On The Brink with Castle Island - Zachary Kelman (Kelman Law) on the FATF, Bitcoin, and the International Order (EP.117)

Episode Date: August 26, 2020

Zachary Kelman, managing partner at Kelman Law PLLC, joins the show to shed light on the FATF – it's origins and its current mandate – the travel rule, and what the industry can expect from these developments. Covered in this episode: Zach's prior career in bank compliance and how he decided to focus on Bitcoin How Zach noticed the blurring of lines between stopping crime and politics for bank AML Why overseas payments in the correspondent bank system are expensive What the Travel Rule actually means Why Zach thinks Bitcoin compares favorably with the default correspondent banking system Why banks freeze out certain sectors even without a specific ban or prohibition How Coins.ph moved the needle for financial inclusion in the Philippines The history of the FATF and its original mandate and intent Why the FATF's recommendation could possibly bifurcate the bitcoin market How the end of the Cold War might have influenced the creation of the FATF What Fukuyama's End of History has to do with financial crimes enforcement Will the decline of the US-led international order mean organizations like the FATF will have a reduced ability to police global finance Zach's thesis that western Europe might end up being a haven for the crypto industry How the FATF recommendations actually get enforced at the local level How the FATF black and graylists change bank behavior Why NYDFS has so much control over global finance How bank behavior in the US is often more norm based than couched in law Why a rise of nationalism could advantage Bitcoin  

Hello everyone. Welcome back to On the Brink with Castle Island. Today on the show we have Zachary Kelman, who is a founder of Kelman, PLLC, which is a law firm active in the crypto industry covering AML compliance, securities laws, and corporate structuring. Prior to founding Kelman law, Zach actually worked at some of the largest banks in the world on their internal compliance AML programs. So he's very much seen how the sausage is made, which makes him an amazing candidate to weigh in on the subject matter of today's episode because he's very active in crypto, but also deeply understands the structure of the correspondent banking system and how it's a tool for power projection, how the lines became blurred between stopping crime and using the New York-based financial system for political

purposes. So I set out to ask Zach about the burning questions on my mind, which was the FATIF, the travel rule, and maybe what that meant for the crypto industry in the short term. But we ended up embarking on a much more expansive exploration of why the FATF even exists, where its power actually derives from, and how it has the ability to instrumentalize its recommendations. We ended up talking as much about geopolitics and the international order as we did about compliance or AML rules. My takeaway from this episode was there's certainly a concerted effort from these multilateral organizations to reckon with the crypto industry. And the FAAF and the travel rule is the most visible current manifestation of that. But this U.S.-based

financial order whereby most transactions are cleared through New York, which gives NYDFS very significant power over banks worldwide may not necessarily last forever. And indeed, I think we've had roughly a 30-year period of effectively a unipolar world, but it's possible that it's going to become multipolar once again. And already we're seeing this financial network with kind of one or two very large nodes. We're seeing alternatives develop, obviously, in the form of Bitcoin and cryptocurrency. While some of these organizations might seem omnipotent, I think there are genuine political constraints to their power, which is potentially cause for optimism. And Zach has extremely well-developed opinions on what future trajectories might look like in terms of the financial

system if it's the case that the U.S. withdraws from its current place in the international order. I always try to learn from my guests, but I feel like listening to Zach in this episode, I really leveled up in terms of my understanding of the travel rule, but just more generally, this much larger financial context that the crypto industry sits in. And not only the short-term prospects for exchanges and custodians and users, but the long-term forces at play here. So without further do let's jump right in brought down by bad mortgage investments leeman which has 25,000 employees will be liquidated the federal government loans american international group a ig 85 billion dollars this is a different kind of market and the fed is asleep the federal government is stepping it to

stabilize fanny may and freddy mac the two mortgage giants that have been threatened by the housing crisis the bank of england has pumped 75 billion pounds more into britain's ailing economy with a new round of constitutive easing and print a couple trillion dollars and all of a sudden people start to worry so out of this worry, we have something called a Bitcoin. Bitcoin. Zach, welcome to the show. I'm very excited to have you on.

Thanks for joining us today. Thanks, Nick. Excited to be here. Big fan of the show. All right. Yeah. So we're going to tackle some pretty difficult topics today. Topics which give people in the crypto industry pause.

And it's kind of like this specter, which is haunting the industry right now, which few people understand. But it also seems to be getting more concrete in terms of potentially a threat to, you know, the way that this industry operates at present. So I'm referring to the infamous FATIF, the travel rule which people are talking about, the recategorization of exchanges and consortians and divasps. There's all this terrifying jargon floating around. I'll admit it's definitely perturbed me somewhat.

So you have an excellent ability to understand. understand this stuff and you've really the perfect background to kind of explain it to us. So I want to dive into all that, but maybe before we start, you can tell us about your background and how you made your way into this industry and what your firm does. Okay, good. So I get a chance to plug the firm, huh? Of course. Yeah.

