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Tokenised money proposal

Virtual Financial Ecosystem Simulation - CEMI Financial Innovation Lab
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Tokenised money proposal

A proposed extension, available for testing today in a world that opts in, standing outside the regulated providers, awaiting the Bank’s view. It is never presented as built, and never as a suggestion to the Bank.

Status: proposal, for Carlos's decision · 2026-09-06, revised 2026-09-07 after the second deep-research round was verified · author: Claude for Carlos Miranda Levy · EN (Spanish rendering: extension-tokenised-money.es.md)
Scope: whether, and on what terms, the Virtual Financial Ecosystem Simulation (../finlab-financial-ecosystem-simulation-plan.md) should carry a layer of tokenised money — a permissioned distributed ledger, a peso stablecoin, a dollar stablecoin for remittance legs, a virtual-asset service provider, tokenised deposits, and a what-if wholesale central-bank token.
Discipline: the anti-hallucination canon of this repository's CLAUDE.md and the verification protocol of [foundations.md](foundations.md) §1. Every factual statement below is tagged [SOURCE], [INFERENCE] or [REQUIRES VERIFICATION]. Nothing carrying [REQUIRES VERIFICATION] may ship into a rule, a page, a proposal or a letter.
Companion documents: [gaps.md](gaps.md) §B (new rows), [bcrd-consultation-annex.md](bcrd-consultation-annex.md) (new numbered consultations), [foundations.md](foundations.md) §5 (new bibliography area 11), and the source ledger for the second round at [deep-research/verification/areas-11-16.md](deep-research/verification/areas-11-16.md).

What the 2026-09-07 revision changed. Three deep-research returns on virtual assets were verified source by source. Three findings were added that this document did not have — a second Dominican prohibition (SIMV Circular 04/23, §1.2), the Central Bank's own published CBDC research (§1.2 and §3.6), and the read texts of Brazil's virtual-asset resolutions and Chile's implementing norm (§1.5 and §5.2.1) — and three statements this document made were corrected: that the Bank had published nothing on central-bank digital currency; that the securities regulator's position could not be read; and that Resolução BCB 584 belonged to Brazil's virtual-asset framework. A sixth consultation question follows from the first of them. Nothing in §5.1's Dominican tier changed.


1. Why this belongs in the ecosystem, and why it is an extension and not an article

1.1 The one discipline, and what it forbids here

The ecosystem has exactly one constitutional rule, and everything else in it is downstream of that rule: no rule exists without its article, its resolution and that resolution's date. The loader enforces it — loadRuleCatalogue throws on a rule missing article, instrument, resolution, resolutionDate or effectiveDate, "so a catalogue that has drifted cannot be run at all" (finlab-ecosystem/docs/spec/rule-catalogue-format.md). The naming and disclaimers spec states the same discipline in its negative form: "Never state a regulatory fact the plan does not give with its citation."

That rule is what makes this extension hard, and it is also what makes it possible to do honestly. A Dominican article that says how a token is issued, held, transferred, redeemed or supervised does not exist. Article 78 of the Reglamento classifies the electronic payment instruments as a closed list of three — electronic funds transfers, payment cards, and electronic payment accounts [SOURCE: Reglamento de Sistemas de Pago, Segunda Resolución de la Junta Monetaria, 28 August 2025, Art. 78: "Se considerarán instrumentos de pago electrónicos: a) Las transferencias electrónicas de fondos… b) Las tarjetas de pago; y, c) Las cuentas de pago electrónico."] — and a token is on none of the three lines. There is therefore no article to cite for a token's behaviour, and writing a rule that cited one would be the single thing this repository is built not to do.

1.2 A correction: the Reglamento does speak about virtual assets, and what it says is a refusal

Our working reading, carried into the brief for this document, was that the Reglamento and the three instructivos contain no provision at all on virtual assets, tokens or distributed ledgers. That reading was half right, and the wrong half is load-bearing. It is recorded here as a correction rather than adjusted in silence, which is the rule this Lab applies to itself (bcrd-consultation-annex.md, "Cómo el Lab incorporará las respuestas", point 4).

The full text of the Reglamento was downloaded from the Central Bank's own document root and searched, term by term, on 2026-09-06. What the search establishes:

The consequence for this proposal is decisive and, in the end, favourable. The Dominican rulebook does have something executable to say about virtual assets, and what it says is a prohibition on seven named provider categories. That is a rule the ecosystem can carry in the catalogue with a real article, a real resolution and a real date. It is a refusal rule: a simulated electronic-payment entity that tries to offer a product based on a virtual asset must fail, loudly, citing Art. 17 w). Nothing else in this extension may cite a Dominican article, and the reason is not that the country is silent — it is that the country has spoken, in the narrow register of who may not do this, and has said nothing whatever about how it would be done if it were allowed.

Outside the Reglamento, seven more things are established and one is not. They are set out here because the shape of the extension depends on all of them. Three of the seven were added on 2026-09-07 after the second deep-research round was verified ([deep-research/verification/areas-11-16.md](deep-research/verification/areas-11-16.md)), and two of those three correct something this document previously said.

What is verified, and is new, is that the legislative silence is itself being litigated. The Tribunal Constitucional's hearing roll for Wednesday 22 April 2026, under Acción Directa de Inconstitucionalidad, carries as item 9: "Expediente: TC-01-2025-0073. Accionante: Marino Marrero Báez. Omisión cuestionada: omisión legislativa y exceso administrativo en materia de activos virtuales. Autoridades de las cuales emana la norma atacada: Senado y Cámara de Diputados." [SOURCE: Tribunal Constitucional de la República Dominicana, Rol de Audiencias, 22 April 2026, item 9, read 2026-09-07.] What that establishes is the action's existence, number, applicant, subject and hearing date — and nothing else. No decision was located; nothing may be said about how or when the Court will rule, and no Lab material may suggest that a ruling is expected or that it would change the Reglamento.

Three consequences, and none of them is cosmetic. The Dominican position is not the Central Bank's alone — no Lab material may describe it that way again. A second Dominican provider population is prohibited, on a different article, by a different supervisor, and the prohibition is drafted to survive a foreign characterisation ("aún si tales instrumentos son reconocidos como valores en otras jurisdicciones") — which is precisely the branch a simulator would otherwise have got wrong. And «tókenes» is a word in Dominican regulatory text after all: the Reglamento de Sistemas de Pago has no occurrence of it, but the SIMV's circular does, so §1.1's finding must be stated as absent from the payment-system rulebook, not absent from Dominican regulation.

Against that, the Bank's account of the system it is actually building contains nothing of the kind. At the II Foro de Pagos Instantáneos, held 1 May 2026, the Governor said that "la empresa CMA SMALL SYSTEMS, en colaboración con un equipo multidisciplinario de profesionales del Banco Central, están implementando una novedosa solución de pagos instantáneos para la República Dominicana, la cual funcionará a través de una nueva plataforma que procesará todos los pagos minoristas actualmente tramitados a través del servicio de Pagos al Instante BCRD", and that "se está trabajando con todas las entidades del sistema financiero dominicano para que en el próximo año 2027 el sistema de gestión de pagos instantáneos sea una realidad, coincidiendo con la conmemoración del 80 aniversario de la fundación del Banco Central." The page contains no occurrence of token, tokenización, activo virtual, criptoactivo, blockchain, DLT or CBDC. [SOURCE: BCRD, BCRD celebró el II Foro de Pagos Instantáneos, bancentral.gov.do/a/d/6561-…, published 5 May 2026, read with a headless browser 2026-09-07; the page is JS-rendered.]

The two together are the honest statement, and it is more useful than either alone: the Bank researches central-bank digital currency and says the research implies no decision; the rail it is building is account-based fiat and it says so without qualification. The SGPI's 2027 date now rests on the Governor's own words rather than on press, and Lab material should stop writing first half of 2027, which no BCRD source read supports. §3.6's three guards on the wholesale token are unchanged and, if anything, are now better founded: a Lab hypothesis about a wholesale settlement token is a different object from the Bank's published research on a retail CBDC, and the second must never be cited as warrant for the first.

1.3 Why it belongs anyway

Four reasons, in descending order of strength.

It is what a twin has to be able to represent in order to stay a twin. The plan's own qualification of "digital twin" is the ambition it sets: "Our aim is to become the true digital twin of the Dominican financial ecosystem as it takes shape, following the work and guidelines of the Central Bank, the Superintendencia and the industry" (plan §2, Carlos, 2026-09-05). A twin that models the ecosystem only as it is today is a snapshot. The ecosystem was built ahead of the SGPI for exactly this reason — Ready for 2027, today — and the argument does not change shape when the subject does.

The refusal is the product. For every Dominican provider in the seven categories, the operationally useful question in 2026 is not "how do I issue a token" but "how do I prove that my product is not one, and how do my systems behave when a counterparty's is". A wallet provider asked by an overseas partner to accept a dollar stablecoin leg needs to be able to refuse it, and to show the refusal in a record. That capability is testable today, cites Art. 37 j), and nobody in the country can currently rehearse it against anything.

The compliance surface already reaches it. Art. 43 makes the Ley 155-17 obligations reach payment-service providers and SIPARD participants, and Art. 44 puts their records at the supervisors' disposal [SOURCE: Reglamento, Arts. 43–44, verified against the extracted text]. The ecosystem already has a simulated UAF, a monitoring unit and a compliance plug. Whether a Dominican virtual-asset service provider is itself an obligated subject under Ley 155-17 is a separate question, and one for the consultation (§6).

Remittances are the use case, and they are the country's. The Central Bank reports that US$11,866.3 million in remittances entered the Dominican Republic during 2025, an increase of US$1,110.3 million or 10.3% over 2024 [SOURCE: BCRD press release, 9 January 2026, https://www.bancentral.gov.do/a/d/6463-bcrd-informa-que-los-flujos-de-remesas-alcanzaron-us118663-millones-en-2025: "durante el año 2025, se recibieron US$11,866.3 millones por concepto de remesas, lo que representa un aumento de US$1,110.3 millones (10.3 %) en comparación con el año 2024". Retrieved with a headless browser; the page is JS-rendered.] The dominant origin is the United States, and the Bank states that share monthly, not annually — 80.0% of formal flows in December 2025 [SOURCE: same release: "desde ese país se originó el 80.0 % de los flujos formales del mes de diciembre, unos US$751.9 millones"]. Write it as a December figure or as roughly four in five formal flows; the annual framing that circulates in the press is not in the Bank's text. The 2026 part-year confirms both the scale and the discipline: "durante el periodo enero-mayo de 2026, el flujo de remesas hacia el país alcanzó los US$5,170.1 millones, lo que representa un incremento interanual de 5.4 %", with May at US$1,090.2 million and the United States originating "el 82.3 % de los flujos formales recibidos en mayo, equivalentes a US$827.9 millones", Spain second at 6.2%; the Bank projects remittances "por encima de los US$12,200 millones" for the year [SOURCE: BCRD press release of 14 June 2026, https://www.bancentral.gov.do/a/d/6593-…, read with a headless browser 2026-09-07]. The United States share is a monthly statistic in the Bank's writing in 2026 exactly as it was in 2025. And note what that release does not say: it attributes the outlook to tourism, exports, foreign direct investment and United States labour-market indicators, and contains no reference to any United States remittance tax — a claim one research return attached to it and which must never be attributed to the Bank.

Three further disciplines on this paragraph, because it is the one most likely to be lifted into a proposal. Remittances as a share of GDP is not a BCRD figure — the World Bank's series puts personal remittances received at about 9.7% of Dominican GDP in 2025, and it must be attributed to the World Bank [SOURCE: World Bank indicator BX.TRF.PWKR.DT.GD.ZS, https://api.worldbank.org/v2/country/DOM/indicator/BX.TRF.PWKR.DT.GD.ZS?format=json, 2025 = 9.74.] The cost of sending money to the Dominican Republic must be written directionally and with no percentage attached: the World Bank's Remittance Prices Worldwide site refused automated access from every route, and the two reachable World Bank–derived series for the corridor disagree by roughly a factor of two, one of them carrying an implausible negative value [REQUIRES VERIFICATION: any cost-of-sending figure for the United States → Dominican Republic corridor, at a named quarter, read off remittanceprices.worldbank.org itself.] And the Bank publishes no cash-versus-account channel mix; the only adjacent published number is that informal "remesas de bolsillo" represent less than 10% of the total value [SOURCE: BCRD, Estándares metodológicos de la compilación de las estadísticas del sector externo, https://www.bancentral.gov.do/a/d/6438], which is a formal/informal split and must never be repurposed as a cash/account one.

1.4 What "extension" means in this repository, precisely

The repository already has a mechanism for carrying a system whose rules are not Dominican law: the SLA profile. rules/profiles/ holds pix.yaml, spei.yaml, sepa-instant.yaml, fednow.yaml, bre-b.yaml, upi.yaml and nexus.yaml. Each restates catalogued parameters as another real system publishes them, every value carries the ledger id of the verified foundations row it comes from, a value the verification passes could not establish is recorded in notVerified and carries no number, and the loader refuses a profile that breaks either discipline. The README states the point that governs this entire proposal: "A run under a profile is a comparison and nothing else. It is not a statement about the Dominican system, and the report says so in its header, on every moved parameter, and in the comparison table."

That is the shape of this extension. MiCA, the GENIUS Act and the FATF Recommendations enter the ecosystem the way Pix and SPEI already do — as reference profiles under their own jurisdiction's name, never as Dominican law, never as a default, and always with the comparison notice on the report. What enters the Dominican catalogue proper is only what cites a Dominican article: the definition in Art. 4 a) and the seven prohibitions.

The distinction is not cosmetic. A rule in rules/.yaml is the Reglamento made executable. A rule in rules/profiles/.yaml is another country's homework, shown for comparison. Putting a token rule in the first place would be a fabrication of Dominican law; putting it in the second is the honest thing this repository was designed to do.

1.5 What the region has already done, and what it does not settle

Five regional cases were verified for this document. Read together they say something the Lab should take seriously: in this region the enacted instruments are perimeter-and-prohibition instruments, not permission frameworks — which is exactly the shape of the Dominican Arts. 11 v through 39 l, and exactly the shape the ecosystem is best placed to model.

Brazil is the closest precedent for the method, not only for the subject. The Banco Central do Brasil's Drex pilot describes itself as "a fase de testes para operações com a moeda digital brasileira", on a platform where "transações com ativos digitais são simuladas e liquidadas em Drex de varejo ou Drex de atacado, dependendo de sua natureza"; its participants are the central bank, the securities commission, the national treasury and institutions authorised by their own regulators — and, in the sentence that matters most to this Lab, "Usuários finais não serão participantes, sendo suas operações simuladas." Phases 1 and 2 are both recorded as closed, with the phase-2 report em construção. [SOURCE: BCB, Piloto Drex, https://www.bcb.gov.br/estabilidadefinanceira/piloto-drex, and Drex – Real Digital, https://www.bcb.gov.br/estabilidadefinanceira/drex, both read on 2026-09-06 with a headless browser; the pages are JS-rendered.] A central bank running a tokenised-money pilot in which the end users are simulated is not an argument the Lab has to make for itself — it is the method, in a central bank's own words. [REQUIRES VERIFICATION: any production launch date for Drex; none is stated on the BCB pages reached. Press accounts of a platform shutdown in late 2025 and of a phase-3 scope are not corroborated on any BCB page and must not be repeated.]

