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Jamestown Foundation Issues Commentary: Post-Election Speculation Mounted About Kiriyenko's Kremlin Position
WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor:
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Post-Election Speculation Mounted About Kiriyenko's Kremlin Position
Alex Horobets
Executive Summary:
* First Deputy Chief of Staff of the Presidential Administration Sergei Kiriyenko's absence from Russian President Vladimir Putin's September 28 meeting with the leaders of political parties that won seats in the recent State Duma election and the Federal Security Service (FSB)-led arrest of political scientist Alexander Kynev, who was obliquely ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Post-Election Speculation Mounted About Kiriyenko's Kremlin Position Alex Horobets Executive Summary: * First Deputy Chief of Staff of the Presidential Administration Sergei Kiriyenko's absence from Russian President Vladimir Putin's September 28 meeting with the leaders of political parties that won seats in the recent State Duma election and the Federal Security Service (FSB)-led arrest of political scientist Alexander Kynev, who was obliquelyassociated with Kiriyenko, raised speculation about the Kremlin domestic policy bloc losing autonomy and protection.
* Kiriyenko's cooling ties with the Kovalchuk family, billionaires close with Putin, and the security services' growing independence may have weakened his support network. Rumored next steps include a loss of domestic policy control, a move to Moscow City Hall, or another government posting.
* For now, Kiriyenko's absence from the September meeting and the Kynev arrest are indicators of possible tensions within the Presidential Administration, though Kiriyenko has resumed public appearances in his role. In a system where official statements rarely reflect the actual distribution of power, such signals are what make it possible to track the shifting dynamics beneath the surface of Russian politics.
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On September 28, Russian President Vladimir Putin held a meeting in the Kremlin with the leaders of political parties that won seats in the recent State Duma election (President of Russia, September 28). This is a routine post-election meeting, in which Putin thanks the Central Election Commission for conducting the election, outlines the priorities for the new parliamentary term, and demonstrates that the political parties with power remain under his control. This time, however, Sergei Kiriyenko, first deputy chief of staff of the Presidential Administration and the official overseeing domestic policy, was absent. He is responsible for organizing the State Duma election campaign and its outcome. Instead, sitting to Putin's left was Alexei Gromov, another first deputy chief of staff who oversees information policy and relations with the media. The official explanation was that Kiriyenko had gone on vacation without waiting for the meeting to take place. In the Kremlin's political culture, however, the absence of a key official from a ceremonial meeting reviewing the results of his own work is rarely accidental. No major change involving Kiriyenko has been announced as of October 22, and he has continued to perform public duties in his position.
Russian authorities took political scientist Alexander Kynev into custody in Moscow a few days before the meeting. He is regarded as one of Russia's leading experts on elections and regional politics who remained in the country even after being designated as a foreign agent early this year (Nastoiashee Vremia, February 20; BBC Russian Service, September 25). Kynev described the latest State Duma election as "the most unfair" Duma election ever, and declared the victory of United Russia as the result of large-scale electoral fraud (Novaya Gazeta, September 29). Immediately after votes were counted, Kynev was detained in an operation involving Federal Security Service (FSB) officers and was severely beaten. He has been charged with attempted large-scale drug trafficking, but denies the allegations.
Kynev unofficially worked with New People, a political party part of the Kremlin-managed opposition regarded as close to Kiriyenko, in recent years (The Moscow Times, September 29). Kynev's arrest does not directly weaken Kiriyenko's position since the two were not personally close. Russian political circles, however, have been discussing the possibility that the security agencies did not alert Kiriyenko about the arrest until after the fact. The security services' arrest of Kynev sends the message that cooperation with the Presidential Administration's domestic policy bloc does not guarantee protection (Telegram/@russicaru, September 28).
Kiriyenko's absence from the post-election meeting and the high-profile detention of someone connected to his policy apparatus occurred amid frequent rumors of major personnel changes in the Kremlin before the end of this fall. The two moves deserve attention as signs of a potential realignment of power within the ruling elite, not as isolated scandals.
The Kremlin often appears monolithic from the outside. In practice, it is a system of competing factions in which influence is measured by formal positions, the ability to protect one's allies, and control of key processes. Since 2016, when he assumed his current position, Kiriyenko has built a relatively autonomous civilian apparatus for managing domestic politics, encompassing elections, regional governors, party projects, relations with the regions and, in part, soft power and Ukrainian territories occupied by Russia in 2014 and 2022. The success of the September State Duma election, with official turnout reported at almost 60 percent and United Russia securing a constitutional majority, should have strengthened Kiriyenko's position. Other trends, however, emerged immediately after the election. First, the security agencies demonstrated that they can intervene in civilian political structures, diminishing the value of protection from the Presidential Administration. Second, potential changes to Kiriyenko's position, along with the possible rise of other figures, have direct implications for the configuration of Russia's governing apparatus ahead of the next political succession cycle, after 2030--or earlier, depending on the state of the system--and for who will determine the terms of the transfer of power.
Russian Telegram channels focused on political affairs have reported a gradual distancing of relations between the Kovalchuk family and Kiriyenko. Yuri Kovalchuk, a billionaire and close friend of Putin, was previously considered one of the patrons who paved Kiriyenko's way into the Kremlin. Over time, however, the first deputy chief of staff accumulated his own bureaucratic clout and began acting more independently. Now, the Kovalchuks appear to prefer keeping their distance, observing events from the sidelines rather than protecting projects associated with Kiriyenko's circle (Telegram/@politpochta, September 29). At the same time, they are redirecting some of their projects toward Stepan and Kirill Kovalchuk. The cancellation of Kanye West concerts in St. Petersburg is a symbolic example. Structures linked to VKontakte, Russia's largest social media and technology company, headed by Kiriyenko's son, Vladimir, were responsible for organizing the event and managing its media coverage (Repost News, September 30).
Kynev's arrest adds to this broader pattern. Even if the political scientist was not personally close to Kiriyenko, he worked within the political infrastructure overseen by the Presidential Administration's domestic policy bloc. The fact that the security agencies apparently did not consider it necessary even to notify their counterparts in the Presidential Administration points to a shift in the rules of the game and growing independence on the part of the security services. It suggests that ties to Kiriyenko no longer guarantee protection from detention or physical abuse.
Against the backdrop of the possibility of further personnel changes in the Presidential Administration and the Russian government before the end of the fall, three potential scenarios for Kiriyenko's future are being discussed (Telegram/@taynaya_kantselyariya, September 21). The first is that Kiriyenko retains his position as first deputy chief of staff but loses control over domestic political affairs, which would be transferred to Chief of the Presidential Domestic Policy Directorate Andrei Yarin and the security agencies. Kiriyenko himself would be left to focus on international affairs. The second scenario involves his move to Moscow City Hall, accompanied by a substantial part of his team, potentially paving the way for incumbent Moscow Mayor Sergei Sobyanin to return to the position of chief of staff of the Presidential Administration of Russia. The third option is a move into the government as deputy prime minister responsible for the fuel and energy sector. The Moscow scenario is the one most frequently discussed and is reportedly the most attractive to Kiriyenko himself. It raises the question, however, of what would happen to Sobyanin, who is an influential and well-resourced political player in his own right (Telegram/@taynaya_kantselyariya, September 21).
If Kiriyenko leaves the Presidential Administration, his most likely replacement would be Yarin. During his years working under Kiriyenko, Yarin has significantly increased his bureaucratic influence, becoming a key link between the civilian political apparatus and the security agencies (Telegram/@taynaya_kantselyariya, September 21). He has also earned a reputation as a disciplined executor of orders. If promoted, Yarin could not only inherit Kiriyenko's projects but also reshape them. Domestic politics, in turn, could come under tighter control by the security services.
Kiriyenko's potential move to Moscow City Hall, with the prospect of eventually becoming mayor, would weaken his direct influence over the federal domestic political machinery. He would lose his levers of control, the projects under his supervision, and his position in the president's inner circle. The longer-term implications, however, are far more significant. By the standards of Russia's political elite, Kiriyenko is relatively young. The Moscow mayoralty offers substantial resources, public visibility, control over the capital's budget and personnel, and the opportunity to build new networks as an independent political heavyweight. In the context of a future transfer of power, this could prove a more advantageous position than remaining the "perennial" first deputy chief of staff.
Kiriyenko's absence from one meeting and Kynev's arrest are not proof of an imminent dismissal. They do, however, offer insight into the trends surrounding Kiriyenko and the Presidential Administration as a whole. These developments suggest that the autonomy the first deputy chief of staff has built over the past decade is beginning to face constraints. His growing distance from former patrons has also weakened his network of support at precisely the moment when the security agencies are increasingly setting the rules without regard for civilian officials responsible for domestic politics.
The cabinet reshuffle that the Kremlin announced in October produced new appointments, but no change involving Kiriyenko (The Moscow Times, October 19). The latter would provide a more direct indicator of whether the balance of power within the Kremlin has shifted. A potential move by Kiriyenko to Moscow City Hall, followed eventually by his appointment as mayor, would create a political figure with substantial resources at his disposal. Meanwhile, Yarin's rise and the growing influence of the security agencies over domestic politics would strengthen the role of repressive and control mechanisms in the management of Russia's regions and political parties. For now, Kiriyenko's absence from the September meeting and the Kynev arrest appear to be more indicators of possible tensions within the Presidential Administration than evidence that Kiriyenko is on the verge of leaving his post. But in a system where official statements rarely reflect the actual distribution of power, such signals are precisely what make it possible to track the shifting tectonic plates beneath the surface of Russian politics. Ignoring them means viewing the Russian government as a static entity rather than as a living, conflict-ridden structure in a constant state of realignment.
* * *
Alex Horobets is a PhD candidate at the Institute of History of Ukraine National Academy of Sciences of Ukraine, within the Department of International Relations and Foreign Policy of Ukraine. His main research topics include international politics and military activity in the Arctic.
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Original text here: https://jamestown.org/post-election-speculation-mounted-about-kiriyenkos-kremlin-position/
[Category: ThinkTank]
* * *
Post-Election Speculation Mounted About Kiriyenko's Kremlin Position
Alex Horobets
Executive Summary:
* First Deputy Chief of Staff of the Presidential Administration Sergei Kiriyenko's absence from Russian President Vladimir Putin's September 28 meeting with the leaders of political parties that won seats in the recent State Duma election and the Federal Security Service (FSB)-led arrest of political scientist Alexander Kynev, who was obliquely ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Post-Election Speculation Mounted About Kiriyenko's Kremlin Position Alex Horobets Executive Summary: * First Deputy Chief of Staff of the Presidential Administration Sergei Kiriyenko's absence from Russian President Vladimir Putin's September 28 meeting with the leaders of political parties that won seats in the recent State Duma election and the Federal Security Service (FSB)-led arrest of political scientist Alexander Kynev, who was obliquelyassociated with Kiriyenko, raised speculation about the Kremlin domestic policy bloc losing autonomy and protection.
* Kiriyenko's cooling ties with the Kovalchuk family, billionaires close with Putin, and the security services' growing independence may have weakened his support network. Rumored next steps include a loss of domestic policy control, a move to Moscow City Hall, or another government posting.
* For now, Kiriyenko's absence from the September meeting and the Kynev arrest are indicators of possible tensions within the Presidential Administration, though Kiriyenko has resumed public appearances in his role. In a system where official statements rarely reflect the actual distribution of power, such signals are what make it possible to track the shifting dynamics beneath the surface of Russian politics.
-
On September 28, Russian President Vladimir Putin held a meeting in the Kremlin with the leaders of political parties that won seats in the recent State Duma election (President of Russia, September 28). This is a routine post-election meeting, in which Putin thanks the Central Election Commission for conducting the election, outlines the priorities for the new parliamentary term, and demonstrates that the political parties with power remain under his control. This time, however, Sergei Kiriyenko, first deputy chief of staff of the Presidential Administration and the official overseeing domestic policy, was absent. He is responsible for organizing the State Duma election campaign and its outcome. Instead, sitting to Putin's left was Alexei Gromov, another first deputy chief of staff who oversees information policy and relations with the media. The official explanation was that Kiriyenko had gone on vacation without waiting for the meeting to take place. In the Kremlin's political culture, however, the absence of a key official from a ceremonial meeting reviewing the results of his own work is rarely accidental. No major change involving Kiriyenko has been announced as of October 22, and he has continued to perform public duties in his position.
Russian authorities took political scientist Alexander Kynev into custody in Moscow a few days before the meeting. He is regarded as one of Russia's leading experts on elections and regional politics who remained in the country even after being designated as a foreign agent early this year (Nastoiashee Vremia, February 20; BBC Russian Service, September 25). Kynev described the latest State Duma election as "the most unfair" Duma election ever, and declared the victory of United Russia as the result of large-scale electoral fraud (Novaya Gazeta, September 29). Immediately after votes were counted, Kynev was detained in an operation involving Federal Security Service (FSB) officers and was severely beaten. He has been charged with attempted large-scale drug trafficking, but denies the allegations.