By all means. Okay. So Kelman, PLC, we're primarily a litigation firm. It's my brother and I, Daniel Kelman. and you may have heard of him. He was heavily involved with the Mount Gox. The whole litigation process, he represented a lot of different claimholders in Mount Gox,

trying to get the money back very early on. We've both been in the crypto space very early. I think, interestingly, we started off as enthusiasts and hobbyists, as opposed to say lawyers, given that there weren't laws at the time related to crypto directly. So that was our entry into it. But yes, we do litigation, all kinds of disputes between founders and, you know, the investors and the projects or, you know, anything between employees and owners and normal litigation towards employment law, things like that, contracts especially. We also do compliance work and we do structuring, kind of offshore business structuring, those kinds of things.

We also do a lot of advising of governments and drafting legislation and things like that. And I think last two, the structuring and advising kind of go hand in hand. But my background initially was more of a compliance focus. So I worked in New York at Morgan Stanley and Credit Suisse and New York-based banks, doing AML compliance mostly. I did some other areas of compliance, but mostly AML compliance. And I got a firsthand look at how that system works. I was actually reviewing different accounts, transactions,

most of the roles that you'd have in AML compliance. So you have the due diligence role where you're reviewing clients. You have the transaction monitoring rule where you're looking at the rules that were set up and what transactions are happening and who's doing them and whether it's an L risk or not. That was my background initially at the time I found out about Bitcoin. And one of the things I learned was that I kind of wasn't sure about how it worked going into it in terms of whether this is a kind of like a law enforcement job. I wasn't quite sure of the mandate that the banks have.

And, you know, obviously I can't give a lot of details about the specific things I saw. But in a nutshell, the realization I made was that it's hard to tell the extent to which what I was doing was law enforcement oriented in nature or political in nature. You know, and if you just look at, for example, the notion of sanctions. I mean, the idea behind anti-money laundering is criminals that are trying to use a system need to be stopped and you need to be able to know what they're doing with the money. The banks need to be deputized to be recording their transactions and looking for it. And criminals, right? So people that commit financial crimes or other crimes that have proceeds.

That's the notion of it. But look at sanctions, for example. you know, we've said that all of the people of, you know, country exits Iran or North Korea or what have you, suddenly every transaction with any person in that country becomes the same as a criminal functionally. And so clearly there's a political element to it. Again, my focus wasn't on sanctions specifically, but I'm just using that to illustrate the point that it's hard to substantiate the idea that you're just stopping pure criminals. You know, and obviously if you're looking at just the anti-money laundering in that context, there's also questions about whether

you're stopping criminals or not, right? So in any event, it wasn't just that point. It was also the way that this worked is wire transfers between banks. And I don't know if people know a whole lot about this legacy correspondent banking world, but essentially the way money moved around the world prior to crypto pretty exclusively, other than, say, shoving pallets of cash. to a boat and moving it to another country was through wire transfers. And it's a whole system where at the center of it is New York City and maybe to a lesser extent, London, Hong Kong, and a couple other places where clearing happens. It's like the center of this kind of network.

And I'd say New York pretty fairly is that hub. And the reason is New York Department of Financial Services regulates these banks and authorizes them to do dollar clearing. So you can take wherever this money is coming from, if it's, you know, from China, if it's from Italy, if it's from somewhere in Africa, the money ultimately ends up in these New York banks, they sort it out, and then they transfer it back out. And so the number of steps you are away from that is a cost, a massive cost. So if you're a small bank, if you're operating in a small bank in Africa and you want to send money to, say, another person who has a bank account in a different country in sub-Saharan Africa, what you might end up seeing

is you go to your local bank, they pay a fee to send it to a larger bank in that country, then they pay a larger fee to send it to probably a European country, who then pays another fee to send it to New York, and then you go through the exact same chain or a similar chain in reverse, and they're paying fees all the way, and it's taking time all the way. It could take weeks, and the fees could end up being pretty substantial. And for some countries, it's 10, 20, 30 percent of the transaction on average. although that's pretty high. I'd say usually between 10 and 20 for some of the developing countries that are considered to be high risk. So looking at this system, seeing how it works, seeing,

you know, what I saw as some kind of political elements to the system, when I found out about Bitcoin, I was really interested in it and excited because I saw, obviously, there's no intermediaries blocking this from happening. It's decentralized, right? And so, yeah, I guess I could jump to the travel rule really quickly to note that that's kind of the change here is that the travel rule would in the countries it's implemented in require crypto vaps virtual asset service providers which is a broad term that's still being sorted out but certainly includes exchanges and OTCs and you know ATM machines and whatnot to have you know to carry personal information on individuals who are using their platforms.

form and pass that on to the next one. If you've ever read a wire detail, the wire shows who's on both sides of the transactions, some information like their address and things like that. So in any event, that's why I'm so interested in this subject is that I'm seeing that system. I thought we were escaping that. It's being really reimposed into the crypto space. But obviously, it's not that simple.

We'll get into the details on how it works, how does FATIF work, how do the countries what kind of pressure are they under to implement this and those sorts of things. So contrasting your early vision of Bitcoin with your experience in the kind of correspondent banking sector was the thing that you liked about Bitcoin that it was neutral in terms of the way it treated the participants in the network. So it was much more difficult to impose political discretion on who could transact with whom? Or was it more of this promise to break apart this hub-based model of correspondent banking and flatten the hierarchy with who gets access to financial services?

