Bankless - Does the FinCEN's Rule Break DeFi? | Jake Chervinsky

Episode Date: December 22, 2020

🚀 SUBSCRIBE TO NEWSLETTER: http://bankless.substack.com/ ✊ STARTING GUIDE BANKLESS: https://bit.ly/37Q17uI❤️ JOIN PRIVATE DISCORD: https://bit.ly/2UVI10O🎙️ SUBSCRIBE TO PODCAST: http://podcast.banklesshq.com/ 👕 BUY BANKLESS TEE: https://merch.banklesshq.com/ -----GO BANKLESS WITH THESE SPONSOR TOOLS:  ⭐️LEDGER - BEST HARDWARE WALLET TO SECURE YOUR CRYPTOhttps://bankless.cc/ledger 🚀  ZERION - INVEST IN DEFI FROM ONE PLACEhttps://bankless.cc/zerion 💳 MONOLITH - GET THE HOLY GRAIL OF BANKLESS VISA CARDShttps://bankless.cc/monolith 🤖YEARN - YIELD-SEEKING MONEY ROBOT THAT FARMS DEFI FOR YOU http://bankless.cc/yearn------ Jake Chervinsky on the recent FinCEN Proposed Rulemaking FinCEN has finally released a long-rumored proposed rule on how crypto-asset custodians like Coinbase, Gemini, or Cash app can compliantly enable their users to take control over their cryptocurrency funds into 'self-hosted' or 'unhosted wallets'.  This new rule would impose new obligations on virtual asset service providers (VASPs) like exchanges & custodians and increase the reporting requirements on outbound transactions to their customers' wallets.  The actual release:https://home.treasury.gov/news/press-releases/sm1216 We bring on Jake Chervinsky to help us go through some of this news and help us digest what was released! Read Jake's tweet thread!https://twitter.com/jchervinsky/status/1340135040399904770?s=20 ------Don't stop at the video! Subscribe to the Bankless newsletter programhttp://bankless.substack.com/ Visit the official Bankless website for resourcehttp://banklesshq.com/ Follow Bankless on Twitterhttps://twitter.com/BanklessHQ Follow Ryan on Twitterhttps://twitter.com/ryansadams Follow David on Twitterhttps://twitter.com/TrustlessState -----Not financial or tax advice. This channel is strictly educational and is not investment advice or a solicitation to buy or sell any assets or to make any financial decisions. This video is not tax advice. Talk to your accountant. Do your own research. Disclosure. From time-to-time we may add links in this channel to products we use. We may receive commission if you make a purchase through one of these links. We'll always disclose when this is the case

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And coming soon to the Zirion app is the ability to buy and sell your assets straight from your mobile device. So download the app. It works on iOS and Android. Go to zirion.io. Plug in your wallets and get a historical report of your portfolio over time, as well as a comprehensive breakdown of all the assets that you own and how much yield they're generating for you. Bankless Nation, welcome to this special episode. We brought our best legal mind onto the episode. He is crypto, Twitter's lawyer. He is the national representative of the bankless nation, I feel like, at least in our hearts, he is. This is Jake Trevensky. He's also the chief legal officer at Compound Labs. And he is here to help us understand this new 12 o'clock midnight rule that just came down the pipe, the proposed rule from Treasury

Secretary Manusian. Jake, how are you doing today? Happy holidays. I'm doing well. Happy holidays. How are you guys? We are doing. Trying to figure this out. I'm trying to figure out what this means. Yeah. So that's what this episode, we want this episode to be is just you put us some Twitter threads about it. Can you explain this rule? I guess to cue everyone up to the context, there had been rumors circulating around the crypto universe for what feels like, well, it feels like months, but it's probably been weeks, that something was coming, right? Some regulatory rule, some clarification, something from Finson. The rumor was that it was coming from Manusian. You put out this tweet a couple of weeks ago that said,

hey, heads up, get your coins off of exchanges, it's kind of sounding the alarm again, that something was coming. So this has been, I guess, in the rumor mill for quite some time. We finally got what was coming down the pike. I hope this is all that's coming down the pike, but it finally landed. And it is a proposed rule from the financial crimes enforcement networked in the U.S.

and the title is it's aimed at closing anti-money laundering regulatory gaps. It does have an impact on crypto. And so we are here to understand what that is. I'm going to share maybe your tweet thread, Jake, because I think that provides a great summary of what we're looking at here. But could you just go over, like, where this rule came from, what it actually is and the highlights of it? Sure.

So you're right that this is the long-awaited new, from FinCEN, the Financial Crimes Enforcement Network, that everyone has been talking about for quite a while. It is the only thing that we're expecting for now. So this is sort of the big fight that we need to have before Treasury Secretary Manuchin is out of a job in January. So to give you sort of an overview, FinCEN is a Bureau of the Treasury Department that enforces the anti-money laundering regulations, which, to boil it down to a very simple explanation, requires certain regulated financial institutions to have compliance programs that record certain information

about transactions that their customers are conducting through those intermediaries, and also to report some of that information to the government, among other requirements. Of course, crypto exchanges and custodians and other service providers are regulated financial institutions and have to comply with the AML regulations that FinCEN enforces. FinCEN derives its authority from the Bank Secrecy Act to the BSA, which we talk about a lot

when we're discussing these types of regulations. The Bank Secrecy Act is federal law passed by Congress. It delegates authority to FinCEN to create its own implementing regulations. So FinCin gets to decide to some extent what the rules are going to be for what financial institutions have to do to comply with the AML regulations. Until now, crypto companies that were subject to the Bank Secrecy Act only had to do this type of record keeping and reporting for certain transactions, generally speaking, transactions between regulated financial institutions. So transactions from institution to another institution. And this was done under something called the travel rule, which we also talk