Kynev unofficially worked with New People, a political party part of the Kremlin-managed opposition regarded as close to Kiriyenko, in recent years (The Moscow Times, September 29). Kynev's arrest does not directly weaken Kiriyenko's position since the two were not personally close. Russian political circles, however, have been discussing the possibility that the security agencies did not alert Kiriyenko about the arrest until after the fact. The security services' arrest of Kynev sends the message that cooperation with the Presidential Administration's domestic policy bloc does not guarantee protection (Telegram/@russicaru, September 28).
Kiriyenko's absence from the post-election meeting and the high-profile detention of someone connected to his policy apparatus occurred amid frequent rumors of major personnel changes in the Kremlin before the end of this fall. The two moves deserve attention as signs of a potential realignment of power within the ruling elite, not as isolated scandals.
The Kremlin often appears monolithic from the outside. In practice, it is a system of competing factions in which influence is measured by formal positions, the ability to protect one's allies, and control of key processes. Since 2016, when he assumed his current position, Kiriyenko has built a relatively autonomous civilian apparatus for managing domestic politics, encompassing elections, regional governors, party projects, relations with the regions and, in part, soft power and Ukrainian territories occupied by Russia in 2014 and 2022. The success of the September State Duma election, with official turnout reported at almost 60 percent and United Russia securing a constitutional majority, should have strengthened Kiriyenko's position. Other trends, however, emerged immediately after the election. First, the security agencies demonstrated that they can intervene in civilian political structures, diminishing the value of protection from the Presidential Administration. Second, potential changes to Kiriyenko's position, along with the possible rise of other figures, have direct implications for the configuration of Russia's governing apparatus ahead of the next political succession cycle, after 2030--or earlier, depending on the state of the system--and for who will determine the terms of the transfer of power.
Russian Telegram channels focused on political affairs have reported a gradual distancing of relations between the Kovalchuk family and Kiriyenko. Yuri Kovalchuk, a billionaire and close friend of Putin, was previously considered one of the patrons who paved Kiriyenko's way into the Kremlin. Over time, however, the first deputy chief of staff accumulated his own bureaucratic clout and began acting more independently. Now, the Kovalchuks appear to prefer keeping their distance, observing events from the sidelines rather than protecting projects associated with Kiriyenko's circle (Telegram/@politpochta, September 29). At the same time, they are redirecting some of their projects toward Stepan and Kirill Kovalchuk. The cancellation of Kanye West concerts in St. Petersburg is a symbolic example. Structures linked to VKontakte, Russia's largest social media and technology company, headed by Kiriyenko's son, Vladimir, were responsible for organizing the event and managing its media coverage (Repost News, September 30).
Kynev's arrest adds to this broader pattern. Even if the political scientist was not personally close to Kiriyenko, he worked within the political infrastructure overseen by the Presidential Administration's domestic policy bloc. The fact that the security agencies apparently did not consider it necessary even to notify their counterparts in the Presidential Administration points to a shift in the rules of the game and growing independence on the part of the security services. It suggests that ties to Kiriyenko no longer guarantee protection from detention or physical abuse.
Against the backdrop of the possibility of further personnel changes in the Presidential Administration and the Russian government before the end of the fall, three potential scenarios for Kiriyenko's future are being discussed (Telegram/@taynaya_kantselyariya, September 21). The first is that Kiriyenko retains his position as first deputy chief of staff but loses control over domestic political affairs, which would be transferred to Chief of the Presidential Domestic Policy Directorate Andrei Yarin and the security agencies. Kiriyenko himself would be left to focus on international affairs. The second scenario involves his move to Moscow City Hall, accompanied by a substantial part of his team, potentially paving the way for incumbent Moscow Mayor Sergei Sobyanin to return to the position of chief of staff of the Presidential Administration of Russia. The third option is a move into the government as deputy prime minister responsible for the fuel and energy sector. The Moscow scenario is the one most frequently discussed and is reportedly the most attractive to Kiriyenko himself. It raises the question, however, of what would happen to Sobyanin, who is an influential and well-resourced political player in his own right (Telegram/@taynaya_kantselyariya, September 21).
If Kiriyenko leaves the Presidential Administration, his most likely replacement would be Yarin. During his years working under Kiriyenko, Yarin has significantly increased his bureaucratic influence, becoming a key link between the civilian political apparatus and the security agencies (Telegram/@taynaya_kantselyariya, September 21). He has also earned a reputation as a disciplined executor of orders. If promoted, Yarin could not only inherit Kiriyenko's projects but also reshape them. Domestic politics, in turn, could come under tighter control by the security services.
Kiriyenko's potential move to Moscow City Hall, with the prospect of eventually becoming mayor, would weaken his direct influence over the federal domestic political machinery. He would lose his levers of control, the projects under his supervision, and his position in the president's inner circle. The longer-term implications, however, are far more significant. By the standards of Russia's political elite, Kiriyenko is relatively young. The Moscow mayoralty offers substantial resources, public visibility, control over the capital's budget and personnel, and the opportunity to build new networks as an independent political heavyweight. In the context of a future transfer of power, this could prove a more advantageous position than remaining the "perennial" first deputy chief of staff.
Kiriyenko's absence from one meeting and Kynev's arrest are not proof of an imminent dismissal. They do, however, offer insight into the trends surrounding Kiriyenko and the Presidential Administration as a whole. These developments suggest that the autonomy the first deputy chief of staff has built over the past decade is beginning to face constraints. His growing distance from former patrons has also weakened his network of support at precisely the moment when the security agencies are increasingly setting the rules without regard for civilian officials responsible for domestic politics.
The cabinet reshuffle that the Kremlin announced in October produced new appointments, but no change involving Kiriyenko (The Moscow Times, October 19). The latter would provide a more direct indicator of whether the balance of power within the Kremlin has shifted. A potential move by Kiriyenko to Moscow City Hall, followed eventually by his appointment as mayor, would create a political figure with substantial resources at his disposal. Meanwhile, Yarin's rise and the growing influence of the security agencies over domestic politics would strengthen the role of repressive and control mechanisms in the management of Russia's regions and political parties. For now, Kiriyenko's absence from the September meeting and the Kynev arrest appear to be more indicators of possible tensions within the Presidential Administration than evidence that Kiriyenko is on the verge of leaving his post. But in a system where official statements rarely reflect the actual distribution of power, such signals are precisely what make it possible to track the shifting tectonic plates beneath the surface of Russian politics. Ignoring them means viewing the Russian government as a static entity rather than as a living, conflict-ridden structure in a constant state of realignment.
* * *
Alex Horobets is a PhD candidate at the Institute of History of Ukraine National Academy of Sciences of Ukraine, within the Department of International Relations and Foreign Policy of Ukraine. His main research topics include international politics and military activity in the Arctic.
* * *
Original text here: https://jamestown.org/post-election-speculation-mounted-about-kiriyenkos-kremlin-position/
[Category: ThinkTank]
Jamestown Foundation Issues Commentary: Middle Corridor Grows in Volume But Not in Cohesion
WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor:
* * *
Middle Corridor Grows in Volume but Not in Cohesion
Megi Benia
Executive Summary:
* Washington hosted officials from Armenia, Azerbaijan, Georgia, and five Central Asian states on September 23 to discuss the Trans-Caspian Enterprise Fund and the Trump Route for International Peace and Prosperity (TRIPP) along the Middle Corridor.
* Cargo along the Middle Corridor is rising, but the fragmentation that drives demand for routes bypassing Russia also ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Middle Corridor Grows in Volume but Not in Cohesion Megi Benia Executive Summary: * Washington hosted officials from Armenia, Azerbaijan, Georgia, and five Central Asian states on September 23 to discuss the Trans-Caspian Enterprise Fund and the Trump Route for International Peace and Prosperity (TRIPP) along the Middle Corridor. * Cargo along the Middle Corridor is rising, but the fragmentation that drives demand for routes bypassing Russia alsoleaves regional states diversifying in different directions, often trading one dependence for another without a common decision-making body.
* The United States, People's Republic of China, European Union, Russia, Turkiye, and Iran compete for ports, railways, and rules, so even TRIPP, despite a planned 74 percent U.S. stake, adds an option without removing dependencies.
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On September 23, on the sidelines of the UN General Assembly, the United States convened an event in New York titled "Prosperity Through Peace: Investing in the Trans-Caspian Trade Route and TRIPP," bringing together officials from the United States, Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan, as well as private sector representatives, to discuss regional connectivity (Armenian Ministry of Foreign Affairs and International Trade, September 23). The event also focused on the Trans-Caspian Enterprise Fund, a $201 million U.S.-supported nonprofit vehicle for channeling private investment across eight South Caucasus and Central Asian states. U.S. Secretary of State Marco Rubio announced the fund in August, and it remains legally distinct from the Trump Route for International Peace and Prosperity (TRIPP) itself (Modern.az, August 8).
The event revealed a central paradox of the Middle Corridor. Long framed as an alternative to routes through Russia, the corridor has become a platform on which Washington, Moscow, Beijing, Ankara, Tehran, and Brussels pursue distinct objectives. The same geopolitical fragmentation that increased demand for routes bypassing Russia also keeps national, regional, and international initiatives from merging into a unified framework and prevents diversification from producing genuine autonomy. Commercial activity remains robust. Azerbaijan reported over 9.1 million tons of transit freight on its east-west and north-south routes in the first seven months of 2026, with east-west volumes up 16.5 percent (Trend News Agency, August 10). Increase in volume, however, does not equate to integration.
That distinction is most apparent in how participating states approach diversification, which often replaces one dependence with another. In Central Asia, geography and bargaining power differ sharply from state to state. Kazakhstan provides the land bridge and the key Caspian ports, yet Kazakh President Kassym-Jomart Tokayev stressed at the October 8 summit in Avaza, Turkmenistan, that the north-south route through Russia remains "particularly relevant" (The Times of Central Asia, October 9). Uzbekistan sent 83 percent of its Middle Corridor cargo through the Turkmen port of Turkmenbashi, while Kyrgyzstan's participation in the China-Kyrgyzstan-Uzbekistan (CKU) railway, majority-owned by the People's Republic of China (PRC), offers a route around Kazakhstan at the price of deeper reliance on PRC investment (Ankara Center for Crisis and Policy Studies, April 3; Akchabar, April 8). Whether cargo departs from Kazakh ports or Turkmenbashi, it must cross the Caspian to reach Azerbaijan, linking Central Asia's distinct transport strategies to transit routes shaped in part by the South Caucasus.
The South Caucasus states face the same trade-off between diversification and dependence. Azerbaijan, whose ports anchor the western Caspian, balances its alliance with Turkiye against normalized relations with Russia, largely based on north-south trade that traverses Azerbaijani territory (Eurasianet, July 16). Georgia, the corridor's western outlet to the Black Sea, has made its planned deep-sea port at Anaklia a test of geopolitical alignment. After a PRC-led consortium went unmentioned in Tbilisi's July 6 announcement, the government proposed state ownership under a "landlord" model, in which the state owns the port and private companies operate it, but with no confirmed partner and no named Western stakeholders (Eurasianet, July 8). Armenia's maneuverability is constrained by a railway operated since 2008 by a Russian Railways subsidiary, which Armenian Prime Minister Nikol Pashinyan says discourages Western users, and by reliance on Iranian territory for up to a quarter of its foreign trade (Barcelona Centre for International Affairs, April 2026; Report, August 13).
Regional cooperation formats show that competition for control shapes coordination more than a shared interest in efficiency. In 2024, Azerbaijan, Kyrgyzstan, Tajikistan, and Uzbekistan established the Eurasian Transport Route International Association (ETRIA), a Baku-based body to coordinate tariffs and digital tools along the corridor's southern branch. In February, Azerbaijan, Turkmenistan, Uzbekistan, and Georgia signed a separate protocol in Ashgabat to boost cargo transportation and digitize processes along the corridor (Embassy of Turkmenistan in the United Kingdom, February 11; The Astana Times, February 12). None of these formats brings all eight corridor states into a common decision-making body. The Trans-Caspian Enterprise Fund spans all eight, but it is a U.S. investment vehicle, not a regional institution. Without a regional body to set priorities among ports and routes, diversification widens the menu of options without strengthening strategic autonomy, and leaves the choice to outside powers with their own interests.
Outside powers deepen the fragmentation because they compete less for cargo than for control of the nodes it passes through and the rules that govern them. Washington's stake is the most explicit. Through a planned 74 percent controlling share in the TRIPP Development Company, it seeks a durable foothold on the corridor's western segment (Armenian Ministry of Foreign Affairs and International Trade, May 26). Beijing, by contrast, stays out of that contest and builds around it through its 51 percent stake in the joint venture developing the CKU Railway, opening a southern route that bypasses Kazakhstan (Kaktus Media, April 17). Meanwhile, its apparent exit from Anaklia leaves the Black Sea outlet without a declared sponsor (OC-Media, July 6). The European Union approaches the corridor through its Global Gateway strategy. Its Connectivity Agenda Platform, launched on June 23, came with statements of intent from international financial institutions expected to mobilize up to 2 billion euros ($2.25 billion) for the Black Sea region and the South Caucasus (European Commission, June 23). The European Union and the European Bank for Reconstruction and Development (EBRD) finance Kazakhstan's Aktau port without holding any stake in TRIPP's governance, so even Western engagement runs on separate tracks (EBRD, September 30, 2025; CivilNet, August 6).
