Senate Republicans released a substitute amendment to the CLARITY Act on September 10, just five days before a scheduled cloture vote, marking a significant last-minute change to legislation that would define the regulatory perimeter for digital assets. The revised text adds CFTC registration requirements and Bank Secrecy Act obligations for trading protocols deemed not sufficiently decentralized, limits the DeFi safe harbor to spot and cash digital commodity transactions only, and carves out new permissions for credit unions dealing in digital assets.
For Armada's crypto-collateral desk, the revised decentralization threshold is the critical variable. If Armada's repo infrastructure or any counterparty protocol is classified as non-decentralized, CFTC registration and BSA compliance obligations could apply, affecting onboarding, reporting, and permissible collateral. Legal counsel should review the substitute text against Armada's operational model before cloture.