I would definitely say both, but to me, it's more, it's less a kind of a contrast and more the implications of a secondary system existing altogether. I thought both A, the crypto system would solve some of these issues of privileging certain countries and groups in this network, as well as putting pressure on the network to flatten a bit, right? But I think the main point is that I don't think people fully realize the impact that this system has on people. And this correspondent banking system is kind of, in many ways, it's the primary mechanism by which these international organizations can enforce these rules, can push countries into adopting rules like the travel rule. Yeah, well, I would say the politicization runs the gimmut from local to transnational,

the politicization of financial rail specifically. You have in the U.S. in very recent history, maybe even happening right now, certain federal agencies expressing policy views through the mechanism of FDIC, and saying, we're going to disempower certain industries based on who gets access to banking. But then, as you note, on the transnational level, access to the banking system, mostly running through New York, is one of the most powerful tools of instruments of hard power that the U.S. can wield. And even the threat alone is sufficient in many cases to kind of achieve strategic aims.

So it's almost like, regardless of whether it's the hyper local level or the transnational level, our financial system is politicized. My interest when it came to Bitcoin, and this is what led me to work internationally in Bitcoin was primarily with the way the correspondent banking system affects people overseas. And I tend to think that what you often see are these kind of edgy libertarian takes on it, like about financial, you know, issues here and, you know, they're going to shut down your bank account. My focus was primarily on how people in developing countries were affected by it. And they really are. And it's not a, it's not like an edgy point, you know, it's, it's, uh, people actually are in countries that, that are deemed to be high risk, um, end up having, many times losing their bank accounts, many times waiting forever to get bank banking. They have like a, they live in a country that has a

banking monopoly. They're paying money to hold money in their bank. accounts, it really just incentivizes banking. And it just give you a little sense of it for a bank. If you take a small country that's deemed high risk, for them, they either need to devote a lot of internal resources in New York, in America, toward understanding this country, understanding the crime risks in this country. And there's not a whole lot of data on that. You know, look at a small Caribbean island. Who knows the details of who all the people are and, you know, in power and, you know, the crime dynamics, you know, you're going to have to hire a local police officer, really, if you ever really wanted to understand that. Of course, I doubt that's actually done. So you either

weigh that interest of measuring the risk all the time and gauging it and minimizing it against the benefit. And if it's a small country, oftentimes the decision is let's just remove this. We will, we will, you know, de-risk this bank is the term. So they'll stop working with that bank. We saw this with Belize, who has virtually no banking at this point. They have like one or two correspondent banks. It's hard to get money in and out. A lot of people just go to Mexico to do their banking. And for a lot of other countries, it hasn't quite happened to the point where it's impossible to get banking,

but they went from having a competitive banking market to a non-competitive banking market. And as a result, the ability to hold bank accounts, get money into your bank, get money out of the bank, became much more expensive and time-consuming. And, you know, I haven't seen stats. that have shown that this was pretty recent. This is like five, six, seven years ago. This really started to happen. But I wouldn't be surprised if, you know, bank account ownership rates have gone down since then.

So I can just say having been in those countries and known lots of people, that's a major political issue in the country. It's not an obscure economist issue. Sometimes what's happening with the banking system in these countries becomes the biggest new story in the country as opposed to here where it's like an obscure public interest. story. So by the time this interview airs, the prior week's episode, which isn't out right now at the time of recording, will have been addressing this exact topic. So we've cast this spotlight on entrepreneurs a couple times that are using Bitcoin as a bridge currency to facilitate remittances,

generally in a manner that's penetrating remittance channels, which are inefficient for whatever reason, and taking advantage of installed crypto financial infrastructure that exists in some of these countries, which is more resilient, perhaps, or less exposed directly to government intervention, doesn't necessarily rely on banks per se. and, you know, end users are not actually being exposed to Bitcoin is just that Bitcoin is the bridge asset in that fiat-to-fiat remittance transaction. So this isn't necessarily just a pipe dream. I would say there's a good number of founders that are actually instrumentalizing this process of treating Bitcoin like a parallel financial infrastructure. And, you know, I think we're starting

to see the actual consequences there. I mean, I would say it's still early and it's too early to rest on our laurels, but it seems extremely positive in terms of financial exclusion and some of these channels that have a really tough time using the current financial system. Yeah. So when I worked at CoinsPH in around 2017, the banking inclusion rate for the Philippines was, I think, 15%. And the company itself, at one point, had over a million users from the country of 100 million people. So that's about 1% of the population or more who had the app. So you could see that – I saw that happen in real time, and that app is exactly what you described.

It's a – what do you say? It's like a mobile wallet, but you use Bitcoin as the Rails. But, yeah, that was what attracted me to that company. so much as it was causing this real financial inclusion on a real scale. And I didn't hear many stories about it in the crypto space. It was more, people are more interested in, you know, obviously the prices and all that. But again, I don't think people realize that the speculation in the markets in many sense, I mean, we've seen Bitcoin turn into just kind of the gold alternative. But I think a lot of the speculation around the success and universality of these,

these crypto assets and blockchains are based on that notion that the current monetary system and banking system doesn't serve huge percentages of the globe. And that to the extent that crypto can do that, it is a real competitor to that system. And to the extent that it doesn't do it, I think it's not. So if that never happens, if we don't see real rails being built in places where the current monetary and financial system is not. providing those services, I don't know that Bitcoin and crypto will really be an alternative system in any meaningful way in the developed world.