Russia, Turkiye, and Iran answer with positional leverage. Moscow has rejected proposals to transfer the Armenian railway concession to a third party (CivilNet, February 19). Russian Deputy Foreign Minister Mikhail Galuzin said Russia's position must be taken into account because TRIPP is planned to pass through an area guarded by Russian and Armenian border troops, and transit would also have to comply with the rules of the Eurasian Economic Union (TASS, June 29). Moscow has also called for regional states and their immediate neighbors--Russia, Iran, and Turkiye--to shape the solutions, a formula that implicitly excludes Washington, while promoting a north-south corridor linking Russia with Iran, Kazakhstan, and Turkmenistan (The Times of Central Asia, October 9). Turkiye, Azerbaijan's security guarantor, supports TRIPP but reportedly makes normalization with Armenia a precondition while building its own Kars-Dilucu railway from eastern Turkiye toward Nakhchivan (CivilNet, May 16). Iran vowed in 2025 to block the route, though Armenian Foreign Minister Ararat Mirzoyan said on October 7 that Tehran is satisfied with Armenian transparency (Armenpress, October 7). The result is a layered rivalry in which the United States seeks to anchor a western outlet, Russia and Iran defend a north-south axis, and Turkiye and the PRC pursue their own initiatives, leaving participating states to bargain among competing offers.
TRIPP illustrates how these competing offers play out in a single project. Washington has secured a signed framework agreement under which a company it controls would hold development rights for the link between mainland Azerbaijan and Nakhchivan (Armenian Ministry of Foreign Affairs and International Trade, May 26). Capital and a controlling stake do not determine whose preferences prevail along the route. Armenia retains authority over border control and customs under the published framework, while the Russian, Turkish, and Iranian positions described above remain in place. As a result, TRIPP adds a U.S.-backed option to the corridor without removing the dependencies on Russia and Iran that continue to shape Armenian choices.
Strategic importance, rooted in a favorable geographic position, does not automatically translate into transregional integration, just as diversification does not necessarily confer autonomy. Alternative routes can generate new dependencies even as they reduce existing ones. Whether the Middle Corridor becomes a successful and integrated system will depend less on physical infrastructure than on whether its participants can overcome the geopolitical constraints and great-power interests that created demand for it in the first place.
* * *
Ms. Megi Benia is a former Georgian diplomat and security and foreign policy professional specializing in Russia's influence operations, NATO's collective defense posture, international cybersecurity, resilience, and transatlantic affairs. She currently serves as a Contributing Editor of New Eastern Europe.
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Original text here: https://jamestown.org/middle-corridor-grows-in-volume-but-not-in-cohesion/
[Category: ThinkTank]
* * *
Middle Corridor Grows in Volume but Not in Cohesion
Megi Benia
Executive Summary:
* Washington hosted officials from Armenia, Azerbaijan, Georgia, and five Central Asian states on September 23 to discuss the Trans-Caspian Enterprise Fund and the Trump Route for International Peace and Prosperity (TRIPP) along the Middle Corridor.
* Cargo along the Middle Corridor is rising, but the fragmentation that drives demand for routes bypassing Russia also ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Middle Corridor Grows in Volume but Not in Cohesion Megi Benia Executive Summary: * Washington hosted officials from Armenia, Azerbaijan, Georgia, and five Central Asian states on September 23 to discuss the Trans-Caspian Enterprise Fund and the Trump Route for International Peace and Prosperity (TRIPP) along the Middle Corridor. * Cargo along the Middle Corridor is rising, but the fragmentation that drives demand for routes bypassing Russia alsoleaves regional states diversifying in different directions, often trading one dependence for another without a common decision-making body.
* The United States, People's Republic of China, European Union, Russia, Turkiye, and Iran compete for ports, railways, and rules, so even TRIPP, despite a planned 74 percent U.S. stake, adds an option without removing dependencies.
-
On September 23, on the sidelines of the UN General Assembly, the United States convened an event in New York titled "Prosperity Through Peace: Investing in the Trans-Caspian Trade Route and TRIPP," bringing together officials from the United States, Armenia, Azerbaijan, Georgia, Kazakhstan, Kyrgyzstan, Tajikistan, Turkmenistan, and Uzbekistan, as well as private sector representatives, to discuss regional connectivity (Armenian Ministry of Foreign Affairs and International Trade, September 23). The event also focused on the Trans-Caspian Enterprise Fund, a $201 million U.S.-supported nonprofit vehicle for channeling private investment across eight South Caucasus and Central Asian states. U.S. Secretary of State Marco Rubio announced the fund in August, and it remains legally distinct from the Trump Route for International Peace and Prosperity (TRIPP) itself (Modern.az, August 8).
The event revealed a central paradox of the Middle Corridor. Long framed as an alternative to routes through Russia, the corridor has become a platform on which Washington, Moscow, Beijing, Ankara, Tehran, and Brussels pursue distinct objectives. The same geopolitical fragmentation that increased demand for routes bypassing Russia also keeps national, regional, and international initiatives from merging into a unified framework and prevents diversification from producing genuine autonomy. Commercial activity remains robust. Azerbaijan reported over 9.1 million tons of transit freight on its east-west and north-south routes in the first seven months of 2026, with east-west volumes up 16.5 percent (Trend News Agency, August 10). Increase in volume, however, does not equate to integration.
That distinction is most apparent in how participating states approach diversification, which often replaces one dependence with another. In Central Asia, geography and bargaining power differ sharply from state to state. Kazakhstan provides the land bridge and the key Caspian ports, yet Kazakh President Kassym-Jomart Tokayev stressed at the October 8 summit in Avaza, Turkmenistan, that the north-south route through Russia remains "particularly relevant" (The Times of Central Asia, October 9). Uzbekistan sent 83 percent of its Middle Corridor cargo through the Turkmen port of Turkmenbashi, while Kyrgyzstan's participation in the China-Kyrgyzstan-Uzbekistan (CKU) railway, majority-owned by the People's Republic of China (PRC), offers a route around Kazakhstan at the price of deeper reliance on PRC investment (Ankara Center for Crisis and Policy Studies, April 3; Akchabar, April 8). Whether cargo departs from Kazakh ports or Turkmenbashi, it must cross the Caspian to reach Azerbaijan, linking Central Asia's distinct transport strategies to transit routes shaped in part by the South Caucasus.
The South Caucasus states face the same trade-off between diversification and dependence. Azerbaijan, whose ports anchor the western Caspian, balances its alliance with Turkiye against normalized relations with Russia, largely based on north-south trade that traverses Azerbaijani territory (Eurasianet, July 16). Georgia, the corridor's western outlet to the Black Sea, has made its planned deep-sea port at Anaklia a test of geopolitical alignment. After a PRC-led consortium went unmentioned in Tbilisi's July 6 announcement, the government proposed state ownership under a "landlord" model, in which the state owns the port and private companies operate it, but with no confirmed partner and no named Western stakeholders (Eurasianet, July 8). Armenia's maneuverability is constrained by a railway operated since 2008 by a Russian Railways subsidiary, which Armenian Prime Minister Nikol Pashinyan says discourages Western users, and by reliance on Iranian territory for up to a quarter of its foreign trade (Barcelona Centre for International Affairs, April 2026; Report, August 13).
Regional cooperation formats show that competition for control shapes coordination more than a shared interest in efficiency. In 2024, Azerbaijan, Kyrgyzstan, Tajikistan, and Uzbekistan established the Eurasian Transport Route International Association (ETRIA), a Baku-based body to coordinate tariffs and digital tools along the corridor's southern branch. In February, Azerbaijan, Turkmenistan, Uzbekistan, and Georgia signed a separate protocol in Ashgabat to boost cargo transportation and digitize processes along the corridor (Embassy of Turkmenistan in the United Kingdom, February 11; The Astana Times, February 12). None of these formats brings all eight corridor states into a common decision-making body. The Trans-Caspian Enterprise Fund spans all eight, but it is a U.S. investment vehicle, not a regional institution. Without a regional body to set priorities among ports and routes, diversification widens the menu of options without strengthening strategic autonomy, and leaves the choice to outside powers with their own interests.
Outside powers deepen the fragmentation because they compete less for cargo than for control of the nodes it passes through and the rules that govern them. Washington's stake is the most explicit. Through a planned 74 percent controlling share in the TRIPP Development Company, it seeks a durable foothold on the corridor's western segment (Armenian Ministry of Foreign Affairs and International Trade, May 26). Beijing, by contrast, stays out of that contest and builds around it through its 51 percent stake in the joint venture developing the CKU Railway, opening a southern route that bypasses Kazakhstan (Kaktus Media, April 17). Meanwhile, its apparent exit from Anaklia leaves the Black Sea outlet without a declared sponsor (OC-Media, July 6). The European Union approaches the corridor through its Global Gateway strategy. Its Connectivity Agenda Platform, launched on June 23, came with statements of intent from international financial institutions expected to mobilize up to 2 billion euros ($2.25 billion) for the Black Sea region and the South Caucasus (European Commission, June 23). The European Union and the European Bank for Reconstruction and Development (EBRD) finance Kazakhstan's Aktau port without holding any stake in TRIPP's governance, so even Western engagement runs on separate tracks (EBRD, September 30, 2025; CivilNet, August 6).
Russia, Turkiye, and Iran answer with positional leverage. Moscow has rejected proposals to transfer the Armenian railway concession to a third party (CivilNet, February 19). Russian Deputy Foreign Minister Mikhail Galuzin said Russia's position must be taken into account because TRIPP is planned to pass through an area guarded by Russian and Armenian border troops, and transit would also have to comply with the rules of the Eurasian Economic Union (TASS, June 29). Moscow has also called for regional states and their immediate neighbors--Russia, Iran, and Turkiye--to shape the solutions, a formula that implicitly excludes Washington, while promoting a north-south corridor linking Russia with Iran, Kazakhstan, and Turkmenistan (The Times of Central Asia, October 9). Turkiye, Azerbaijan's security guarantor, supports TRIPP but reportedly makes normalization with Armenia a precondition while building its own Kars-Dilucu railway from eastern Turkiye toward Nakhchivan (CivilNet, May 16). Iran vowed in 2025 to block the route, though Armenian Foreign Minister Ararat Mirzoyan said on October 7 that Tehran is satisfied with Armenian transparency (Armenpress, October 7). The result is a layered rivalry in which the United States seeks to anchor a western outlet, Russia and Iran defend a north-south axis, and Turkiye and the PRC pursue their own initiatives, leaving participating states to bargain among competing offers.
TRIPP illustrates how these competing offers play out in a single project. Washington has secured a signed framework agreement under which a company it controls would hold development rights for the link between mainland Azerbaijan and Nakhchivan (Armenian Ministry of Foreign Affairs and International Trade, May 26). Capital and a controlling stake do not determine whose preferences prevail along the route. Armenia retains authority over border control and customs under the published framework, while the Russian, Turkish, and Iranian positions described above remain in place. As a result, TRIPP adds a U.S.-backed option to the corridor without removing the dependencies on Russia and Iran that continue to shape Armenian choices.
Strategic importance, rooted in a favorable geographic position, does not automatically translate into transregional integration, just as diversification does not necessarily confer autonomy. Alternative routes can generate new dependencies even as they reduce existing ones. Whether the Middle Corridor becomes a successful and integrated system will depend less on physical infrastructure than on whether its participants can overcome the geopolitical constraints and great-power interests that created demand for it in the first place.
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Ms. Megi Benia is a former Georgian diplomat and security and foreign policy professional specializing in Russia's influence operations, NATO's collective defense posture, international cybersecurity, resilience, and transatlantic affairs. She currently serves as a Contributing Editor of New Eastern Europe.
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Original text here: https://jamestown.org/middle-corridor-grows-in-volume-but-not-in-cohesion/
[Category: ThinkTank]
Jamestown Foundation Issues Commentary: Baku's Hijab Ban Sparks Protests in Azerbaijan and Creates Problems With Turkiye
WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor:
* * *
Baku's Hijab Ban Sparks Protests in Azerbaijan and Creates Problems With Turkiye
Paul Goble
Executive Summary:
* Baku's September 21 decision to ban the wearing of the hijab by pupils and teachers in Azerbaijani state schools and the protests that have followed have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye.
* In their wake, Azerbaijanis are now asking more questions about the proper relationship ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Baku's Hijab Ban Sparks Protests in Azerbaijan and Creates Problems With Turkiye Paul Goble Executive Summary: * Baku's September 21 decision to ban the wearing of the hijab by pupils and teachers in Azerbaijani state schools and the protests that have followed have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye. * In their wake, Azerbaijanis are now asking more questions about the proper relationshipbetween secularism and freedom of religion than ever, and Baku has been forced to recognize that the balance Baku seeks and the one Ankara does are increasingly at odds.
