Relating to the recognition of gold and silver specie as legal tender and the establishment of a transactional currency based on gold and silver; authorizing a fee.

Contracts

• Terms of Service (ToS): Participating merchants must amend consumer-facing agreements to stipulate that transaction value is determined by the Comptroller’s system at the moment of sale, mitigating liability for spot-price fluctuations.
• Refund Policies: Contracts must clarify whether returns on goods purchased with specie will be refunded in specie or USD to prevent exchange rate arbitrage by consumers.
• Vendor Agreements: Financial institutions contracting with the state must negotiate front-loaded cost structures, as the law anticipates vendors covering initial setup costs ($1M/year est.) with reimbursement via future fees.

Hiring/Training

• Compliance Training: Staff handling accounts must be trained on 15 C.F.R. Section 791.4. The law strictly prohibits transactions involving "foreign adversaries." This requires a screening layer similar to OFAC checks.
• Point-of-Sale Training: Front-line staff require training on the specific POS interface for digital specie, specifically regarding transaction finality and exchange rates.

Reporting & Record-Keeping

• Dual-Ledger Accounting: Businesses must maintain transaction logs distinguishing between standard USD revenue and Gold/Silver currency revenue.
• Identity Verification (KYC): To comply with the foreign adversary ban, vendors and participating institutions must document and verify the identity of account holders, effectively extending Know Your Customer (KYC) requirements to this state-level system.

Fees & Costs

• Merchant Use Fees: The Comptroller is authorized to set transaction fees to cover administrative costs. These rates are currently TBD but will likely exceed standard credit card interchange fees to cover the physical storage costs of the bullion.
• Insurance Premiums: Participating businesses should anticipate potential increases in Cyber Liability and E&O premiums due to the risks associated with digital asset valuation and custody.