Yeah. I mean, it's tricky because if you just look at the data and you fundamentally look at what Bitcoin is being used for, for instance, most of the transactional volume does relate to speculation. But in my view, that was maybe kind of inevitable because it wasn't going to be useful right out of the box. So kind of it's not that surprising that the first thing people really use Bitcoin for was just to speculate on the price of Bitcoin or get access to exchanges to buy altcoins or to trade Bitcoin on a leverage basis. But I think that phenomenon, which we've seen over the last decade or so, has also subsidized the buildout of genuine crypto financial

infrastructure, which is now localized in most countries worldwide, either through centralized exchanges or peer-to-peer exchanges, which offer those on and off-ramps to Fiat directly. And not only that, but wallet software, which is reliable, for instance. So that orgy of speculation had the positive externality of funding this infrastructure, which allows the delivery of Bitcoin on a seamless basis to, you know, large fractions of the world's population. So it was almost a precondition for it becoming reliable infrastructure. And I'm not saying it is just yet.

But there's definitely positive externalities to the more speculative side of the industry, I would say. Oh, I totally agree. I mean, you know, if you look at any technology that takes off, even businesses, you know, people are not buying, there's like a maturity level that they get to. And you're buying it at an early stage. You're not buying it for the present value. You're buying it on the speculative value.

I'm just saying, I think, if it remains a speculative asset. And let's be clear, a lot of people talk about it that way. And I think a lot of people are speculating it on it, especially Bitcoin on the kind of since the bull run of 2017 as a financial asset for the developed world as a gold alternative kind of alternative investment strategy, and that's what it will remain. And in many sense, it's certainly better suited to that today. But I think a lot of the value, especially early on, people saw it in it, was the ability to operate as an alternative system.

So if it never happens, I don't know if that harms the value. Maybe it just, it's fine as a gold substitute, better than gold substitute, whatever you want to say. But I still think that potential's there. Maybe not particularly with Bitcoin, but with crypto writ large with blockchain tech writ large, decentralized blockchain tech, rather. But yeah, that's more my point is I think there was some speculation that it would get there. And to this day, obviously, most people say, I don't understand why anyone would hold Bitcoin as opposed to dollars and using digital money and things like that, using your bank accounts, using Venmo and so forth.

But I've never heard anyone from the kind of vast, unbanked world say that. I've only heard people from the developed world who have plentiful options say that. Right. So let's talk about the FATIF or financial action task force. I think that's actually the short version of the name. I think there might be something about counterterrorism in there as well, unless I'm mistaken. So this is obviously an area of focus for the industry right now. They've been quietly kind of publishing guidance and white papers for a while, but, you know, most crypto people weren't reading it.

But the noise in the industry press has gotten louder, almost reaching a crescendo now about how exchanges are going to have to dramatically alter their practices. But maybe before that, why don't we talk about the history? of the FATIF and where it derived from and what the original intent was, because I think that would make its present actions much more comprehensible. Well, the way I'd look at it is the modern financial system, world economy, really globalism you might want to call it, started, I'd say around and particularly right after the First World War. What you had after the first World War was an ineffective body called League of Nations, which the U.S. didn't even join. And it spotted a lot of policies that could have led to a massive deflation before it happened and couldn't get countries not to follow it.

For example, France had a lot of national debt, so they were kind of gold hoarding. The U.S. had passed the Smoot-Hawley tariffs. most of the countries went for the kind of more gold bug strategy before at the same time, and it led to massive deflation. One of the aspects was most of the European countries owed money to the U.S., so they were all trying to get money to pay back the U.S., and eventually the U.S. had to figure out ways to accept it. You had a lot of European countries kind of harvesting German industry and using that to repay the U.S. but essentially the big winners from this model were people that said,

note, you know, you need to spend as much as you can during this period. And if you don't, you'll end up in a deflationary spiral, which is what happened. And so then you ended up with the Second World War. And after that, it was kind of a consensus view that, A, we need a system that's run around one country. So the debt issue to the U.S. got kind of resolved with the Brett and Wood system. At the same time, European countries didn't have much. of a political interest in doing this. They had large populations of people that were working class and had just won this war.

And so for them, they had not, and we're talking mostly Western Europe, obviously. I personally think that, you know, Western European Americans get a lot more credit for it in the war. I think Russia obviously had a big role in that. But, you know, sidebar. But anyway, the point is more that Western European countries, why would they adopt this Brettonwood system around the dollar and lose their kind of mercantile empires? So the U.S. offered to repay these countries with the Marshall Plan, right?

So a huge amount of money given to an organization that went on to become the OECD. And that entity was meant to spend all this money. And in exchange, you ended up with this global dollar system. And at the same time, there were a number of other NGOs. So UN and GAT, ultimately, this trade organization around iron metals in Europe. which turned into the EU. So you saw multilateralism as a model that could work. And these multilateral organizations grew and proliferated throughout the 20th century.