* Because the two countries have hitherto been the closest of allies, something like this, which divides them so deeply, almost certainly will have major consequences not only for the two of them and their relationship but also for the region around them and beyond.
-
Baku decided on September 21 to ban pupils and teachers from wearing the hijab in Azerbaijani state schools. The protests that the move has sparked have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye (RTV Online, October 17). Azerbaijanis have been prompted to ask more questions than ever about the proper relationship between secularism and freedom of religion, and Baku has been forced to recognize that the balance Baku seeks and the one Ankara does are beginning to be at odds (Svobodnaya Pressa, October 16; The Caspian Post, October 20). Because the two countries have hitherto been the closest of allies, this division will have significant consequences not only for them and their relationship but for the region around them and beyond (Nezavisimaya Gazeta, October 18). Consequently, what may seem to some outsiders like a minor issue is major, and its resolution will affect the situation and policies of even powers distant from the South Caucasus (Voyenno-politicheskaya analitika, October 16).
Since the Azerbaijani republic was founded just over a century ago, secularism has been a core value of its leaders. They saw it as essential to maintaining stability in a country with many religions and as a necessary feature of a modern state (RFI, October 14). That commitment strengthened during Soviet times, albeit for different reasons, and re-emerged as a centerpiece of post-Soviet Azerbaijan's construction. Maintaining a balance between secularism and freedom of religion, however, has never been easy. When Baku has intervened on that question in recent years and tilted toward secularism, such actions have sparked protests, most notably in 2010-2011 (Radio Free Europe/Radio Liberty, May 6, 2011). As a result, until earlier this year, the Azerbaijani government moved cautiously, especially in handling the issue, since it affected schools and, given how many people in the country are part of the education system, had wide-ranging consequences.
Baku has long been worried about Iranian efforts to promote radical Islam in Azerbaijan and thus destabilize the regime there. Given the growing conflict between Iran, on the one hand, and Israel and the United States, on the other, Baku moved further and faster to ensure that Azerbaijani schools would be purely secular and thus could not become seedbeds of Islamist radicalism. Senior Azerbaijani officials, however, were careful not to publicly name Iran as the proximate cause of their actions (OC-Media, October 16). Since the start of this year, the Azerbaijani government has moved step by step to do so, establishing dress codes for pupils and teachers on July 7, tightening those codes on September 21 as far as pupils were concerned--an action that did not mention the hijab but was interpreted by school officials as targeting that in particular--and, on October 6, extending such restrictions to teachers as well (RTV Online).
These moves prompted hundreds of pupils, their parents, and rights activists to take to the streets to protest. Authorities have arrested dozens of them and restricted social media so they could not organize more protests. (For a sampling of the enormous reporting about the protests and about the arguments of those that the wearing of the hijab does not interfere with secular education, see Kavkaz Uzel, October 12, 18; Minval.az, October 12, 13; Aktsenty, October 12; OC-Media, October 13, 16; AsiaNews; Novaya Gazeta Evropa, October 15.) In these articles, the most impressive features of the protests were their size and length in a country whose government typically blocks any protest and shuts it down almost instantly, but that was not what made them most noteworthy.
From the outset of the protests in Azerbaijan, participants and observers focused on what these actions meant for Azerbaijan itself and for its relations with other countries. Perhaps unsurprisingly, they began by focusing on Baku's relationship with Muslim countries in general, and Central Asian ones in particular, with which Azerbaijan has sought to expand its ties (Aktsenty, October 14). They quickly shifted to the impact of these events on the relationship between Azerbaijan and Turkiye, two countries that for more than 30 years have described themselves as "one nation--two states."
Ever more observers even suggested that Azerbaijan's ban had highlighted the limitations of that formula. The ban had appeared at a time when Turkiye too was committed to secularism, which has long passed given that Ankara is integrating Islam into the ideology of the Turkish state (Svobodnaya Pressa, October 16; Nesavisymaya Gazeta, October 18; The Caspian Post, October 20). As Israeli Caucasus specialist Abraham Shmulyevich noted in his commentary the formula "one nation--two states" still reflects the profound historical, linguistic, and cultural affinity between Azerbaijan and Turkiye. It does not, however, change that under Turkish President Recep Tayyip Erdogan, the two countries have developed along fundamentally different political and state models. They share ethnic kinship, strategic interests, and a common historical memory, but they differ on the role of religion in society, the limits of state intervention, and the very logic of national development (The Caspian Post, October 20). That scholarly judgment was echoed in the streets of Istanbul, where Turkish demonstrators at the Azerbaijani consulate against the hijab ban by Baku declared, "Such a state cannot be our brother!" (akcent.site/novosti/46235).
As this controversy has continued, Azerbaijani President Ilham Aliyev has repeatedly lashed out at Turkiye for criticizing his policies. Turkiye does not have the right to try to teach Baku how to live, he has said, adding that while there is no question that Turks and Azerbaijanis are one people, they are different countries with different values and that each must respect the other (Nezavisimaya Gazeta, October 15; Svobodnaya Pressa, October 16). Some Azerbaijani officials and scholars have tried to downplay the obvious implications and argue that this is not a break and that the two countries will still operate as one on many issues. That seems increasingly unlikely the longer this war of words goes on. That in turn is something that will affect both countries, their relations with each other, and their relations with third countries including, but not limited to, Israel, where there are already signs of a break; Central Asia, where a division between the two will affect trade across the Caspian; and Europe, the People's Republic of China, and the United States, each of which has a stake in issues on which the presence or absence of cooperation between Ankara and Baku depends.
Aliyev has a record of changing course relatively quickly when he judges that it is necessary. Whether he keeps the hijab ban in place is yet to be seen. Such a change will depend not only on what he has said but also on how Turks in general have reacted to it. Consequently, what may seem to many like a small internal matter in Azerbaijan casts a large shadow over the world as a whole, one that must factor into considerations of all such issues.
* * *
Paul Goble is a longtime specialist on ethnic and religious questions in Eurasia. Most recently, he was director of research and publications at the Azerbaijan Diplomatic Academy.
* * *
Original text here: https://jamestown.org/bakus-hijab-ban-sparks-protests-in-azerbaijan-and-creates-problems-with-turkiye/
[Category: ThinkTank]
* * *
Baku's Hijab Ban Sparks Protests in Azerbaijan and Creates Problems With Turkiye
Paul Goble
Executive Summary:
* Baku's September 21 decision to ban the wearing of the hijab by pupils and teachers in Azerbaijani state schools and the protests that have followed have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye.
* In their wake, Azerbaijanis are now asking more questions about the proper relationship ... Show Full Article WASHINGTON, Oct. 23 -- The Jamestown Foundation issued the following commentary on Oct. 22, 2026, in the foundation's Eurasia Daily Monitor: * * * Baku's Hijab Ban Sparks Protests in Azerbaijan and Creates Problems With Turkiye Paul Goble Executive Summary: * Baku's September 21 decision to ban the wearing of the hijab by pupils and teachers in Azerbaijani state schools and the protests that have followed have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye. * In their wake, Azerbaijanis are now asking more questions about the proper relationshipbetween secularism and freedom of religion than ever, and Baku has been forced to recognize that the balance Baku seeks and the one Ankara does are increasingly at odds.
* Because the two countries have hitherto been the closest of allies, something like this, which divides them so deeply, almost certainly will have major consequences not only for the two of them and their relationship but also for the region around them and beyond.
-
Baku decided on September 21 to ban pupils and teachers from wearing the hijab in Azerbaijani state schools. The protests that the move has sparked have had a profound impact not only on Azerbaijani society but also on Azerbaijan's relations with Turkiye (RTV Online, October 17). Azerbaijanis have been prompted to ask more questions than ever about the proper relationship between secularism and freedom of religion, and Baku has been forced to recognize that the balance Baku seeks and the one Ankara does are beginning to be at odds (Svobodnaya Pressa, October 16; The Caspian Post, October 20). Because the two countries have hitherto been the closest of allies, this division will have significant consequences not only for them and their relationship but for the region around them and beyond (Nezavisimaya Gazeta, October 18). Consequently, what may seem to some outsiders like a minor issue is major, and its resolution will affect the situation and policies of even powers distant from the South Caucasus (Voyenno-politicheskaya analitika, October 16).
Since the Azerbaijani republic was founded just over a century ago, secularism has been a core value of its leaders. They saw it as essential to maintaining stability in a country with many religions and as a necessary feature of a modern state (RFI, October 14). That commitment strengthened during Soviet times, albeit for different reasons, and re-emerged as a centerpiece of post-Soviet Azerbaijan's construction. Maintaining a balance between secularism and freedom of religion, however, has never been easy. When Baku has intervened on that question in recent years and tilted toward secularism, such actions have sparked protests, most notably in 2010-2011 (Radio Free Europe/Radio Liberty, May 6, 2011). As a result, until earlier this year, the Azerbaijani government moved cautiously, especially in handling the issue, since it affected schools and, given how many people in the country are part of the education system, had wide-ranging consequences.
Baku has long been worried about Iranian efforts to promote radical Islam in Azerbaijan and thus destabilize the regime there. Given the growing conflict between Iran, on the one hand, and Israel and the United States, on the other, Baku moved further and faster to ensure that Azerbaijani schools would be purely secular and thus could not become seedbeds of Islamist radicalism. Senior Azerbaijani officials, however, were careful not to publicly name Iran as the proximate cause of their actions (OC-Media, October 16). Since the start of this year, the Azerbaijani government has moved step by step to do so, establishing dress codes for pupils and teachers on July 7, tightening those codes on September 21 as far as pupils were concerned--an action that did not mention the hijab but was interpreted by school officials as targeting that in particular--and, on October 6, extending such restrictions to teachers as well (RTV Online).
These moves prompted hundreds of pupils, their parents, and rights activists to take to the streets to protest. Authorities have arrested dozens of them and restricted social media so they could not organize more protests. (For a sampling of the enormous reporting about the protests and about the arguments of those that the wearing of the hijab does not interfere with secular education, see Kavkaz Uzel, October 12, 18; Minval.az, October 12, 13; Aktsenty, October 12; OC-Media, October 13, 16; AsiaNews; Novaya Gazeta Evropa, October 15.) In these articles, the most impressive features of the protests were their size and length in a country whose government typically blocks any protest and shuts it down almost instantly, but that was not what made them most noteworthy.
From the outset of the protests in Azerbaijan, participants and observers focused on what these actions meant for Azerbaijan itself and for its relations with other countries. Perhaps unsurprisingly, they began by focusing on Baku's relationship with Muslim countries in general, and Central Asian ones in particular, with which Azerbaijan has sought to expand its ties (Aktsenty, October 14). They quickly shifted to the impact of these events on the relationship between Azerbaijan and Turkiye, two countries that for more than 30 years have described themselves as "one nation--two states."
Ever more observers even suggested that Azerbaijan's ban had highlighted the limitations of that formula. The ban had appeared at a time when Turkiye too was committed to secularism, which has long passed given that Ankara is integrating Islam into the ideology of the Turkish state (Svobodnaya Pressa, October 16; Nesavisymaya Gazeta, October 18; The Caspian Post, October 20). As Israeli Caucasus specialist Abraham Shmulyevich noted in his commentary the formula "one nation--two states" still reflects the profound historical, linguistic, and cultural affinity between Azerbaijan and Turkiye. It does not, however, change that under Turkish President Recep Tayyip Erdogan, the two countries have developed along fundamentally different political and state models. They share ethnic kinship, strategic interests, and a common historical memory, but they differ on the role of religion in society, the limits of state intervention, and the very logic of national development (The Caspian Post, October 20). That scholarly judgment was echoed in the streets of Istanbul, where Turkish demonstrators at the Azerbaijani consulate against the hijab ban by Baku declared, "Such a state cannot be our brother!" (akcent.site/novosti/46235).
As this controversy has continued, Azerbaijani President Ilham Aliyev has repeatedly lashed out at Turkiye for criticizing his policies. Turkiye does not have the right to try to teach Baku how to live, he has said, adding that while there is no question that Turks and Azerbaijanis are one people, they are different countries with different values and that each must respect the other (Nezavisimaya Gazeta, October 15; Svobodnaya Pressa, October 16). Some Azerbaijani officials and scholars have tried to downplay the obvious implications and argue that this is not a break and that the two countries will still operate as one on many issues. That seems increasingly unlikely the longer this war of words goes on. That in turn is something that will affect both countries, their relations with each other, and their relations with third countries including, but not limited to, Israel, where there are already signs of a break; Central Asia, where a division between the two will affect trade across the Caspian; and Europe, the People's Republic of China, and the United States, each of which has a stake in issues on which the presence or absence of cooperation between Ankara and Baku depends.
Aliyev has a record of changing course relatively quickly when he judges that it is necessary. Whether he keeps the hijab ban in place is yet to be seen. Such a change will depend not only on what he has said but also on how Turks in general have reacted to it. Consequently, what may seem to many like a small internal matter in Azerbaijan casts a large shadow over the world as a whole, one that must factor into considerations of all such issues.
* * *
Paul Goble is a longtime specialist on ethnic and religious questions in Eurasia. Most recently, he was director of research and publications at the Azerbaijan Diplomatic Academy.
