1st Quarter - Report — INVARIANT LLC for XAPO BANK LIMITED (2026)

Firm

INVARIANT LLC

Client

XAPO BANK LIMITED

Income

$80,000

Expenses

—

What was lobbied

2 issue areas, each in the filer's own words, with who lobbied on it and where.

Financial Institutions/Investments/Securities FIN

Educate Members of Congress on stablecoin and cryptocurrency issues and legislation, including P.L. 119-27, the GENIUS Act; H.R. 2392, the STABLE Act of 2025; and H.R. 3633, the CLARITY Act of 2025. Monitor cryptocurrency proposals.

Lobbyist	Covered position, as disclosed
CAROLYN G CODA	—
ALDEN KNOWLTON	—

Contacted: HOUSE OF REPRESENTATIVES; Securities & Exchange Commission (SEC); SENATE; Treasury, Dept of

Bills named: H.R. 3633 (119th), H.R. 2392 (119th)

Banking BAN

Educate policymakers on Xapo's business model. Educate Members of Congress on stablecoin and cryptocurrency issues and legislation, including H.R. 3633, the CLARITY Act of 2025; H.R. 2392, the STABLE Act of 2025; S.954, the BITCOIN Act; and P.L. 119-27, the GENIUS Act of 2025. Monitor cryptocurrency proposals.

Lobbyist	Covered position, as disclosed
CAROLYN G CODA	—
ALDEN KNOWLTON	—

Contacted: White House Office; Treasury, Dept of; SENATE; HOUSE OF REPRESENTATIVES

Bills named: H.R. 2392 (119th), S. 954 (119th), H.R. 3633 (119th)

Shown as published by the Senate Office of Public Records and the House Clerk under the Lobbying Disclosure Act. The official filing is the record; open it for the full form.