But none of them actually are governance bodies. I mean, the UN arguably is, but again, you have the Security Council. And so you need to get all the biggest countries in the world to agree on it, which is pretty rare. So functionally, it doesn't do a whole lot. But instead of that, you have our G7s and G20s where countries actually get together and say, hey, here's what we're all going to pass. And they don't always all pass it, but when you have a group of people that agree on something, it creates pressure. And this is kind of the mechanism on which these things work.

And note, I should just jump ahead quickly and say FATF was formed by one of these G7 groups. It sits in Paris at the OECD headquarters. But in an event, the way that this works is that they don't have actual control over the countries. Countries can join it and join FATF or join one of these G7, G20, whichever groups. the group will make a choice, the country then can decide whether to go along with it or not. So it's a bit, and, you know, it's like, okay, why should they do it? They don't have to do it. And if it's against their interest as a country, why would they do it?

And the way I put it is it's a bit like this. If you have a bunch of colleagues and everybody decides what to eat for lunch every day, and they keep saying, hey, let's go get Mexican food. And you simply say, no, actually, I'm going to go on my own to eat Italian food. I'm not interested. and you keep doing that, you know, there's a kind of reciprocity aspect to it. And that's the nice way of putting it, right? There's a lot of other pressures on the political level.

But again, that's not the major mechanism of how these work. And I'll get into that in a second. So toward the end of the Cold War, we saw a new kind of system. Now, jumping a step back, you know, you have to look at the Bank Secrecy Act of 1970, which the U.S. passed, which just required banks to keep information on people. And, you know, bank secrecy accident, Orwellian, because obviously there was about the banks keeping secrets, but that's about knowing who all the people transacting are and keeping those secrets for law enforcement for when they want it. But that was kind of the extent of it. In many ways, you could look at the banks at this period as, you know, the way that exchanges kind of are now.

They're keeping your information, your KYC information, but you're not expecting them to do anything with that. I mean, maybe law enforcement will query it. You know, people get paranoid about it. but mostly it's the exchange just holding your info so they can comply with their own local laws. I call it the Bank Anti-Secrecy Act. That's not original to me, but... Right. Yeah, I don't have thought of it that way. But yeah, it is Orwellian, right?

Although you could argue that they're required to keep secrets they didn't keep before. So technically, I guess it's a secret keeping rule. But it wasn't until, you know, post-Cold War period and kind of three-nine. 11 period that you saw this change. So it was in 1996. Well, FATIF was formed right around the end of the Cold War. I think it was 1989. And it was again, you saw, you can look at WTO and CAD at the time as working to coordinate trade laws between countries to facilitate global trade. And it's a bit more innocuous, right? But FATIF was more oriented around crime. You know, it's like a 20th century kind of financial crime to Interpol kind of deal where again it's not not not effective like

interpol it's not a police force but it was an organization for countries to get together and coordinate laws around it to work with each other to to to to stop international crime right but in 1996 the u.s. passed the travel rule for its own banks and that's that was and eventually obviously that led to to an international version of it but the travel rule was unique because because it took that information that banks were required to keep under the bank secrecy act and then to transfer it in wire details. You couldn't send wires without including the name and the account number and their address and things like that. And not to mention on the other side of the transaction, the other person's name and their information.

So that was mandatory. And so you ended up with this network of information stored that way. So if you look at like a blockchain analogy, it's with the travel rule, before the exchanges kept the information like Bank Secrecy Act style, but they weren't disclosing it. The next step is they have to know who's on both sides of the transaction. So does this mean that they're going to immediately start mapping out the blockchain and make all the public? Well, no, right? That's not going to happen yet. That's not required under this rule.

I would not be surprised if it ends up like that down the line, which is what I'm actually more concerned about. I think a lot of people look at travel rule as the end and it's bad and it's going to disrupt these businesses, which is true. But I'm much more concerned with the longer term future of the travel rule, where it's headed. And the way we can maybe take a look at that is what happened next after the travel rule, well, this is post 9-11, was a Patriot Act, which truly deputized banks to do some of their own law enforcement on their own customers. And so at some point, I could see that happening for VASPs where you see more rules being passed and more countries dealing with it. And, you know, for example, transaction monitoring, looking for bad guys and reporting them. That's not a requirement under the travel rule for VASPs. But I think that could end up happening.

My biggest concern, though, is ultimately if enough of the transactions on the blockchain that are filled with metadata, that certain parties know about, I could see it getting to the point where those get mapped out more and more by all these blockchain analytics companies. And you could end up in a point where much of the block, you can know in one way or the other whether the transaction is clean or not, where the coins are clean or not in some sense, or how dirty they are. And you could start seeing the VASPs not allowed to touch the dirty coins until you end up with the clean blockchain that's fully KYC and has nothing to do with price. Obviously, excuse me. Yeah. And then the part of the blockchain that is actually private, you know, that is that is verboten, you know, and you end up with. And to some extent when I'm seeing exchanges getting regulated in different countries saying no dark coins, that's the first thing that comes to my mind.