* * *
Original text here: https://jamestown.org/bakus-hijab-ban-sparks-protests-in-azerbaijan-and-creates-problems-with-turkiye/
[Category: ThinkTank]
CSIS Issues Newsletter Entitled 'Risk to Refugee Return'
WASHINGTON, Oct. 23 -- The Center for Strategic and International Studies issued the following newsletter:
* * *
Risk to Refugee Return
by Ninar Fawal
October 22, 2026
Unexploded Ordnance (UXO) in Syria Poses Significant Threats to Refugee Return
Estimated UXO per 1000 returnees by governorate
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Map: UXO per 1000 Returnees
* * *
More than 1.7 million Syrian refugees have returned to Syria following the fall of the Bashar al-Assad regime in December 2024, with explosive remnants of war now posing a significant obstacle to safe resettlement. This installment of Charting the Middle East ... Show Full Article WASHINGTON, Oct. 23 -- The Center for Strategic and International Studies issued the following newsletter: * * * Risk to Refugee Return by Ninar Fawal October 22, 2026 Unexploded Ordnance (UXO) in Syria Poses Significant Threats to Refugee Return Estimated UXO per 1000 returnees by governorate * * * Map: UXO per 1000 Returnees * * * More than 1.7 million Syrian refugees have returned to Syria following the fall of the Bashar al-Assad regime in December 2024, with explosive remnants of war now posing a significant obstacle to safe resettlement. This installment of Charting the Middle Easthighlights how the scale of unexploded ordnance (UXO) contamination, relative to returning populations, varies across Syria. These disparities underscore the importance of prioritizing mine clearance and risk awareness efforts in areas of particular concern.
In 2025, Syria was the second-largest recipient of returned refugees worldwide while also reporting the highest number of UXO-related casualties globally. By measuring estimated UXO presence per 1,000 returnees, this analysis identifies a particular challenge in the northeastern governorates of Al-Hasakeh and Ar-Raqqa, which record the highest ratios of refugee return amid UXO presence nationwide.
Both governorates form part of Syria's agricultural breadbasket, where activities such as farming can require turning over soil contaminated with explosive ordnance. The HALO Trust estimates that more than 60 percent of detonation incidents in 2025 have taken place on agricultural or grazing lands, underscoring the particular dangers facing returnees whose livelihoods depend on agriculture.
De-mining activities and awareness-raising initiatives, such as the Syria Mine Action Partner Conference in Geneva held in June 2026, have accelerated in recent months. However, establishing a national baseline of contamination and building trust with affected communities remain significant challenges. As returns continue, considering contamination levels and patterns of refugee return together will be critical to informing mine clearance priorities and supporting safe resettlement.
* * *
Ninar Fawal
Program Manager and Research Associate, Middle East Program
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Original text here: https://www.csis.org/analysis/risk-refugee-return
[Category: ThinkTank]
* * *
Risk to Refugee Return
by Ninar Fawal
October 22, 2026
Unexploded Ordnance (UXO) in Syria Poses Significant Threats to Refugee Return
Estimated UXO per 1000 returnees by governorate
* * *
Map: UXO per 1000 Returnees
* * *
More than 1.7 million Syrian refugees have returned to Syria following the fall of the Bashar al-Assad regime in December 2024, with explosive remnants of war now posing a significant obstacle to safe resettlement. This installment of Charting the Middle East ... Show Full Article WASHINGTON, Oct. 23 -- The Center for Strategic and International Studies issued the following newsletter: * * * Risk to Refugee Return by Ninar Fawal October 22, 2026 Unexploded Ordnance (UXO) in Syria Poses Significant Threats to Refugee Return Estimated UXO per 1000 returnees by governorate * * * Map: UXO per 1000 Returnees * * * More than 1.7 million Syrian refugees have returned to Syria following the fall of the Bashar al-Assad regime in December 2024, with explosive remnants of war now posing a significant obstacle to safe resettlement. This installment of Charting the Middle Easthighlights how the scale of unexploded ordnance (UXO) contamination, relative to returning populations, varies across Syria. These disparities underscore the importance of prioritizing mine clearance and risk awareness efforts in areas of particular concern.
In 2025, Syria was the second-largest recipient of returned refugees worldwide while also reporting the highest number of UXO-related casualties globally. By measuring estimated UXO presence per 1,000 returnees, this analysis identifies a particular challenge in the northeastern governorates of Al-Hasakeh and Ar-Raqqa, which record the highest ratios of refugee return amid UXO presence nationwide.
Both governorates form part of Syria's agricultural breadbasket, where activities such as farming can require turning over soil contaminated with explosive ordnance. The HALO Trust estimates that more than 60 percent of detonation incidents in 2025 have taken place on agricultural or grazing lands, underscoring the particular dangers facing returnees whose livelihoods depend on agriculture.
De-mining activities and awareness-raising initiatives, such as the Syria Mine Action Partner Conference in Geneva held in June 2026, have accelerated in recent months. However, establishing a national baseline of contamination and building trust with affected communities remain significant challenges. As returns continue, considering contamination levels and patterns of refugee return together will be critical to informing mine clearance priorities and supporting safe resettlement.
* * *
Ninar Fawal
Program Manager and Research Associate, Middle East Program
* * *
Original text here: https://www.csis.org/analysis/risk-refugee-return
[Category: ThinkTank]
American Action Forum Issues Insight: OCC's Stablecoin Rule - Limits of Regulatory Clarity
WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight:
* * *
October 22, 2026
The OCC's Stablecoin Rule: The Limits of Regulatory Clarity
Thomas Kingsley
Executive Summary
* The Office of the Comptroller of the Currency (OCC) has finalized its rule implementing the GENIUS Act, establishing requirements for payment stablecoin issuers under its jurisdiction.
* Two changes to the final rule are particularly significant: The OCC eliminated a proposed rebuttable presumption that certain third-party rewards arrangements violate the statutory prohibition on stablecoin ... Show Full Article WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight: * * * October 22, 2026 The OCC's Stablecoin Rule: The Limits of Regulatory Clarity Thomas Kingsley Executive Summary * The Office of the Comptroller of the Currency (OCC) has finalized its rule implementing the GENIUS Act, establishing requirements for payment stablecoin issuers under its jurisdiction. * Two changes to the final rule are particularly significant: The OCC eliminated a proposed rebuttable presumption that certain third-party rewards arrangements violate the statutory prohibition on stablecoinyield and adopted a principles-based approach to reserve diversification and concentration supplemented by quantitative liquidity and counterparty limits.
* Both changes reflect a preference for regulatory flexibility over a more prescriptive framework; they also leave questions about the boundaries of permissible stablecoin rewards, the appropriate treatment of competing financial products, and the extent to which agencies should determine consequential policy choices that Congress has left unresolved.
-
Introduction
The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, enacted in July 2025, establishes a federal framework for payment stablecoins, including requirements for permitted issuers, reserve backing, redemption, and supervision. The Office of the Comptroller of the Currency's (OCC) final rule, effective January 18, 2027, implements the act for issuers under its jurisdiction, including certain bank subsidiaries, federally qualified nonbank issuers, qualifying state issuers subject to OCC oversight, and foreign payment stablecoin issuers. It also establishes requirements for certain custody activities conducted by OCC-supervised entities. The rule addresses most of the OCC's required implementing regulations, with Bank Secrecy Act, anti-money laundering, and sanctions requirements reserved for separate rulemaking.
The final rule establishes standards governing permissible activities, reserve management, redemption, risk management, capital and operational backstops, audits, reporting, licensing, and ongoing supervision. The final rule also amends existing regulations concerning capital adequacy, prompt corrective action, assessments, and administrative proceedings. The OCC received more than 20 comments on its proposal and revised several provisions in response, particularly those concerning reserve management and the prohibition on stablecoin yield. The resulting framework combines statutory requirements and quantitative standards with substantial supervisory discretion. Two changes illustrate the implications of that approach.
The Yield Prohibition: A Rule Without Defined Boundaries
The GENIUS Act prohibits permitted payment stablecoin issuers from paying interest or yield solely in connection with holding, using, or retaining a payment stablecoin. The difficulty lies in determining when a payment described as a reward or commercial incentive is, in substance, prohibited yield. The OCC's proposed rule addressed this question through a rebuttable presumption covering certain arrangements involving issuers and affiliates or related third parties. Under that approach, covered arrangements would be presumed prohibited, subject to an issuer's ability to demonstrate otherwise.
The final rule eliminates this presumption. The OCC concluded that it could capture permissible arrangements while failing to identify other arrangements that violate the statute, and that the resulting rebuttal process could impose compliance costs without a commensurate benefit. Instead, the agency will initially rely on applications, ongoing supervision, and enforcement, issuing additional guidance as appropriate and considering further rulemaking as it gains experience with the market.
This approach preserves flexibility but leaves firms without clear prospective standards for distinguishing permissible transaction-based payments from prohibited yield. The OCC interprets the word "solely" to allow arrangements that serve a genuine purpose beyond holding, using, or retaining a stablecoin to fall outside the prohibition. That does not establish a categorical exemption for transaction-based rewards: The agency retains the authority to examine the substance of an arrangement and address attempts to evade the prohibition. The practical boundaries of the statutory rule will therefore depend in part on future supervisory judgements.
There are arguments for this approach. The market is nascent, and a prescriptive framework could capture legitimate commercial arrangements or become obsolete as business models evolve. But the alternative is not costless. Issuers must assess the legality of rewards programs without knowing how the OCC will treat arrangements that have not yet been addressed. Removing the presumption may reduce one source of compliance burden while increasing the importance of the agency's discretionary interpretation.
The OCC has not abandoned the prohibition or established a general safe harbor for rewards programs. It has instead deferred the development of more specific standards until it has accumulated experience through supervision and enforcement. Whether that sequence produces a more adaptable framework or prolongs uncertainty remains to be seen.
Reserve Requirements: Flexibility Within Statutory Limits
The GENIUS Act specifies the principal categories of eligible reserve assets and requires at least one-to-one backing of outstanding payment stablecoins. Congress therefore made the fundamental policy choice about eligible assets; the OCC's discretion instead concerns the implementation of liquidity, diversification, concentration, and risk-management requirements.
The proposed rule offered two approaches to diversification and concentration: a principles-based standard with an optional quantitative safe harbor, or quantitative requirements for all issuers. The final rule adopts a principles-based approach supplemented by two quantitative requirements. Issuers generally must maintain at least 5 percent of reserve assets in specified funds available on demand, while exposure to a single counterparty is generally limited to 40 percent of reserve assets, subject to specified exclusions and exceptions. The rule omits the proposed weekly liquidity requirement, weighted-average maturity limit, and separate quantitative safe-harbor limits on concentration at individual financial institutions. It also strengthens requirements for monetizing reserves under stress, including stress testing and, where necessary, reserve buffers above outstanding issuance value.
The OCC has not abandoned quantitative reserve regulation; it has narrowed its use while placing greater weight on issuers' ability to demonstrate adequate diversification, liquidity, and operational resilience. This may allow requirements to reflect differences in business models and risk profiles, rather than impose uniform constraints on every issuer. At the same time, principles-based standards leave more room for supervisory interpretation and may make compliance less predictable.
The question is whether the OCC has provided sufficient clarity for firms to understand their obligations while retaining the discretion necessary to manage risks that cannot be fully anticipated in advance. The final rule preserves quantitative safeguards, but its reduced reliance on uniform portfolio constraints places greater weight on consistent supervision.
Is This a Battle Between Banking and Crypto?
The debate over stablecoin rewards is often presented as a contest between traditional banks and crypto firms. Banks have reason to be concerned that stablecoins offering attractive rewards could compete with deposits, while crypto firms have an interest in developing products that make stablecoins more attractive to consumers and businesses. The consequences could extend beyond individual firms to bank funding, lending, and the allocation of money across the financial system.
The scale of those effects remains uncertain. It will depend on the adoption of stablecoins, the structure of rewards programs, the location and stability of reserve deposits, and the extent to which stablecoins substitute for existing payment instruments and bank accounts. Stablecoin reserves can also provide funding to banks, so the relationship between stablecoins and traditional banking is not simply one of displacement. The net effect will depend on where reserves are held and whether stablecoins are acquired from existing bank deposits or other assets.
The policy questions should be distinguished accordingly. Financial stability concerns center on reserve quality, liquidity, redemption, and the possibility of destabilizing outflows. Competition concerns center on whether firms offering economically similar products face comparable risks and regulatory burdens. Protecting bank deposits from competition is a separate objective that should be evaluated on its merits rather than assumed to follow from the need for financial stability.
The distinction between banking and crypto matters to the extent that competing business models present different risks or operate under different regulatory constraints. It matters less when industry labels substitute for an examination of the economic substance of competing products. The central issue is whether the framework permits competition consistent with financial stability, not whether one industry prevails in a regulatory dispute.
Congress and the Agencies: Who Makes the Policy?