about a lot, which basically says when institutions send crypto between each other, they have to send along with that crypto information about the people who are parties to the transaction. So, you know, the names and the addresses, social security numbers, other information about the parties to the transaction. Until now, and including right now, the travel rule does not apply to transactions from institution to an individual's wallet where they hold their own private keys. This is what the government calls an unhosted wallet, as opposed to a hosted wallet, which is basically just an account that you have with an exchange or custodian. I think we're sort of trying to get away from the term unhosted, which sort of signals that when a person holds

their own private keys, it's somehow unusual or scary or dangerous or something like that. It's just self-hosted. It's not unhosted, right? Sure, self-hosted. You could call it non-custodial. You could just call it a wallet, right? if you have a ledger or a treasurer or a metamask, that's just a wallet. And if you have an account at Coinbase or Gemini or some other exchange, that's an account that you have with them, where they are in custody of your assets. But anyway, the travel rule in the anti-money laundering regulations did not apply to transactions between an institution and your wallet.

This new proposed rule that FinCEN put out on Friday would extend AML regulation to, those transactions from institution to personal non-custodial wallet so that for you to withdraw your Bitcoin or Ether or other asset from Coinbase to your own wallet, Coinbase will be required to collect your name and address associated with that wallet. But the impact of this regulation basically is an increase in the amount of record collection and reporting that an exchange or custodium would have to do. Now, with Coinbase, they do that anyway, right? So in order to onboard or trade with Coinbase, it's AML KYC, you have to provide identity,

you have to provide address, all of those things. But I guess the distinction here is that it wasn't explicitly required when you withdrew some crypto assets from Coinbase to a particular wallet. They didn't ask necessarily for you to prove or identify that particular self-hosted wallet. Is that kind of the difference here? Because I guess tell us about what we have been doing and submitting and then what it's going to look like moving forward should this move forward. Yeah. So that's right. So, so Ryan, let's say you have an account at Coinbase, right? Coinbase has already KYCDU. They know who you are and they have all of your information related to your account with

them. But when you go to withdraw assets from Coinbase to any other address on the Bitcoin blockchain or the Ethereum blockchain, they do not ask you for information about who owns or controls that public address that you're withdrawing to. So this new rule would require you to say you're withdrawing to an address that is controlled by a certain person, whether it's you, or let's say you want to withdraw assets from Coinbase to David's wallet, you would have to give Coinbase David's name and David's physical address, or else they would not allow the transaction. That's interesting because we do that all the time with, you know, a lot of people use exchanges as a poor man's version of a mixer. If you want your transactions to be obfuscated

from one ether address to another, you can kind of route it through an exchange. So something like that, I guess you'd have to prove. Do you have to prove it or you just have to identify what the wallet is on the other side? If I just say, yeah, this is David's wallet and here's this address and information, do I have to prove that it's genuinely David's wallet? It's a great question. And it actually gets to one of the biggest flaws of this rule, which is no one knows and the rule doesn't say. So what the rule says basically is the exchange has to verify you the customer. So Ryan, if you have an account at Coinbase, Coinbase has to quote unquote, verify your information, but they do not have to verify the name and address of the person

who's on the other side of the transaction. They simply have to obtain an electronic record of their name and physical address. So basically, this is very uncertain what that means. It's possible that you would just have to tell Coinbase who the person is and where they live. and Coinbase wouldn't have to do any diligence to see if you're lying to them. It's sort of hard to believe that FinCEN would be okay with that because of the two requirements that this rule has. One is that a Coinbase or other exchange or custodian has to collect the name and physical address for transactions over $3,000.

If the transaction is over $10,000, they have to submit a currency transaction report to FinCent. So they actually have to turn over. that information automatically to the government. And the problem with this is someone like Coinbase can't turn over information to the government if they haven't done any diligence to see if that information is correct. So they would, in theory, have to do some kind of verification or something like that to see if you're lying to them. It's just totally unclear what's actually sufficient in order to satisfy that requirement.

So the person on the other side of the wallet, say David might have to somehow verify his identity associated with that account before Coinbase would release the funds to his wallet, let's say. That's a possibility. It's certainly possible. And one of the sort of disappointing things about this rule is whenever we have new rules, we want them to be clear so that the institutions that are subject to them know how to comply. When they don't know how to comply, we end up in this world where you have lawyers like me trying to give them good advice, but not really knowing what's good enough.

And what we see in traditional finance often is when you have this element of uncertainty, institutions decide we don't know how to comply. We don't want to take the risk that we're going to get this wrong. So we're just not going to allow this type of activity at all because that way we know we're not going to commit any kind of violation. This is known as de-risking. So in the worst case scenario, someone like Coinbase says, look, we don't know what's enough to verify or be sure about the name and address of someone who controls a public address on the Ethereum blockchain. So we're just not going to allow any transactions with those addresses at all.

That way we know that we're not going to violate the law. And maybe, Jake, that's where your tweet came from a while ago where you said, you know, maybe now is a good time to get your money off of exchanges because perhaps you were fearful that exchanges didn't know what to do, therefore that they would just start restricting in an abundance of caution. Is that maybe that's where that tweet? you came from? That's part of it. The other thing is, aside from the actual text of the rule, I think it's important to consider what government is trying to achieve here. And specifically, what Secretary Mnuchin is the really the brains behind this idea, what he is trying to achieve. That end result, where it is impossible to withdraw assets to your own wallet, where you can

use them in a censorship-resistant fashion, that is what Secretary Mnuchin wants. He believes that crypto addresses are Swiss banks in everyone's pocket. He is fundamentally opposed to that concept. And I think that if he could pass a rule that says self-custody is illegal, period, I think he would. I think that, you know, not to get into sort of the inside baseball here, but, you know, there have been a lot of reports about how much lobbying went on behind the scenes to stop something like that from happening. And thankfully, the rule didn't come out as bad and restricted as that. But ultimately, we have to understand that there are policymakers who think that is the solution here to mandate custody so that they can reassert the ability

