{"entity":{"id":29188,"slug":"coinbase","name":"Coinbase","type":"company","role":"Largest U.S. cryptocurrency exchange (NASDAQ: COIN)","description":"Coinbase Global, Inc. is the largest U.S.-licensed cryptocurrency exchange. 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Accession number: N/A.","confidence":"inferential","dateOccurred":"2025-10-09","source":{"title":"SEC EDGAR: filing — Coinbase (2025-10-09)","url":"https://efts.sec.gov/LATEST/search-index?q=%22Coinbase%22&dateRange=custom&forms=4,SC%2013D,SC%2013G,DEF%2014A,10-K,10-Q","publication":"SEC EDGAR"}},{"id":41362,"text":"The Fairshake super-PAC spent approximately $40 million in the 2024 election to successfully oppose incumbent Senator Sherrod Brown in Ohio.","confidence":"secondary","dateOccurred":"2024-11-05","source":null},{"id":40145,"text":"Coinbase's public policy statements endorsing FIT21, the GENIUS Act, and SAB 121 repeal provide explicit criteria that correlate with Fairshake spending patterns, but no public document confirms these criteria were formally applied to internal allocation decisions.","confidence":"secondary","dateOccurred":"2024-06-15","source":null},{"id":40144,"text":"FEC reporting regulations for independent-expenditure-only committees do not require disclosure of corporate donors' internal deliberations, strategy memos, or legislator-selection criteria governing contributions to super-PACs like Fairshake.","confidence":"secondary","dateOccurred":"2024-06-15","source":null},{"id":39395,"text":"Coinbase Custody Trust Company is a New York–chartered limited-purpose trust company that competes for institutional crypto custody mandates that the SAB 121 repeal opened to traditional banks.","confidence":"secondary","dateOccurred":"2024-06-15","source":null},{"id":39161,"text":"Coinbase's policy team participated directly in markup negotiations for both the FIT21 market-structure bill and the GENIUS Act stablecoin framework.","confidence":"secondary","dateOccurred":"2024-06-15","source":null},{"id":39160,"text":"Coinbase contributed in excess of $45 million to the Fairshake super-PAC and its affiliates during the 2023-2024 election cycle, making it the single largest corporate donor to the network.","confidence":"secondary","dateOccurred":"2024-06-15","source":null},{"id":39397,"text":"Coinbase publicly endorsed and lobbied for H.J.Res.109, the Congressional Review Act resolution to rescind SAB 121.","confidence":"primary","dateOccurred":"2024-05-15","source":{"title":"H.J.Res.109 — Disapproving SEC Staff Accounting Bulletin No. 121","url":"https://www.congress.gov/bill/118th-congress/house-joint-resolution/109","publication":"Congress.gov"}},{"id":39396,"text":"Coinbase issues USDC jointly with Circle through the Centre Consortium framework and shares in USDC reserve-yield economics under their distribution agreement, making it a direct beneficiary of any expansion of the USDC float.","confidence":"secondary","dateOccurred":"2023-06-15","source":null},{"id":41018,"text":"Evidence gap: The internal allocation of Coinbase's federal lobbying spend and Fairshake-directed contributions across specific 2024 federal races is not itemised in Coinbase's investor disclosures.","confidence":"inferential","dateOccurred":null,"source":null},{"id":39399,"text":"Evidence gap: The exact share of Coinbase's USDC-related revenue attributable to the Circle distribution agreement has not been broken out separately in Coinbase's 10-Q or 10-K filings.","confidence":"inferential","dateOccurred":null,"source":null},{"id":39400,"text":"Evidence gap: Direct communications between Coinbase's policy office and the offices of the GENIUS Act sponsors are not in the public record.","confidence":"inferential","dateOccurred":null,"source":null},{"id":39162,"text":"Evidence gap: Internal Coinbase deliberations on which legislators to support via Fairshake have not been disclosed; the selection criteria are inferred from spending patterns rather than documented in filings.","confidence":"inferential","dateOccurred":null,"source":null}],"connections":[{"id":19180,"relationshipType":"policy_interest","description":"Schumer, as Senate Majority Leader (2021-2025), would have overseen financial services and cryptocurrency legislation. Coinbase is a major cryptocurrency exchange and known entity in the database involved in lobbying.","confidence":"inferential","firstDocumented":"2021","lastDocumented":null,"other":{"id":7826,"name":"Chuck Schumer","slug":"chuck-schumer","type":"elected_official"}},{"id":19176,"relationshipType":"industry connection","description":"Balderson's pro-crypto voting record, including FIT21 and SAB 121 repeal, aligns with industry positions advocated by Coinbase and other crypto firms (indirect connection via policy alignment).","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":11087,"name":"Troy Balderson","slug":"congress-b001306","type":"person"}},{"id":19013,"relationshipType":"affiliation","description":"Hunt voted for all major pro-crypto legislation including FIT21, the GENIUS Act, CLARITY Act, SAB 121 repeal, and CBDC Anti-Surveillance State Act. While Coinbase did not directly contribute to Hunt, crypto industry support likely flowed through the Fairshake super PAC which targeted pro-crypto Republicans.