As part of its ongoing mission, ARGA Observatory and ARGA Atlas have participated in several open international regulatory consultations conducted by key government and oversight bodies in the United States and Australia.
The submissions focused on critical areas such as transnational legal risks, compliance, procedural fairness, and digital governance systems. All comments were filed through official channels, with registration numbers (Tracking Numbers) issued by the respective regulatory systems
Block 1. United States — Federal Regulators (Regulations.gov)
Expert positions were submitted via the Regulations.gov platform for the following consultations:
1.1. DHS/USCIS — Employment Authorization Reform for Asylum Applicants
The submission highlights the link between access to employment and the protection of procedural rights for asylum seekers. We emphasized how financial stability directly impacts an applicant’s ability to participate effectively in legal proceedings.
- Status: Successfully submitted.
- Tracking Number (ARGA Observatory):
mnw-28a4-83vr. - Tracking Number (ARGA Atlas):
mnw-4amx-ojwa.
1.2. FinCEN — Whistleblower Incentives and Protections
Our comments focused on the balance between incentivizing disclosures and maintaining the quality of reported data. We addressed potential risks of abuse and the necessity of robust procedural safeguards for good-faith whistleblowers.
- Status: Successfully submitted.
- Tracking Number (ARGA Observatory):
mnw-2d4z-w4rl. - Tracking Number (ARGA Atlas):
mnw-3olp-yuw4.
1.3. FinCEN / OCC — Stablecoin AML/CFT and Regulatory Framework
An analysis of compliance requirements within transnational digital financial systems, focusing on risk management, algorithmic transparency, and the allocation of responsibility.
- Status: Successfully submitted.
- Tracking Number (FinCEN):
mnw-3lyy-iljg. - Tracking Number (OCC):
mnw-2fzt-114g
1.4. FSOC — Nonbank Financial Company Designations
FSOC — Nonbank Financial Company Designations
This submission aimed to ensure the transparency of designation criteria and adherence to the principle of proportionality when identifying systemically important financial entities.
- Status: Successfully submitted.
- Tracking Number:
mnw-2v7r-qtk3.
Block 2. Australia — ASIC
Submissions regarding the Australian market were delivered via the official electronic filing channels of the Australian Securities and Investments Commission (ASIC):
2.1. ASIC — Derivative Transaction Reporting (CS 48)
A position regarding data quality, the harmonization of reporting standards, and the reduction of fragmentation across transnational financial systems.
- Status: Submitted via email to
otcd@asic.gov.au
An analysis focusing on the allocation of responsibility, investor transparency, and the proportionality of regulation for portfolio management services.
- Status: Submitted via email to
IM.sunsettingconsultation@asic.gov.au
Block 3. ARGA Atlas (Digital Governance and AI)
In separate filings, ARGA Atlas presented specialized positions concerning the governance of automated compliance systems, the risks associated with “black-box” regulatory processes, and the critical need to maintain human-in-the-loop oversight in digital environments.
These submissions reflect the growth of our specialized AI Governance direction within the organization’s broader expert framework
Block 4. Jurisdiction-Specific Restrictions (Brazil)
Regarding consultations in Brazil (including ANATEL and MJSP), participation was technically restricted due to local registration requirements. Accessing the gov.br state portal to submit comments requires a CPF (Brazilian Taxpayer ID), which prevents international organizations without a local legal presence from filing directly.
Conclusion
ARGA Observatory views participation in international consultations as a core part of its systematic efforts to establish an expert voice in transnational law, compliance, and the protection of rights in the digital age. We will continue to expand our activities in this direction.