to censor these transactions. And so I wouldn't be surprised if we had aggressive regulators that they would try to use a rule like this as a smokescreen to disguise a desire to prohibit those transactions. So I want to back up real quick and kind of go over the technical details of what we think this rule is likely proposing. So if you, when you get a Coinbase account, you actually get one specific Coinbase wallet, one specific Ethereum address, one specific Bitcoin address. They can change, but until they do, you have one address, right? And if you want to, according to this new rule, if you want to send outbound money, you have to attest to the ownership of that wallet either by you or somebody else. And it seems to be that if you are an individual

who uses Coinbase frequently, this won't really impact you if you set up another wallet, an outbound wallet, say your ledger or your Metamask, and you say that this is my wallet, and you are free to transact between your Coinbase account and your wallet that you've claimed ownership over. And then from that new wallet that you've outbound all your money to, you can use that as you've normally had. You don't have to register transactions out of that wallet. So if you are trying to remove the impact of this rule from yourself, you can just simply send all your money from Coinbase to a wallet that you own first to get out of the walled garden of Coinbase. And then you can send it to all your friends and family and smart contracts. And those transactions don't require any reporting requirements.

You just have to get your money to your wallet outside of the Coinbase walled garden first. Is that correct? That's right. So the way to think about this is current law applies to transactions from institution to institution. This new rule would extend those obligations to transactions from institution to wallet. They would not extend any requirements at all to transactions from wallet to wallet. So once you're outside the world of regulated financial institutions, there are no anti-money laundering obligations on you as an individual.

I think that's really the scope to be paying attention to. To me, what this is is a constricting of the unknowns about how regulatory guidance wants to treat cryptocurrency transactions. It's restricting the unknowns down to just a few types of transactions. But then ultimately, we find ourselves in like across the outside of the wall of garden in the crazy world of defy where there's still, we still haven't gotten regulation on that. It seems to be there's just like this approach, this incremental like concreteness. about what the state wants. And now it's getting further and further into the world of Defi. And now it seems to have just gotten one transaction closer, right?

That's kind of how I view this. Yeah, I think that's right for now. I think it's just important to keep in mind as we look at a policy battle that I think we'll be having for years to come, that the ultimate world that many policymakers would like to see is either one where assets are very difficult to get out of that wild garden so that they can maintain control over as much of this financial activity as possible, or a world where there are some requirements that are imposed on wallet-to-wallet transfers.

We haven't seen any jurisdiction, at least that I'm aware of, you know, in the world, try yet to impose some regulation like that. But, you know, like I said, I think as a policy matter, there are some folks in government who would really like to see that. So this is a battle that we are going to be fighting for a long time. Yeah, let's be clear. I mean, this is absolutely the final boss raising its head, right? It's not unleashing hell and all its torpedoes and all its firepower on crypto yet.

But this is absolutely the final boss kind of like peaking its way into crypto. And the interesting thing about this, Jake, is this also could have been a lot worse, right? Well, we could have gone down the path that Switzerland has gone down, which is a bit more arduous as I understand it. in terms of identifying, like, self-custodied wallets. We could have gone down the path that maybe Manusian wanted to go down, which is sort of, like, prohibiting self-custodied wallets altogether, and etherdresses altogether.

So this is definitely the final boss raising its head and poking around at crypto, but it's also not as bad as it could have been. I'd love your thoughts on that, and also your thoughts on, is this, I guess, more arduous? Is this kind of rule, proposed rule, more arduous than what we see in the traditional financial state? Have they specifically targeted crypto? So yes to both of those questions. Yes, this is the final boss, right? This is government perceiving peer-to-peer financial networks as a threat both to their monetary sovereignty and their ability to track our financial transactions for ostensibly law enforcement purposes,

but also any other reason why the government might want to have insight into our financial activity. This is the big fight that we are going to have to have, and I think it's coming now because especially over the course of the last year, the importance of cryptocurrency on the global stage has increased significantly. We're seeing Bitcoin hitting new all-time highs. now there are a lot of people who are expressing support for the future of crypto networks. There are other governments that are setting up their own blockchain-based systems as in China, for example. So this is us getting to the final stage and having to fight the final boss.

Is this more arduous than what traditional finance institutions are required to do? Yes, it is. This is, I think, not the same rule for the same which is how regulation is supposed to happen. In the traditional world, if you consider paper cash, for example, when you go to a bank to withdraw cash, the bank knows who you are, right? You are K. Y, succeed by the bank. You have an account with them. You prove who you are by, for example, putting a debit card into an ATM and entering a pin. You can then withdraw cash. You do not need to prove anything about where the cash is going. You don't have to prove that you're pants belong to you before you put cash in your pocket. This new rule, though, would require

basically that, right, proof of pants for crypto withdrawals, right? You are already KIC'd by a crypto exchange. You prove who you are by logging in and hopefully using two-factor authentication. You should then be able to do whatever you want with your money. It's an ATM. It becomes an ATM. That's exactly right. And, you know, as we all have talked about since the very beginning of Bitcoin with Satoshi's white paper, this is pure to pure cash. It is a bearer instrument, and there's no reason why it should be subject to additional restrictions beyond how paper cash has been treated for decades and centuries. This is very much to me, Jake, the macro battle here, because it very much feels like, and this applies to crypto absolutely, but not just

crypto. As the world, as our society transitions more to a digital world from an analog world, It feels very much that those in power, those in control, whether it's a large corporation like Facebook or whether it's a nation state, want to strip away and take away rights that we previously had in the analog world because it's digital, because they can, because it's easier, because you can put it all in a database. This is one of my biggest worries for our world as we enter the 21st century, right? We need like a digital bill of rights that spells out, our individual sovereignty and our rights inside of this digital landscape. Because if the nation state and like the powers that be get their, get their preferences in place, there will be a stripping away