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":10890,"name":"Wesley Hunt","slug":"congress-h001095","type":"person"}},{"id":18997,"relationshipType":"indirect support","description":"Stand With Crypto Alliance, which rated Nehls highly, is an advocacy group supported by Coinbase. Nehls' crypto-friendly voting record aligns with Coinbase's policy goals.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":10987,"name":"Troy E. Nehls","slug":"congress-n000026","type":"person"}},{"id":18933,"relationshipType":"oversight","description":"Crypto trading platforms like Coinbase and Robinhood would receive direct regulatory benefit from H.R. 4763 (FIT21), which Jackson supported on the Subcommittee on Digital Assets.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":10930,"name":"Jonathan L. Jackson","slug":"congress-j000309","type":"person"}},{"id":18688,"relationshipType":"sector_alignment","description":"Spartz voted for the crypto industry's top legislative priority (FIT21). Coinbase is a major crypto industry player that supports such legislation through its advocacy arm.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":11017,"name":"Victoria Spartz","slug":"congress-s000929","type":"person"}},{"id":17828,"relationshipType":"unspecified proximity in known entities list","description":"Proximity in known entities list suggests possible industry alignment or collaborative advocacy given both operate in crypto/DeFi regulatory space.","confidence":"inferential","firstDocumented":"2023","lastDocumented":null,"other":{"id":923,"name":"DeFi Education Fund","slug":"defi-education-fund","type":"organization"}},{"id":17744,"relationshipType":"donor","description":"Coinbase is a major cryptocurrency company that has publicly supported pro-crypto PACs like Fairshake, though specific contributions are not documented in the provided facts.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":32304,"name":"Fairshake PAC","slug":"fairshake","type":"organization"}},{"id":17636,"relationshipType":"affiliation","description":"The GENIUS Act (S. 1582) codified a dual state-federal regulatory regime for stablecoins — a framework Gillibrand worked on via the Lummis-Gillibrand bills, affecting crypto firms like Coinbase.","confidence":"inferential","firstDocumented":"2025","lastDocumented":null,"other":{"id":1127,"name":"Kirsten Gillibrand","slug":"kirsten-gillibrand","type":"elected_official"}},{"id":16698,"relationshipType":"connected_entity_industry","description":"Coinbase CEO Brian Armstrong reversed opposition to STABLE Act implementation following events related to Hill's legislative work.","confidence":"inferential","firstDocumented":"2026","lastDocumented":null,"other":{"id":11134,"name":"J. 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Gregory Steube","slug":"congress-s001214","type":"person"}},{"id":13478,"relationshipType":"affiliation","description":"Timmons voted for FIT21 (H.R. 4763), the crypto industry's top legislative priority, and has 9/9 pro-crypto votes per Stand With Crypto, aligning with Coinbase's advocacy for clear crypto regulation.","confidence":"inferential","firstDocumented":"2024","lastDocumented":null,"other":{"id":11051,"name":"William R. 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Additionally, Ansari completed Coinbase's Stand With Crypto questionnaire and had a dedicated blockchain/crypto policy section on her campaign website.","confidence":"primary","firstDocumented":"2024","lastDocumented":null,"other":{"id":11198,"name":"Yassamin Ansari","slug":"congress-a000381","type":"person"}},{"id":17563,"relationshipType":"engagement","description":"Liccardo completed the Stand With Crypto questionnaire, an initiative associated with Coinbase, on March 5, 2025, more than three months before voting against the CLARITY Act. StandWithCrypto, a Coinbase initiative, engaged him actively on crypto policy.","confidence":"primary","firstDocumented":"2025","lastDocumented":null,"other":{"id":11194,"name":"Sam T. Liccardo","slug":"congress-l000607","type":"person"}},{"id":17542,"relationshipType":"endorsement_rating","description":"Randall's campaign was rated a 'strong' crypto supporter by Coinbase's Stand With Crypto initiative.","confidence":"primary","firstDocumented":"2024","lastDocumented":null,"other":{"id":11192,"name":"Emily Randall","slug":"congress-r000621","type":"person"}},{"id":17071,"relationshipType":"investor","description":"David Sacks, former a16z partner, now controls regulatory fate of major a16z portfolio company Coinbase as AI/Crypto Czar","confidence":"primary","firstDocumented":"2026","lastDocumented":null,"other":{"id":120,"name":"Andreessen