El Salvador is the clearest verified case of a tokenised-money regime being wound back, and it is worth stating precisely because it is so often stated loosely. The Ley Bitcoin, Decreto Legislativo N° 57 of 8 June 2021, made bitcoin "moneda de curso legal, irrestricto con poder liberatorio, ilimitado en cualquier transacción y a cualquier título que las personas naturales o jurídicas, públicas o privadas requieran realizar" (Art. 1), obliged every economic agent to accept it (Art. 7), allowed all tax contributions to be paid in it (Art. 4), and committed the State to provide automatic and instantaneous convertibility to the dollar (Arts. 8–9). Decreto N° 199 of 29 January 2025, published in Diario Oficial N° 21, Tomo N° 446 of 30 January 2025 and in force ninety days after publication, reformed Art. 1 to read "la regulación del Bitcoin como curso legal, definido por su poder liberatorio ilimitado, con aceptación voluntaria por las personas naturales o jurídicas con total participación privada únicamente"; reformed Art. 7 so that "Únicamente las personas naturales, o jurídicas con total participación privada, podrán aceptar Bitcoin"; reformed Art. 12 so that "Las obligaciones monetarias del Estado, domésticas y externas, deberán ser pagadas en las monedas que fueron contraídas"; and derogated Arts. 4, 8 and 9 outright. [SOURCE: Asamblea Legislativa de la República de El Salvador, Decreto N° 57 and Decreto N° 199, both PDFs downloaded from asamblea.gob.sv and read in full on 2026-09-06.] Note the mechanism: the bar on paying taxes in bitcoin was achieved by repealing the article that permitted it, not by adding a prohibition — a detail most secondary accounts get wrong. And note what the decree did not do: the words curso legal remain in the reformed Art. 1. What was removed is the obligation, not the status. "El Salvador stripped bitcoin of legal-tender status" overstates the instrument and must not be written.

Brazil, separately from Drex, has an enacted virtual-asset statute and central-bank rules under it — and those rules have now been read. This paragraph previously listed them as "Lei 14.478/2022 and BCB Resolutions 520, 521 and 584" on an agent's report, with the instruction to cite the numbers and never their substance. Two corrections and one upgrade. The correction: the trio is 519, 520 and 521, all of 10 November 2025; Resolução BCB nº 584 of 7 August 2026 is a payment-fraud amendment to Resolução 142/2021 and does not belong in this list. The upgrade: the substance may now be cited, because the instruments were read at the BCB's own normative pages on 2026-09-07.

[SOURCE: BCB normative pages for Resoluções 519, 520, 521, 561 and 584, and the BCB note BC faz enquadramento prudencial para sociedades prestadoras de serviços de ativos virtuais of 1 July 2026, all read with a headless browser on 2026-09-07; the pages are JS-rendered. Lei 14.478/2022 and Decreto 11.563/2023 are named in every one of those preambles, which establishes their existence, date and role — their own texts were not read and their substance is still not cited.]

The contrast the Dominican consultation will want in front of it is now sharper than "the same central bank pilots tokenised money and supervises virtual-asset service providers". It is this: permission in Brazil is institution-specific, activity-specific and rail-specific. Being a regulated provider is not a flag; it is a segment, an authorisation, and a list of what that authorisation does not reach.

Mexico, Chile and Colombia complete the pattern. These three were verified by a research agent against the primary URLs named below and were not re-fetched in this session; that provenance is stated rather than hidden.

The regional comparison, with the unverified cells saying so

Four questions, seven jurisdictions and two reference regimes. A cell carries a claim only if a primary text was read for it; every other cell says what is missing and why, because a comparison table is exactly the artefact in which an unmarked guess becomes a fact. The two reference regimes are included because they are what the extension's profiles (§5.2) encode.

JurisdictionMay a regulated bank / e-money issuer touch virtual assets?Is stablecoin issuance licensed?Tokenised deposits or a wholesale central-bank token piloted?Verified from
Dominican RepublicNo, for eight named provider populations. Seven payment-provider categories may not "ofrecer productos ni servicios basados en activos virtuales" (Arts. 11 v, 17 w, 31 t, 33 l, 35 p, 37 j, 39 l); securities intermediaries "no podrán invertir ni realizar actividades de intermediación con activos virtuales" (SIMV Circular 04/23, point IV, citing Art. 121 of the Reglamento para los Intermediarios de Valores); and the Central Bank states that regulated institutions "no están autorizadas para usar ni efectuar operaciones con los mismos dentro del Sistema de Pagos". The payment-gateway provider has no obligations article and so is not reached by the payment-system prohibition — an omission whose deliberateness is consultation question 1.No regime, and the securities regulator says so in terms: "no existen regulaciones oficiales en la República Dominicana para la oferta o promoción de activos virtuales o criptoactivos u otros activos similares, o de unidades de valor denominadas «tókenes»".No. The SGPI is account-based fiat in the Governor's own account of it; the Bank has published retail-CBDC research with an express statement that it implies no decision to issue, and nothing on tokenised deposits or a wholesale token.Reglamento (28 Aug 2025); SIMV Circular 04/23 (9 Mar 2023); BCRD communiqué (30 Sep 2021); BCRD DT 2025-01; BCRD II Foro page (5 May 2026)
BrazilYes, but never as a blanket permission. Authorisation under Res. 519, activity rules under Res. 520, FX treatment under Res. 521, prudential classification as Tipo 3 with requirements from 1 Jan 2027 and S4 status until 30 Jun 2028 — and S5 institutions barred outright (Res. 580). Virtual assets are separately barred from eFX settlement from 1 Oct 2026 (Res. 561).Not an issuer licence — but the object is regulated. Res. 520 defines the fiat-referenced virtual asset, confines its reserve to fiat and same-government securities, requires proof of reserves and client-fund segregation, and forbids offering algorithmically-controlled stablecoins.Yes — Drex, on the BCB's own pages: a test platform where "transações com ativos digitais são simuladas", end users simulated, phases 1 and 2 closed. [REQUIRES VERIFICATION: any production launch date, and the reported 2025 reorientation from retail to wholesale, which appears on no BCB page reached.]BCB Res. 519, 520, 521, 561, 584 and the prudential note of 1 Jul 2026; BCB Piloto Drex and Drex – Real Digital pages
MexicoInternal operations only. Circular 4/2019 excludes from authorisation any direct provision to clients of "servicios de intercambio, transmisión o custodia de activos virtuales", on the stated rationale of "mantener una sana distancia entre los activos virtuales y el sistema financiero".No regime verified.No pilot verified.Ley Fintech Art. 30 (DOF, 9 Mar 2018); Banxico Circular 4/2019 · [REQUIRES VERIFICATION: the consolidated state of Circular 4/2019 after Circular 37/2020.]
ColombiaNo. SFC concepto 2020259314-001: the rules "no autorizan a las entidades vigiladas… para invertir, custodiar, intermediar, ni operar con criptoactivos". One closed pilot allowed banks to supply the fiat edge only: "se les permitió a las plataformas ofrecer la compraventa de criptoactivos y su almacenamiento en billeteras digitales… sin que estos activos entraran al sistema financiero colombiano", seven alliances, ended 13 June 2024.No regime verified.No pilot verified.SFC concepto (18 Dec 2020); SFC laArenera closing balance (27 Jun 2024) · [REQUIRES VERIFICATION: the fate of Proyecto de Ley 139 de 2021.]
ChileYes, through a definitional chain and a register. A cryptoasset is an activo financiero virtual, which is an instrumento financiero, which brings the Art. 2 services into the CMF's Registro de Prestadores de Servicios Financieros (Ley 21.521, Arts. 2, 3, 5). NCG 502 then imposes a 100% capital requirement on cryptoasset positions (0.65 partial offset for a CMF-listed Type A asset).No distinct issuer licence verified; a token is classified and then routed to whichever licensed service reaches it.[REQUIRES VERIFICATION.] The Banco Central de Chile is reported to run a CBDC proof of concept tokenising a financial instrument; its pages returned no content to an automated client and nothing may be said about it until read.Ley 21.521 (BCN); CMF NCG 502 (12 Jan 2024)
Peru[REQUIRES VERIFICATION.] An AML/CFT perimeter for PSAV exists under Resolución SBS N° 02648-2024, but the norm was not read and an AML regime is not a product permission. No banking-permission source was read.No regime verified.Retail, not wholesale. The BCRP's first digital-money innovation pilot with Bitel, under Circular 0011-2024-BCRP, one calendar year, for the unbanked without internet. [REQUIRES VERIFICATION: any user count.]El Peruano dispositivo listing (1 Aug 2024); BCRP Proyecto CBDC and pilot pages
El SalvadorAcceptance is voluntary since 29 January 2025, and only "personas naturales, o jurídicas con total participación privada" may accept bitcoin; the State's monetary obligations are payable in the currency contracted; Arts. 4, 8 and 9 of the Ley Bitcoin were derogated. The words curso legal survive the reform, so "stripped of legal-tender status" overstates it.Not a stablecoin-issuance regime.No.Decretos Legislativos N° 57 (2021) and N° 199 (2025), read in full
Panama · Costa Rica · Guatemala · Honduras · CMCA / SIPA[REQUIRES VERIFICATION — deliberately empty.] The only primary-sourced statement is GAFILAT's August 2023 survey that Costa Rica, Guatemala, Honduras, Panama, Peru, the Dominican Republic and Uruguay "no han emitido regulación de AV y PSAV". Nothing later; nothing at all on the regional councils.GAFILAT guide ¶124 (Aug 2023)
EU (reference profile)Credit and e-money institutions may issue e-money tokens; crypto-asset service providers are authorised.Yes — the EMT and ART regimes, with redemption "at any time and at par value" and without fee, and a standing reserve of assets for ARTs.Outside MiCA.Regulation (EU) 2023/1114, Arts. 3(1)(6)–(7), 36(1), 49(2)(4)(6)
United States (reference profile)— (not a question the Act answers directly)Yes — the permitted payment stablecoin issuer, with reserves "on an at least 1 to 1 basis" and a flat prohibition on paying holders "any form of interest or yield".Public Law 119-27, Secs. 4(a)(1)(A), 4(a)(11)

What the table is for, and what it is not. It is the answer to "what does everyone else do", which is the first question a Dominican supervisor, bank or university asks, and it is the reason the extension's profiles are profiles rather than rules. It is not an argument that the Dominican position is behind: the two jurisdictions with the most developed frameworks, Brazil and Chile, both arrived at prohibitions of their own — Brazil's on a payment rail and on a prudential segment, Chile's through a 100% capital charge that prices the activity out of most balance sheets. In this region the enacted instruments are perimeter-and-prohibition instruments, and the Dominican Arts. 11 v through 39 l are recognisably of the same family.

On stablecoin remittances into Latin America, the honest answer is that we have no institutional figure and will not invent one. No verified figure was obtained for the stablecoin share of remittances into the region or into any of its corridors. That absence is itself evidenced rather than assumed: a central-bank survey run by CEMLA asked its respondents for a high / medium / low estimate in the absence of statistical information. [REQUIRES VERIFICATION: the CEMLA survey's exact title, date and URL, which were reported to us without them.] What is available as a general anchor is the World Bank's Remittance Prices Worldwide global average for sending US$200 — 6.36% globally and 5.64% for Latin America and the Caribbean in Q3 2025 [SOURCE: reported by a research agent from Remittance Prices Worldwide, Q3 2025. A separate attempt to reach that host from this session was refused, so the figure is carried with its provenance stated; it is a global and regional average and is not a Dominican corridor figure.] — against the SDG target of 3%. Several figures circulate widely and none of them may appear in any Lab material: a "US$174bn LAC remittances 2025" total; "71% of Latin American institutions use stablecoins"; "US$324bn LAC stablecoin volume, up 89%"; "US$8.9bn saved on the US–LAC corridor"; and a claim that 2–3% of Mexico's remittances travel by crypto attributed to Banco de México, which must never be attributed to it. A "Migration and Development Brief 41" does not exist; the series ends at No. 40. Write this use case directionally — dollar stablecoins are used in remittance corridors, we do not know how much, and the Lab's interest is in the rails and the refusals rather than in the volumes.


2. What already maps

Four pieces of the ecosystem already carry, under Dominican law and with Dominican citations, most of what a tokenised-money layer would need. Naming them precisely is the difference between an extension and a new product.

2.1 The electronic payment account is the closest lawful analogue of a fully reserved peso token

Article 19 gives the electronic payment account three properties, in one sentence: "Dichas cuentas reflejarán como balance el valor nominal recibido de parte de los usuarios y no generarán intereses. El titular podrá solicitar en cualquier momento la devolución de los fondos disponibles en la cuenta, sin penalidad alguna." [SOURCE: Reglamento, Art. 19] — the balance equals the nominal value received, it bears no interest, and the holder may demand the funds back at any moment without penalty.

Those three properties reappear, term for term, in the two payment-stablecoin regimes this document verified. Par value and redemption on demand are MiCA's Art. 49(4) — the issuer "shall redeem it, at any time and at par value", and the redemption "shall not be subject to a fee" (Art. 49(6)). The prohibition on yield is Sec. 4(a)(11) of the GENIUS Act, which bars an issuer from paying a holder "any form of interest or yield … solely in connection with the holding, use, or retention" of the stablecoin. [SOURCE: Regulation (EU) 2023/1114, Art. 49; Public Law 119-27, Sec. 4(a)(11) — both in §8.] [REQUIRES VERIFICATION: whether MiCA separately prohibits interest on e-money tokens; the article that would carry it was not read.] The Dominican regime arrived at the same three from a different direction — a payment account, not a bearer instrument — and Art. 19 predates both.

Four further articles complete the analogue, and each has a counterpart in the tokenised-money literature:

PropertyDominican articleWhat it says
Par value, no interest, redemption on demandArt. 19quoted above
Permitted operations, closed listArt. 20 a)–j)cash withdrawal, direct credit, direct debit, POS, ATM withdrawal, e-commerce, top-ups, bill payment, inbound remittances, social subsidies
Funding and balance cap over 30 calendar daysArt. 21RD$75,200 for natural persons in the 2025 text, three times that for natural persons with commercial activity, four times for legal persons, adjusted yearly by the Junta Monetaria by CPI — RD$79,000 in the 2026 values (plan §3.4)
Reserve of the floatArt. 22funds of accounts managed by an electronic-payment entity "deberán estar depositados en una cuenta corriente en el Banco Central a favor de dicha entidad o en valores emitidos por el Banco Central o el Ministerio de Hacienda, pignorados a modo de garantía a favor del Banco Central… Dichos fondos estarán separados del patrimonio de la entidad."
Wind-down and return of fundsArt. 25an entity ceasing the service must return the funds with at least thirty calendar days' notice

[SOURCE: Reglamento, Arts. 19, 20, 21, 22 and 25, each verified against the extracted text on 2026-09-06.]

Article 22 deserves to be stated on its own, because it is stronger than what most stablecoin regimes require and it is already law here: the float sits in a current account at the Central Bank in the entity's own favour, or in Central Bank or Ministerio de Hacienda securities pledged to the Central Bank, segregated from the entity's patrimony. There is no commercial-bank deposit option in the article and no percentage wording — a point the foundations ledger already recorded as a correction to an earlier reading (foundations.md, 8-08). A Dominican electronic-payment entity's float is central-bank money or sovereign paper. Whatever else is true about tokenised money here, the reserve question that occupies the rest of the world is, for this one instrument, already settled by the Reglamento and settled tightly.

Where the analogue breaks, and it breaks in four places. An electronic payment account is an account, not a bearer instrument: the claim is against a named issuer, held in a ledger the issuer controls, and it does not travel to an address whose holder the issuer has never onboarded. It is peso-only"Las cuentas de pago electrónico serán emitidas y gestionadas en moneda nacional" (IN-36-024, p. 9 numeral 13). Its issuers are a closed set — financial-intermediation entities and electronic-payment entities, and no one else. And it is capped, which no token design assumes. A "fully reserved DOP token" is therefore not an electronic payment account; it is the thing an electronic payment account would become if three of its four defining constraints were removed. Saying so plainly is what keeps this section from becoming an argument that the regime already permits what it does not mention.