of rights that we previously had in the analog world as we enter the digital world. It's my big fear for all of this stuff as we enter the 21st century. You are so speaking in my language. And I think this is so important to understand that as the world transitions into the digital era, we are losing rights that we used to have and that should be guaranteed, especially here in the United States, by the Constitution. So just as an example, when you walk down the street now, you are captured basically every step of the way by cameras everywhere in cities, right? You basically do not have any privacy the second that you step outside of your home. 50 years ago, that was not the case. And similarly with money and finance, there were many more ways to transact 50 years ago

privately that we're just losing now because so many of these transactions are moving online where records are naturally kept and where they're being shared with government thanks to the Bank Secrecy Act. And the question is, as everything comes to be online in one fashion or another, at what point will we say our rights still matter and we should still be able to protect them in the digital space just like we had in the physical space for so long. They're boiling the frog, guys. We have to actively stand against this stuff. Let's talk more about this rule, Jake, because so it feels like it's definitely inconvenient

for exchanges and like anyone who runs a custody crypto service provider, the coinbases, the circles, the bit pay is definitely inconvenient. It feels also. inconvenient for users, but there's something here that is also hidden that could throw a wrench in things. And Jeremy Lear from Circle mentioned this, Naraj from Coin Center mentioned this. Naraj used the term, I think, I'm going to look up a tweet. He said, this might break smart contracts. They might have broken smart contracts with this ruling. And what I think he means is that we, so far we've been talking about the very simple use case where you're withdrawing from Coinbase to another eth address or Bitcoin address that an individual owns or some organization owns

that has some physical location, right? But we all know in Defi, this is not the case often. In fact, like we think the use cases are going to be you withdraw to protocols, you withdraw to money robots, right? You withdraw to some sort of programmable Dow that doesn't have an address. There's all of these use cases. Because if there's an address, it is therefore trusted, and that's not what we are here for. Exactly.

And we've also talked about very often the protocol sync thesis, right, which is basically this idea that the world will build on these credibly neutral protocols and that even crypto banks. So the coin basis and circles of the world will start to build on D5 protocols. But this might throw a wrench into things from a regulatory perspective. Can you tell us about that? What if the address that I'm trying to withdraw to is something like a protocol or compound or uniswap or something that doesn't have a physical address? How does the rule affect that? No one knows. So sort of similarly, right? One of the big flaws of this rule is it just doesn't say. There's no answer to that question at all. The rule is drafted to consider

that very basic use case of Ryan is a customer of Coinbase. Ryan wants to withdraw assets either to his own hardware wallet or to a hardware wallet controlled by somebody else. And Coinbase is required to collect the name and physical address of the person who owns that hardware wallet, whoever that person is. The rule does not even describe the concept of a smart contract. So when the rule says that this record keeping and reporting requirement applies, it says it applies to transactions with quote unquote unhosted wallets. And it defines an unhosted wallet in the way that we would talk about an ordinary non-custodial wallet. It's a public, private key pair where an individual, not an institution, is in control of the private key. It is, of course, theoretically possible that a

Coinbase could figure out how to get comfortable obtaining the name and physical address of the controller or the owner of a private key, it's totally incomprehensible how they could do that for a decentralized protocol, right? Decentralized protocols are not people. They do not have physical locations. I think there's maybe three ways of looking at how this might apply. And this is a good point for me to throw in my usual disclaimer that although I am a lawyer, I am not your lawyer, do I represent anyone listening to this? And so nothing that I say here is legal advice, just sort of my thoughts on where this might go. But I think there's a couple ways of looking at this. One is because the rule does not talk about decentralized protocols, it doesn't apply to

decentralized protocols, right? There just wouldn't be this requirement at all to obtain any records related to those protocols. Defi protocols don't have private keys. Contract actors don't have private keys. Right. So it may be that this rule just doesn't apply at all, and it's no problem at all for defy or for smart contracts, and we don't have to worry about it. That's one way of thinking about it. Another way of thinking about it would be... I like that way. I like that way of thinking about it. Yeah, that sounds reasonable. Yeah, me too. This is the problem when you have a rule that just doesn't say, which is you could imagine a regulator trying to make some argument that a decentralized protocol is a subset of an

unhosted wallet, and they really meant for that to apply. And hey, exchange, are you sure that you feel comfortable sending customer assets to that protocol? Do you really want to de-risk that activity, right? This is where you're giving leverage to individuals working in government to scare their, you know, subjects of regulation out of doing certain things. And by the way, that also scares the innovation away from jurisdictions like the United States, for instance, right? So Binance might feel perfectly comfortable building on top of defy, but maybe a U.S. jurisdiction-based exchange does not as a result of this. They could try to de-risk things.

Sorry, there are other ways to interpret it. Yeah, tell us. Yeah, so the first is, look, this rule doesn't apply to defy at all. Everything is cool. A second way would be to say the rule technically applies, it says, to the exchangeers to collect the name and physical address of the counterparty to the transaction. The counterparty might not be the decentralized protocol or the smart contract. It might be some other person who is using the decentralized protocol or smart contract. So imagine an institution, for example, that is conducting an exchange through a decentralized exchange protocol, like a uniswap or something like that.

Well, maybe the government could say the rule requires collecting the name and address of whoever is on the other side of that trade. It's not the protocol. It's the counterparty, right? And that, I think, would be probably impossible because how do you figure out who the counterparty is? It might mean a specific individual. It might mean something else. I think the-

The protocol, the contract is the facilitator of economic activity between one and another party or one in multiple parties. And there's no way that we really see any ability for these parties to actually, like, coordinate outside of that contract. in some sort of like email fashion or telegram saying, hey, here's who I am, because the whole nature of the protocol is to not really require that. Right.