The final rule illustrates the limits of congressional legislation that leaves consequential implementation questions unresolved. Congress enacted the GENIUS Act, specified eligible reserve assets, and prohibited certain stablecoin yield payments. It also directed regulators to establish standards for liquidity, diversification, risk management, and other aspects of issuer supervision. The OCC's task is to translate those statutory requirements into administrable rules, but that task necessarily involves judgements that can affect market structure and competition.
The yield prohibition is a particularly clear example. Congress established the legal boundary, but the application of that boundary to third-party rewards and commercial arrangements remains uncertain. The OCC proposed a presumption, received objections that it could capture permissible arrangements, and removed it from the final rule. The agency will now develop its understanding through supervision and enforcement before considering further rulemaking. That may be a defensible response to uncertainty, but it leaves the practical scope of the prohibition to be developed over time - and future development and administration to future agencies and administrations.
Reserve regulation presents a different balance. Congress specified eligible assets and minimum backing, while delegating the development of risk-management standards to regulators. The OCC's final rule retains quantitative requirements but relies more heavily on principles-based diversification and concentration standards. Here, discretion is not an alternative to statutory direction; it is part of the implementation authority Congress expressly provided.
The broader question is where implementation ends and policymaking begins. Agencies need discretion to respond to changing markets and unforeseen risks, but extensive reliance on supervision and case-specific interpretation can leave firms uncertain about the rules governing their conduct. Conversely, rigid statutory requirements may become outdated or impose costs that Congress did not anticipate.
The standard should be practical: Firms should be able to understand the principal factors governing compliance before making consequential business decisions, without requiring the OCC to prescribe the treatment of every possible arrangement. Where the agency's interpretation determines which business models can compete, it should explain its reasoning and provide meaningful notice of the standards it intends to apply.
These questions will become more consequential as stablecoins develop and the regulatory framework expands. The OCC has stated that it expects to update its rules and supplement them with guidance as market practices evolve. That approach acknowledges the limits of what can be resolved in a first rulemaking, but it also makes the quality and transparency of future implementation central to the success of the statutory framework.
Conclusion
The OCC's final rule establishes a substantial framework for payment stablecoin issuance, but its most consequential choices increase the discretion retained by the agency. Eliminating the rebuttable presumption leaves the yield prohibition in place while deferring clearer standards for its application; the reserve provisions preserve quantitative safeguards while relying more heavily on principles-based supervision. Neither change necessarily proves that the OCC has sided with banks or crypto firms. If anything, the OCC appears to have sided with itself. Firms should not have to discover the limits of a federal prohibition by guessing what a regulator might decide after the fact. Delegated discretion is not permission to leave consequential policy questions unresolved.
* * *
Thomas Kingsley is the Director of Financial Services Policy at the American Action Forum.
* * *
Original text here: https://www.americanactionforum.org/insight/the-occs-stablecoin-rule-the-limits-of-regulatory-clarity/
[Category: Think Tank]
* * *
October 22, 2026
The OCC's Stablecoin Rule: The Limits of Regulatory Clarity
Thomas Kingsley
Executive Summary
* The Office of the Comptroller of the Currency (OCC) has finalized its rule implementing the GENIUS Act, establishing requirements for payment stablecoin issuers under its jurisdiction.
* Two changes to the final rule are particularly significant: The OCC eliminated a proposed rebuttable presumption that certain third-party rewards arrangements violate the statutory prohibition on stablecoin ... Show Full Article WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight: * * * October 22, 2026 The OCC's Stablecoin Rule: The Limits of Regulatory Clarity Thomas Kingsley Executive Summary * The Office of the Comptroller of the Currency (OCC) has finalized its rule implementing the GENIUS Act, establishing requirements for payment stablecoin issuers under its jurisdiction. * Two changes to the final rule are particularly significant: The OCC eliminated a proposed rebuttable presumption that certain third-party rewards arrangements violate the statutory prohibition on stablecoinyield and adopted a principles-based approach to reserve diversification and concentration supplemented by quantitative liquidity and counterparty limits.
* Both changes reflect a preference for regulatory flexibility over a more prescriptive framework; they also leave questions about the boundaries of permissible stablecoin rewards, the appropriate treatment of competing financial products, and the extent to which agencies should determine consequential policy choices that Congress has left unresolved.
-
Introduction
The Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act, enacted in July 2025, establishes a federal framework for payment stablecoins, including requirements for permitted issuers, reserve backing, redemption, and supervision. The Office of the Comptroller of the Currency's (OCC) final rule, effective January 18, 2027, implements the act for issuers under its jurisdiction, including certain bank subsidiaries, federally qualified nonbank issuers, qualifying state issuers subject to OCC oversight, and foreign payment stablecoin issuers. It also establishes requirements for certain custody activities conducted by OCC-supervised entities. The rule addresses most of the OCC's required implementing regulations, with Bank Secrecy Act, anti-money laundering, and sanctions requirements reserved for separate rulemaking.
The final rule establishes standards governing permissible activities, reserve management, redemption, risk management, capital and operational backstops, audits, reporting, licensing, and ongoing supervision. The final rule also amends existing regulations concerning capital adequacy, prompt corrective action, assessments, and administrative proceedings. The OCC received more than 20 comments on its proposal and revised several provisions in response, particularly those concerning reserve management and the prohibition on stablecoin yield. The resulting framework combines statutory requirements and quantitative standards with substantial supervisory discretion. Two changes illustrate the implications of that approach.
The Yield Prohibition: A Rule Without Defined Boundaries
The GENIUS Act prohibits permitted payment stablecoin issuers from paying interest or yield solely in connection with holding, using, or retaining a payment stablecoin. The difficulty lies in determining when a payment described as a reward or commercial incentive is, in substance, prohibited yield. The OCC's proposed rule addressed this question through a rebuttable presumption covering certain arrangements involving issuers and affiliates or related third parties. Under that approach, covered arrangements would be presumed prohibited, subject to an issuer's ability to demonstrate otherwise.
The final rule eliminates this presumption. The OCC concluded that it could capture permissible arrangements while failing to identify other arrangements that violate the statute, and that the resulting rebuttal process could impose compliance costs without a commensurate benefit. Instead, the agency will initially rely on applications, ongoing supervision, and enforcement, issuing additional guidance as appropriate and considering further rulemaking as it gains experience with the market.
This approach preserves flexibility but leaves firms without clear prospective standards for distinguishing permissible transaction-based payments from prohibited yield. The OCC interprets the word "solely" to allow arrangements that serve a genuine purpose beyond holding, using, or retaining a stablecoin to fall outside the prohibition. That does not establish a categorical exemption for transaction-based rewards: The agency retains the authority to examine the substance of an arrangement and address attempts to evade the prohibition. The practical boundaries of the statutory rule will therefore depend in part on future supervisory judgements.
There are arguments for this approach. The market is nascent, and a prescriptive framework could capture legitimate commercial arrangements or become obsolete as business models evolve. But the alternative is not costless. Issuers must assess the legality of rewards programs without knowing how the OCC will treat arrangements that have not yet been addressed. Removing the presumption may reduce one source of compliance burden while increasing the importance of the agency's discretionary interpretation.
The OCC has not abandoned the prohibition or established a general safe harbor for rewards programs. It has instead deferred the development of more specific standards until it has accumulated experience through supervision and enforcement. Whether that sequence produces a more adaptable framework or prolongs uncertainty remains to be seen.
Reserve Requirements: Flexibility Within Statutory Limits
The GENIUS Act specifies the principal categories of eligible reserve assets and requires at least one-to-one backing of outstanding payment stablecoins. Congress therefore made the fundamental policy choice about eligible assets; the OCC's discretion instead concerns the implementation of liquidity, diversification, concentration, and risk-management requirements.
The proposed rule offered two approaches to diversification and concentration: a principles-based standard with an optional quantitative safe harbor, or quantitative requirements for all issuers. The final rule adopts a principles-based approach supplemented by two quantitative requirements. Issuers generally must maintain at least 5 percent of reserve assets in specified funds available on demand, while exposure to a single counterparty is generally limited to 40 percent of reserve assets, subject to specified exclusions and exceptions. The rule omits the proposed weekly liquidity requirement, weighted-average maturity limit, and separate quantitative safe-harbor limits on concentration at individual financial institutions. It also strengthens requirements for monetizing reserves under stress, including stress testing and, where necessary, reserve buffers above outstanding issuance value.
The OCC has not abandoned quantitative reserve regulation; it has narrowed its use while placing greater weight on issuers' ability to demonstrate adequate diversification, liquidity, and operational resilience. This may allow requirements to reflect differences in business models and risk profiles, rather than impose uniform constraints on every issuer. At the same time, principles-based standards leave more room for supervisory interpretation and may make compliance less predictable.
The question is whether the OCC has provided sufficient clarity for firms to understand their obligations while retaining the discretion necessary to manage risks that cannot be fully anticipated in advance. The final rule preserves quantitative safeguards, but its reduced reliance on uniform portfolio constraints places greater weight on consistent supervision.
Is This a Battle Between Banking and Crypto?
The debate over stablecoin rewards is often presented as a contest between traditional banks and crypto firms. Banks have reason to be concerned that stablecoins offering attractive rewards could compete with deposits, while crypto firms have an interest in developing products that make stablecoins more attractive to consumers and businesses. The consequences could extend beyond individual firms to bank funding, lending, and the allocation of money across the financial system.
The scale of those effects remains uncertain. It will depend on the adoption of stablecoins, the structure of rewards programs, the location and stability of reserve deposits, and the extent to which stablecoins substitute for existing payment instruments and bank accounts. Stablecoin reserves can also provide funding to banks, so the relationship between stablecoins and traditional banking is not simply one of displacement. The net effect will depend on where reserves are held and whether stablecoins are acquired from existing bank deposits or other assets.
The policy questions should be distinguished accordingly. Financial stability concerns center on reserve quality, liquidity, redemption, and the possibility of destabilizing outflows. Competition concerns center on whether firms offering economically similar products face comparable risks and regulatory burdens. Protecting bank deposits from competition is a separate objective that should be evaluated on its merits rather than assumed to follow from the need for financial stability.
The distinction between banking and crypto matters to the extent that competing business models present different risks or operate under different regulatory constraints. It matters less when industry labels substitute for an examination of the economic substance of competing products. The central issue is whether the framework permits competition consistent with financial stability, not whether one industry prevails in a regulatory dispute.
Congress and the Agencies: Who Makes the Policy?
The final rule illustrates the limits of congressional legislation that leaves consequential implementation questions unresolved. Congress enacted the GENIUS Act, specified eligible reserve assets, and prohibited certain stablecoin yield payments. It also directed regulators to establish standards for liquidity, diversification, risk management, and other aspects of issuer supervision. The OCC's task is to translate those statutory requirements into administrable rules, but that task necessarily involves judgements that can affect market structure and competition.
The yield prohibition is a particularly clear example. Congress established the legal boundary, but the application of that boundary to third-party rewards and commercial arrangements remains uncertain. The OCC proposed a presumption, received objections that it could capture permissible arrangements, and removed it from the final rule. The agency will now develop its understanding through supervision and enforcement before considering further rulemaking. That may be a defensible response to uncertainty, but it leaves the practical scope of the prohibition to be developed over time - and future development and administration to future agencies and administrations.
Reserve regulation presents a different balance. Congress specified eligible assets and minimum backing, while delegating the development of risk-management standards to regulators. The OCC's final rule retains quantitative requirements but relies more heavily on principles-based diversification and concentration standards. Here, discretion is not an alternative to statutory direction; it is part of the implementation authority Congress expressly provided.
The broader question is where implementation ends and policymaking begins. Agencies need discretion to respond to changing markets and unforeseen risks, but extensive reliance on supervision and case-specific interpretation can leave firms uncertain about the rules governing their conduct. Conversely, rigid statutory requirements may become outdated or impose costs that Congress did not anticipate.
The standard should be practical: Firms should be able to understand the principal factors governing compliance before making consequential business decisions, without requiring the OCC to prescribe the treatment of every possible arrangement. Where the agency's interpretation determines which business models can compete, it should explain its reasoning and provide meaningful notice of the standards it intends to apply.
These questions will become more consequential as stablecoins develop and the regulatory framework expands. The OCC has stated that it expects to update its rules and supplement them with guidance as market practices evolve. That approach acknowledges the limits of what can be resolved in a first rulemaking, but it also makes the quality and transparency of future implementation central to the success of the statutory framework.
Conclusion
The OCC's final rule establishes a substantial framework for payment stablecoin issuance, but its most consequential choices increase the discretion retained by the agency. Eliminating the rebuttable presumption leaves the yield prohibition in place while deferring clearer standards for its application; the reserve provisions preserve quantitative safeguards while relying more heavily on principles-based supervision. Neither change necessarily proves that the OCC has sided with banks or crypto firms. If anything, the OCC appears to have sided with itself. Firms should not have to discover the limits of a federal prohibition by guessing what a regulator might decide after the fact. Delegated discretion is not permission to leave consequential policy questions unresolved.
* * *
Thomas Kingsley is the Director of Financial Services Policy at the American Action Forum.
