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In 2026, blockchain is no longer a niche innovation quietly maturing in the background of digital finance. It has become both a global infrastructure layer and a global risk vector — a duality that most national strategies, including the United States’, still fail to fully confront.

While the Trump administration has embraced a pro-crypto posture — advancing stablecoin legislation, rolling back prior enforcement stances, and even creating a strategic bitcoin reserve — its latest national security strategy omits blockchain and digital assets entirely. Instead, the focus falls squarely on AI, biotech, and quantum computing.

This omission stands in stark contrast to what is happening at the operational edge of the crypto ecosystem, where stablecoins have become the new backbone of illicit finance. A New York Times investigation revealed how criminals, sanctioned actors, and transnational smuggling networks are now leveraging dollar-linked tokens to move money with unprecedented ease, speed, and anonymity.

For project managers and tech strategists, the message is clear:
You cannot rely on national policy to set the boundaries of blockchain risk. You must build that understanding — and the controls — internally.

1. Stablecoins Have Become the New Infrastructure of Illicit Finance

For decades, sanctioned individuals, traffickers, and organized crime syndicates relied on diamonds, gold, and art to move value discreetly. These assets were opaque but inconvenient: hard to transport, hard to store, and difficult to convert.

Stablecoins solved all of that.

According to Chainalysis, up to $25 billion in illicit transactions involved stablecoins last year. These tokens now provide:

• Frictionless cross-border transfers
• On-off ramps using unregulated intermediaries
• Anonymity via crypto ATMs, Telegram bots, and offshore card issuers
• Instant conversion into debit or payment cards
• The ability to bypass sanctions, capital controls, and traditional AML systems

The NYT investigation showed just how simple it is:
A journalist fed $40 into a crypto ATM and, within minutes, used a Telegram bot to generate a Visa card loaded with stablecoins — no identity verification required.

This is not fringe technology. It is operational, scalable, and widely used.

For project managers and strategists, the implication is profound:

Your blockchain-adjacent products, payment systems, DeFi integrations, or wallet features may already be interacting with risk vectors that your compliance frameworks do not cover.

2. The Regulatory Landscape Is Fragmented — and Criminals Are Exploiting Every Gap

The GENIUS Act, passed in mid-2025, represents the first major U.S. regulatory framework for stablecoins. It sets federal oversight, mandates compliance programs, and aims to reduce illicit activity.

But the law’s jurisdictional limits are glaring:

• It applies primarily to U.S.-based exchanges, not offshore platforms or stablecoins issued abroad.
• Tether, with over $180 billion in circulation, is headquartered in El Salvador and remains outside U.S. regulatory reach.
• Decentralized systems — liquidity pools, mixers, peer-to-peer swaps — fall into gray zones with inconsistent enforcement.
• The compliance responsibility can fall through cracks between card issuers, fintech intermediaries, and offshore service providers.

A global network of anonymous Visa/Mastercard issuers funded by stablecoins now spans:

• Costa Rica
• Georgia
• Kazakhstan
• Malta
• Russia
• Kyrgyzstan

Actors use multi-layered custody chains to obscure origins and evade sanctions. The NYT traced one such card through two companies — one in Hong Kong, another in Brazil — neither fully accountable for AML/KYC enforcement.

The blockchain ecosystem moves faster than regulators can coordinate — and far faster than most organizations’ risk frameworks can adapt.

3. The U.S. National Security Strategy Is Silent on Blockchain — and That’s a Strategic Blind Spot

Despite its pro-crypto policies, the Trump administration’s 2025 national security strategy makes no mention of:

• cryptocurrencies
• stablecoins
• blockchain infrastructure
• tokenized payments
• decentralized protocols

Instead, it concentrates on AI, biotech, and quantum computing as pillars of U.S. technological leadership.

This sends an unmistakable signal:

Washington does not yet view blockchain as a strategic technology — even as adversaries and criminal networks are using it at strategic scale.

For project managers and tech strategists, this mismatch means: Policy guidance will continue to lag behind operational risk, leaving compliance expectations ambiguous and forcing internal teams — rather than regulators — to shoulder the bulk of security responsibilities. In this environment, vendors may provide tools, but they will not deliver the comprehensive safety frameworks organizations need to navigate the accelerating complexity of blockchain-related threats.

Just as the FLI AI Safety Index revealed that industry safety for AI is far behind capability, blockchain is facing a similar maturity gap — but with even less global oversight.