There's just no infrastructure to make that happen. I think the third and maybe the worst way of looking at this is you would say every single user of the protocol is a counterparty. Right. So every single liquidity provider in uniswap, in theory, is a party to every single transaction that goes through uniswap. I mean, that's how Ethereum works. there's no way to tell which liquidity providers you're purchasing through UniSop or something like that.

So then you could say the rule requires Coinbase to get the name and physical address of every single person in the world who is using protocol. So who knows. Because of this ambiguity, right, every single legal team is part of these exchanges, as part of anyone who does custody of crypto assets is having that conversation. And it's probably pissed. And they're, but they're probably saying like they're, their legal teams are probably saying like something along lines of what you just said, where there's ambiguity here. What's your risk tolerance? You could interpret it in these three

ways. How would you like to proceed, basically? So what that ends up doing is it has a chilling effect on exchanges doing work with decentralized protocols. Is that a valid take? That's very valid. I think it does a couple things. One is yes, it scares people away from activity. that isn't clearly prohibited, but that they're just not sure how they can comply. It's really the worst thing about regulation is when there's uncertainty. Businesses don't mind complying with regulations when they know how to comply and avoid the risk of a violation. It's uncertainty that chills innovation.

The other problem is it pushes a lot of this analysis, and to the extent that there is any clarity, it pushes it into behind-the-scenes conversations between specific entities and the regulators that they're talking to in private conversations behind closed doors. So it may be that Coinbase would go to FinCEN and have a conversation with them and work out some deal of how FinCEN is going to apply this rule to Coinbase specifically, but no one else is going to know what that conversation sounds like. So the process becomes private as opposed to public. And this is really the biggest issue with this rule is not even so much the substance of the

rule. It's the process. It's that the public is supposed to have an opportunity to participate in this rulemaking. The industry is supposed to have an open public conversation with regulators about what rules make sense, what they can actually accomplish, what's going to achieve the goals that government wants to accomplish in the end. And that's not what's happening right now, right? This is just a last-minute rule that Secretary Mnuchin is trying to force through before he's out of a job in 30 days. Why? Why is he doing this? Right. So there's a number of things going on. First off, it's extremely unclear legislation, so we don't like that. Also, we have this very, very shortened comment period, which apparently is unusual, where we just as a world, we don't really

have much time to communicate about this. So, Jake, I want to see if I can get you to get into the psychology of the people drafting this proposed rulemaking. Like, why, why are they okay with the lack of clarity? Do they, do you think that they understand how unclear it actually is and maybe they don't care? And what's with this shortened comment period? What's up with all of this? This is weird. Like, all of this is, has a through line of kind of, you know, giving the middle finger to our industry, right? That's what I'm interpreting it as. It's very weird. It's, it's totally out of order. It is not how policy should be made in the United States. It's, it's very unusual in terms of the policy process we usually see. First, let me just make one quick correction.

David, you said this was legislation. It's actually not legislation, and that's an important distinction. Legislation comes from Congress. It comes from our elected representatives, our our representatives in the House and the senators in Congress, that's where this kind of thing should be done, right? These kinds of very significant rules should go through the democratic process. They should be considered by our representatives who are accountable to us. This is administrative rulemaking that's coming from one individual who is not elected, but rather was appointed, who is not answerable to us at all. And that really is sort of what's behind all of this. It's a personal passion, I suppose, you could call it, of the Treasury Secretary, who is in charge of the entire Treasury Department.

This is something that Steve Mnuchin thinks is important. Why exactly, with everything going on in the world, with everything that the Treasury Department could be focused on during a raging pandemic, while we're all trying to figure out if there's a stimulus deal that's going to help Americans feed themselves, instead of standing in food lines, why this is the priority? I have no idea. And I think a lot of people are pretty confused and surprised that this is how Secretary Munutcheon wants to spend his time right now. I think it's important to note that there is not consensus in favor of this rule within government broadly or within the Treasury Department specifically. FinCEN, which would be tasked with enforcing this rule is actually fairly friendly to the industry. The folks over at FinCEN are really very supportive and they understand the need for innovation and they spend a lot

of time talking to us in industry to try to figure out how we can work together to accomplish their objectives, which we all think are important, right? No one wants cryptocurrency to be used to finance terrorism or to obscure, you know, illicit activity or anything like that. We want to help to the extent we can stop that kind of bad behavior. FinCEN, I think, is unfortunately having to take its cues from its boss, Secretary Manuchin, who's decided that with limited time left, the only way that he can get this rule in effect before he leaves office is to do it through this very hasty, very inappropriate process, and that's just what we're dealing with now.

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And Jake, you don't have to comment on this, but this is a rule coming from a banker for bankers. The worst of bankers. Let's talk about like, so the problem, and Jake, you don't feel like you need to comment. I know you have like to talk to people in D.C., but like, guys, what's the problem here? We're getting a banker to regulate the banking industry. And he's putting in place pro banker rules.

That's what's going on. I mean, Stephen Nushin, his dad worked for Goldman Sachs. like 1995, 85, excuse me, he graduates from Yale and he goes to work at Goldman Sachs an investment banker, just like his father. This is a guy who has a very pro-banking agenda and either doesn't care about defy or like doesn't see it. I mean, that is the macro problem here. I'm curious, Jake, like, how is it possible that we, uh,

in the American system that regulators have this level of power, that unelected officials have this level of power to voice something like this upon the American citizens. Tell us about the checks and balances. I mean, could some legislation come out that overrules this? You said this was not the proper process or the traditional process to follow, but it seems like Treasury has the power

to push this through and enforce it. What's going on with our system that we allow this kind of thing to happen? So I'm not convinced that they have the authority to do this, actually. And I'll tell you why in a little more detail, but first, sort of how do we get here in the first place? The answer is from the start, legislation, as I said, comes from Congress. it comes from our elected representatives. Congress makes laws. In making laws, Congress can delegate some authority to administrative rulemakers. And that's what's happened here. In the Bank Secrecy Act,

Congress sets some of the requirements, sets the general framework for the anti-money laundering regulations, but then delegates the authority to the Secretary of the Treasury to pass these implementing regulations. So Congress has authorized a lot of this administrative rulemaking. You know, over the course of time, and what I mean is, you know, decades and centuries since the founding of our country, the power of the administrators of the executive branch has expanded significantly. And a lot of that is, as Congress has sort of become less effective, they've wanted to push off a lot of these tough decisions to someone else who's not going to be challenged or want to take, you know, difficult political positions in order to implement those rules.