* * *
Original text here: https://www.americanactionforum.org/insight/the-occs-stablecoin-rule-the-limits-of-regulatory-clarity/
[Category: Think Tank]
American Action Forum Issues Insight: Lowering Housing Costs, Expanding Federal Risk?
WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight:
* * *
October 22, 2026
Lowering Housing Costs, Expanding Federal Risk?
Thomas Kingsley
Executive Summary
* President Trump today issued an executive order Decreasing Housing Costs For The American People directing the Federal Housing Finance Agency to use its authority over Fannie Mae and Freddie Mac to lower mortgage-insurance and refinance closing costs through automated tools, while establishing a task force to expand factory-built housing and instructing the Departments of Agriculture and Veterans Affairs ... Show Full Article WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight: * * * October 22, 2026 Lowering Housing Costs, Expanding Federal Risk? Thomas Kingsley Executive Summary * President Trump today issued an executive order Decreasing Housing Costs For The American People directing the Federal Housing Finance Agency to use its authority over Fannie Mae and Freddie Mac to lower mortgage-insurance and refinance closing costs through automated tools, while establishing a task force to expand factory-built housing and instructing the Departments of Agriculture and Veterans Affairsto reduce rates on certain direct loans.
* Although these measures could reduce transaction costs and ease some regulatory barriers to construction, the package primarily addresses financing frictions rather than the underlying supply constraints on new housing; they also prompt questions about the reliability of automated risk assessments and the appropriate role of the federal government in housing finance.
* Implementation will determine whether borrowers realize meaningful savings without weakening risk discipline, increasing taxpayer exposure, or further entrenching federal involvement in the housing market at the expense of private competition.
-
Introduction
Housing affordability is fundamentally constrained by the insufficient supply of homes in the places people want to live. Part of this problem is bureaucratic: Restrictive zoning, permitting delays, impact fees, and other barriers to construction limit the ability of the housing market to respond to demand, contributing to high prices and making homeownership unaffordable. President Trump's executive order Decreasing Housing Costs For The American People seeks to address some of these costs by directing the Federal Housing Finance Agency (FHFA), using its authority over Fannie Mae and Freddie Mac, the housing government-sponsored enterprises (GSEs) to drive down costs and reduce regulatory friction by expanding the role of automated tools and advancing factory-built housing. It also instructs the Departments of Agriculture (USDA) and Veterans Affairs (VA) to lower rates on certain direct loans, consistent with statute and available appropriations.
The EO builds on previous efforts, including the 2024 title-acceptance pilot, existing GSE practices concerning servicer outreach for mortgage-insurance cancellation, and broader deregulatory proposals. But how much does it actually do to expand the housing supply, rather than lower the cost of buying, refinancing, and carrying existing homes? The order's push to use advanced automation and "Super Intelligence" also raises questions about reliability and risk given the use of new an untested technologies. More fundamentally, even if the order delivers benefits does that justify a greater federal role in housing finance? Using the federally backed GSEs to reduce transaction costs may bring some benefits, but could also displace private alternatives and further entrench government involvement in the market.
Proactive Cancellation of "Excessive" Mortgage Insurance
Section 2 of the EO instructs the FHFA director to instruct the GSEs--where consistent with their interests, safety and soundness, and applicable requirements--to review single-family loans periodically using automated valuation models and other data, identify borrowers who appear to meet equity thresholds, and cancel "excessive" mortgage insurance when those thresholds and other conditions are satisfied. Using the language of "excessive" (and a clarification that proactive cancellation will not apply to historic private mortgage insurance) appears to attempt to differentiate between private mortgage insurance writ large and that which is unnecessary or unwanted, but does not provide any new definitional standard. The executive order also requires the creation of a pilot program for testing purposes.
Existing rules allow borrowers to request mortgage-insurance cancellation once they meet the applicable equity and other eligibility requirements. The EO would go further by directing Fannie Mae and Freddie Mac to regularly review their loans, use current property values to identify eligible borrowers, and proactively cancel mortgage insurance when all requirements are met. This could save homeowners money by ending premiums they would otherwise continue paying unnecessarily. Using automated valuation models could also reduce the need for costly appraisals and simplify the cancellation process.
The harder questions concern model risk and the credit exposure left behind. Automated valuations can overstate property values, and errors may be correlated across regions or property types. If that leads to mortgage insurance being cancelled prematurely, the GSEs could face larger losses when borrowers default. A downturn could expose weaknesses that were less apparent in a rising market, particularly if valuation errors move together. The EO's push to employ "Super Intelligence" does not eliminate these risks; it may amplify them if models rely on flawed data or shared assumptions. FHFA will need clear eligibility standards, transparent performance measures, and ongoing model validation to ensure that cost savings do not come at the expense of sound underwriting.
Manufactured Housing and the Task Force
Section 3 of the EO establishes an interagency task force co-chaired by the Department of Housing and Urban Development and FHFA to recommend ways to expand modern factory-built housing eligible for federal programs--through common specifications, reciprocal recognition of inspections and certifications, elimination of duplicative federal requirements, and the use of federal financing and guarantee authorities. It is also to evaluate conditioning grant funding on state and local adoption of standardized permitting and to prepare legislative recommendations.
Factory-built and modular housing offer a promising way to increase supply and lower construction costs, particularly where regulation prevents manufacturers from benefiting from standardized, off-site production. The ROAD to Housing framework takes a similar approach by modernizing manufactured-housing requirements and reducing barriers to construction. The EO builds on that effort through reciprocal recognition of inspections and certifications, fewer duplicative federal requirements, and consideration of grant conditions tied to state and local permitting reform. These steps could help, but they will not resolve local zoning and land-use restrictions that prevent homes from being built in the first place. Any grant conditions should also use clear, objective standards rather than leave federal agencies broad discretion over local policy. The measure of success will be whether more homes get built faster and at lower cost.
Expanding Title Acceptance, the USDA and the VA
Section 4 of the EO directs expansion of the 2024 pilot into a nationwide program under which the GSEs may accept automated title reviews or other approved assessments in place of traditional lenders' title insurance on eligible refinances. Higher loan-to-value ratios, broader provider competition, reduced documentation for payment-reducing refinances, and lower GSE fees are all to be considered, with savings required to flow to borrowers.
The title-acceptance pilot was initially limited to certain low-risk refinances, but expanding it nationwide raises questions about who ultimately bears the risk. Title defects may be uncommon, but losses can be significant, and any additional exposure for the GSEs will depend on how liability is divided among the GSEs, lenders, and assessment providers. Competition among providers could lower costs, but it should not come at the expense of sound standards. FHFA should establish whether automated assessments can deliver meaningful savings while keeping responsibility for errors clear and avoiding unnecessary expansion of the GSEs' role at taxpayers' expense.
The EO also directs VA and USDA to reduce interest rates on certain direct home loans, subject to applicable law and available appropriations. These reductions could benefit eligible borrowers, but their scale and fiscal implications are not established in the order, and they do little to address the underlying shortage of housing.
Conclusion
Any good-faith attempt to lower mortgage-insurance premiums, refinance closing costs, and barriers to factory-built housing is to be celebrated, but the real test is whether these measures deliver meaningful savings without increasing taxpayer exposure. The directive remains focused on making housing transactions cheaper rather than addressing the underlying shortage of homes. And while the GSEs may be useful tools for reducing certain costs, they should not become the federal government's answer to every housing-market problem. Lasting affordability will require more homes, fewer barriers to construction, and greater room for private competition--not another expansion of federal involvement in a market already struggling under the weight of its own constraints.
* * *
Thomas Kingsley is the Director of Financial Services Policy at the American Action Forum.
* * *
Original text here: https://www.americanactionforum.org/insight/lowering-housing-costs-expanding-federal-risk/
[Category: Think Tank]
* * *
October 22, 2026
Lowering Housing Costs, Expanding Federal Risk?
Thomas Kingsley
Executive Summary
* President Trump today issued an executive order Decreasing Housing Costs For The American People directing the Federal Housing Finance Agency to use its authority over Fannie Mae and Freddie Mac to lower mortgage-insurance and refinance closing costs through automated tools, while establishing a task force to expand factory-built housing and instructing the Departments of Agriculture and Veterans Affairs ... Show Full Article WASHINGTON, Oct. 23 -- The American Action Forum issued the following insight: * * * October 22, 2026 Lowering Housing Costs, Expanding Federal Risk? Thomas Kingsley Executive Summary * President Trump today issued an executive order Decreasing Housing Costs For The American People directing the Federal Housing Finance Agency to use its authority over Fannie Mae and Freddie Mac to lower mortgage-insurance and refinance closing costs through automated tools, while establishing a task force to expand factory-built housing and instructing the Departments of Agriculture and Veterans Affairsto reduce rates on certain direct loans.
* Although these measures could reduce transaction costs and ease some regulatory barriers to construction, the package primarily addresses financing frictions rather than the underlying supply constraints on new housing; they also prompt questions about the reliability of automated risk assessments and the appropriate role of the federal government in housing finance.
* Implementation will determine whether borrowers realize meaningful savings without weakening risk discipline, increasing taxpayer exposure, or further entrenching federal involvement in the housing market at the expense of private competition.
-
Introduction
Housing affordability is fundamentally constrained by the insufficient supply of homes in the places people want to live. Part of this problem is bureaucratic: Restrictive zoning, permitting delays, impact fees, and other barriers to construction limit the ability of the housing market to respond to demand, contributing to high prices and making homeownership unaffordable. President Trump's executive order Decreasing Housing Costs For The American People seeks to address some of these costs by directing the Federal Housing Finance Agency (FHFA), using its authority over Fannie Mae and Freddie Mac, the housing government-sponsored enterprises (GSEs) to drive down costs and reduce regulatory friction by expanding the role of automated tools and advancing factory-built housing. It also instructs the Departments of Agriculture (USDA) and Veterans Affairs (VA) to lower rates on certain direct loans, consistent with statute and available appropriations.
The EO builds on previous efforts, including the 2024 title-acceptance pilot, existing GSE practices concerning servicer outreach for mortgage-insurance cancellation, and broader deregulatory proposals. But how much does it actually do to expand the housing supply, rather than lower the cost of buying, refinancing, and carrying existing homes? The order's push to use advanced automation and "Super Intelligence" also raises questions about reliability and risk given the use of new an untested technologies. More fundamentally, even if the order delivers benefits does that justify a greater federal role in housing finance? Using the federally backed GSEs to reduce transaction costs may bring some benefits, but could also displace private alternatives and further entrench government involvement in the market.
Proactive Cancellation of "Excessive" Mortgage Insurance
Section 2 of the EO instructs the FHFA director to instruct the GSEs--where consistent with their interests, safety and soundness, and applicable requirements--to review single-family loans periodically using automated valuation models and other data, identify borrowers who appear to meet equity thresholds, and cancel "excessive" mortgage insurance when those thresholds and other conditions are satisfied. Using the language of "excessive" (and a clarification that proactive cancellation will not apply to historic private mortgage insurance) appears to attempt to differentiate between private mortgage insurance writ large and that which is unnecessary or unwanted, but does not provide any new definitional standard. The executive order also requires the creation of a pilot program for testing purposes.
Existing rules allow borrowers to request mortgage-insurance cancellation once they meet the applicable equity and other eligibility requirements. The EO would go further by directing Fannie Mae and Freddie Mac to regularly review their loans, use current property values to identify eligible borrowers, and proactively cancel mortgage insurance when all requirements are met. This could save homeowners money by ending premiums they would otherwise continue paying unnecessarily. Using automated valuation models could also reduce the need for costly appraisals and simplify the cancellation process.
The harder questions concern model risk and the credit exposure left behind. Automated valuations can overstate property values, and errors may be correlated across regions or property types. If that leads to mortgage insurance being cancelled prematurely, the GSEs could face larger losses when borrowers default. A downturn could expose weaknesses that were less apparent in a rising market, particularly if valuation errors move together. The EO's push to employ "Super Intelligence" does not eliminate these risks; it may amplify them if models rely on flawed data or shared assumptions. FHFA will need clear eligibility standards, transparent performance measures, and ongoing model validation to ensure that cost savings do not come at the expense of sound underwriting.
Manufactured Housing and the Task Force
Section 3 of the EO establishes an interagency task force co-chaired by the Department of Housing and Urban Development and FHFA to recommend ways to expand modern factory-built housing eligible for federal programs--through common specifications, reciprocal recognition of inspections and certifications, elimination of duplicative federal requirements, and the use of federal financing and guarantee authorities. It is also to evaluate conditioning grant funding on state and local adoption of standardized permitting and to prepare legislative recommendations.
Factory-built and modular housing offer a promising way to increase supply and lower construction costs, particularly where regulation prevents manufacturers from benefiting from standardized, off-site production. The ROAD to Housing framework takes a similar approach by modernizing manufactured-housing requirements and reducing barriers to construction. The EO builds on that effort through reciprocal recognition of inspections and certifications, fewer duplicative federal requirements, and consideration of grant conditions tied to state and local permitting reform. These steps could help, but they will not resolve local zoning and land-use restrictions that prevent homes from being built in the first place. Any grant conditions should also use clear, objective standards rather than leave federal agencies broad discretion over local policy. The measure of success will be whether more homes get built faster and at lower cost.
