (capital, governance, AML) and directly handles credit institutions/e-money institutions offering crypto services (e.g. Banca Sella's notification route).

Crypto-Asset Exchange Service Provider (CAESP) registration with the Prime Minister (delegated to the FSA), under Article 63-2 of the Payment Services Act (PSA). Crypto derivatives trading is separately regulated as a Type I Financial Instruments Business under the Financial Instruments and Exchange Act (FIEA). A parallel intermediary-only registration category was introduced by the 2025 PSA/LPAI amendments.

Financial Services Agency of Japan (FSA / JFSA), registration authority, acting via the Prime Minister's delegated power and Local Finance Bureaus. The Japan Virtual and Crypto-assets Exchange Association (JVCEA) is the FSA-certified self-regulatory organisation that runs mandatory token-listing screening and conduct rules; JVCEA membership is the de facto baseline for registration even though not a strict legal requirement.

Virtual Asset Service Provider (VASP) registration, not a bespoke prudential licence. Legal basis: the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008, the Money Laundering (Jersey) Order 2008, and the JFSC's AML/CFT/CPF Handbook, implementing FATF VASP Guidance (effective from early 2023). This is fundamentally an AML/CFT registration, without a conduct-of-business or prudential capital regime. As of mid-2026, Jersey has not introduced a dedicated substantive VASP licensing framework with conduct/prudential requirements.

Jersey Financial Services Commission (JFSC).

MiCA CASP authorisation under Regulation (EU) 2023/1114, administered nationally by Latvijas Banka; specific Latvian implementing statute name not confirmed in this research pass.

Latvijas Banka (Bank of Latvia) is the lead CASP licensing/supervisory authority; sources note some residual/overlapping role for the FCMC on broader financial-market alignment, not fully reconciled in this pass.

MiCA CASP Authorisation granted by FMA Liechtenstein, operating alongside (and increasingly converged with) the pre-existing domestic TVTG (Token and VT Service Provider Act) registration regime

Finanzmarktaufsicht (FMA) Liechtenstein

MiCA Crypto-Asset Service Provider (CASP) authorisation under Title V of Reg (EU) 2023/1114; replaced the national VASP registration. Single passportable licence covering the services applied for.

Bank of Lithuania (Lietuvos bankas) - single competent authority. Publicly selective stance: wants few, solid firms rather than the ~370-strong legacy VASP pool.

MiCA CASP Authorisation granted by the Commission de Surveillance du Secteur Financier (CSSF)

Commission de Surveillance du Secteur Financier (CSSF)

MiCA CASP authorisation under the Markets in Crypto-Assets Act (Cap. 647); replaces the legacy VFA licence (VFA Act 2018) via a fast-track conversion. Malta granted one of the EU's first full CASP licences (Jan 2025).

Malta Financial Services Authority (MFSA) - single competent authority; a long-standing crypto supervisor since the 2018 VFA regime.

No dedicated public-facing crypto licence. Ley Fintech (2018) offers the IFPE (e-money institution) and IFC (crowdfunding) routes; virtual-asset operations by regulated entities need Banxico authorisation (internal-only, effectively not granted for customer crypto).

CNBV authorises/supervises ITFs (with the Comite Interinstitucional); Banco de Mexico (Banxico) controls virtual-asset authorisations and payments; SHCP/SAT/UIF for AML; CONDUSEF for consumer protection.

MiCA CASP Authorisation (Crypto-Asset Service Provider), granted by AFM; DNB co-assesses fitness/propriety and AML for licence holders

Autoriteit Financiële Markten (AFM) - lead conduct regulator and licensing authority; De Nederlandsche Bank (DNB) supports with prudential/AML input

MiCA CASP authorisation applies to Norway via the EEA Agreement (Norway is not an EU member but MiCA is being incorporated into the EEA framework). Notably, Norway's first authorised firm, AK Jensen Norway AS, was approved under MiCA Article 60 (the simplified route for existing authorised investment firms/securities firms to add crypto-asset services) rather than a fresh standalone CASP application, illustrating that Norway's incumbent-firm pathway is active even before/alongside full standalone CASP processing.