Likewise, when I see crackdowns on dexes, that's another kind of red flag for me, you know, looking at it downstream because obviously decks is can't really comply with these. rules. So, I mean, actually, theoretically, they could, but I don't, you know, I don't think, I don't see why they would, right, and their financial interest, too. Yeah. Today, there's actually an interesting column from J.P. Koenig who compared Bitcoin's potential transition here to the way that the gold markets operate. As you know, presumably, most of the gold and the, most of the investment gold, well, a large amount of it, it exists in this kind of highly permissioned Waldgarden in London, overseen by the LBMA, the London Bullion Market Association. And they have these very precise standards for what constitutes London gold, so good delivery

gold. And they carefully authenticate everyone along the supply chain, the miners, refiners, recyclers, jewelers, you know, all of the links in the supply chain to ensure the that that gold is authentic, that they know what the provenance is, that it's not blood gold, quote unquote, that it's not kind of mysterious gold, where they don't know where it came from. And those physical bars of gold very rarely actually leave. You know, there's a bit of a dislocation where during COVID, you know, some of those bars had to fly to New York to make it into Comax, I guess. And that was that was a challenge.

So JP was positing that the Bitcoin markets could end up similarly where the major VASPs or the major exchanges and custodians, there's just a set amount of clean coins that circulate among them that never, ever leave that walled garden. And as you say, like, we could have a total bifurcation in the market where the dark coins don't. ever mingle with these coins that have been baptized that are considered clean, which is it's certainly something that privacy advocates in the crypto industry have warned about for a long time. But I'll admit, I didn't think it was going to happen so quickly. Yeah, I didn't expect that either. But yeah, to further your analogy, I would simply say, look, for the dark coins, and I think we don't mean literally dark coins, but the coins that are not seem to be sanctified.

Those, and therefore exchanges couldn't touch in this scenario. What can happen is that the coins could be baptized. You could simply arrest the people who had them, you know, in some way or another, you know, effectively launder it through the government legally, right? I should probably use the term laundered because that's not how we look at it. Technically, it does the same thing. We saw this happen with a lot of the seizures. Yeah.

The auction of the gox coins. And me and Matt joke about it, that those are the cleanest coins the world has ever seen because they're being auctioned directly from the sheriffs. Yeah, that's exactly right. And so to me, that's kind of where I see. People are always saying what's going to happen is they're going to make Bitcoin illegal and they're going to make crypto illegal. No, I don't think that's going to happen.

I mean, it's theoretically possible. But I think this way of doing it is much more lucrative and makes a lot more sense. you're using the laws to decide which coins are clean and which ones aren't. You're seizing the ones that are not clean and you're reselling them using the force of the state. And I will say this, this is not a purely kind of a doom and gloom thing. I mean, look, the state can't just go to your grandma, take her crypto and say she's bad. I mean, you know, in some level that can happen. But there's some, you know, back and forth between the public and the state.

And so on my mind, I like to look at it as the extent to which, you know, the actual criminal activity, look, this happens and we shouldn't downplay it. I mean, think of all the people you know in crypto that have been hacked and the money that's been stolen and ripped off and all of these things. This is very real. We all know it's real. We shouldn't pretend it's not real. To the extent to which the activity of these regulators is to go after that and seize the head and return it is legitimacy, right? It leads to more legitimacy for the system. in many ways it is legitimate.

So I see and obviously we've seen more of that. I mean, we can we can split hairs on a lot of it because a lot of it I don't know is quite as legitimate as say someone that actually gets, you know, they've beaten up and their hard wallet stolen from all the coins with a gun to their head versus say, you know, someone violated some part of a money transfer law or something like that unintentionally. But, you know, but in any event, it's a tug and pull between the legitimate reasons and the political reasons. And that's something that can't really be separated.

It's hard to say. I mean, sometimes it's like, you know, when you see it, this clearly was a legitimate, non-political, crime-oriented reason for seizure or for punishment. And you can also say, no, this was a totally political thing. This was unjust. But it's kind of in the eye of the beholder most of the time. So just returning briefly to the history lesson, actually,

I wanted to ask this at the time. So when the FATIF was created in 1996, I think it was 96. It was 89, but the travel rule was 96. Okay, great, 89, even better. So collapse of the Soviet Union. So at this point, the U.S. has become the world's sole superpower. We've gone from a multipolar to a unipolar world. Was that the major catalyst, which is that the U.S. had achieved a level of power, having, you know, won the

Cold War, where they decided to effectively take control of the world's financial markets through this, or they felt ambitious enough that they felt that they could kind of police all major kind of financial transactions globally through their order, even though, you know, strictly speaking, the FATIF is not a U.S. organization, but it's kind of broadly part of the Washington consensus, or was it a historical contingency whereby more and more transactions were being digitized at that point, and they felt that the changing technological nature of banking meant that they could both, that they could enforce financial crimes more efficiently, and so that was a good catalytic time to start it.

Okay, so at the time, certainly everybody would have agreed it was the latter reason, right? nobody would have, I mean, looking back on it, I think we're in a, you kind of a, what you say, Francis Fukuyama with the book, End of History about how the end of the Cold War meant we now have this global kind of multilateral. I don't, you might use a term neoliberal. I'm not a big fan of that term, but you could say that it's a neoliberal world order that we now have now that the Soviet Union's over. And I think maybe that period, now that that period's maybe ended, I don't know if everyone agrees it's ended, but we're certainly a more kind of nationalist world political system now than we were then.