Expanding Title Acceptance, the USDA and the VA
Section 4 of the EO directs expansion of the 2024 pilot into a nationwide program under which the GSEs may accept automated title reviews or other approved assessments in place of traditional lenders' title insurance on eligible refinances. Higher loan-to-value ratios, broader provider competition, reduced documentation for payment-reducing refinances, and lower GSE fees are all to be considered, with savings required to flow to borrowers.
The title-acceptance pilot was initially limited to certain low-risk refinances, but expanding it nationwide raises questions about who ultimately bears the risk. Title defects may be uncommon, but losses can be significant, and any additional exposure for the GSEs will depend on how liability is divided among the GSEs, lenders, and assessment providers. Competition among providers could lower costs, but it should not come at the expense of sound standards. FHFA should establish whether automated assessments can deliver meaningful savings while keeping responsibility for errors clear and avoiding unnecessary expansion of the GSEs' role at taxpayers' expense.
The EO also directs VA and USDA to reduce interest rates on certain direct home loans, subject to applicable law and available appropriations. These reductions could benefit eligible borrowers, but their scale and fiscal implications are not established in the order, and they do little to address the underlying shortage of housing.
Conclusion
Any good-faith attempt to lower mortgage-insurance premiums, refinance closing costs, and barriers to factory-built housing is to be celebrated, but the real test is whether these measures deliver meaningful savings without increasing taxpayer exposure. The directive remains focused on making housing transactions cheaper rather than addressing the underlying shortage of homes. And while the GSEs may be useful tools for reducing certain costs, they should not become the federal government's answer to every housing-market problem. Lasting affordability will require more homes, fewer barriers to construction, and greater room for private competition--not another expansion of federal involvement in a market already struggling under the weight of its own constraints.
* * *
Thomas Kingsley is the Director of Financial Services Policy at the American Action Forum.
* * *
Original text here: https://www.americanactionforum.org/insight/lowering-housing-costs-expanding-federal-risk/
[Category: Think Tank]
America First Policy Institute Issues Letter to Ark. Human Services Secretary Mann
WASHINGTON, Oct. 23 (TNSletter) -- The America First Policy Institute issued the following letter to Arkansas Human Services Secretary Janet Mann:
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Here is the text of the letter:
October 13, 2026
Ms. Janet Mann, Secretary
Arkansas Department of Human Services
700 Main Street
P.O. Box 1437, Slot S201
Little Rock, Arkansas 72203
RE: Updated CMS Guidance Protecting Voting Rights in Arkansas Nursing Facilities QSSAM-26-04-NH
Dear Secretary Mann:
On behalf of the America First Policy Institute (AFPI), we hereby request that the Arkansas Department of Human Services (DHS) promptly notify ... Show Full Article WASHINGTON, Oct. 23 (TNSletter) -- The America First Policy Institute issued the following letter to Arkansas Human Services Secretary Janet Mann: * * * Here is the text of the letter: October 13, 2026 Ms. Janet Mann, Secretary Arkansas Department of Human Services 700 Main Street P.O. Box 1437, Slot S201 Little Rock, Arkansas 72203 RE: Updated CMS Guidance Protecting Voting Rights in Arkansas Nursing Facilities QSSAM-26-04-NH Dear Secretary Mann: On behalf of the America First Policy Institute (AFPI), we hereby request that the Arkansas Department of Human Services (DHS) promptly notifyMedicaid nursing facilities of updated federal guidance protecting residents' voting rights and autonomy. We also ask that DHS ensure compliance with resident rights and notice requirements.
On July 20, 2026, the Centers for Medicare & Medicaid Services (CMS) issued Quality and Safety Special Alert Memo QSSAM-26-04-[NH],1 Protecting the Voting Rights and Autonomy of Vulnerable Residents in Long-Term Care (LTC) Facilities, rescinding QSO-21-02-[NH]2 and QSO-24-21-[NH].3 The alert provides notice to nursing facilities and skilled nursing facilities of their obligation to comply with all applicable federal and state laws and regulations to avoid instances of coercion or other violations of resident rights or voter protection laws.
Under 42 C.F.R. Sec. 483.10(b)(1)-(2), facilities must support residents' exercise of their rights and protect them from interference, coercion, discrimination, and reprisal. The CMS alert specifically cautions against registering residents without their knowledge or consent and completing a resident's mail ballot without authorization. The alert also recognizes residents' freedom to decline participation and calls for residents needing assistance to be offered help from their authorized representative. Under 52 U.S.C. Sec. 10508, voters needing assistance because of blindness, disability, or inability to read or write may choose their assistant, except their employer, an employer's agent, or a union officer or agent. Nursing facilities offering representative assistance must respect that choice.
Consistent with the voting rights of Arkansas residents living in nursing and assisted living facilities, the State of Arkansas has affirmative oversight and educational duties. Under 42 U.S.C. Sec. 1396r(g)(1)(A)-(B) the State is responsible for certifying compliance by nursing facilities other than state facilities and requires periodic educational programs for facility staff, residents, and their representatives on current regulations, procedures, and policies, including those related to resident's rights to vote.
Federal law also requires facilities to provide residents notice of their rights before or upon admission and during their stay, to explain those rights orally and in writing in a language they understand, and obtain written acknowledgment of the information and amendments. See 42 C.F.R. Sec. 483.10(g)(16). They must also promptly notify residents and their representatives, if any, of changes in resident rights under federal or state law or regulations. 42 C.F.R. Sec. 483.10(g)(14)(iii)(B). The CMS alert specifies that notice should be provided to authorized representatives when residents' legal or civil rights related to voting change. This includes a change in voter registration status.
Accordingly, we ask DHS to take the following steps promptly:
1. Circulate the CMS alert and a bulletin explaining resident protections and notice requirements to every Arkansas Medicaid nursing facility and relevant survey personnel.
2. Direct facilities to review voting assistance practices and resident notices, train staff on consent and the resident's choice of assistant, and ensure required notices reach residents and authorized representatives.
3. Use Arkansas's periodic educational programs to explain these protections to staff, residents, and representatives, and address substantiated noncompliance through applicable survey and enforcement procedures.
4. Coordinate with election officials on lawful assistance, including through the use of bipartisan election workers where authorized by state law, and publicize DHS's complaint process4 and hotline, 800-582-4887.
CMS participation requirements govern federally certified nursing facilities and do not automatically extend to assisted living or other facilities solely because they are state licensed. Federal voting protections apply independently of nursing facility certification. Federal law prohibits voting-related intimidation, threats, and coercion.52 U.S.C. Sec. 10307(b). For elections involving federal office, knowing and willful intimidation and fraud involving registration applications or ballots is also prohibited. 52 U.S.C. Sec. 20511, 52 U.S.C. Sec. 10307(c).
AFPI invites DHS to reproduce and distribute the enclosed poster which summarizes federal protections and provides required notices, to administrators, staff, residents, and representatives, and to include it in training and resident information materials.
We welcome the opportunity for further collaboration on your voter education efforts and respectfully request that you share your office's plans to ensure this information is properly distributed to facilities throughout Arkansas.
Sincerely,
Ashley Hayek, Executive Vice President, America First Policy Institute
The Hon. J. Kenneth Blackwell, Chair, Secure Elections, America First Policy Institute
Encl.
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Original text and footnotes here: https://americafirstpolicy.com/wp-content/uploads/2026/10/CMS-Guidance-Letter-to-State-Agency-Heads-Arkansas.pdf
News Release here: https://americafirstpolicy.com/issues/afpi-moves-to-protect-vulnerable-voters-in-nursing-homes-from-coercive-ballot-harvesting-schemes/
[Category: ThinkTank]
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Here is the text of the letter:
October 13, 2026
Ms. Janet Mann, Secretary
Arkansas Department of Human Services
700 Main Street
P.O. Box 1437, Slot S201
Little Rock, Arkansas 72203
RE: Updated CMS Guidance Protecting Voting Rights in Arkansas Nursing Facilities QSSAM-26-04-NH
Dear Secretary Mann:
On behalf of the America First Policy Institute (AFPI), we hereby request that the Arkansas Department of Human Services (DHS) promptly notify ... Show Full Article WASHINGTON, Oct. 23 (TNSletter) -- The America First Policy Institute issued the following letter to Arkansas Human Services Secretary Janet Mann: * * * Here is the text of the letter: October 13, 2026 Ms. Janet Mann, Secretary Arkansas Department of Human Services 700 Main Street P.O. Box 1437, Slot S201 Little Rock, Arkansas 72203 RE: Updated CMS Guidance Protecting Voting Rights in Arkansas Nursing Facilities QSSAM-26-04-NH Dear Secretary Mann: On behalf of the America First Policy Institute (AFPI), we hereby request that the Arkansas Department of Human Services (DHS) promptly notifyMedicaid nursing facilities of updated federal guidance protecting residents' voting rights and autonomy. We also ask that DHS ensure compliance with resident rights and notice requirements.
On July 20, 2026, the Centers for Medicare & Medicaid Services (CMS) issued Quality and Safety Special Alert Memo QSSAM-26-04-[NH],1 Protecting the Voting Rights and Autonomy of Vulnerable Residents in Long-Term Care (LTC) Facilities, rescinding QSO-21-02-[NH]2 and QSO-24-21-[NH].3 The alert provides notice to nursing facilities and skilled nursing facilities of their obligation to comply with all applicable federal and state laws and regulations to avoid instances of coercion or other violations of resident rights or voter protection laws.
Under 42 C.F.R. Sec. 483.10(b)(1)-(2), facilities must support residents' exercise of their rights and protect them from interference, coercion, discrimination, and reprisal. The CMS alert specifically cautions against registering residents without their knowledge or consent and completing a resident's mail ballot without authorization. The alert also recognizes residents' freedom to decline participation and calls for residents needing assistance to be offered help from their authorized representative. Under 52 U.S.C. Sec. 10508, voters needing assistance because of blindness, disability, or inability to read or write may choose their assistant, except their employer, an employer's agent, or a union officer or agent. Nursing facilities offering representative assistance must respect that choice.
Consistent with the voting rights of Arkansas residents living in nursing and assisted living facilities, the State of Arkansas has affirmative oversight and educational duties. Under 42 U.S.C. Sec. 1396r(g)(1)(A)-(B) the State is responsible for certifying compliance by nursing facilities other than state facilities and requires periodic educational programs for facility staff, residents, and their representatives on current regulations, procedures, and policies, including those related to resident's rights to vote.
Federal law also requires facilities to provide residents notice of their rights before or upon admission and during their stay, to explain those rights orally and in writing in a language they understand, and obtain written acknowledgment of the information and amendments. See 42 C.F.R. Sec. 483.10(g)(16). They must also promptly notify residents and their representatives, if any, of changes in resident rights under federal or state law or regulations. 42 C.F.R. Sec. 483.10(g)(14)(iii)(B). The CMS alert specifies that notice should be provided to authorized representatives when residents' legal or civil rights related to voting change. This includes a change in voter registration status.
Accordingly, we ask DHS to take the following steps promptly:
1. Circulate the CMS alert and a bulletin explaining resident protections and notice requirements to every Arkansas Medicaid nursing facility and relevant survey personnel.
2. Direct facilities to review voting assistance practices and resident notices, train staff on consent and the resident's choice of assistant, and ensure required notices reach residents and authorized representatives.
3. Use Arkansas's periodic educational programs to explain these protections to staff, residents, and representatives, and address substantiated noncompliance through applicable survey and enforcement procedures.
4. Coordinate with election officials on lawful assistance, including through the use of bipartisan election workers where authorized by state law, and publicize DHS's complaint process4 and hotline, 800-582-4887.
CMS participation requirements govern federally certified nursing facilities and do not automatically extend to assisted living or other facilities solely because they are state licensed. Federal voting protections apply independently of nursing facility certification. Federal law prohibits voting-related intimidation, threats, and coercion.52 U.S.C. Sec. 10307(b). For elections involving federal office, knowing and willful intimidation and fraud involving registration applications or ballots is also prohibited. 52 U.S.C. Sec. 20511, 52 U.S.C. Sec. 10307(c).
AFPI invites DHS to reproduce and distribute the enclosed poster which summarizes federal protections and provides required notices, to administrators, staff, residents, and representatives, and to include it in training and resident information materials.
We welcome the opportunity for further collaboration on your voter education efforts and respectfully request that you share your office's plans to ensure this information is properly distributed to facilities throughout Arkansas.
Sincerely,
Ashley Hayek, Executive Vice President, America First Policy Institute
The Hon. J. Kenneth Blackwell, Chair, Secure Elections, America First Policy Institute
Encl.
* * *
Original text and footnotes here: https://americafirstpolicy.com/wp-content/uploads/2026/10/CMS-Guidance-Letter-to-State-Agency-Heads-Arkansas.pdf
News Release here: https://americafirstpolicy.com/issues/afpi-moves-to-protect-vulnerable-voters-in-nursing-homes-from-coercive-ballot-harvesting-schemes/
[Category: ThinkTank]