Finanstilsynet (the Financial Supervisory Authority of Norway), sole competent authority for CASP authorisation and supervision, operating under the EEA-incorporated MiCA framework rather than as an EU member state authority.

MiCA CASP authorisation is legally required (MiCA is directly applicable EU law) but Poland has NO functioning domestic legal basis to grant it: the Crypto-Assets Market Act, which would designate KNF as competent authority and set out the licensing procedure, has been vetoed by the President three times (1 December 2025, 12 February 2026, and again in June 2026 per later reporting). Three competing draft bills (government, Poland 2050, Konfederacja) remain stuck in the legislative process.

KNF (Komisja Nadzoru Finansowego / Polish Financial Supervision Authority) is the intended competent authority under the stalled Crypto-Assets Market Act, but KNF currently has NO statutory power to accept or process CASP applications because no law has designated it as the Article 3(1)(35)(a) MiCA competent authority. This is a genuine regulatory vacuum, not merely a slow regulator.

MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration.

Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.)

MiCA CASP authorisation (EU Regulation 2023/1114, directly applicable). National implementation is unsettled: 2025 commentary cited GEO 10/2025 as the transposition instrument in force from 13 Mar 2025, while ASF stated on 1 Jul 2026 that the designating act is still a draft and no competent authority is yet in place; see recent changes.

Autoritatea de Supraveghere Financiara (ASF, Financial Supervisory Authority). A technical pre-clearance of IT systems by the Authority for Digitalisation of Romania (ADR) is also required before ASF grants a licence - a Romania-specific extra step.

Payment Services Act 2019 Digital Payment Token (DPT) service licence, held as a Standard (SPI) or Major Payment Institution (MPI) - most crypto firms are MPIs. Plus the newer DTSP regime (FSMA 2022 Part 9) and a finalised (not-yet-legislated) stablecoin issuer framework.

Monetary Authority of Singapore (MAS) - central bank and integrated regulator; administers the PSA, the DTSP regime, the SFA and the stablecoin framework.

MiCA CASP authorisation under Regulation (EU) 2023/1114, supplemented nationally by Act No. 248/2024 Coll. on certain obligations and authorisations in the field of crypto-assets (adopted September 2024).

Narodna banka Slovenska (NBS, National Bank of Slovakia)

MiCA CASP authorisation under Regulation (EU) 2023/1114, supplemented by the national Law on the Implementation of the EU Regulation on Crypto-Asset Markets (ZIUTK), in force from 23 November 2024.

Agencija za trg vrednostnih papirjev (ATVP, Securities Market Agency) for ordinary CASP authorisation, supervision, qualifying holdings, and white-paper matters; Banka Slovenije handles e-money-token matters.

VASP registration (not a discretionary licence) under the Act on Reporting and Using Specified Financial Transaction Information (the 'FTRA'/AML Reporting Act, amended effective 25 Mar 2021), which requires: (1) ISMS certification from KISA (Korea Internet & Security Agency); (2) for KRW fiat on/off-ramp services, a bank-issued real-name verified account; plus fit-and-proper/AML program requirements. Layered on top since 19 July 2024 is the Act on the Protection of Virtual Asset Users (VAUPA), which adds customer-asset segregation, insurance/reserve, and market-abuse rules but does not replace the underlying FTRA registration.

Financial Services Commission (FSC), Korea's top financial policymaker; Korea Financial Intelligence Unit (KoFIU, also referred to as FIU), an FSC-subordinate unit established 2001 under the FTRA that receives and processes VASP registrations and AML reporting; day-to-day supervision/inspection is delegated to the Financial Supervisory Service (FSS), which set up dedicated Virtual Asset Supervision/Investigation bureaus (announced 29 Nov 2023). FSC retains final sanctioning authority.

