I 

118TH CONGRESS 

1ST SESSION H. R. 6605 

To require the Secretary of the Treasury to study the threat of digital 

location obfuscation as it relates to national security and financial technology, and for other purposes. 

IN THE HOUSE OF REPRESENTATIVES 

DECEMBER 5, 2023 

Mr. NUNN of Iowa (for himself and Mrs. BEATTY) introduced the following 

bill; which was referred to the Committee on Financial Services 

A BILL 

To require the Secretary of the Treasury to study the threat 

of digital location obfuscation as it relates to national 

security and financial technology, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE; FINDINGS. 

4 (a) SHORT TITLE.—This Act may be cited as the 

5 ‘‘Stop Terrorism and Illicit Finance Location Exploitation 

6 Act of 2023’’ or the ‘‘STIFLE Act of 2023’’. 

7 (b) FINDINGS.—The Congress finds the following: 

8 (1) Financial sanctions are a primary national 

9 security tool for the United States. 


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1 (2) Financial technology has created both new 

2 beneficial financial innovations and emerging illicit 

3 finance risks, including the evasion of sanctions. 

4 (3) A financial technology platform must be 

5 able to determine the precise location of an active 

6 user of the platform to effectively implement loca7 tion-based access controls for compliance with— 

8 (A) sanctions programs administered by 

9 the Office of Foreign Assets Control; 

10 (B) obligations imposed by the Anti-Money 

11 Laundering Act of 2020, the Bank Secrecy Act, 

12 and regulations associated with such Acts; and 

13 (C) any other regulatory obligation. 

14 (4) Financial technology platforms generally 

15 use an Internet Protocol (in this Act referred to as 

16 ‘‘IP’’) address as the primary or sole indicator of 

17 their users’ precise location. 

18 (5) IP addresses were first created in 1974 and 

19 standardized in 1983 as unique identification num20 bers attributed to devices on an interconnected com21 puter network and are the foundation of the modern 

22 internet. 

23 (6) IP addresses are assigned by Internet Serv24 ice Providers (in this Act referred to as ‘‘ISPs’’) and 

25 have become a less accurate determinant of precise 


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1 location as a result of the proliferation of mobile de2 vices, dynamic IP addresses, globalized content de3 livery networks, and other innovations. 

4 (7) IP addresses can be manipulated through 

5 the use of Virtual Private Networks (in this Act re6 ferred to as ‘‘VPNs’’), proxy servers, anonymizing 

7 darknet website browsers, and other location obfus8 cation techniques for the purpose of— 

9 (A) illicit finance; 

10 (B) evading detection under existing sanc11 tions; and 

12 (C) evading requirements set forth in the 

13 Anti-Money Laundering Act of 2020 and the 

14 Bank Secrecy Act. 

15 (8) Global System for Mobiles triangulation, 

16 Wi-Fi triangulation, and GPS data provide substan17 tially more accurate location information than IP 

18 addresses, but are individually susceptible to similar 

19 manipulation through device tampering, freely avail20 able downloadable software, and other obfuscation 

21 techniques. 

22 (9) Technology that combines enhanced data 

23 analytics with aggregated authentic sources of loca24 tion data is widely used to effectively ensure compli25 ance with United States sanctions, the Anti-Money 


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1 Laundering Act of 2020, the Bank Secrecy Act, and 

2 other statutory and regulatory requirements. 

3 SEC. 2. REPORT ON THE THREAT OF DIGITAL LOCATION 

4 OBFUSCATION TO NATIONAL SECURITY AND 

5 FINANCIAL TECHNOLOGY COMPLIANCE OBLI6 GATIONS. 

7 (a) STUDY.—The Secretary of the Treasury, acting 

8 through the Undersecretary of the Treasury for Terrorism 

9 and Financial Intelligence, and in consultation with tech10 nology experts, national security experts, and law enforce11 ment, shall conduct a study to assess the following: 

12 (1) The role that location obfuscation tech13 niques, including VPNs, proxy servers, GPS location 

14 manipulation applications, and device tampering 

15 plays in money laundering, sanctions evasion, and 

16 other forms of illicit finance. 

17 (2) The ease with which an illicit actor can ma18 nipulate and falsify location data relevant to compli19 ance with sanctions, the Anti-Money Laundering Act 

20 of 2020, the Bank Secrecy Act, and any other statu21 tory and regulatory obligation. 

22 (3) The degree to which a financial technology 

23 platform relies upon an IP address as the primary 

24 or sole indicator of the precise location of a user of 

25 the platform. 


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1 (4) The ability of a financial technology plat2 form to use multiple aggregated points of location 

3 data to indicate the precise location of a user of 

4 such platform if an illicit actor manipulates one or 

5 more of such data points. 

6 (b) REPORT.—Not later than 1 year after the date 

7 of the enactment of this Act, the Secretary of the Treas8 ury, acting through the Undersecretary of the Treasury 

9 for Terrorism and Financial Intelligence, and in consulta10 tion with technology experts, national security experts, 

11 and law enforcement, shall submit to the Congress a re12 port that contains the following: 

13 (1) Each finding and determination made in 

14 the study required under subsection (a). 

15 (2) Any insufficiency in or lack of available 

16 data inhibiting any finding and determination made 

17 in the study required under subsection (a). 

18 (3) A comprehensive analysis of any cost, ben19 efit, and potential risk associated with the mod20 ernization of precise location standards used by a fi21 nancial technology platform that relies on an IP ad22 dress as the primary or sole indicator of the precise 

23 location of a user of the platform. 

24 (4) A comprehensive analysis of the ways in 

25 which technology that combines enhanced data anaVerDate Sep 11 2014 01:51 Dec 27, 2023 Jkt 049200 PO 00000 Frm 00005 Fmt 6652 Sfmt 6201 E:\BILLS\H6605.IH H6605

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1 lytics with multiple aggregated and authenticated 

2 sources of location data may be used to reduce eva3 sion of United States sanctions, requirements under 

4 the Anti-Money Laundering Act of 2020, the Bank 

5 Secrecy Act, and any other statutory and regulatory 

6 obligation. 

7 (c) DEFINITIONS.—In this Act: 

8 (1) ANTI-MONEY LAUNDERING ACT OF 2020.— 

9 The term ‘‘Anti-Money Laundering Act of 2020’’ 

10 means Division F of the National Defense Author11 ization Act for Fiscal Year 2021. 

12 (2) BANK SECRECY ACT.—The term ‘‘Bank Se13 crecy Act’’ has the meaning given the term under 

14 section 6303 of the Anti-Money Laundering Act of 

15 2020 (31 U.S.C. 5301 note). 

Æ 


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