It looks like that. It looks like this was the U.S. seizing, you know, the day and then kind of orchestrating this. Again, it happened around the end of the Soviet Union. I don't know if it was quite over. Certainly the plans for it occurred before. It was obvious that it was ending. And the actual initial meetings happened before it ended.

But looking back on it from kind of a Monday morning quarterback perspective, it seems like that, right? So I don't know that we can quite know the answer because the truth is all these organizations frame these things as purely policy-interested movements, and you kind of have to play the Realpolitik game to look at it from a larger political perspective and the kind of arc of history perspective.

I will take this opportunity to say that I feel that Fukuyama is actually unfairly maligned for that book, which isn't as very, maybe one-dimensional and kind of triumphalistic as people make it out to be. But yeah, you can certainly see how this would have been seen as the apotheosis of U.S. power, you know, having effectively conquered communism and, you know, having united the world under their, you know, largely market-driven capitalist doctrine, and then policymakers effectively saying, well, why don't we put all of the world's financial transactions under our purview? Whether it was designed to achieve the kind of

intrusive intervention that the U.S. wields today or whether that was done for initially benevolent reasons, I guess the question would be to the extent that that U.S. order is potentially degenerating now, you know, to the extent that that unipolar world is ending, is that a sign as well that institutions like the fat of which are derivatives of U.S. power will also lose their ability to kind of manifest their will on the world? I think the answer is probably yes. I don't, we haven't seen that happen yet. So, and it's, it can go so many different ways.

So, for example, we might see a more polar world, multi-polar world, probably bipolar world. Bad connotation, but between, obviously, U.S.-led coalition and a Chinese-led coalition. I mean, you know, China spends a lot of money internationally and has been trying to build a coalition with the whole Belt Road initiative, you know, billions a year. we recently saw them sign an agreement with Iran, which I think was $200 billion investment, maybe even more than that. And that represents a substantial amount of the money they spent internationally. Now, granted, it's all in Renminbi. So there's that whole question. But yeah, I think in that context, you might see NGOs and Europe playing more of a arbiter role. I actually could see, because to me, when I first think about that question, it's kind of like,

Well, what's going to happen with the dollar? To me, that's the centerpiece of it. So if the dollar becomes wanes in power and is no longer, we have a multipolar world or gold and Bitcoin or whatever are this tool of international, you know, kind of wealth, I don't know what else to call, like the unit. I don't want to say it's unit of account, but it's basically the source of wealth. The dollar is no longer the centerpiece of it. In that world, the most interesting thing to me is all of the countries,

in Western Europe and a lot of other places that might be well suited and appear on some level to be at least hedging toward crypto. Will they adopt crypto? Will they try to play the, like I, you know, I've been thinking about how Switzerland played this role in the 19th century and ultimately became this first major offshore haven that was remaining neutral. Could Western Europe or maybe larger, you know, Europe writ large, be the Switzerland of that more multipolar, you know, globalized world where nationalism is stronger.

It's like exactly what Switzerland ended up doing because they were neutral, given their positioning and protection, will Europe end up playing that role in the future? Because I don't think we've seen small offshore countries, smaller countries that tended to, you know, succeed in the offshore world and kind of playing the modern, you know, system, the multilateral system to their advantage. we haven't seen them jump into crypto. We just haven't. I would have thought we'd seen a lot more of that.

Instead, we've seen them adopt travel rule and VASP. So they're succumbing to the international pressure as opposed to seizing the day and saying, you know, we're going to buck the trend here. We see a lot of potential for it. And I think in large part, it's simply because if you are in that world of multilateral politics and NGOs and whatnot, it's hard to look at crypto as anything except money laundering vehicle. And obviously it is in many ways a money laundering vehicle, but that's in large part because it's a competitor to a system that is not,

that is, you know, opaque and centralized, right? So you're going to have some of that. So in any event, that's, that's like my macro thesis here is, I think if we ended up with a more nationalistic world, we might end up with a European arbiter who's playing the various sides and acting as an intermediary trying to keep the world together. And it's a big arbitrage for them and financially beneficial for them in the same way that the Swiss in the 19th century played it to their advantage. So, yeah, that's my kind of. And I'm basing that in part on the fact that you've seen a lot of European countries pass interesting crypto-friendly rules in the past year or two. Yeah, I was going to say, obviously in Switzerland now, there are, I believe, four banks, which are directly custody.

crypto. Germany has some fairly progressive legislation on the topic of crypto. And then you have kind of havens like Malta, which have been very overly pro-crypto, albeit, I think they might have been brought to heal recently, actually. I don't know the latest there. But that's certainly an interesting grand thesis. In terms, I like it when when guests have these these very well worked out kind of grand theses for how the world is going to develop. One question that I think people don't really understand, including myself, is, you know, how does, because the FATF isn't really an enforcement body per se. They kind of develop recommendations and then those percolate down through to the various

countries in the world. how mechanically do FATIF recommendations end up being implemented as policy in, you know, places like the U.S., for instance, but also abroad? Right. Okay. And I think that's a really good question. So technically, as noted, these are suggestions at the end of the day. There's no legal mechanism to require, say, Malta or Bermita or whomever to adopt those laws. but as a the way the place that this happens is in new york it happens in at the banks themselves so as i was mentioning earlier um let's say that you are a bank in in new york you're in the compliance office you work for i don't want to say city group or something um and you see the new fadif blacklist has passed and you had a country say it's like i don't want to pick on anybody but um Well, let's see.

