CTF Written Submission

Crypto’s Evidentiary Debt Crisis

Sept. 23, 2025
  • Evidentiary asymmetry in crypto markets undermines enforcement because regulators cannot prove the absence of misconduct (e.g., wash trading, front-running), creating a persistent "evidentiary debt."
  • Cryptographic receipts of absence offer a novel compliance mechanism by mathematically attesting that prohibited activities did not occur within a defined scope, enhancing auditability and legal defensibility.
  • Mandating or endorsing such receipts would support the SEC’s goals of clear regulatory boundaries, tailored disclosures, and stronger investor protections through verifiable compliance.

Last Reviewed or Updated: Sept. 24, 2025