There are also good reasons this happens, right? It's really hard and really not necessary all of the time to go to Congress and get all of our elected officials engaged on the minutia of the definition of a money transmitter, right? It's okay to let administrative rulemaking take care of that. The thing is administrative rulemaking is limited by something called the Administrative Procedures Act, the APA, which is another federal statute that outlined, how rulemaking has to be done. The APA has requirements called notice and comment rulemaking requirements, which says when the executive wants to adopt rules, it first needs to give notice to the public of the proposed rule, and then it needs to accept comments from the public, to give the public an opportunity to participate in the rulemaking process, and only after it's done that, can it implement a new rule? after implementing a new rule, they have to give at least a 30-day period before the rule becomes effective, right, which gives people time to figure out how are they going to comply with that new rule. I think that what we're looking at right now is, is the Treasury Department in violation

of the APA by passing a rule like this and giving the industry only a 15-day period to comment, is that a genuine opportunity to participate in the rulemaking process, as federal law requires, or is it just a pretext to jam through a rule that Secretary Mnuchin is going to pass no matter what the public says about it? And if that's the case, if this isn't a genuine notice and comment process, then it's very likely we could challenge the rule in court and that a federal judge would strike it down as a violation of the APA. So we have the macro problem is we've vested a lot of power into the executive branch and therefore this gives administrators the ability to push things down the pike like this. We might have a chance to get it struck down by the courts, right? However, it seems to me there are kind of two big things that are outstanding, I guess, for this bill. So the first is what will Congress do, right, in the future? Will they be pro-crypt

pro our industry or against it. And that's a longer legislative path, right, which I don't know how many months or years that will kind of take to get some clarity round. But the big most immediate thing is, of course, we've got a lame duck executive branch right now. And the new Treasury Secretary will begin in January. And that, of course, is Janet Yellen, if I'm correct, right? Biden's pick is Janet Yellen. So there's the possibility that she could take a different administrative posture to this proposed rule or crypto in general. But like what do we know about Janet Yellen? Because it's not clear to me that she is much more crypto friendly than Steve Munition is. What do you think happens when the Biden administration takes over to both this proposed rule and then

like projecting Ford into her tenure? So first of all, I think you're right to think about this as a 30-day sprint to try to stop this from happening before Secretary Munnuchin is gone. And then after that, a very long and protracted policy discussion and hopefully not, but potentially battle over our ability to transact peer-to-peer, which will definitely go on for years. In terms of Janet Yellen, she is Biden's pick. I think it's fair to assume that she will be confirmed. Everyone seems to support her. She's a fairly moderate voice. I don't think that she'll be challenged. So I do expect that we will have a Treasury Secretary Yellen at some point,

probably February, maybe March. To say that she's more positive on crypto than Secretary Manuchin isn't saying much, you really can't get worse than Secretary Manuchin in truth. But I do think there are reasons to be hopeful. And if nothing else, I do think that a Secretary Yellen will be open to having an adult conversation with industry and with the people who have input on this issue will be willing to listen to reasonable voices. And so I think if we can just survive this 30-day period, hopefully without this rule going into effect, we'll have a fresh slate starting on January 20th at 12.01 p.m. Eastern, and we'll be able to have a real discussion about what types of regulations might be appropriate, right? We are going to have to have that

discussion. We're not going to live in a totally unregulated world forever in terms of DFI specifically. but we just need to get to that point and start having that conversation and see where Janet Yellen is on these issues, you know, what matters to her and what we can accomplish. Maybe I'm overly optimistic or overly bullish about my industry, but I feel like if we got a person or a set of regulators that could have what you just said, Jake, which is an adult conversation, then that is bullish for our side of the debate, our side. side of the conversation. And again, maybe that's just my bias. But I feel like an adult conversation benefits us, bodes well for us as representatives of the industry due to some very sound arguments that

I hear coming out of people like you, Jake, and people like just the whole cohort at Coin Center, simply arguments, like if the status quo is to create regulation that mimics earlier regulation, then crypto has a lot going for it that could be protected by legacy regulation. And I feel like if we could just get a quote unquote adult in the room that we can help regulate this industry appropriately, that seems like the best path forward for both sides. Does that resonate with you? Very much so. I completely agree.

I think that if we can have this conversation out, if we can get all of the nuance out and discuss the cost benefit analysis of, you know, preserving financial privacy and improving the ability of individuals to get access to financial services and having more resilient financial infrastructure for the modern era, right? All of these things, I think, are very persuasive. And I think the weight of the evidence and the weight of the arguments falls on our side. Obviously, I wouldn't be here doing this if I didn't believe that very strongly. There is a really, big conversation that we have to have. I mean, just for example, you guys are going to talk to Rohan Gray about the Stable Act. It's coming out tomorrow. Oh, that's awesome. And, you know,

there's a very different view among some policymakers on the left about how the financial system should operate, just like there are very different views on the right, not all in favor of the world that we envision. But I do believe that we can convince the majority. that what we are building is net positive for the world. We just have to have that opportunity, and that requires adults to be in the room and in charge of making policy and enacting regulation. Hopefully that's something that we can get done

with this new administration. Jake, I want to see if I can get you to speculate here on something. Do you think that this bill, this proposed rulemaking, proposed regulation, whatever, would still have come if the latter half of 2020 didn't see the crazy price action that Bitcoin and Ethereum and this whole entire space has, do you think that the noise from the bullish cohort of crypto people kind of kicked this regulatory movement into high gear? Do you think that noise from the

crypto space made this happen? This would have happened anyway. In fact, I think it's the opposite. I think that if not for Bitcoin setting new all-time highs and getting a lot more support and becoming front of mind for a lot of people who in past years weren't interested in this. I'm thinking about the Stan Drucken-Millers of the world, right? The big investors have gotten into this. I think if not for that, then the regulation would have been worse. This was always coming. And we've been hearing signs of this for a really long time.