Horowitz (a16z)","slug":"andreessen-horowitz-a16z","type":"company"}},{"id":16710,"relationshipType":"constituent_business_interest","description":"Coinbase has expanded its operational footprint in Tennessee, the state Hagerty represents.","confidence":"primary","firstDocumented":"2024","lastDocumented":null,"other":{"id":9283,"name":"Bill Hagerty","slug":"bill-hagerty","type":"elected_official"}},{"id":16611,"relationshipType":"post-enactment briefing coordination","description":"In March 2026, the Senate Banking Committee's new GOP Staff Director (appointed under Scott's chairmanship) initiated non-public implementation briefings with Coinbase to coordinate the rollout of the CLARITY Act yield-rewards compromise.","confidence":"primary","firstDocumented":"2026","lastDocumented":null,"other":{"id":9281,"name":"Tim Scott","slug":"tim-scott","type":"elected_official"}},{"id":16598,"relationshipType":"policy beneficiary","description":"The CLARITY Act safe harbor for 'activity-based rewards' was designed to accommodate Coinbase's revenue-sharing architecture with Circle; technical definitions tracked Coinbase-affiliated trade group recommendations.","confidence":"primary","firstDocumented":"2026","lastDocumented":null,"other":{"id":2306,"name":"CLARITY Act","slug":"clarity-act","type":"instrument"}},{"id":16597,"relationshipType":"lobbying target","description":"Coinbase's policy team participated in markup negotiations for the GENIUS Act stablecoin framework, and Coinbase's Q1 2026 LDA filing lists 'Implementation of the GENIUS Act' as a primary issue area.","confidence":"primary","firstDocumented":"2025","lastDocumented":null,"other":{"id":2305,"name":"GENIUS Act","slug":"genius-act","type":"instrument"}},{"id":16596,"relationshipType":"competitor","description":"Fairshake spent ~$40 million in the 2024 election to successfully oppose incumbent Senator Sherrod Brown in Ohio, funded significantly by Coinbase.","confidence":"primary","firstDocumented":"2024","lastDocumented":null,"other":{"id":9273,"name":"Sherrod Brown","slug":"sherrod-brown","type":"elected_official"}},{"id":16592,"relationshipType":"Revenue/Distribution Partner","description":"Coinbase captured approximately 80% ($1.35B) of Circle's total distribution payments (estimated $1.68B) in FY 2025.","confidence":"primary","firstDocumented":"2025","lastDocumented":null,"other":{"id":29187,"name":"Circle Internet Financial","slug":"circle-internet-financial","type":"company"}},{"id":16589,"relationshipType":"donor","description":"Coinbase is identified as one of the principal funders of the Fairshake network, which channels money into Protect Progress; representatives declined to answer questions about governance.","confidence":"primary","firstDocumented":"2025","lastDocumented":null,"other":{"id":29190,"name":"Protect Progress","slug":"protect-progress-pac","type":"institution"}},{"id":13197,"relationshipType":"Advocacy Support","description":"Houchin was rated a 'strongly supportive' candidate by Coinbase's Stand With Crypto initiative and has been publicly embraced by crypto advocacy groups.","confidence":"primary","firstDocumented":"2023","lastDocumented":null,"other":{"id":10933,"name":"Erin Houchin","slug":"congress-h001093","type":"person"}},{"id":11524,"relationshipType":"donor","description":"Connection documented in FINDING-2026-009","confidence":"primary","firstDocumented":null,"lastDocumented":null,"other":{"id":32223,"name":"Zac Moffatt","slug":"zac-moffatt","type":"person"}},{"id":11487,"relationshipType":"lobbied-against","description":"Coinbase publicly campaigned for the repeal of SAB 121, which constrained institutional custody of crypto assets that Coinbase competes to provide.","confidence":"primary","firstDocumented":"2023","lastDocumented":null,"other":{"id":29218,"name":"SEC Staff Accounting Bulletin No. 121","slug":"sab-121","type":"instrument"}},{"id":11478,"relationshipType":"donor","description":"Coinbase is among the largest corporate donors to the Fairshake super-PAC.","confidence":"primary","firstDocumented":"2023","lastDocumented":null,"other":{"id":29189,"name":"Fairshake","slug":"fairshake-pac","type":"institution"}},{"id":20092,"relationshipType":"donor","description":"2024: Cryptocurrency firm donations totaling $217,000+ from Coinbase, Ripple, Uniswap Labs, Andreessen Horowitz, and dYdX Trading employees. Gillibrand co-sponsored the GENIUS Act creating a stablecoin regulatory framework.","confidence":"secondary","firstDocumented":null,"lastDocumented":null,"other":{"id":1127,"name":"Kirsten Gillibrand","slug":"kirsten-gillibrand","type":"elected_official"}},{"id":20091,"relationshipType":"donor","description":"2024 cycle: $25,600 total ($23,100 individual + $2,500 PAC). Crypto exchange; aligns with Hill's role as Chair of the Digital Assets Subcommittee.","confidence":"secondary","firstDocumented":null,"lastDocumented":null,"other":{"id":11134,"name":"J. 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