New COIN Act Bans Public Officials and Their Families from Trading Crypto and NFTs for Up to Two Years After Leaving Office

The Curbing Officials' Income and Nondisclosure (COIN) Act is a massive overhaul of ethics rules aimed squarely at the world of digital assets. Simply put, this bill wants to keep public officials—and their immediate families—from using their positions, or their knowledge gained in office, to profit from volatile assets like cryptocurrencies, meme coins, NFTs, and payment stablecoins. It doesn't just stop at current service; it extends the ban 180 days before they start and for a full two years after they leave.

The Digital Asset Lockdown

Section 2 is the core of the bill, creating a new class of "Prohibited Financial Transactions." If you’re a covered official or related to one, you can’t issue, sponsor, or even endorse these digital assets while in office, or during the transition periods. This is a big deal for anyone who might have crypto holdings or whose spouse works in the Web3 space. For example, if an official's spouse owns a significant NFT collection or has stock options tied to a crypto exchange, they would likely be forced to liquidate or divest before the official even takes the oath, and they couldn't jump back in until two years after the official is gone. The bill clarifies that this doesn't stop officials from holding standard stocks or bonds, but it specifically targets the high-risk, often regulatory-sensitive digital asset class.

When "Insider Trading" Meets Crypto

This bill doesn't just rely on civil fines; it brings serious criminal penalties into play under Section 3. If an official knowingly violates the ban and causes a $1 million loss to the public, or if they profit from the prohibited transaction, they face up to five years in prison. If the violation involves a bribe—say, accepting a token in exchange for an official act—the penalty jumps to 15 years and a fine up to three times the value of the bribe. Crucially, the bill also explicitly treats any action related to these prohibited transactions as an "unofficial act," meaning the official loses any civil or criminal immunity they might otherwise have. This removes a major shield for officials engaging in shady digital asset deals.

The Disclosure Dragnet and Conflict of Interest

For regular federal employees who aren't high-level officials, the COIN Act tightens up disclosure rules under Section 4. If you’re a federal employee who has to file financial disclosures, you now must report any digital asset—crypto, NFT, stablecoin—worth over $1,000 at the end of the year. This significantly expands the scope of what the government tracks about its employees' finances. Furthermore, the bill amends the core conflict of interest law (Section 208 of Title 18) to explicitly state that owning these digital assets constitutes a “financial interest.” This means if you hold a specific stablecoin, you are automatically barred from participating in any official government decision or matter that affects that stablecoin.

The Stablecoin Certification Catch

Section 5 introduces a unique requirement for stablecoin issuers. If a stablecoin company wants to be approved to operate, they must certify to the Office of Government Ethics (OGE) and their regulator that absolutely no public official is profiting from their stablecoin issuance. This isn't a one-time form, either; they have to recertify every single quarter. If they fail to submit the certification, their license to operate is revoked. This puts the burden of proof directly on the stablecoin industry to ensure they are not being used as a personal piggy bank for government officials, adding a powerful layer of transparency that the OGE must then make public.