I think the last time I spoke with you guys, we had a chat. about this a little bit, you know, going back to June of 2019, the FATF, the Financial Action Task Force and International Standard-Satting body was already talking about money laundering and terrorist financing concerns of peer-to-peer transactions. So this is something that's been on the radar for a long time. I think it was always coming. And frankly, the more successful we are and the more sort of reputable, credible folks from traditional finance express support for what we're working on, the less aggressive, I think,

regulators can get away with being. But look back to Ryan's point about who Secretary Mnuchin is. I don't want to disparage him personally. I think that he has genuinely held beliefs about crypto being for criminals. I think that's what he thinks. I think he believes that honestly. but you are right to point out that he comes from a world that probably doesn't want to see this technology succeed in the way that we want it to. I'll be very curious to see where he goes after he's out of office, but a lot of this does come from sort of the traditional world, you know, to the extent that they're not accepting of working on trying to sort of tamp it down. I'm going to guess he doesn't go work at a defy-critical startup after his tenure here, but we will see. I think that's fair. Yeah, the other thing is just like the lack of understanding or care about like defy that that sort of comes through.

And that makes sense. And in the banker world, you know, every bank account is owned by an individual or a company. And the defy world, that is not the case. So it's a new paradigm too. So some of this is just so ham-fisted in its last lack of specificity. It comes from that place, too. I want to get your prediction on something else, too, Jake. So you said the next 30 days is sprint time.

right? What's the probability that the crypto industry rallies, the folks that are anti this particular rule win and it doesn't go into effect? What kind of probability do you give that and what needs to happen for that outcome to happen? I think that all told, the probability that we can stop the rule from being effective as of January 20 is more than 50 percent. maybe not by much, 51%. There's two reasons for that. One is there is still a chance

as committed as we think Secretary of Munition is to this that we can still convince him this is the wrong way to do it. It's at least worth trying. And what that means is we need to be very active in making the most of our very limited public comment period, even over Christmas and New Year's. So the one thing I'll ask the audience, to do is please submit a public comment. If you don't know how follow me on Twitter,

I will put out a thread at some point soon with some general thoughts about how to do this, how to write an effective public comment. But we need to rally the troops and make sure we are heard loud and clear about how bad this rule is and how bad the process behind this rule is. There's still some chance that we can convince the Treasury Department not to put the rule into effect at all. If they do, I think it is highly likely, I wouldn't say guaranteed, but highly likely, that a lawsuit will be filed immediately the moment that the rule goes into effect. And that lawsuit would seek from a judge a preliminary injunction to prevent enforcement of the rule. And if we get a preliminary injunction, which again, who knows, but I think the chances are pretty good. I think the arguments for an APA violation are very strong, then the rule would not be effective as of January 20th.

So I think we've got those two shots, convince Treasury not to do the rule, convince a judge to enjoin enforcement of the rule. And if it's not in effect as of January 20th, I believe very strongly that FinCEN will walk away from it. So that's what we need to do. We need to make sure FinCEN can walk away from it. this on January 20th. Jake, you know, bankless nation is going to be behind helping to comment on this and like make sure that it doesn't go into effect to the extent we are able to. Can I ask you about the comments themselves?

Does anyone actually read them? If a whole bunch of bankless members who are using defy protocols submit individual comments about how they're using defy and, you know, Does that really matter? Like, do people, does Manusian and the folks that are around him, are they actually going to read these things? And does it make a difference? It, in general, it does make a difference. I think it makes more of a difference than people give it credit for.

First of all, the law requires this to be a genuine process, right? The law says that public comment is not a mere formality. So someone does have to read these comments. and they are supposed to, at least under law, be considering these comments very seriously and really looking for input from the public. I also think that as much as we may bash regulators for having their own ideas and not really wanting to engage with us, there are a lot of really thoughtful people on the other side of these decisions. And if you have intelligent, respectful, and persuasive public comments, if you come in in volume, a lot of comments and with substance, right, deep thinking, then I do think that that can make a huge

difference. And also, look, if we submit hundreds or thousands of really well-considered comments, and then five minutes after the comment period is over, the Treasury Department puts this rule into effect and doesn't address any of the arguments made in those comments, that's going to make our lawsuit a lot stronger. So it is really important. that we do that. There's some chess playing going on with how to approach this. It sounds like. Yes, definitely.

It's a complex game, but that's the game we're playing. So we got to do it right. Ryan, you're muted. It sounds like we have some action items here then. So Jake, how long do we have to comment? Is it 15 days? Yeah, so I think at this moment, the comment period isn't even open yet. So the rule was not yet published in the federal.

register, so that's the moment when the comment period opens. I'm guessing that's going to happen today or tomorrow. Once it does, we can all make sure that the place to submit comments is easily accessible, so I'll make sure that's available. I'll send it to you guys, too, to send out to the bankless nation. And then, yes, it seems the comment period will be open until January 4th. It is best for people to write their own comments, right? Their own unique thoughts that are personal to them, but for people who can't do that or don't feel comfortable, we will also try to create a template with suggested language that people can use.