2.2 The dollar legs already have their counterparts

The ecosystem carries exchange-agent (the agente de cambio proper), remittance-agent (the agente de remesas y cambio) and sipa-counterpart as live actors, with the FX rule family 80-fx.yaml behind them: no correspondent needed for a dollar transfer through Pagos al Instante, conversion by the originating institution, the conversion recorded, the exchange agent's two-sided quoted rate, its counter threshold, and its report to the Central Bank. Art. 20 Párrafo I already routes an inbound remittance into an electronic payment account in national currency, at the rate agreed in the country of origin, reported as a purchase of foreign currency under the Reglamento Cambiario, and requires the electronic-payment entity to hold an agreement with a financial-intermediation entity or an exchange agent and a remittance-and-exchange agent to do it [SOURCE: Reglamento, Art. 20 Párrafo I].

The counterparty is a real, small and named population: the Central Bank's own register of exchange entities authorized by the Junta Monetaria, dated September 2026, lists six agentes de remesas y cambio among its authorizations [SOURCE: BCRD, Relación de agentes de cambio y agentes de remesas y cambio autorizados por la Junta Monetaria, September 2026, https://cdn.bancentral.gov.do/documents/estadisticas/mercado-cambiario/documents/lista_agentes_cambio.pdf; count taken from the register's own numbered rows.] — noting that commercial banks also pay remittances and are not on that register, so six is not the number of payout channels. The role itself is defined by the Reglamento Cambiario as "personas jurídicas… debidamente autorizadas por la Junta Monetaria, para realizar intermediación cambiaria, así como recibir y/o enviar órdenes de pago (transferencias) desde o hacia el exterior en calidad de remesas" [SOURCE: BCRD, Reglamento Cambiario, disposiciones generales, https://cdn.bancentral.gov.do/documents/normativa/documents/normas_vigentes/monetarios/Reglamento_Cambiario_Disposiciones_Generales.pdf]. [REQUIRES VERIFICATION: the enacted text of the November 2025 modification to the Reglamento Cambiario. Only the July 2025 public-consultation draft was retrieved, and a draft is not a norm.]

This is the single most important mapping in the document. A dollar-stablecoin remittance leg does not need a new process in the ecosystem; it needs a new instrument on an existing process. The origination, the rate, the conversion, the crediting, the foreign-exchange report and the cap all exist and all cite articles. What is new is the rail between the sender abroad and the Dominican payout, and a USDL leg can be run against exactly the same downstream rules as a SIPA leg or a traditional remittance leg — which is what makes the comparison scenario in §4 worth building.

2.3 The financial-intelligence surface exists

The simulated UAF, the monitoring unit and the CEMI Cumplimiento plug are live; 90-aml.yaml runs over the records that Arts. 41–44 make available and retainable for ten years. A freeze on a request from the simulated UAF, a suspicious-transaction report on a token flow, and a refusal for missing originator or beneficiary information are all behaviours the existing actors already have — what changes is the object they act on.

2.4 What does not map at all

Custody of a bearer asset on behalf of a client; an address that is not an account; a ledger no single simulated institution owns; an issuer that is neither a financial-intermediation entity nor an electronic-payment entity; an asset denominated in a foreign currency held by a Dominican resident outside the exchange-agent perimeter; and settlement finality on something other than the LBTR. Each of these is a genuinely new object, and each is why §3 proposes counterparts rather than fields on existing ones.


3. The proposed counterparts

Every one of these carries an invented Lab name and the constant LAB_NOTICE, exactly as the twenty-five existing actors do: "Simulated counterpart operated by the CEMI Financial Innovation Lab. Not a real institution, not endorsed by the entity it is modelled after, and not an ambiente de prueba under Art. 83." The "modelled after" column names the kind of thing whose role is played, and is never a claim of identity, affiliation or endorsement.

Lab nameProposed roleModelled afterSits whereStatus
Libro Distribuido del Labdistributed-ledgera permissioned distributed ledger operated by a consortiumthe instruments row, beside the instrument engines — not inside the simulated SIPARDproposed
Emisor de Moneda Estable del Lab (token DOPL)stablecoin-issuera single-currency, fully reserved payment-token issuerentities that operate instrumentsproposed
Emisor Externo del Lab (token USDL)foreign-token-issueran offshore dollar payment-token issuer, outside any Dominican perimeteroutside the ecosystem's own perimeter, reachable only across the ledgerproposed
Proveedor de Servicios de Activos Virtuales del Lab (PSAV del Lab)vaspan exchange with custody and fiat on/off rampsentities that operate instrumentsproposed
Depósito Tokenizado de Banco Nortea capability of the existing bank actor, not a new actora tokenised commercial-bank depositinside the simulated bankproposed
Ficha Mayorista del Labwholesale-tokena wholesale settlement token on the same ledgerwhat-if worlds onlyproposed · what-if

3.1 Libro Distribuido del Lab — a settlement system that is not one of the SIPARD's

A permissioned ledger with a named membership: each simulated institution that holds tokens holds a node, transactions are ordered into blocks, and a transfer is final on the ledger when the block carrying it is committed. What the ledger is not is more important than what it is.

It is not one of the systems that make up the SIPARD. The SIPARD is a public service of the Central Bank's exclusive ownership, its component systems are enumerated on the Central Bank's own page, and the Reglamento makes the Central Bank the administrator of the instant-payments system with that administration expressly non-delegable (Art. 62) [SOURCE: plan §3.2 and its cited BCRD pages; Reglamento Arts. 60–62]. Putting a Lab ledger inside the simulated SIPARD would model a legal relationship that does not exist. It therefore sits on the instruments row of the Central Bank's own Elementos de un sistema de pago diagram, as a rail an instrument can travel over, and it is drawn on the ecosystem map outside the SIPARD box, with the edges into it marked as what they are.

The consequence is a design constraint the ecosystem must enforce rather than describe: finality on the Lab ledger is not settlement finality in the LBTR. Principle 8 of the PFMI requires an FMI to define the point at which settlement is final, and the LBTR's own rule is that an order is irrevocable once settled and revocable only while queued (plan §3.5). A block commit on the Lab ledger is a different event, with a different legal weight — which is to say, in this simulation, none. Every scenario that crosses from one to the other must show the crossing, and the rule LEDGER.COMMIT_IS_NOT_LBTR_FINALITY exists to make a run that blurs them fail.

Fault modes it must have from the first day, because they are what a team actually needs to rehearse: an outage of the whole ledger; a single node partitioned from the rest; a block reordering; a transaction that is accepted, then not included; and a validator that is slow rather than absent. The existing chaos mode already has the shape for this (130-resilience.yaml), and a ledger is the cleanest possible subject for it.

3.2 Emisor de Moneda Estable del Lab — a peso token with a reserve at a simulated bank

A single-currency issuer with the smallest possible surface: mint, burn, transfer, freeze, unfreeze, and an attestation endpoint that publishes what the reserve holds and when it was last checked. The reserve is a real balance at a simulated bank inside the ecosystem — not a number in the issuer's own configuration — so that a run can break the reserve without the issuer's cooperation and the depeg scenario in §4 becomes a genuine test rather than a story.

Four Lab controls define it, and not one of them cites a Dominican article, because none exists:

The first three are deliberately the three properties Art. 19 gives an electronic payment account (§2.1), stated as Lab controls rather than as Dominican rules, so that the comparison between the two is visible in the report instead of asserted in prose. The fourth has no Dominican analogue at all and is drawn from the reference profiles in §5.

Where the reserve sits is a Lab decision and must be declared as one. Art. 22 puts an electronic-payment entity's float at the Central Bank or in sovereign securities pledged to it. A token issuer is not an electronic-payment entity and Art. 22 does not reach it; a reserve at a simulated commercial bank is what the international profiles describe, and it is what we model. The gap between the two is one of the questions for the Bank (§6), and until it is answered the reserve's location is assumption-backed, not article-backed.

3.3 Emisor Externo del Lab and the token USDL — a foreign asset, deliberately

USDL is modelled as a foreign asset held outside the ecosystem's perimeter, not as an instrument any Dominican simulated provider issues. That is the honest shape for the remittance case: the sending side is abroad, the token is issued abroad, and what the Dominican side does with it is receive, refuse, convert or report. The issuer actor exists so that the token has a provenance and an attestation state a compliance actor can interrogate — and so that the "unattested foreign token" scenario in §4 has something to be unattested about.

By default the external issuer publishes no attestation. A run that wants an attested one turns it on. The asymmetry is the point: the interesting Dominican behaviour is the refusal, and a refusal is only interesting when accepting was possible.

3.4 PSAV del Lab — the exchange, the custody and the ramps

A virtual-asset service provider with four functions: exchange between tokens, exchange between a token and fiat, custody of a client's tokens, and the on and off ramps to the rest of the ecosystem — which in practice means an electronic payment account at the simulated electronic-payment entity, or a deposit account at a simulated bank.

It is the actor where the travel rule lives. A transfer that leaves the PSAV for another provider must carry originator and beneficiary information; one that arrives without it must be refused, quarantined or returned, and the choice among those three is itself a parameter a run declares. It is also the actor where the unhosted address problem appears: a transfer to an address with no provider behind it is a different object from a transfer to another provider's client, and a run must be able to show which one it made.

Whether such a provider would be an obligated subject under Ley 155-17 is not something this document may answer. Art. 43 reaches "payment-service providers and SIPARD participants", and a PSAV is neither under the Reglamento's own taxonomy. The question goes to the Bank (§6) and, in the meantime, the PSAV's AML behaviour in the ecosystem is a Lab control drawn from a reference profile, flagged as such on every finding it produces.

3.5 Tokenised deposits — a capability of a bank, not a new institution

A tokenised deposit is a claim on a specific commercial bank, transferable on the ledger, and redeemable one-for-one at that bank. Modelling it as a capability of the existing bank actor rather than as a new actor is the whole design argument: it is the same liability, on a different rail. The simulated bank that issues it is the same simulated bank that holds the deposit, subject to the same balances, the same records and the same settlement in the LBTR.

That makes one scenario worth more than the rest of this section put together: atomic settlement of a tokenised-deposit transfer against the LBTR. Two simulated banks, one payment, and the question of whether the token leg and the interbank leg either both happen or neither does. It is the cleanest illustration in the ecosystem of why finality is a state transition and not a message, and it is the scenario a bank's payments team will want to see first.

3.6 Ficha Mayorista del Lab — the what-if, cut on 2026-09-07

A wholesale settlement token on the same ledger, held only by simulated direct participants, was proposed here as a what-if behind three guards. Carlos cut it on 2026-09-07 (§7.4, decision 4). Not because the guards were weak: because the Bank has published its own exploration of central-bank digital currency — Documento de Trabajo 2025-01, on a retail CBDC, expressly implying no decision to issue (§1.2) — and on this subject the Lab follows the Bank rather than anticipates it. The Lab will simulate a wholesale token the day the Bank asks for it, from the Bank's own design, and not before. Until then, no Lab material may cite DT 2025-01, or the Bank's CBDC research programme, as evidence that the Bank has studied, contemplated or would welcome a wholesale settlement token; the matter is put to the Bank as a question, in §6.2 question 5, and never as a suggestion.


4. The rails and the processes, as scenarios

Twelve scenarios. Each is a YAML file in the existing scenario format — actors, a synthetic population, a seeded clock, ordered steps, expected states, and cites naming the rules it claims to exercise, which the report then checks. The first one is the only one in the set that cites a Dominican article, and it is deliberately first.

#ScenarioWhat it provesRules it cites
0The provider that must refuse — a simulated electronic-payment entity, wallet provider and initiation provider are each asked to offer a product based on a virtual asset, and each must refuse, citing its own articlethat the ecosystem models the Dominican rule as it actually is: a prohibition on seven named provider categoriesVA.PROVIDER_OFFERS_NO_VIRTUAL_ASSET_PRODUCT (Arts. 11 v, 17 w, 31 t, 33 l, 35 p, 37 j, 39 l)
1On-ramp from an electronic payment account — a holder funds a PSAV position from an electronic payment account and receives DOPLthat the cap, the permitted-operation vocabulary and the record survive the crossing into a tokenEPA. (existing), TOKEN.RESERVE_FULLY_BACKED, VASP.
2Peer-to-peer transferDOPL moves between two holders on the ledgerledger ordering, commit, and that a commit is not LBTR finalityLEDGER.COMMIT_IS_NOT_LBTR_FINALITY
3Merchant payment — a merchant is paid in DOPL against a QR built to the Lab's declared profile, and settles to its bank accountthat the token leg reuses the existing QR and acquiring lanes rather than forking themexisting QR and acquiring rules, plus TOKEN.*
4Redemption — a holder redeems DOPL at par into an electronic payment account, and the issuer burnspar redemption, the burn, and the reserve moving in stepTOKEN.REDEEM_AT_PAR_ON_DEMAND, TOKEN.RESERVE_FULLY_BACKED
5Remittance, two ways — the same inbound remittance is run twice from one seed: once over USDL into a PSAV and out to an electronic payment account, once over the existing SIPA and remittance-agent lanethe comparison scenario of the whole extension: same beneficiary, same amount, two rails, two reports side by sideexisting 80-fx.yaml and remittance rules on both runs; VASP. and TOKEN. on one
6Atomic tokenised-deposit settlement — a tokenised deposit moves between two simulated banks and the interbank leg settles in the LBTR, both legs or neitherthat finality is a state transition; the failure variant leaves neither leg standingTOKDEP.ATOMIC_SETTLEMENT_AGAINST_LBTR, existing 20-lbtr.yaml finality rules
7Depeg and reserve shortfall — the reserve balance at the simulated bank is reduced without the issuer's cooperation, redemptions queue, and the attestation goes stalethat the reserve is a real balance and not a number the issuer reports about itselfTOKEN.RESERVE_FULLY_BACKED (fails), TOKEN.ATTESTATION_CURRENT (fails), TOKEN.REDEEM_AT_PAR_ON_DEMAND
8Freeze on a request from the simulated UAF — a case in the simulated financial-intelligence unit produces a freeze request, the issuer freezes an address, and the record shows who asked and whenthat a token with a freeze function is a different compliance object from one withoutTOKEN.FREEZE_ON_AUTHORITY_REQUEST, existing 90-aml.yaml
9Travel-rule refusal — an inbound transfer arrives at the PSAV without the required originator or beneficiary information and is refusedthat the refusal is a first-class outcome with a record, not an errorVASP.TRAVEL_RULE_DATA_PRESENT (Lab control, fatf-r15-16 profile)
10Ledger outage — the ledger is unavailable mid-flow; in-flight transfers, the merchant's till and the redemption queue must all degrade wellthe chaos mode applied to the newest and least proven rail130-resilience.yaml, LEDGER.*
11The unattested foreign tokenUSDL arrives from an issuer publishing no attestation, and the compliance actor refuses itthat provenance is checkable and that refusing is the default when it is notVASP.UNATTESTED_TOKEN_REFUSED, existing compliance rules

Two disciplines across all twelve. First, every scenario has a negative control, as the adversarial scenarios already do (A-53): a run in which the thing that must be refused is instead correctly accepted, so that a rule that always fails is caught. Second, scenario 5 is run from one seed and reported as one comparison, in the shape the SLA profiles already use — the report says on its face that a profile run is a comparison and nothing else, and the same header discipline applies here.


5. The rules

Three tiers, and the boundary between them is the whole ethical content of this proposal.