4. Key Risks Project Managers and Tech Strategists Must Understand

Risk 1 — Stablecoin Abuse and Sanctions Evasion

Your systems could inadvertently interact with addresses linked to sanctions, terrorism financing, or transnational crime.

Risk 2 — Opaque Intermediary Chains

The blockchain ecosystem is filled with intermediaries (wallet providers, card issuers, liquidity services) that are not subject to uniform KYC/AML rules.

Risk 3 — Identity Laundering Through Payment Cards

Anonymous crypto-funded payment cards with high spending limits undermine traditional fraud controls.

Risk 4 — Compliance Blowback

Even if your platform is compliant, your users’ actions through third-party wallets or cards may generate:

• suspicious activity flags
• law enforcement inquiries
• reputational damage

Risk 5 — Weak Vendor Oversight

Blockchain vendors, DeFi protocols, and exchanges have uneven governance, and many operate offshore.

Risk 6 — Strategic Vulnerability

If U.S. national policy does not treat blockchain as a strategic technology, organizations must assume adversaries will exploit that gap.

5. A Practical Blockchain Risk Playbook for PMs and Tech Strategists (2026 Edition)

1. Map Your Exposure to Stablecoin Flows

Catalog where stablecoins touch your ecosystem:

• wallets
• payment features
• customer deposits
• DeFi integrations

Don’t assume “we don’t handle crypto” means no exposure — users often bridge funds through external services.

2. Conduct Counterparty and Vendor Risk Assessments

Evaluate:

• where vendors are incorporated
• their AML/KYC policies
• enforcement track records
• whether they work with offshore issuers or crypto-funded card programs

3. Integrate On-Chain Analytics

Use services (Chainalysis, TRM Labs, Elliptic) for:

• address screening
• transaction monitoring
• sanctions detection
• anomaly scoring

4. Introduce Conditional Access and Spend Controls

For any crypto-connected feature:

• set thresholds
• require additional identity verification
• implement velocity checks
• enable real-time flags or holds

5. Build Internal Sanctions-Awareness Protocols

Even if your product is not a financial institution, you need:

• documentation of your sanctions exposure
• escalation paths
• incident reporting workflows

6. Prepare for Future Regulation

The absence of blockchain in the U.S. national security strategy today is not a guarantee of continued silence. When regulation arrives, it may be:

• retroactive
• sweeping
• technically complex

Prepare compliance documentation now.

6. The Bigger Picture: AI Is Getting Guardrails, Blockchain Is Not

AI is receiving global policy attention — safety institutes, national plans, alignment research, regulatory frameworks.
Blockchain, despite underpinning billions in illicit flows and reshaping cross-border finance, remains largely peripheral in national strategy.

This asymmetry creates a dangerous dynamic:

AI risk is being mitigated, while blockchain risk is being monetized.

For project managers and strategists, the implication is immediate:

You must not treat blockchain as a mature, well-governed technology.

You must treat it as an evolving high-stakes ecosystem with growing national-security relevance.

Conclusion:

Blockchain Is Now a Strategic Risk Surface — and Leaders Must Treat It That Way

The NYT investigation makes one thing unmistakably clear:
stablecoins have become the preferred medium for illicit finance at global scale.

The omission of blockchain from the U.S. national security strategy reinforces another truth:
governments are not yet prepared to manage these risks.

Just as with AI, the responsibility now shifts to leaders inside organizations:

• to map exposure
• to implement controls
• to monitor on-chain behavior
• to evaluate vendors
• to prepare for regulatory whiplash

Blockchain remains transformational — but it is also becoming one of the most exploited infrastructures on Earth.
Organizations that acknowledge this duality, and build appropriate safety, compliance, and governance structures, will be the ones that thrive in a world where digital assets are as common as email — and as powerful as the dollar itself.

Sources

Godbole, O. (2025, December 7). Trump’s national security strategy ignores Bitcoin and blockchain. CoinDesk. https://www.coindesk.com/opinion/2025/12/07/trump-s-national-security-strategy-ignores-bitcoin-and-blockchain

Silverman, R. (2025, December 7). How a cryptocurrency helps criminals launder money and evade sanctions. The New York Times. https://www.nytimes.com/2025/12/07/technology/how-a-cryptocurrency-helps-criminals-launder-money-and-evade-sanctions.html