Look, it's less effective to have a thousand comments that are all the exact same language, but it's better than nothing, so we'll try to get that out too. Jake, here's what we want to do, I think. So, you know, it sounds like we'll have at least till the first week of January, maybe into the second week to submit one of these comments, right?

So maybe come the first week of January, if you put out some resources, we will publish a how-to in bank lists that is how to create an effective comment on this kind of proposed rule. And we will rally the troops and get as many folks as possible to comment on this and see what we can do. At least we will make our voices heard. That is what we are here to do. I tweeted this out. It's, to me, this kind of thing, long term, it's not really crypto that has to worry about it, right? Like, it's, it's, it's, it's, it's, crypto will be fine whether or not very, um, severe regulation goes into place. Like long term, crypto's going to survive.

It's going to be fine. Other jurisdictions, other nations will adopt it. That at least is my belief. This is kind of like more for the US. Does the US want to put a chill on this industry and get left behind? the rest of the world, right? That's the question is, as an individual that lives in the US, I don't want that to happen.

I want the US to take an active role in promoting cryptocurrency. So that to me is another reason why we comment and why we try to push this through at the nation state level. I think that's kind of it guys. Well, we covered it. It seems like the summary is this is not as bad as it could have been, right?

You know, as far as folks taking their funds off of exchanges, it feels like they can do that now. It feels like if this goes into place, there's the possibility, Jake, that some crypto exchanges could take kind of a fully de-risk line and stop exits off exchanges, right? That's a possibility that exists. So you might want to use this period of time to think through the implications of that. and like maybe withdraw some funds from exchanges. Comment period coming up, it definitely feels like this turnover from Mnuchin to Janet Yellen could be another opportunity for us. It also feels like the fight is not over yet. So this 30-day sprint is going to be a very important period of time for us to try to get this proposed rule out of the conversation and knock it down.

So is there anything else in summary? Dave or Jake. That's all I've got. I just want to say I really appreciate your support. I think this matters a lot to all of us. And maybe the last thing I would say is what gives me hope is everyone in our world has banded together to fight this. This is one of those moments where it doesn't matter if you're a bitcoiner or an Ethereum, we are all together on this. And it's been amazing to see everyone band together. So we will get this done. And in the end, we will prevail. So thanks a lot for the chance to come on and chat about this. Yeah, thanks for coming on and then helping us walk through it, Jake, as always, you are a light in a dark night when it comes to things like this. And I think

the only thing I want to leave the listeners with is like, this is likely not the only time we're going to be doing this. This is not going to be the only piece of legislation that is proposed or something that we don't want to see happen. And so this is, this is a battle, but there is a war to be fought. And so it's really important for the bankless nation to actually be participatory in their civic engagement, in their civic duties, right? This is going to be a marathon, not a sprint, and we need everyone to be in on that with us together. So if when we put out some sort of like how to write a public comment, that is your training for the next time that we have to do this too, because it's going to come. And so we might as well get into the habit now. Yeah, it's a good point.

And look, not to drag this out, but it is good to learn how to write a public comment in general because there are going to be good things that we want to comment on too, right? Someday the SEC is going to solicit public comment on an ether ETF. And I'm guessing folks are going to want to know how to write in favor, right, in support of the Ether ETF approval. So this is something we should get in the habit of. We should engage in our democratic process and make the most of it. Yeah, I mean, some of these public comments likely led to you, the possible CME listing of Ether Futures. So it does matter. It does have an impact. Last thing,

guys, we have a podcast, kind of a podcast, a YouTube only, I guess. It's not going on the podcast with Rowan Gray. And David, that comes out, I think, tomorrow on Tuesday. Yeah. So could you tee maybe that up? Because that's almost an extension of this conversation. Rowan comes at it from a left progressive movement in the U.S. perspective. And the thing that struck me about that conversation is he's very M-M-T. He thinks basically the nation-state should be kind of the sole arbiter of money as a public good. He also thinks transactions should be private, right? So privacy preservation. So my guess is he would be anti this kind of minutiaean type of AML-K A. Y, C, enforcement. Can you give, like, tee up that episode?

Yeah, yeah, I do like that characterization where there are people in government that want the government to do things that are completely the opposite or totally alternative to what Manusian is proposing with this. So, like, we have to fight the fight on different fronts, I guess, but also there's different reasons or different arguments that we would have to put up against Rohan, what we would against something like coming out of Manusian. I actually really like, between minutia and Rohan, I actually much prefer Rohan as a, as a, he's much more fun and friendly to engage with. And he's really smart. The guy's really smart. People in the crypto space think that he's like this dummy guy that doesn't know and understand our industry

and they're wrong. And the conversation with Rowan, for me, was really valuable because he does understand our industry. He does understand what can happen out of the technology here. yet he still wants a state top-down money system alternative. And so understanding those arguments, I think is really valuable. And it's, again, just another angle that we're going to have to fight from the nation-state side of things. And so totally different from what minutia is proposing, but still the same because it's coming from the central government. So I guess this week is just a crypto-verse nation-state type of week. I would almost want his comments on this, this, uh, Mnuchin proposed rule, because like, we should,

we should tweet this out to him because one of our challenges at the end of the episode with Rowan is basically like, hey, if you're asking us to put all of our, our eggs in the nation state basket, you better make sure that citizens have their privacy, right? And that, that comes intact. Because while he's doing that and centralizing things on the MMT front, there are folks in government like Mnuchin that are, you know, make it so that individual citizens don't have, don't have privacy. So one often goes with the other. Anyway, this is an ongoing conversation on bankless, as you can tell. Jake Trevensky, thank you so much for being with us.

Thank you for being the crypto lawyer for the Bankless Nation today. We appreciate it. Thank you, guys.