5.1 The Dominican tier — one family, seven articles, and it is the only one that cites Dominican law

rules/200-virtual-assets.yaml, one family, catalogued exactly like every other rule with article, instrument, resolution, resolutionDate and effectiveDate, so the loader accepts it and every finding it produces prints its citation.

RuleCheckArticleSeverity
VA.PROVIDER_OFFERS_NO_VIRTUAL_ASSET_PRODUCTmust_be_false on a simulated provider of any of the seven categories offering a product or service based on a virtual assetArts. 11 v, 17 w, 31 t, 33 l, 35 p, 37 j, 39 lcritical
VA.DEFINITION_EXCLUDES_LEGAL_TENDER_AND_CURRENCYa payload classified as a virtual asset must not be legal tender or foreign currencyArt. 4 a)major

Both carry resolution: Segunda Resolución de la Junta Monetaria and resolutionDate: "2025-08-28". Neither carries needsRecheck, because both come from the current Reglamento and not from a 2021 instructivo.

A third Dominican rule is now available, and it belongs to a different supervisor. (Added 2026-09-07.) SIMV Circular 04/23 of 9 March 2023 tells securities intermediaries they "no podrán invertir ni realizar actividades de intermediación con activos virtuales, aún si tales instrumentos son reconocidos como valores en otras jurisdicciones", citing Art. 121 of the Reglamento para los Intermediarios de Valores. It has everything the loader requires — an instrument, an article, an issuing body and a date — but it is not the Reglamento de Sistemas de Pago and not the Junta Monetaria, and the ecosystem does not currently model a securities intermediary as an actor. Two consequences. It enters the catalogue only if a securities-intermediary counterpart is built, and if it does it enters as its own family with instrument: Circular SIMV 04/23 — never merged into the VA. family, because a report must never show a payment-system finding citing a securities regulator. And it is already useful without entering the catalogue at all: it is the answer to the question a reader of the report will ask about the seven articles — is that the whole of it?* — and the answer is no. [REQUIRES VERIFICATION before it becomes a rule: the text of Art. 121 itself, which the circular quotes the effect of but which was not opened.]

Nothing else in this document may enter rules/. The catalogue is the Reglamento made executable; a token rule in it would be a Dominican regulatory statement that does not exist.

5.2 The reference tier — three profiles, under their own jurisdictions' names

rules/profiles/ already carries seven foreign systems on exactly this logic, and its README states the governing sentence: "A run under a profile is a comparison and nothing else. It is not a statement about the Dominican system, and the report says so in its header, on every moved parameter, and in the comparison table."

One honest extension of the mechanism is needed. Today a profile overrides a catalogued Dominican parameter — Pix's forty seconds replacing the SGPI's ten. Here there is no Dominican parameter to override, because there is no Dominican rule. So these three profiles carry controls of their own rather than overrides, and the loader must be taught the difference: a control-bearing profile declares kind: reference, its controls never merge into the Dominican catalogue, and a finding produced by one prints the foreign instrument's name in the place where a Dominican finding prints its article. A reader of a report can therefore never mistake one for the other, which is the only property that matters.

mica.yaml — Regulation (EU) 2023/1114. [SOURCE: Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, OJ L 150/40, 9 June 2023.] It supplies the two definitions the ecosystem needs to tell a peso token from a basket token — "'electronic money token' or 'e-money token' means a type of crypto-asset that purports to maintain a stable value by referencing the value of one official currency" (Art. 3(1)(7)) and "'asset-referenced token' means a type of crypto-asset that is not an electronic money token and that purports to maintain a stable value by referencing another value or right or a combination thereof, including one or more official currencies" (Art. 3(1)(6)) — and the redemption control: "Upon request by a holder of an e-money token, the issuer of that e-money token shall redeem it, at any time and at par value", with redemption "not… subject to a fee" (Art. 49(4) and 49(6)), the holder having "a claim against the issuers" (Art. 49(2)). The asset-referenced-token reserve obligation is Art. 36(1): "Issuers of asset-referenced tokens shall constitute and at all times maintain a reserve of assets."

genius.yaml — the GENIUS Act. [SOURCE: Guiding and Establishing National Innovation for U.S. Stablecoins Act, S. 1582, 119th Congress, Public Law 119-27, enacted 18 July 2025, 139 Stat. 419; enrolled text on govinfo.gov.] Two controls, and one correction to how it is usually described. The reserve requirement at Sec. 4(a)(1)(A) is to "maintain identifiable reserves backing the outstanding payment stablecoins of the permitted payment stablecoin issuer on an at least 1 to 1 basis""at least 1 to 1" is a floor, not an exact ratio, and the profile must encode it as a floor. The permitted reserve assets named in the clauses read include US coins and currency or money credited to an account at a Federal Reserve Bank, demand deposits or insured shares at an insured depository institution, Treasury bills, notes or bonds with 93 days or less remaining, and overnight repurchase and reverse-repurchase agreements collateralised by such Treasuries. [REQUIRES VERIFICATION: the reserve-asset clauses beyond the fifth, which were not read; money-market funds and central-bank reserve deposits appear in later clauses and must be read before being encoded.] The yield prohibition at Sec. 4(a)(11) is the sharpest single sentence in the whole reference set: "No permitted payment stablecoin issuer or foreign payment stablecoin issuer shall pay the holder of any payment stablecoin any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin."

fatf-r15-16.yaml — the FATF Recommendations. [SOURCE: FATF, International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation — The FATF Recommendations, updated October 2025.] Three things it supplies, and one of them is a correction the Lab must absorb before it writes a line of copy.

Three companion documents inform the profiles without becoming controls of their own, because their addressees are authorities rather than participants: the FATF's Updated Guidance for a Risk-Based Approach — Virtual Assets and Virtual Asset Service Providers of October 2021, which carries FATF's own standing caveat that it "does not reflect revisions to the FATF standards made after its date of publication, including the 2025 revisions to Recommendation 1"; CPMI-IOSCO's Application of the Principles for Financial Market Infrastructures to stablecoin arrangements (BIS paper d206, July 2022); and the FSB's two sets of high-level recommendations of 17 July 2023. The CPMI-IOSCO finding is the one that decides where the Lab ledger sits on the map (§3.1): a stablecoin arrangement performing the transfer function "is considered an FMI for the purpose of applying the PFMI and, if determined by relevant authorities to be systemically important, the SA as a whole would be expected to observe all relevant principles in the PFMI", and its Principle 8 expectation is to "clearly define the point at which a transfer of a stablecoin through the operational method used becomes irrevocable and unconditional". That is the sentence behind LEDGER.COMMIT_IS_NOT_LBTR_FINALITY. The FSB's redemption recommendation supplies the same discipline from the other direction: authorities should require that arrangements "provide a robust legal claim to all users against the issuer and/or underlying reserve assets and guarantee timely redemption", and "For GSCs referenced to a single fiat currency, redemption should be at par into fiat."

Two data standards, carried as formats and not as controls. The originator and beneficiary payload uses IVMS 101 — an industry standard maintained by the Interoperability Standards Working Group under GBBC Digital Finance, described by its own publisher as "the universal common language for communication of required originator and beneficiary information between VASPs", current as IVMS 101.2023 with an update released 4 June 2024 [SOURCE: https://www.intervasp.org/] — and never as an ISO or FATF standard, which it is not. The token interface is ERC-20 / EIP-20, status Final, created 19 November 2015, authors Fabian Vogelsteller and Vitalik Buterin, whose abstract states it "allows for the implementation of a standard API for tokens within smart contracts" with totalSupply, balanceOf, transfer, transferFrom, approve and allowance [SOURCE: https://eips.ethereum.org/EIPS/eip-20]. A token in the ecosystem presents that interface because it is the de-facto one, exactly as the card lane speaks ISO 8583 — the format is real; the institutions are the Lab's.

On ISO 20022 and tokenised assets: we assert nothing. No published ISO 20022 message set, business justification or deliverable specific to tokenised assets was retrieved from a primary page. [REQUIRES VERIFICATION: any ISO 20022 work on digital tokens, by name, number and date, read off iso20022.org itself.] What is verified is the adjacent identifier standard: ISO 24165-1:2025 and ISO 24165-2:2025, Digital token identifier (DTI), both second editions published in 2025, whose own committee describes the registry as affirming "only the existence of a digital token, creating a 1:1 relationship between a digital token and its identifier" and states explicitly that inclusion "does not warranty (or even mention) the features, functions, legal status, suitability for investment, or regulatory status of a digital token" [SOURCE: ISO catalogue entries 85546 and 85547; ISO/TC 68 committee page.] That last sentence is a gift to this Lab and the profiles should quote it: an identifier is not a judgement, which is precisely the posture a simulator must keep.

5.2.1 The parameters that now carry a cited value — the build list

Added 2026-09-07 from the verified second research round. A reference profile's discipline is that every value carries the id of the verified entry it came from, and a value the verification could not establish is recorded in notVerified and carries no number. Until this round, the three profiles could state rules but almost no numbers: MiCA's redemption obligation has no figure in it, and the GENIUS Act's only figures are a ratio floor and a maturity. These are the parameters that can now be written with a value and a source. Everything not on this list stays a Lab control or stays out.

ProfileParameterValueSource (bibliography id)
fatf-r15-16Travel-rule de minimis threshold, wire transfersUSD/EUR 1,000 ("no higher than" — a ceiling on the threshold, not a threshold)11-12 (INR.16 ¶9)
fatf-r15-16Occasional-transaction CDD threshold for a virtual-asset service providerUSD/EUR 1,00011-12 (INR.15 ¶7(a))
fatf-r15-16Required originator/beneficiary elementsfive: names of originator and beneficiary; account numbers where an account is used; originator's address and beneficiary's country and town; originator's date of birth for a natural person; for a legal person a BIC, an LEI or a unique official identifier — a disjunction, never a mandatory LEI11-12 (INR.16 ¶9)
fatf-r15-16International implementation state, for the report's comparison headeras of April 2026, across 149 assessed jurisdictions: 34% largely compliant with R.15, 43% partially, 22% not, one fully; 83% of 2026 survey respondents have passed Travel Rule legislation11-39
geniusReserve ratioat least 1 to 1 — a floor, not an exact ratio11-21 (Sec. 4(a)(1)(A))
geniusPermitted reserve maturity, Treasuries93 days or less remaining11-21 · [REQUIRES VERIFICATION: the reserve-asset clauses beyond the fifth.]
geniusYield to holderprohibited outright, in cash, tokens or other consideration, solely in connection with holding, use or retention11-21 (Sec. 4(a)(11))
micaRedemptionat any time, at par value, without fee, against a claim on the issuer11-20 (Arts. 49(2), (4), (6))
micaAsset-referenced token reserveconstituted and maintained at all times (no ratio stated in Art. 36(1))11-20
bcb-vasp (new, proposed)Stablecoin reserve-asset allowlistfiat currency and the government securities issued by the same governments that issue those currencies — and nothing else11-42 (Res. 520, Art. 2 III)
bcb-vasp (new, proposed)Algorithmic stabilisationprohibited from being offered by a provider operating in the country11-42 (Res. 520, Art. 31 §3)
bcb-vasp (new, proposed)Client-fund segregationown funds held separately from clients', through payment or deposit accounts individualised in each client's name11-42 (Res. 520, Art. 28)
bcb-vasp (new, proposed)Prudential classification and commencementTipo 3 under Res. 436/2024; prudential requirements from 1 January 2027; Segment 4 until 30 June 2028 regardless of size; Segment 5 institutions barred from providing the services at all11-42 (Res. 580 and the BCB note of 1 Jul 2026)
bcb-vasp (new, proposed)Rail exclusionvirtual assets barred from eFX international payment/transfer settlement, in force 1 October 202611-42 (Res. 561)
cmf-fintec (new, proposed)Capital requirement on cryptoasset positions100% — on the net position of a CMF-listed Type A asset, on the gross position of a Type B asset11-43 (NCG 502 §D.4)
cmf-fintec (new, proposed)Partial-offset coefficient, Type A only0.65 applied to the smaller of the long and short legs11-43 (NCG 502 §D.4)
cmf-fintec (new, proposed)Admission to quotationa public technical specification stating what is represented digitally, what rights the acquirer obtains and against whom11-43 (NCG 502)

Two consequences for the build. First, TOKEN.RESERVE_FULLY_BACKED and TOKEN.NO_YIELD_TO_HOLDER currently rest on two reference regimes; they now rest on three, and the third is a Latin American central bank's own text, which is the one a Dominican reader will find most legible. Second, the two proposed profiles change decision 6 in §7, which recommended three profiles and no fourth: see the annotation there.

5.3 The Lab tier — controls that cite an assumption, never an article

Everything in §3 that is not covered above is a Lab control: it carries no Dominican article, its source names the numbered assumption it rests on, and every finding it produces says so. The proposed set, with the assumption each would open:

ControlRests onWhat it asserts
LEDGER.PERMISSIONED_MEMBERSHIPA-56only declared members hold nodes and submit transactions
LEDGER.COMMIT_IS_NOT_LBTR_FINALITYA-56a block commit is not settlement finality; a run that treats them as one fails
TOKEN.RESERVE_FULLY_BACKEDA-58tokens outstanding never exceed the reserve balance held at the simulated bank
TOKEN.REDEEM_AT_PAR_ON_DEMANDA-57redemption at nominal value, without penalty, inside the declared window
TOKEN.NO_YIELD_TO_HOLDERA-57no interest or reward is credited for holding
TOKEN.ATTESTATION_CURRENTA-58an attestation older than the declared interval makes a new mint fail
TOKEN.FREEZE_ON_AUTHORITY_REQUESTA-59a freeze exists, is recorded with who asked and when, and is reversible
VASP.TRAVEL_RULE_DATA_PRESENTA-59the five INR.16 ¶9 elements travel with the transfer, in IVMS 101 shape
VASP.UNATTESTED_TOKEN_REFUSEDA-59provenance is checked and refusal is the default when it is absent
TOKDEP.ISSUER_IS_THE_DEPOSIT_TAKERA-60a tokenised deposit is a claim on the bank that holds the deposit, and on no one else
TOKDEP.ATOMIC_SETTLEMENT_AGAINST_LBTRA-60both legs or neither
WHOLESALE.WHAT_IF_ONLYA-60the wholesale token cannot exist outside a world declared as a what-if

The assumption ids A-56 to A-60 are reserved, not registered: they enter assumptions.md only if the layer is approved.

5.4 The notice every payload must carry

Every actor in the ecosystem already carries LAB_NOTICE: "Simulated counterpart operated by the CEMI Financial Innovation Lab. Not a real institution, not endorsed by the entity it is modelled after, and not an ambiente de prueba under Art. 83." For this layer that is necessary and not sufficient, because the risk here is not that a reader mistakes a Lab bank for a real one — it is that a reader mistakes a simulated token for something Dominican law permits.

So every payload of this layer carries a second notice, and it is the Central Bank's own stated position, reproduced rather than paraphrased. On the token object, on the ledger transaction, on the issuer's attestation, on the PSAV's transfer, in the report header and on every finding:

Aviso. Instrumento simulado. El Banco Central de la República Dominicana ha declarado públicamente que las criptomonedas y las monedas y activos virtuales «no cuentan con el respaldo de esta institución ni con la autorización de la Junta Monetaria para su emisión y utilización como medio de pago», que «no tienen curso legal ni fuerza liberatoria de obligaciones públicas o privadas en todo el territorio nacional», y que «las instituciones reguladas del sistema financiero nacional no están autorizadas para usar ni efectuar operaciones con los mismos dentro del Sistema de Pagos de la República Dominicana». El Reglamento de Sistemas de Pago prohíbe además a siete categorías de proveedores «ofrecer productos ni servicios basados en activos virtuales» (Artículos 11 v, 17 w, 31 t, 33 l, 35 p, 37 j y 39 l). Nada en esta simulación representa una actividad permitida en la República Dominicana.

