5 corruption gaps Congress must close in the Clarity Act
The U.S. Senate is advancing the Clarity Act, legislation considered among the most consequential for crypto policy worldwide. In an opinion piece published June 9, 2026, policy analyst Greytak warns the bill, as drafted, leaves the United States exposed to money laundering, sanctions evasion and conflicts of interest at the highest levels of government — shortcomings Greytak summarizes as five distinct "corruption gaps."
The five corruption gaps: broad themes identified
Greytak frames the concerns around five interlocking vulnerabilities. First is the risk that the Act’s regulatory boundaries create AML enforcement gaps, allowing bad actors to exploit weakly regulated on- and off-ramps. Second is the potential for sanctions evasion if the law fails to align compliance obligations across exchanges, custodians and stablecoin issuers. Third is the danger of conflicts of interest where policymaking or regulatory implementation lacks robust recusal and disclosure rules for officials and private-sector actors. Fourth is incomplete transparency and reporting requirements for tokenized assets, stablecoins and custodial arrangements that could obscure illicit flows. Fifth is fragmented enforcement authority and insufficient safeguards to prevent regulatory capture or interference at senior levels of government.
Why this matters for markets, infrastructure and institutions
The issues Greytak raises are materially relevant to exchanges, stablecoin issuers, tokenized-asset platforms and institutional participants. Gaps in AML and sanctions controls can increase compliance risk for U.S. firms and their global partners, potentially prompting higher onboarding costs, more restrictive counterparty screening or relocation of services. Exchanges and custodians depend on clear, consistent rules to maintain correspondent relationships with banks and to support custody for institutional products such as spot Bitcoin and Ether ETFs.
Stablecoins and tokenized assets are particularly sensitive to transparency and enforcement standards. Market-makers and liquidity providers price-in legal and compliance risk; uncertainty or perceived permissiveness on illicit finance and sanctions could compress liquidity or raise the cost of capital for projects seeking institutional adoption. For BTC, ETH and other major tokens, the practical effect would be on exchange flows, custody arrangements and the availability of regulated derivatives and ETF products rather than on protocol fundamentals.
Institutional custodians, prime brokers and banks that interface with crypto platforms require durable legal frameworks to manage custody liabilities and compliance responsibilities. If the Clarity Act leaves enforcement authority unclear or creates avenues for conflicts of interest, institutions may face operational strain and reputational risk while regulators contend with uneven oversight.
What Congress and market participants may monitor next
Greytak’s op-ed urges legislators to close the identified gaps through targeted amendments and safeguards. Key items for market participants to watch include Senate committee markups and floor amendments that clarify AML obligations, align sanctions compliance across entity types, strengthen disclosure and recusal rules, and delineate enforcement roles among Treasury, FinCEN, the SEC and the CFTC.
Beyond the text of the bill, stakeholders will monitor regulatory guidance, interagency coordination, and industry responses from exchanges, stablecoin issuers and institutional custodians. Those developments will determine how the Clarity Act reshapes compliance regimes, market infrastructure and the path to broader institutional adoption of digital assets.