MiCA CASP Authorisation granted by the Comisión Nacional del Mercado de Valores (CNMV); Banco de España separately supervises stablecoin (ART/EMT) issuance

Comisión Nacional del Mercado de Valores (CNMV) - lead CASP authority; Banco de España co-supervises stablecoin issuers

MiCA CASP authorisation under EU Regulation 2023/1114, administered directly by Finansinspektionen (FI) under Sweden's existing financial supervisory framework (no major new primary legislation was flagged as required, unlike Belgium/Poland). Sweden's national transitional period for pre-MiCA providers closed 30 September 2025.

Finansinspektionen (FI), Sweden's single competent authority for CASP authorisation and supervision under MiCA.

No single crypto licence - regulated by economic function (FINMA token taxonomy; DLT Act 2021). Typical exchange/custodian/broker needs SRO/AMLA affiliation (e.g. VQF) plus, where deposits/custody are involved, a FinTech licence (Banking Act Art. 1b); larger deposit-taking needs a banking licence; a DLT trading facility needs FinMIA authorisation.

FINMA (Swiss Financial Market Supervisory Authority) grants all prudential licences; for AML only, firms affiliate with a FINMA-recognised SRO (e.g. VQF).

Digital Asset Business licence under the Emergency Decree on Digital Asset Businesses B.E. 2561 (2018), as amended (most significantly by an April 2025 amendment extending extraterritorial scope). Categories, each with its own capital tier: Digital Asset Exchange, Digital Asset Broker, Digital Asset Dealer, ICO Portal, Digital Asset Fund Manager, Digital Asset Advisory Service and Digital Asset Custodial Wallet Provider.

Securities and Exchange Commission (SEC) Thailand is the primary licensing/supervisory authority; the Ministry of Finance formally grants the licence on SEC recommendation. The Ministry of Digital Economy and Society (MDES) holds blocking powers over unlicensed platforms (added by the 2025 amendment). The Bank of Thailand has a consultative role for certain payment-related and stablecoin aspects.

Crypto Asset Service Provider (CASP) operating licence/permit under Law No. 7518 (amendment to Capital Markets Law No. 6362), adopted 26 June 2024, in force 2 July 2024. Secondary regulation via Communiqués III-35/B.1 (establishment/operating principles) and III-35/B.2 (operating procedures and capital adequacy), published in Official Gazette No. 32840, 13 March 2025. Distinguishes platform operators (exchanges) from custody-only providers.

Capital Markets Board of Turkey (CMB / Sermaye Piyasası Kurulu, SPK). AML/CFT compliance is separately overseen by MASAK (Financial Crimes Investigation Board).

VARA VASP licence under the Virtual Assets and Related Activities Regulations 2023 - licensed PER ACTIVITY (Advisory, Broker-Dealer, Custody, Exchange, Lending & Borrowing, Management & Investment, Transfer & Settlement, plus VA Issuance). A DET/free-zone commercial licence is also required.

VARA (Virtual Assets Regulatory Authority) - sole authority across the Emirate of Dubai except the DIFC. Parallel UAE regimes exist: ADGM/FSRA (Abu Dhabi), DFSA (DIFC), and federal SCA/Central Bank.

No single federal crypto licence. Fragmented dual-layer regime: (a) State-level Money Transmitter Licence (MTL), required in 49 states (all except Montana) plus DC, applied for via NMLS (Nationwide Multistate Licensing System) under each state's money transmission statute (31 states have adopted the Money Transmission Modernization Act, MTMA, in full or part as of Feb 2026); (b) Federal FinCEN Money Services Business (MSB) registration under the Bank Secrecy Act, via FinCEN Form 107, required for any business acting as a money transmitter/administrator/exchanger of convertible virtual currency. Some states have specific regimes (e.g., NY BitLicense from NYDFS, 23 NYCRR Part 200) as an alternative/superseding requirement.

No single federal crypto regulator. Federally, FinCEN (US Treasury) handles MSB registration and BSA/AML oversight. At the state level, each state's banking/financial-services department (e.g., NYDFS in New York, DFPI in California) issues and supervises money transmitter licences via NMLS. The SEC and CFTC separately assert jurisdiction over certain crypto activities (securities/commodities), the allocation of that jurisdiction is the subject of the pending CLARITY Act.