(BCRD, comunicado de 30 de septiembre de 2021, que reitera el de 27 de junio de 2017; Reglamento de Sistemas de Pago, Segunda Resolución de la Junta Monetaria del 28 de agosto de 2025.)

Three properties make it a control rather than a disclaimer. It is a required field on the payload type, so a payload without it does not type-check. It is catalogued as LAB.VIRTUAL_ASSET_NOTICE_PRESENT, critical severity, so a run that strips it fails visibly. And it is quoted, not summarised — the Lab does not restate the Central Bank's position in its own words, in any language, on any surface.


6. Status on the map, and the questions for the Bank

6.1 A fourth status: «proposed»

The ecosystem map today carries three node statuses — NodeStatus = 'live' | 'planned' | 'awaiting-the-bank' in packages/actors/src/ecosystem-graph.ts — and the map's filter was rewritten on 2026-09-06 to show status and fidelity instead of development phases (gap A15). The three mean, respectively: built and running; declared and not yet connected (the floor machines, the regulator seats); and drawn on an assumption that is still open in the register, clearing itself when the assumption closes.

None of the three fits this layer, and the misfit is not pedantry. planned would say the Lab has decided to build it. awaiting-the-bank would say a Dominican rule is expected that would settle it — and no such rule is expected, because the Bank has published a prohibition and not a framework. The proposal is a fourth status, proposed: drawn on the map, visibly distinct, and meaning this layer exists as a written proposal, is not built, and is not asserted to be coming.

Three mechanical consequences, so that the status is real and not a colour:

The wholesale token is proposed and what-if — two orthogonal flags, because the second is about attribution and the first about existence.

6.2 The questions for the Bank

Six, appended to [bcrd-consultation-annex.md](bcrd-consultation-annex.md) as numbered items 15–20 in the annex's own Spanish and its own style, and to [gaps.md](gaps.md) §B as rows B12–B17. They are written to be answerable — a technical criterion is worth as much to us as a norm, and an answer that says "the prohibition means exactly what it says and there is nothing further" is a complete and useful answer that closes four of the six.

The sixth is new, added 2026-09-07, and it exists because the verification pass found a second Dominican prohibition (§1.2): SIMV Circular 04/23 bars securities intermediaries from investing in or intermediating virtual assets "aún si tales instrumentos son reconocidos como valores en otras jurisdicciones". That finding also sharpens questions 1 and 4 rather than replacing them, and the annex text for items 15 and 18 has been amended accordingly.

  1. The reach of the prohibition (Arts. 11 v, 17 w, 31 t, 33 l, 35 p, 37 j, 39 l). Does "no ofrecer productos ni servicios basados en activos virtuales" reach a provider that merely receives an instruction whose funding leg was a virtual asset abroad, or only one that offers the virtual-asset product itself? And is the absence of the prohibition from the payment-gateway provider's duties — the one recognised provider with no obligations article — deliberate?
  2. Does the electronic-payment-account regime extend to a token? An instrument with the three properties of Art. 19 — balance equal to nominal value received, no interest, refundable on demand — but recorded on a distributed ledger and transferable between holders: is it an electronic payment account under Arts. 19–25, an instrument outside the closed list of Art. 78, or a virtual asset under Art. 4 a)?
  3. May an electronic-payment entity issue one? If such an instrument were within the regime, would Art. 22 reach its reserve — the current account at the Central Bank or pledged Central Bank / Ministerio de Hacienda securities — and would the Art. 21 funding cap apply to it?
  4. Are virtual-asset service providers obligated subjects? Art. 43 extends the Ley 155-17 obligations to payment-service providers and SIPARD participants; a virtual-asset service provider is neither under the Reglamento's taxonomy. Is such a provider an obligated subject under Ley 155-17 and its reglamentos, and which supervisor would receive its records under Art. 44?
  5. Tokenised deposits and a wholesale token. Does the Bank hold a view on a deposit liability of a supervised financial-intermediation entity made transferable on a distributed ledger, and on the settlement of its interbank leg in the LBTR? And — asked as a question and never as a suggestion — does the Bank wish the Lab's simulation to represent a wholesale settlement token at all, or to omit it?
  6. Which regulator's refusal governs which object, and does either reach the other's population? (New, 2026-09-07.) Two Dominican prohibitions now sit side by side on different populations: the Reglamento's seven provider categories may not offer products or services based on virtual assets, and SIMV Circular 04/23 tells securities intermediaries they may not invest in or intermediate them, citing Art. 121 of the Reglamento para los Intermediarios de Valores, and drafts around a foreign characterisation — "aún si tales instrumentos son reconocidos como valores en otras jurisdicciones". A simulator must decide which branch a payload enters. Does an instrument that would be a valor under Ley 249-17 fall to the SIMV's regime rather than to the Reglamento's Art. 4 a), or to both? Does a financial-intermediation entity that is also a securities intermediary carry both duties at once? And is the Central Bank's view that the two prohibitions are cumulative, or that each is confined to the activity its own instrument regulates?

The annex's own closing discipline governs these as it governs the eleven before them: an answer replaces a Lab assumption with a founded parameter, the change is published in the rule catalogue with its version, a contradiction is implemented as a declared correction rather than a silent adjustment, and no answer from the Bank is ever presented as an endorsement, a certification or a regulatory conformity of the Lab, of a run or of a third party.


7. Decisions for Carlos, and what we build now

7.1 The decisions

Nine, in the order they have to be taken, because each of the later ones is void if an earlier one goes the other way.

  1. Does the layer exist at all? The recommendation is yes, as a written proposal with a proposed status on the map and nothing instantiable — and no more than that until the Bank answers. The alternative, which is defensible, is that a country whose rulebook prohibits seven provider categories from offering virtual-asset products is a country where a Lab should not model those products even in simulation. The counter-argument is that the prohibition itself is the most valuable thing to model.
  2. Do we publish the correction in §1.2? Our earlier reading — that the Reglamento says nothing about virtual assets — is wrong, and it has travelled: it is the premise of this document's own brief. The recommendation is that the correction is published, in this document, in foundations.md §4 as a fifth Dominican cross-reference, and in the consultation annex, and that the plan's §3 gains a sentence. Silent repair is the one thing the Lab's own rules forbid.
  3. proposed as a fourth map status, or off the map entirely? A fourth status costs a line in NodeStatus, a legend entry and a factory refusal. Keeping the layer off the map costs nothing and says less.
  4. The wholesale token: keep it as a what-if with the three guards of §3.6, or cut it? The Lab gains a genuinely interesting settlement scenario and takes on the only attribution risk in the whole extension. Cutting it costs scenario 6's most elegant variant and nothing else.
  5. Do the six questions go to the Bank now, with the eleven already in the annex, or later? Sending them together is one conversation instead of two and shows the Lab reading the Reglamento closely enough to find a definition and seven prohibitions nobody has been talking about. Sending them later keeps the first consultation narrow and operational, which is what it was designed to be.
  6. Which reference profiles ship. The recommendation is three — mica.yaml, genius.yaml, fatf-r15-16.yaml — and no fourth until one is needed by a scenario.
  7. The Lab names and the token symbols. DOPL and USDL, Libro Distribuido del Lab, Emisor de Moneda Estable del Lab, Emisor Externo del Lab, PSAV del Lab, Ficha Mayorista del Lab. None contains a real institution's name, a real ticker or an ISO currency code standing alone.
  8. Does this become a commercial item? It could: a Dominican provider that has to demonstrate compliance with its own prohibition, or a remittance operator comparing a token leg against SIPA, is a paying interest. The recommendation is not yet — nothing is sold from a layer that is proposed, and the sales conversation would drag the Lab into looking like it advocates a regime the Bank has not created.
  9. Who writes the scenarios. The Toolkit's agents author them under human review, as everything else in the ecosystem is authored; the difference here is that scenario 0 must be reviewed against the Reglamento's seven articles by a person before it is run in front of anybody.

7.1a What the second research round changes about those nine decisions

Added 2026-09-07, after the three deep-research returns on virtual assets were verified source by source ([deep-research/verification/areas-11-16.md](deep-research/verification/areas-11-16.md)). Four decisions are affected, four are unchanged and one is strengthened. Nothing here reverses a recommendation; the changes are to what each decision is being taken about.

  1. Does the layer exist at all? — strengthened, and the argument for it is now better. The case in §1.3 was "the refusal is the product". It is now a pair of refusals from two different supervisors on two different populations, drafted differently, with an unresolved interaction between them (question 6) and a constitutional action pending on the legislative silence around both. A country with one prohibition is a country to model cautiously; a country with two prohibitions that nobody has read side by side is a country where the modelling is the contribution. Recommendation unchanged: yes, as a written proposal.
  2. Do we publish the correction in §1.2? — the answer is now emphatically yes, and there are three corrections rather than one. The Reglamento correction stands. Added: the Central Bank has published on central-bank digital currency, contradicting a sentence this document wrote in §3.6; and the Superintendencia del Mercado de Valores does have a published position, contradicting what §1.2 recorded as unreadable. Publishing one correction is discipline; publishing three in the same document, two of them found by verifying research we commissioned to check ourselves, is the discipline actually working. Recommendation unchanged and reinforced.
  3. proposed as a fourth map status — unchanged. Nothing in the round bears on it.
  4. The wholesale token: keep with three guards, or cut? — the decision is now harder, and in the direction of more care, not less. When §3.6 was written, the Lab's assurance that no Dominican authority had studied a central-bank token rested partly on a belief that the Bank had published nothing on the subject at all. That belief was wrong. The Bank has a research programme, a team, IMF technical assistance and a 2025 working paper — on a retail CBDC, expressly implying no decision to issue. The wholesale token remains a different object and nothing published mentions it. But the risk the three guards exist to manage has changed shape: a reader can now find a real, official, adjacent Dominican document and mistake it for warrant. §3.6 now says so explicitly and forbids the citation. Recommendation: keep the guards, add the prohibition on citing DT 2025-01 as warrant — or, if Carlos judges the adjacency itself too close, cut the token. The case for cutting is stronger than it was.
  5. Do the five questions go to the Bank now? — they are now six, and the sixth is the best argument for going now. Question 6 asks which supervisor's refusal governs which object. It is a question only someone who has read both instruments can ask, it is answerable in a sentence by either institution, and it is the kind of question that makes a first consultation land as competent rather than as a list of things we could not find. Recommendation: unchanged — but if they go, they go as six.
  6. Which reference profiles ship? — this is the decision the round changes most. §7.1 recommended three and "no fourth until one is needed by a scenario". Two more are now available with cited values, which is a different situation from being merely desirable: bcb-vasp (Resoluções 519/520/521/561/580 — a stablecoin definition, a reserve-asset allowlist, a segregation rule, an algorithmic-stablecoin ban, a prudential segmentation and a rail exclusion) and cmf-fintec (NCG 502 — a 100% capital charge with a 0.65 offset). See the build list at §5.2.1. The case for bcb-vasp in particular is that it is a Latin American central bank's own text, which a Dominican reader will find more legible than MiCA and more relevant than the GENIUS Act. Recommendation revised: three now, bcb-vasp next, cmf-fintec only if a scenario needs a capital charge.
  7. Lab names and token symbols — unchanged. No collision with anything in the round.
  8. Does this become a commercial item? — unchanged, and the reason is now stronger. Two prohibitions and a pending constitutional action make this a worse moment, not a better one, to look like a vendor with a position. Not yet.
  9. Who writes the scenarios — unchanged, with one addition: scenario 0's human review must now check the seven Reglamento articles and whether the SIMV branch is in scope for the actors the scenario instantiates.

7.2 What we build now, without waiting for anyone

Three things, and all three are complete in themselves:

7.3 What waits for the Bank

Everything else. The ledger, the two issuers, the virtual-asset service provider, the tokenised deposits and every scenario from 1 to 11 stay as written proposals with a proposed status until the consultation returns. That is not caution for its own sake: the questions in §6.2 determine whether half of these counterparts would be modelling a permitted activity, a prohibited one, or one the Reglamento simply does not reach — and the three are different simulations.

The wholesale token waits for Carlos, not for the Bank, and if it is built it is built only inside a what-if world with the three guards. We do not ask the Central Bank whether we may imagine one; we ask, in question 5 of §6.2, whether it would prefer we did not.


7.4 Decisions taken (Carlos, 2026-09-07)

  1. The layer exists, as built. 2. The corrections are published. 3. proposed stays on the public map. 4. The wholesale-token what-if is cut: the Lab will simulate a wholesale token the day the Bank asks for it, from the Bank's own design; the tokenised-deposit what-if stays behind its flag. 5. The questions go to the Bank with the letter, as annex items 15 to 20. 6. The three reference profiles ship, and bcb-vasp is added with the values the second round verified; no Chile profile yet. 7. Names and symbols unchanged. 8. Not commercialised. 9. Further scenarios come from sponsors and seats once the Bank has seen the layer, each through the same source review.

How the layer is presented, everywhere: a proposed extension, available for testing today in a world that opts in, standing outside the regulated providers, awaiting the Bank's view. Never a pilot, never a feature. The public simulation does not carry it.

8. Bibliography

Written in the format of [foundations.md](foundations.md) §5 — citation as verified, the stable URL actually used, one line on what it establishes and one line on how it applies — with the canon's epistemic tag on each entry. It is reproduced as area 11 of foundations.md and foundations.es.md.

How this area was built, and how it differs from areas 1–10. Those ten came from three deep-research returns, every source of which was then fetched at its primary URL and checked against the primary text. This one had no returns behind it: each source was searched for and fetched on 2026-09-06 under the same protocol — some by the author of this document, some by the Lab's research agents working to it — and the Dominican primary texts of the Reglamento and of Ley 155-17 were downloaded and searched term by term in the session that wrote this, rather than summarised. Where an entry rests on an agent's fetch that was not independently repeated, the entry says so. Four hosts refused automated access — fatf-gafi.org, eur-lex.europa.eu, iso.org and congress.gov — and where they did, the entry names the substitute route actually used: the Internet Archive's raw byte-capture of the publisher's own file, or govinfo.gov for United States law, with the canonical publisher URL given for citation. Inaccessibility is not evidence against a source, and it is not evidence for one either: an entry that could not be opened is tagged [REQUIRES VERIFICATION] and carries no claim.

11.A — Dominican primary texts

11-01 [SOURCE] — BCRD, Reglamento de Sistemas de Pago, Segunda Resolución de la Junta Monetaria, 28 August 2025, Art. 4 a). https://cdn.bancentral.gov.do/documents/normativa/documents/2da-Res-JM-28-08-2025-Mod-Reglamento-SIPARD.pdf
Establishes: "Activo virtual: Representación digital de valor que puede comercializarse o transferirse digitalmente y utilizarse para fines de pago o inversión, sin que en ningún caso se entienda como activo virtual a la moneda de curso legal en el territorio nacional, las divisas ni cualquier otro activo" — a binding definition in force, with an express carve-out of legal tender and foreign currency.
Applies as: the classification control VA.DEFINITION_EXCLUDES_LEGAL_TENDER_AND_CURRENCY, and the correction in §1.2 to the Lab's earlier reading.

11-02 [SOURCE] — Same instrument, Arts. 11 v, 17 w, 31 t, 33 l, 35 p, 37 j, 39 l. Same PDF.
Establishes: seven provider-obligation articles carrying the identical duty "No ofrecer productos ni servicios basados en activos virtuales" — for the administrator of a payment or securities-settlement system, the electronic-payment entity, the acquirer, the sub-acquirer, the ATM-network administrator, the digital-wallet provider and the payment-initiation service provider.
Applies as: VA.PROVIDER_OFFERS_NO_VIRTUAL_ASSET_PRODUCT, critical, and scenario 0 — the only scenario in the extension that cites a Dominican article.

11-03 [SOURCE] — Same instrument, Arts. 19, 20, 21, 22, 25 and 78. Same PDF.
Establishes: the electronic payment account's balance equal to nominal value received, without interest and refundable on demand without penalty (Art. 19); the closed list of ten permitted operations and the remittance rule crediting in national currency at the origin rate (Art. 20 and its Párrafo I); the funding and balance cap over thirty calendar days, RD$75,200 in the 2025 text and adjusted yearly by CPI (Art. 21); the float held in a current account at the Central Bank or in pledged Central Bank or Ministerio de Hacienda securities, segregated from the entity's patrimony (Art. 22); the return of funds on cessation with thirty days' notice (Art. 25); and the closed classification of electronic payment instruments into three families (Art. 78).
Applies as: §2.1 — the closest lawful analogue of a fully reserved peso token, and the four places where the analogue breaks.

11-04 [SOURCE, negative] — Same instrument, full-text search. Same PDF, text extracted with pdftotext on 2026-09-06.
Establishes: zero occurrences of "token", "DLT", "blockchain" or "distribuid*" in the seventy-three pages; eleven occurrences of "virtual", of which the payment-card ones are unrelated.
Applies as: the ground for §1.1 — the technology is genuinely absent from Dominican payment-system law even though the asset is defined and prohibited.

11-05 [SOURCE] — BCRD, Comunicado sobre criptomonedas y monedas y activos virtuales, 30 September 2021, reiterating and reproducing the communiqué of 27 June 2017. https://bancentral.gov.do/a/d/5196-comunicado-sobre-criptomonedas-y-monedas-y-activos-virtuales (JS-rendered; retrieved with a headless browser.)
Establishes: that such assets "no cuentan con el respaldo de esta institución ni con la autorización de la Junta Monetaria para su emisión y utilización como medio de pago"; that they "no tienen curso legal ni fuerza liberatoria de obligaciones públicas o privadas en todo el territorio nacional"; and that "las instituciones reguladas del sistema financiero nacional no están autorizadas para usar ni efectuar operaciones con los mismos dentro del Sistema de Pagos de la República Dominicana".
Applies as: the notice every payload of this layer carries (§5.4), quoted and never paraphrased.

11-06 [SOURCE, negative] — Ley 155-17 contra el Lavado de Activos y el Financiamiento del Terrorismo, Arts. 32 and 33, with decrees 407-17 and 408-17. Full text extracted and searched 2026-09-06.
Establishes: neither the financial nor the non-financial list of obligated subjects names a virtual-asset service provider, and the words virtual, cripto and blockchain do not occur anywhere in the statute or its decrees. Art. 32 Párrafo I nonetheless allows the CNCLA to add obligated subjects by reglamento.
Applies as: consultation question 4 (§6.2) and gap B15; the reason the simulated VASP's AML behaviour is a reference-profile control and not a Dominican rule. [REQUIRES VERIFICATION: a Gaceta Oficial copy of Ley 155-17. The text used was a legal-edition PDF, complete and internally consistent, but not the official gazette.]

11-07 [SOURCE] — GAFILAT, Informe de Evaluación Mutua de la República Dominicana, fourth round, September 2018, p. 148; and Primer informe de seguimiento intensificado, August 2019. https://biblioteca.gafilat.org/wp-content/uploads/2024/07/IEM-RD.pdf
Establishes: "La Recomendación 15 se califica como Cumplida" — but assessed only against criteria 15.1 and 15.2, the pre-October-2018 "new technologies" scope; the VASP criteria 15.3–15.11 are not assessed and activos virtuales does not occur in the report. The 2019 follow-up re-rated only Recommendation 18.
Applies as: a rating that must never be cited as evidence of Dominican compliance on virtual assets. [REQUIRES VERIFICATION: whether a later re-rating covering R.15 exists; none appears on GAFILAT's Dominican country page as of 2026-09-06.]

11-08 [SOURCE] — Cámara de Diputados, legislative-information system. https://www.diputadosrd.gob.do/sil/api/iniciativa/getIniciativas
Establishes: two initiatives and no more — 05569-2024-2028-CD, Proyecto de ley de activos digitales y criptoactivos de la República Dominicana, deposited 9 April 2026, and 05400-2024-2028-CD, Proyecto de ley de prevención, control y regulación de las criptomonedas, deposited 16 March 2026, both VIGENTE with the state Plazo vencido. No enacted law.
Applies as: the evidence for "there is no Dominican virtual-asset regime", stated from the legislature's own tracker rather than from press. [REQUIRES VERIFICATION: the content of either bill, which was not read.]

11-09 [SOURCE] — BCRD, remittance releases and register. Press release of 9 January 2026, https://www.bancentral.gov.do/a/d/6463-...; Relación de agentes de cambio y agentes de remesas y cambio autorizados por la Junta Monetaria, September 2026, https://cdn.bancentral.gov.do/documents/estadisticas/mercado-cambiario/documents/lista_agentes_cambio.pdf; Estándares metodológicos de la compilación de las estadísticas del sector externo, https://www.bancentral.gov.do/a/d/6438; Reglamento Cambiario, https://cdn.bancentral.gov.do/documents/normativa/documents/normas_vigentes/monetarios/Reglamento_Cambiario_Disposiciones_Generales.pdf.
Establishes: US$11,866.3 million received in 2025, up 10.3% on 2024; 80.0% of formal flows in December 2025 originating in the United States; six agentes de remesas y cambio on the September 2026 register; informal "remesas de bolsillo" at less than 10% of total value; and the Reglamento Cambiario's definition of the remittance-and-exchange agent.
Applies as: the use-case sizing in §1.3, with the three disciplines stated there. [REQUIRES VERIFICATION: any cost-of-sending figure for the United States → Dominican Republic corridor at a named quarter; remittanceprices.worldbank.org refused automated access from every route and the two reachable World Bank–derived series disagree by roughly a factor of two.]

11-10 [SOURCE: read in full 2026-09-06 — CPI adjustment of values only; silent on virtual assets] — BCRD, Quinta Resolución de la Junta Monetaria, 29 January 2026. https://cdn.bancentral.gov.do/documents/normativa/documents/5ta-Res-29-01-2026-Ajuste-Reglamento-SIPARD.pdf
Establishes: the annual CPI adjustment and nothing else. Read in full on 2026-09-06 from the Bank's own scanned certification of 5 February 2026, four pages, page by page: factor 1.0495 (CPI 2025 of 4.95%) applied to the paid-in capital minima — RD$78,866,000 for a payment-system administrator and an acquirer; RD$19,720,000 for an electronic-payment entity, a sub-acquirer, an ATM-network administrator and a wallet provider; RD$9,445,500 for an initiation provider — and to the cap for enabling and holding an electronic-payment account and prepaid cards, RD$79,000, with 90 and 30 business days to comply. It does not touch Art. 4 a), the seven prohibitions, or anything on virtual assets, tokens or distributed ledgers. Two of the capital figures are independently corroborated by the Bank's own authorisation requirement sheets (11-32).
Applies as: the 2026 parameter layer over the 2025 rule schema, and the closure of what the second research round called its first-priority gap. (This entry's body text previously said "Establishes: nothing here" — a leftover from before the resolution was read, contradicting its own tag. Corrected 2026-09-07.)

11-11 [SOURCE — half closed 2026-09-07] / [REQUIRES VERIFICATION] — Superintendencia del Mercado de Valores; Superintendencia de Bancos; Ministerio de Hacienda.
Establishes: the SIMV half is closed — see 11-33, which reads Circular 04/23 in full. The Superintendencia de Bancos and the Ministerio de Hacienda were not checked at all and remain open.
Applies as: the correction of this entry's own instruction. It previously said no Lab material may describe the Dominican position as "the Central Bank's alone" until the SIMV was read. The SIMV has now been read, and it turns out the position was never the Central Bank's alone: that phrasing is now not merely unverified but wrong, and must not appear anywhere. [REQUIRES VERIFICATION: the Superintendencia de Bancos and the Ministerio de Hacienda. Their silence is untested, not established.]

11.B — International standards and law

11-12 [SOURCE] — FATF, International Standards on Combating Money Laundering and the Financing of Terrorism & Proliferation — The FATF Recommendations, updated October 2025. https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/FATF%20Recommendations%202012.pdf.coredownload.inline.pdf (publisher blocks automated access; retrieved as a raw byte-capture of the publisher's own file via the Internet Archive.)
Establishes: R.15's obligation that "countries should ensure that virtual asset service providers are regulated for AML/CFT purposes, and licensed or registered and subject to effective systems for monitoring"; R.16 retitled "Payment transparency", requiring accurate originator and required beneficiary information on payments and value transfers, with the five elements of INR.16 ¶9 and a de minimis threshold "no higher than USD/EUR 1 000"; the extension to virtual-asset transfers at INR.15 ¶7(b) and the USD/EUR 1,000 occasional-transaction CDD threshold at ¶7(a); and the glossary definitions of virtual asset and virtual asset service provider with its five activities.
Applies as: fatf-r15-16.yaml, and the correction that any Lab material calling R.16 "the wire-transfer rule" is out of date.

11-13 [SOURCE] — FATF, Updated Guidance for a Risk-Based Approach — Virtual Assets and Virtual Asset Service Providers, October 2021. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets.html
Establishes: the risk-based-approach guidance, carrying FATF's own standing caveat that it "does not reflect revisions to the FATF standards made after its date of publication, including the 2025 revisions to Recommendation 1 on the risk-based approach".
Applies as: background for the profile; cited with its caveat attached, never as current on Recommendation 1.

11-14 [SOURCE] — FATF, sixth targeted update on implementation of the FATF standards on virtual assets and VASPs, 26 June 2025. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-update-virtual-assets-vasps-2025.html
Establishes: "99 jurisdictions have passed or are in the process of passing legislation implementing the Travel Rule", constituting "approximately 98 percent of the global VA market"; earlier updates dated 9 July 2024, 27 June 2023 and 30 June 2022.
Applies as: the reason the travel-rule refusal scenario is worth building — the rule is being implemented almost everywhere the Dominican corridor reaches. [REQUIRES VERIFICATION: the 2025 report's own cover title; only the publisher's press headline was readable.] Superseded for the current implementation picture by 11-39, the seventh targeted update of July 2026, whose cover title was read.

11-15 [SOURCE] — interVASP Messaging Standard IVMS 101.2023, Interoperability Standards Working Group under GBBC Digital Finance. https://www.intervasp.org/
Establishes: the standard is "the universal common language for communication of required originator and beneficiary information between VASPs", initially released in 2020, maintained since April 2023 by GBBC Digital Finance, OpenVASP and VASPnet, with an update released 4 June 2024.
Applies as: the payload shape for VASP.TRAVEL_RULE_DATA_PRESENT. Cited as an industry working-group standard — it is not an ISO or FATF standard and must never be described as one.

11-16 [SOURCE] — CPMI–IOSCO, Application of the Principles for Financial Market Infrastructures to stablecoin arrangements, BIS paper d206, July 2022. https://www.bis.org/cpmi/publ/d206.htm
Establishes: that an arrangement performing the transfer function "is considered an FMI for the purpose of applying the PFMI and, if determined by relevant authorities to be systemically important, the SA as a whole would be expected to observe all relevant principles in the PFMI"; and, under Principle 8, the expectation to "clearly define the point at which a transfer of a stablecoin through the operational method used becomes irrevocable and unconditional". Guidance covers Principles 2, 3, 8 and 9.
Applies as: the source of LEDGER.COMMIT_IS_NOT_LBTR_FINALITY and the reason the Lab ledger is drawn outside the SIPARD box.

11-17 [SOURCE] — FSB, High-level Recommendations for the Regulation, Supervision and Oversight of Global Stablecoin Arrangements, final report, 17 July 2023 (https://www.fsb.org/uploads/P170723-3.pdf); and …of Crypto-Asset Activities and Markets, final report, same date (https://www.fsb.org/uploads/P170723-2.pdf).
Establishes: Recommendation 9 of the first — authorities should require arrangements to "provide a robust legal claim to all users against the issuer and/or underlying reserve assets and guarantee timely redemption", and "For GSCs referenced to a single fiat currency, redemption should be at par into fiat"; Recommendation 3 of the second, on cross-border cooperation and consistency of supervisory outcomes.
Applies as: TOKEN.REDEEM_AT_PAR_ON_DEMAND, and the framing of the remittance comparison as a cross-border supervisory problem and not only a technical one.

11-18 [SOURCE] — BIS, Annual Economic Report 2025, Chapter III, The next-generation monetary and financial system, 29 June 2025. https://www.bis.org/publ/arpdf/ar2025e3.htm
Establishes: "Tokenisation represents a transformative innovation to both improve the old and enable the new"; the trilogy of "tokenised central bank reserves, tokenised commercial bank money and tokenised government bonds"; and the assessment that "Stablecoins offer some promise on tokenisation but fall short of requirements to be the mainstay of the monetary system when set against the three key tests of singleness, elasticity and integrity".
Applies as: the intellectual case for modelling tokenised deposits and a wholesale token alongside a stablecoin rather than instead of it, and the reason the extension does not present a stablecoin as a monetary improvement.

11-19 [SOURCE] — BIS Innovation Hub, Project Agorá: a shared programmable platform for wholesale cross-border payments, BIS paper othp110, 27 May 2026; press release of 14 May 2024. https://www.bis.org/publ/othp110.htm · https://www.bis.org/press/p240514.htm
Establishes: "The collaboration included seven central banks and more than 40 regulated financial institutions", named in the press release as the Banque de France (for the Eurosystem), the Bank of Japan, the Bank of Korea, the Bank of Mexico, the Swiss National Bank, the Bank of England and the Federal Reserve Bank of New York; and the project's aim to test "a multi-currency shared programmable platform for wholesale cross-border payments" by "tokenising – recording central bank reserves and commercial bank deposits on a shared platform".
Applies as: the closest real-world analogue of what §3 proposes, and the evidence that a shared ledger holding both central-bank and commercial-bank money is a subject of serious institutional work rather than a Lab conceit. Note, revised 2026-09-07: the count is genuinely inconsistent across BIS publications. othp110 and the press release say seven; the BIS Innovation Hub topic page and now the Annual Economic Report 2026, Chapter III (11-41) say eight. The instruction is therefore no longer "cite seven" but never write the number without naming the document it comes from, and use the count that matches the document being cited. [REQUIRES VERIFICATION: the project's real-value-testing metrics, which were not read on a primary page; and the reason for the discrepancy in the count, which no BIS page explains.]

11-20 [SOURCE]Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), 31 May 2023, OJ L 150/40, 9 June 2023. https://eur-lex.europa.eu/eli/reg/2023/1114/oj (publisher serves an automated-access challenge; retrieved as a raw byte-capture of the EUR-Lex CELEX HTML.)
Establishes: Art. 3(1)(7) "'electronic money token' … means a type of crypto-asset that purports to maintain a stable value by referencing the value of one official currency"; Art. 3(1)(6) for the asset-referenced token; Art. 49(2), (4) and (6) — a claim against the issuer, redemption "at any time and at par value", and redemption "not… subject to a fee"; Art. 36(1) — "Issuers of asset-referenced tokens shall constitute and at all times maintain a reserve of assets."
Applies as: mica.yaml, and the definitional line the ecosystem needs between a single-currency peso token and anything referencing a basket.

11-21 [SOURCE]GENIUS Act, S. 1582, 119th Congress; Public Law 119-27, enacted 18 July 2025, 139 Stat. 419. https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm (congress.gov blocks automated access; the GPO enrolled text was used.)
Establishes: Sec. 4(a)(1)(A)'s requirement to "maintain identifiable reserves backing the outstanding payment stablecoins … on an at least 1 to 1 basis" — a floor, not an exact ratio — with permitted reserve assets including US currency and Federal Reserve account balances, insured demand deposits, Treasuries of 93 days or less, and overnight repurchase and reverse-repurchase agreements collateralised by them; and Sec. 4(a)(11)'s prohibition on paying "any form of interest or yield (whether in cash, tokens, or other consideration) solely in connection with the holding, use, or retention of such payment stablecoin".
Applies as: genius.yaml, TOKEN.RESERVE_FULLY_BACKED as a floor, and TOKEN.NO_YIELD_TO_HOLDER. [REQUIRES VERIFICATION: the reserve-asset clauses beyond the fifth, which were not read.]

11-22 [SOURCE]ISO 24165-1:2025 and ISO 24165-2:2025, Digital token identifier (DTI) — Registration, assignment and structure, second editions, May and June 2025, ISO/TC 68. https://www.iso.org/standard/85546.html · https://www.iso.org/standard/85547.html (iso.org blocks automated access; catalogue pages retrieved via archived captures.)
Establishes: Part 1 gives the method for registration and assignment, Part 2 the data elements; the committee states the standard "affirms only the existence of a digital token, creating a 1:1 relationship between a digital token and its identifier" and that registry inclusion "does not warranty (or even mention) the features, functions, legal status, suitability for investment, or regulatory status of a digital token".
Applies as: the identifier every simulated token carries, and — quoted in the profiles — the discipline that an identifier is not a judgement.

11-23 [REQUIRES VERIFICATION] — ISO 20022 work on tokenised assets and digital currencies.
Establishes: nothing. No published ISO 20022 message set, business justification or deliverable specific to tokenised assets was retrieved from a primary page. The route was exhausted rather than abandoned: iso20022.org never completed a connection on any direct attempt — an availability failure on the publisher's side, not a block — the ISO browsing platform returned 403, an archived capture of the site's own homepage contains no occurrence of token, DLT, distributed ledger, digital currency or crypto, and an archive-index enumeration of the whole domain filtered on those terms matched nothing. A search-snippet suggestion that the industry intends to reuse the existing settlement message category for digital assets rather than create new messages is unverified and must not be repeated as fact.
Applies as: an open item. No Lab material may name an ISO 20022 digital-token deliverable, number or date until one is read on the publisher's own page.

11-24 [SOURCE]EIP-20, ERC-20: Token Standard, Fabian Vogelsteller and Vitalik Buterin, status Final, created 19 November 2015. https://eips.ethereum.org/EIPS/eip-20
Establishes: the standard "allows for the implementation of a standard API for tokens within smart contracts", with totalSupply, balanceOf, transfer, transferFrom, approve and allowance, the optional name, symbol and decimals, and the Transfer and Approval events.
Applies as: the de-facto token interface a simulated token presents — a real format on invented institutions, exactly as the card lane speaks ISO 8583.

11.C — Regional experience

11-25 [SOURCE] — Banco Central do Brasil, Piloto Drex and Drex – Real Digital. https://www.bcb.gov.br/estabilidadefinanceira/piloto-drex · https://www.bcb.gov.br/estabilidadefinanceira/drex (both JS-rendered; read with a headless browser on 2026-09-06.)
Establishes: the pilot as "a fase de testes para operações com a moeda digital brasileira", on a platform where "transações com ativos digitais são simuladas e liquidadas em Drex de varejo ou Drex de atacado, dependendo de sua natureza"; participants are the BCB, the CVM, the National Treasury and institutions authorised by their own regulators; and "Usuários finais não serão participantes, sendo suas operações simuladas." Phases 1 and 2 both closed, the phase-2 report em construção.
Applies as: the strongest external validation of the Lab's own method — a central bank running a tokenised-money pilot on simulated end users — and the model for splitting a retail leg from a wholesale one. [REQUIRES VERIFICATION: any production launch date; a late-2025 platform shutdown and a phase-3 scope, both of which are press-only and appear on no BCB page reached.]

11-26 [SOURCE — corrected and upgraded 2026-09-07] — Brazil's virtual-asset statute and its central-bank rules: Lei 14.478/2022; Decreto 11.563/2023; Resoluções BCB 519, 520 and 521.
Establishes: that Brazil has an enacted VASP regime distinct from Drex. Two corrections to this entry as first written. The trio is 519, 520, 521, all of 10 November 2025 — not "520, 521 and 584": Resolução BCB nº 584 of 7 August 2026 amends Resolução 142/2021 on payment-fraud controls and does not belong to the virtual-asset framework (it is now recorded at 11-42). And the contents have been read: see 11-42. Lei 14.478/2022 and Decreto 11.563/2023 are named in the fundamento legal preamble of every one of those resolutions, which establishes their existence, date and role; their own texts were still not read (planalto.gov.br refused the connection), so their substance is still not cited.
Applies as: the contrast the Dominican consultation deserves — and a sharper one than first stated: permission in Brazil is institution-specific, activity-specific and rail-specific, never a blanket flag.

11-27 [SOURCE] — Asamblea Legislativa de la República de El Salvador, Decreto Legislativo N° 57 of 8 June 2021 (Ley Bitcoin, D.O. N° 110, Tomo 431, 9 June 2021) and Decreto N° 199 of 29 January 2025 (D.O. N° 21, Tomo N° 446, 30 January 2025; in force ninety days after publication). Both PDFs downloaded from asamblea.gob.sv and read in full on 2026-09-06.
Establishes: the original Art. 1 ("moneda de curso legal, irrestricto con poder liberatorio, ilimitado… públicas o privadas"), Art. 4 (all tax contributions payable in bitcoin), Art. 7 (every economic agent must accept it) and Arts. 8–9 (State-provided automatic convertibility); and the 2025 reform to "aceptación voluntaria… con total participación privada únicamente", the reformed Arts. 7 and 12, and the outright derogation of Arts. 4, 8 and 9.
Applies as: the region's clearest verified retreat from a tokenised-money mandate — and two cautions: the tax bar came from repealing the permitting article, and the words curso legal survive the reform, so "stripped of legal-tender status" overstates it.

11-28 [SOURCE, second-hand] — Mexico: Ley para Regular las Instituciones de Tecnología Financiera, DOF 9 March 2018, Arts. 30, 32, 34 and 88; Banco de México Circular 4/2019, DOF 8 March 2019. https://dof.gob.mx/nota_detalle.php?codigo=5515623&fecha=09%2F03%2F2018 · CNBV consolidated text · banxico.org.mx Circular 4/2019.
Establishes: the Art. 30 ¶1 definition of activo virtual; Art. 30 ¶2 and ¶3, not Art. 34, as the seat of Banxico's determination and prior-authorisation powers; Art. 34 as the client-risk-disclosure article ("El activo virtual no es moneda de curso legal y no está respaldado por el Gobierno Federal, ni por el Banco de México"); and Circular 4/2019's confinement of regulated institutions to internal operations, excluding from authorisation any direct provision to clients of "servicios de intercambio, transmisión o custodia de activos virtuales", on the stated rationale of "mantener una sana distancia entre los activos virtuales y el sistema financiero".
Applies as: the closest regional analogue of the Dominican prohibition, and the phrase — sana distancia — that names what all seven Dominican articles are doing. Verified by a research agent against the URLs named; not re-fetched here. [REQUIRES VERIFICATION: the consolidated state of Circular 4/2019 after the modifying Circular 37/2020.]

11-29 [SOURCE, second-hand] — Chile: Ley N° 21.521, promulgated 22 December 2022, published 4 January 2023 (Diario Oficial N° 43442), Arts. 2, 3 and 5. Retrieved through BCN's own XML service for the norm.
Establishes: the Art. 3 definition of activos financieros virtuales o criptoactivos; the Art. 3 N° 8 definition of instrumento financiero that expressly includes "un activo financiero virtual"; and Art. 5's requirement of inscription in the CMF's Registro de Prestadores de Servicios Financieros for intermediation, custody and alternative transaction systems.
Applies as: the worked example of a jurisdiction reaching crypto through a definitional chain rather than by naming it — and the warning against summarising it as "Chile regulates crypto exchanges".

11-30 [SOURCE, second-hand] / [REQUIRES VERIFICATION] — Colombia: Superintendencia Financiera concepto 2020259314-001 of 18 December 2020; Carta Circular 29 de 2014; the laArenera pilot announced 17 September 2020 and closed 13 June 2024; Banco de la República's position as reproduced in the SFC concepto and in DIAN's normograma.
Establishes: that supervised entities are "no autorizan… para invertir, custodiar, intermediar, ni operar con criptoactivos"; that the pilot "no tiene incidencia en el marco regulatorio vigente… ni puede entenderse como una autorización"; and the central bank's conclusion that cryptoassets are "no son moneda… no son dinero para efectos legales… no son una divisa" and "no son un valor en los términos de la Ley 964 de 2005". No Colombian statute or Circular Externa regulating cryptoassets was found; banrep.gov.co is bot-blocked and no claim rests on a page read there.
Applies as: the third instance of the regional pattern — refusal and perimeter, not a framework. [REQUIRES VERIFICATION: the fate of Proyecto de Ley 139 de 2021 after its second-debate approval in the Cámara on 29 November 2022; and any URF regulatory proposal, which was not found on the pages checked — absence there is not proof of none.]

11-31 [SOURCE, second-hand] and [REQUIRES VERIFICATION] — Stablecoins in Latin American remittance corridors.
Establishes: the World Bank's Remittance Prices Worldwide average cost of sending US$200 at 6.36% globally and 5.64% for Latin America and the Caribbean in Q3 2025, against the SDG 10.c target of 3% — reported by a research agent; a separate attempt to reach that host from this session was refused. And, as a verified negative, that no institution publishes a stablecoin share of Latin American remittances: a CEMLA survey of the region's central banks asked members for a high / medium / low estimate in the absence of statistical information.
Applies as: the licence — and the obligation — to write this use case directionally. [REQUIRES VERIFICATION: the CEMLA survey's title, date and URL.] The following circulating figures are recorded here so that nobody reintroduces them, and none may appear in Lab material: "US$174bn LAC remittances 2025"; "71% of Latin American institutions use stablecoins"; "US$324bn LAC stablecoin volume, +89%"; "US$8.9bn saved on the US–LAC corridor"; "2–3% of Mexico's remittances via crypto, per Banco de México" (never attribute to Banxico); and any citation of a "Migration and Development Brief 41", which does not exist — the series ends at No. 40, June 2024.

11.D — Second research round, verified 2026-09-07

Added after the three deep-research returns on virtual assets (deep-research/returns/virtual-assets-{gemini,chatgpt,claude}.md) were verified source by source. The ledger, with the verdict on every claim each return made, is [deep-research/verification/areas-11-16.md](deep-research/verification/areas-11-16.md). Entries here are the ones that survived: a source appears below only if its primary text was read. Where a return's claim did not survive, it is recorded in that ledger and nowhere else.

11-32 [SOURCE] — BCRD, Requisitos para autorización de empresa de adquirencia o adquirente and Requisitos para autorización de entidad de pago electrónico. https://cdn.bancentral.gov.do/documents/sistema-de-pagos/informacion-general/documents/Requisitos_autorizacion_empresa_de_adquirencia.pdf · …/Requisitos_autorizacion_entidad_de_pago_electronico.pdf
Establishes: two of the Quinta Resolución's figures from a second BCRD document each — "Quinta Resolución de fecha 29 de enero del 2026 dispuso el ajuste anual del capital pagado mínimo exigido a la empresa de adquirencia o adquirente, ajustado a diciembre del 2025 al monto de RD$78,866,000.00", and for the electronic-payment entity "al monto de RD$19,720,000.00". Both sheets also record that the regime they implement was "aprobado mediante la Segunda Resolución dictada por la Junta Monetaria en fecha 28 de agosto del 2025", and both are silent on virtual assets, tokens and distributed ledgers.
Applies as: independent corroboration of 11-10, and the reason the "Quinta Resolución is unverifiable" finding of one research return could be closed rather than argued about.

11-33 [SOURCE]Superintendencia del Mercado de Valores, Circular Núm. 04/23, Advertencias sobre la adquisición de activos virtuales o criptoactivos y la participación en esquemas conocidos como initial coin offerings (ICO, por sus siglas en inglés), 9 March 2023, five pages, addressed "A: Participantes del mercado de valores y público en general". https://simv.gob.do/download/16/circulares-siv/12837/circular-04-23.pdf (the host serves a Cloudflare challenge to every automated client; read from the Internet Archive's raw byte-capture of the SIMV's own file. The SIMV's file page carries datePublished 2023-03-14. Existence and subject independently attested in GAFILAT's regional guide, 11-37 ¶70.)
Establishes: point II, that "actualmente no existen regulaciones oficiales en la República Dominicana para la oferta o promoción de activos virtuales o criptoactivos u otros activos similares, o de unidades de valor denominadas «tókenes»"; point III, that "los activos virtuales no son regulados ni supervisados por la Superintendencia del Mercado de Valores ni otra autoridad competente de la República Dominicana", so participation is at the investor's own risk; and point IV, that securities intermediaries "no podrán invertir ni realizar actividades de intermediación con activos virtuales, aún si tales instrumentos son reconocidos como valores en otras jurisdicciones, de conformidad a lo establecido en el artículo 121 del Reglamento para los Intermediarios de Valores". Its Vistos include the BCRD communiqué of 30 September 2021 and the Reglamento para los Intermediarios de Valores, R-CNMV-2019-21-MV of 13 August 2019.
Applies as: the second Dominican prohibition, and the closure of the SIMV half of 11-11. It supplies consultation question 6 (§6.2), gap row B17, annex item 20, and the standing correction that the Dominican position was never the Central Bank's alone. It is also the only Dominican regulatory text read for this document that uses the word token. (The file is a scan and was OCR'd: typography normalised in the quotations, wording not.) [REQUIRES VERIFICATION: the text of Art. 121 of the Reglamento para los Intermediarios de Valores, which the circular quotes the effect of; no copy was located.]

11-34 [SOURCE] — BCRD, Documento de Trabajo 2025-01, Estimación de una potencial demanda de CBDC en la República Dominicana y su impacto sobre el sistema bancario, Fadua C. Camacho, Víctor De Jesús Díaz, Salomé Pradel Peguero and Juan S. Ubiera, Departamento de Programación Monetaria y Estudios Económicos. https://cdn.bancentral.gov.do/documents/trabajos-de-investigacion/documents/2025-01_DT.pdf
Establishes: that "el Banco Central (BCRD) se encuentra en un ciclo inicial de exploración de las CBDC… se conformó un equipo de trabajo multidisciplinario, en el marco del primer objetivo del Plan Estratégico 2022-2025 de la institución, y se espera que este proceso continúe durante varios años"; that "el BCRD solicitó una asistencia técnica del Fondo Monetario Internacional (FMI) a través de su Departamento de Mercados Monetarios y de Capital"; that "esta agenda de investigación no implica una decisión institucional acerca de si se emitirá o no una CBDC en el país"; and, as a modelled result, that "para niveles de utilidades iguales al efectivo, la adopción de la CBDC podría alcanzar hasta un 11 % de la oferta monetaria ampliada (M2)". The cover carries the standard disclaimer that the authors' views do not necessarily represent the Bank's. Its bibliography names three earlier BCRD working papers on the subject — Camacho, DT 2019(08); Camilo, Monedas virtuales descentralizadas y política monetaria, DT 2019(07); Morla, DT 2019(06) — whose contents were not read.
Applies as: the correction to this document's own §3.6, and the reason §3.6 now forbids citing this paper as warrant for a wholesale settlement token. Retail research is not a wholesale proposal, and an exploration that says it implies no decision may never be reported as an intention.

11-35 [SOURCE] — BCRD, BCRD celebró el II Foro de Pagos Instantáneos, published 5 May 2026, on an event of 1 May 2026. https://www.bancentral.gov.do/a/d/6561-bcrd-celebro-el-ii-foro-de-pagos-instantaneos (JS-rendered; read with a headless browser.)
Establishes: Governor Héctor Valdez Albizu's own account of the SGPI — "la empresa CMA SMALL SYSTEMS, en colaboración con un equipo multidisciplinario de profesionales del Banco Central, están implementando una novedosa solución de pagos instantáneos para la República Dominicana, la cual funcionará a través de una nueva plataforma que procesará todos los pagos minoristas actualmente tramitados a través del servicio de Pagos al Instante BCRD, ofrecido mediante el Sistema de Liquidación Bruta en Tiempo Real (LBTR)" — and the date: "se está trabajando con todas las entidades del sistema financiero dominicano para que en el próximo año 2027 el sistema de gestión de pagos instantáneos sea una realidad, coincidiendo con la conmemoración del 80 aniversario de la fundación del Banco Central." Speakers from the World Bank, the Banco Central del Paraguay and the Banco Central de Costa Rica. No occurrence of token, tokenización, activo virtual, criptoactivo, blockchain, DLT or CBDC.
Applies as: the SGPI's 2027 date on the Bank's own authority rather than on press — Lab material must stop writing first half of 2027 — and the verified negative that the national instant-payments rail is account-based fiat in the Bank's own description of it.

11-36 [SOURCE] — UAF, Informe Estadístico 2025. https://www.uaf.gob.do/index.php/publicaciones/estadisticas?download=228:informe-estadistico-2025
Establishes: 11,535 registered obligated subjects, 714,391 cash-transaction reports and 4,436 suspicious-operation reports for the year; and that "transacciones que involucran criptoactivos" appears inside the residual bucket of report reasons, expressly "los delitos que presentaron una frecuencia inferior a un 1%". Activos Virtuales is one of nine topics listed for a UAF public-awareness event.
Applies as: the honest version of "the UAF and virtual assets". A research return characterised the same document as identifying informal crypto trading as a persistent, high-risk typology requiring strategic dissemination; the primary text says a sub-1% report reason. Cite the three figures and the sub-1% placement; never the characterisation.

11-37 [SOURCE] — GAFILAT, Guía para la Regulación ALA/CFT de Activos Virtuales y Proveedores de Servicios de Activos Virtuales en la Región del GAFILAT, August 2023, produced with GIZ technical assistance. https://biblioteca.gafilat.org/wp-content/uploads/2024/04/Guia-para-la-regulacion-ALACFT-AV-PSAV.pdf
Establishes: its own non-binding character — ¶12, "Esta Guía tiene un carácter explicativo y por ningún motivo debe entenderse como obligatoria para los países de la región del GAFILAT"; the Dominican position as of August 2023 at ¶70, naming both the BCRD's 2021 communiqué and SIMV Circular 04/23, and concluding that "República Dominicana aún no ha emitido disposiciones expresas en materia de AV o PSAV"; the regional survey at ¶124, "Costa Rica, Guatemala, Honduras, Panamá, Perú, República Dominicana y Uruguay no han emitido regulación de AV y PSAV"; and, at footnote 13, that "en 2021, República Dominicana incluyó un módulo sobre AV y PSAV en el proceso de actualización de su ENR".
Applies as: the route by which 11-33 was found; the only primary-sourced statement available about Costa Rica, Guatemala, Honduras and Panama; and evidence for consultation question 4 that the Dominican AML authorities have examined virtual assets without any of it becoming positive law. Never as an operative instrument — its own ¶12 forbids that.

11-38 [SOURCE] — Tribunal Constitucional de la República Dominicana, Rol de Audiencias, Wednesday 22 April 2026, Acción Directa de Inconstitucionalidad, item 9. https://tribunalsitestorage.blob.core.windows.net/media/67557/rol-de-audiencias-22-de-abril-de-2026.pdf
Establishes: "Expediente: TC-01-2025-0073. Accionante: Marino Marrero Báez. Omisión cuestionada: omisión legislativa y exceso administrativo en materia de activos virtuales. Autoridades de las cuales emana la norma atacada: Senado y Cámara de Diputados."
Applies as: the fact that the Dominican legislative silence on virtual assets is itself being litigated. What is verified is the action's existence, number, applicant, subject and hearing date, and nothing else. No decision was located. No Lab material may state or imply an outcome, a timetable, or that a ruling would change the Reglamento.

11-39 [SOURCE] — FATF, seventh Targeted Update on Implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers, July 2026. https://www.fatf-gafi.org/en/publications/Fatfrecommendations/targeted-updated-virtualassets-vasps-2026.html (publisher blocks automated access; read from a mirror of FATF's own .coredownload.pdf, cover title and citing reference confirmed against the file itself.)
Establishes: "As of April 2026, 149 jurisdictions have been assessed for compliance with the FATF standards for VAs and VASPs… The proportion of jurisdictions that are largely compliant (LC) increased from 29% (40 of 138 jurisdictions) in 2025 to 34% (51 of 149 jurisdictions) in 2026, and the proportion of jurisdictions partially compliant (PC)… decreased slightly from 50%… to 43% (64 of 149)… The proportion of jurisdictions not compliant (NC)… remains similar… to 22% (33 of 149)… As in 2025, only one jurisdiction continues to be fully compliant (C) with R.15." On the Travel Rule: "For the 2026 survey, 83% of respondents reported having passed legislation implementing the Travel Rule." The report names no individual jurisdiction, so it neither supplies nor excludes a Dominican R.15 re-rating.
Applies as: the current international implementation picture in fatf-r15-16.yaml's comparison header, superseding 11-14 for that purpose. It lets the Lab state the international target state as a distribution rather than as a slogan — and it is why the travel-rule refusal scenario is worth building.

11-40 [SOURCE] — FSB, Thematic Review on FSB Global Regulatory Framework for Crypto-asset Activities, 16 October 2025, data as of August 2025. https://www.fsb.org/2025/10/thematic-review-on-fsb-global-regulatory-framework-for-crypto-asset-activities/
Establishes: that "jurisdictions have made progress in regulating crypto-asset activities and to a lesser extent global stablecoin arrangements"; that there are "significant gaps and inconsistencies that could pose risks to financial stability"; and that "uneven implementation creates opportunities for regulatory arbitrage and complicates oversight of the inherently global and evolving crypto-asset market."
Applies as: the extension of 11-17 from the 2023 recommendations to their implementation review, and the sentence to quote when a reader asks why a simulated regime should be made to display its own gaps rather than hide them.

11-41 [SOURCE] — BIS, Annual Economic Report 2026, Chapter III, Anchoring trust in money: innovation beyond stablecoins, 23 June 2026. https://www.bis.org/publications/aer-2026/anchoring-trust-money
Establishes: "Project Agorá brings together eight central banks and over 40 regulated institutions to test a shared crossborder platform with a unifying ledger for tokenised commercial bank deposits and separate, jurisdiction-specific ledgers for tokenised central bank reserves"; and the definition "Stablecoins are tokens on a programmable ledger that aim to maintain a stable value against a reference asset (or basket of assets)."
Applies as: the current BIS statement alongside 11-18, and — more usefully — the architectural distinction the extension's §3.5 and §3.6 need: a unifying ledger for tokenised commercial-bank deposits, with separate, jurisdiction-specific ledgers for tokenised central-bank reserves. It is also the second BIS source giving Agorá eight central banks against othp110's seven; see the revised note at 11-19.

11-42 [SOURCE] — Banco Central do Brasil, Resoluções BCB 519, 520, 521 (all 10 November 2025), 561 (30 April 2026), 580 (1 July 2026) and 584 (7 August 2026), read at the BCB's own exibenormativo pages, plus the BCB note BC faz enquadramento prudencial para sociedades prestadoras de serviços de ativos virtuais, 1 July 2026 (https://www.bcb.gov.br/detalhenoticia/21192/nota). (All JS-rendered; read with a headless browser.)
Establishes: 519"Disciplina os processos de autorização relacionados ao funcionamento das sociedades corretoras de câmbio… e das sociedades prestadoras de serviços de ativos virtuais." 520"Disciplina a constituição e o funcionamento das sociedades prestadoras de serviços de ativos virtuais…", with Art. 2 II defining "ativo virtual referenciado em moeda fiduciária (stablecoin): o ativo virtual lastreado em ativos de reserva criado com o propósito de manter seu valor vinculado ao valor de uma moeda fiduciária de referência", Art. 2 III confining the reserve to "a moeda fiduciária e os títulos públicos emitidos pelos mesmos governos que emitem essas moedas", Art. 2 XIII defining "prova de reservas", Art. 28 requiring own funds "de forma segregada dos recursos financeiros de seus clientes e usuários, por meio de contas de pagamento ou de depósito individualizadas em nome desses clientes e usuários", and Art. 31 §3 forbidding the offer of "ativos virtuais referenciados em moeda fiduciária cujos mecanismos de controle dos ativos de reserva sejam efetuados por algoritmos". 521 — folds virtual-asset activity into the FX framework by amending Resoluções 277, 278 and 279 of 2022. 561"sendo vedado o uso de ativos virtuais" in eFX settlement, "entra em vigor em 1º de outubro de 2026"; the word Drex does not occur in it. 580 and the note — VASPs classified "como Tipo 3, nos termos da Resolução BCB nº 436/2024", prudential requirements "a partir de 1º de janeiro de 2027", "enquadradas no Segmento 4 (S4) até 30 de junho de 2028, independentemente de seu porte", and "veda a prestação de serviços de ativos virtuais por instituições enquadradas no Segmento 5 (S5)", on the stated principle "mesma atividade, mesmo risco, mesma regulação". 584 — amends Resolução 142/2021 on payment-fraud controls; it is not part of the virtual-asset framework and 11-26's original grouping of it there is corrected.
Applies as: the proposed bcb-vasp reference profile and its five cited parameters (§5.2.1); the correction to 11-26; and the strongest regional evidence for the extension's own thesis — that a permissive jurisdiction still refuses specific rails and specific institutions, which is exactly what the seven Dominican articles do.

11-43 [SOURCE] — Comisión para el Mercado Financiero (Chile), Norma de Carácter General N°502, 12 January 2024, "Regula el registro, autorización y obligaciones de los prestadores de servicios financieros de la Ley Fintec", issued under Ley N° 21.521. https://www.cmfchile.cl/normativa/ncg_502_2024.pdf
Establishes: section D.4, Requisito de patrimonio de riesgo de crédito y mercado para criptoactivos — the CMF publishes a list of eligible assets, "Los activos incluidos en esta lista se denominarán activos «Tipo A», el resto será clasificado como «Tipo B»", selected "de acuerdo con las características de liquidez, capitalización de mercado, transaccionalidad y disponibilidad de precios"; a 100% capital requirement on the net position of a Type A asset and on the gross position of a Type B asset, with a partial-offset coefficient of 0.65 on the smaller of the long and short legs for Type A only. And, for admission to quotation on an alternative transaction system, "respecto de activos virtuales, sólo se admitirán a cotización criptoactivos que cuenten con un documento público que contenga las especificaciones técnicas… qué activos son representados digitalmente, qué derechos tendrá quien adquiere el criptoactivo, respecto de quién tendrá esos derechos".
Applies as: the upgrade of 11-29 from a statute read second-hand to its implementing norm read directly, the proposed cmf-fintec profile, and the first quantified foreign prudential parameter available to this extension.

11-44 [SOURCE] — BCRD, BCRD informa que los flujos de remesas alcanzaron los US$5,170.1 millones entre enero y mayo de 2026, press release of 14 June 2026. https://www.bancentral.gov.do/a/d/6593-bcrd-informa-que-los-flujos-de-remesas-alcanzaron-los-us51701-millones-entre-enero-y-mayo-de-2026 (JS-rendered; read with a headless browser.)
Establishes: "durante el periodo enero-mayo de 2026, el flujo de remesas hacia el país alcanzó los US$5,170.1 millones, lo que representa un incremento interanual de 5.4 %. De manera específica, en el mes de mayo se captaron US$1,090.2 millones"; "país que originó el 82.3 % de los flujos formales recibidos en mayo, equivalentes a US$827.9 millones"; Spain second at "US$62.0 millones, equivalente al 6.2 %"; and the projection "las remesas se ubicarían por encima de los US$12,200 millones" for 2026.
Applies as: the current-year sizing for the remittance scenario, and the confirmation that the United States share is a monthly statistic in the Bank's own writing in 2026 as in 2025. The release attributes the outlook to tourism, exports, foreign direct investment and United States labour-market indicators and says nothing about any United States remittance tax — a claim one research return attached to it and which must never be attributed to the Bank.

11-45 [SOURCE, in part] / [REQUIRES VERIFICATION] — Peru: Resolución SBS N° 02648-2024, published in El Peruano on 1 August 2024; and the Banco Central de Reserva del Perú's digital-money innovation pilots. https://busquedas.elperuano.pe/dispositivo/SE/2311275-1 · https://www.bcrp.gob.pe/sistema-de-pagos/proyecto-cbdc.html · https://www.bcrp.gob.pe/sistema-de-pagos/proyecto-cbdc/pilotos-de-innovacion-de-dinero-digital.html
Establishes: from the official gazette's own listing, the SBS resolution's number, date and full title — "Aprueban la Norma para la prevención del lavado de activos y del financiamiento del terrorismo aplicable a los Proveedores de Servicios de Activos Virtuales (PSAV) bajo supervisión de la UIF-Perú"its text was not read. From the BCRP's own pages: the framework agreement with the operator Bitel opening the Primer Piloto de Innovación con Dinero Digital del Banco Central, governed by Circular 0011-2024-BCRP, of "un año calendario" extendable by one more, aimed at "la población no bancarizada" without internet access, with an evaluation note of 18 March 2025; and IMF technical assistance approved in May 2021.
Applies as: the regional retail-CBDC comparator, and ChatGPT's useful distinction: an AML/CFT supervisory regime is not a product licence. [REQUIRES VERIFICATION: the SBS norm's text; and any user count for the pilot — a research return gave "over 67,000 rural users" and no BCRP page reached states any number.]

11-46 [REQUIRES VERIFICATION] — Dominican legislation adjacent to, but not about, the payment-system prohibition: Ley 30-26 of 18 June 2026 (de medidas pro crecimiento económico, simplificación fiscal y mitigación de la crisis internacional), reported to add "bienes digitales y criptoactivos" to the capital-asset definition at Art. 289 of the Código Tributario; and Ley 74-25, Código Penal, reported to name criptomonedas, tokens and NFT within the pyramid-fraud offence at Art. 240. https://presidencia.gob.do/leyes/ley-30-26
Establishes: only that Ley 30-26 exists and is dated 18 June 2026, from the Presidency's own page. Neither enacted text was served or read. The crypto provisions of both are reported consistently by professional and press sources but are second-hand, and the sources disagree on Ley 74-25's promulgation date.
Applies as: context and nothing more. Neither law may be cited for its content, and neither enters any rule. Tax and criminal treatment are orthogonal to the payment-system prohibition; they matter to the extension only as evidence that the Dominican legislature has begun to name virtual assets in instruments that are not about payments.