Let's say Madagascar. I don't know why I'm choosing that one, but Madagascar is one of, you have a correspondent bank in relationship with Madagascar, right? Let's say overall net fee-to-fe, you're getting a couple hundred grand out of it per year at the bank, right? So Madagascar is a whitelist country, and it moved from white to black suddenly. They got a new leader in Madagascar, who's who, you know, he wants to align.

he's spoken very highly of ISIS and, you know, he wants to, I don't know, again, Madagascar is not an Islamic country, but just go with it. Go with the analogy. Anyway, you have a wacky new leader who is very pro international terrorism and, you know, it gives money to it. And, you know, he's spoken very fondly of it. And Madagascar gets pushed onto the Fatif Blacklist suddenly. So what the Fatif Blacklist does is it recommends to banks internationally that you might want to be careful in doing business with these countries. So this bank decides, oh, crap, we have to be more careful dealing with Madagascar. So they think about it and they're like, okay, so obviously we need to do enhance due diligence on our banks there. We need to do, you know, look into who owns the banks,

whether they have these kinds of risks with connections to him, you know. And some of this happened with Malta or may have happened with Malta because with Malta you had a prime minister whose close confidants were involved in money laundering. With this Madagascar example, they've then seen it move to the blacklist. They're thinking, okay, so what do we do now? Well, we need to vet everything. And that costs money. You need to hire people to vet the bank and whoever this leader is and his cadre of supporters and people around him. And in most of these circumstances, what happens, especially if they stay in power over time, is their friends and family become the owners and directors of all the banks and major financial institutions in

these countries. For example, that happened to Venezuela. So, you know, over time, that's what happens. The bank looks at this, figures it out, measures the risk, makes sure that they, you do a lot of hand-wringing about who owns the banks, and oftentimes they'll continue working with them and oftentimes they won't. But remember, in this analogy, the bank's getting 200 grand a year for Madagascar. So why, they're going to need to spend more than that to vet all of this. They have to hire New York-based compliance officers and people like this to actually vet all of these, the correspondent banks in that country, the, you know, the directors of them,

they have to worry about the transactions. There's just a risk overall that the transactions could be money laundering. Bear in mind with this individual, with his Al-Qaeda fascination, I don't remember if it was ISIS or Al-Qaeda, but whichever. He's fascinated with these. organizations, there's an enhanced terrorism laundering risk. And that's a, that's more of a, you know, just a low bar. If you get a few hundred dollars for terrorist financing, that's a very serious. Whereas if it's money laundering and it's, it's a very low amount that's not as serious.

So most likely what the bank in the year will decide is that we're not going to, we get 200 grand of this. We're not doing this. This is not worth it. We're just going to de-risk them. So the banks in in Madagascar start to get de-risk. And if you look at a, you know, a simpler analogy, some small Caribbean country with a couple hundred thousand people in it that gets pushed onto FAAF. They don't have a dictator. They've got nothing like that, but they only have a couple hundred thousand people in the country that are, and granted, these people are just regular people, mostly running

businesses, you know, living out their lives. Those banks will get de-risk too because it's not worth measuring and gauging the risk. And so from the individual country's perspective, that's the real risk. It's not that the international community is going to crack down on you. I mean, there's a little bit of that kind of lunch analogy I made earlier. If you're ignoring FADF, you're the guy that went and ate lunch on his own and, you know, is ignoring everybody and is not cool. But on the other hand, it's really the risk of the banks in my country, the financial infrastructure,

is going to get the risk and there's going to be less and less competition. And that's a serious, serious issue. So the mechanism is more happening through correspondent banking. And so that's why I think crypto and Bitcoin are increasingly playing a role in this. I mean, we saw in 2017, 2018, especially 2018, actually even 2019. What do I say? It's been the past four or five years that geopolitics and crypto have become a thing. And that happened way faster than I thought it was going to happen.

But it's happened. And it's happened in part for this reason because there's more and more money is moving into crypto and in Bitcoin. And it can act as a counterweight to this kind of pressure from the banking system, the bank system acting as the enforcer for international order. And again, the banks aren't acting as an enforcer. I mean, they are deputized under the Patriot Act to do transaction monitoring under U.S. law. But it's more that they're afraid, they're receiving guidance from FATIF.

And they're afraid of, you know, getting hit by their, mostly the U.S. government with fines and penalties, which we've seen. We saw it, especially after the financial crisis. all these AML violations. If you remember, you had HSBC scandal. There was a bunch of them at the time. It feels like so long ago. I don't want to name the banks. But yeah, there was a lot of them.

And it was billions of dollars. It was not a small amount of money. So if you're looking at that analysis of Madagascar, it's 200 grand, which will probably not even be able to pay for. And we also then run the risk of even if we go with Madagascar, of getting fined a billion dollars. Well, no way, Jose. We're not interested in that country anymore.

So, like, if you actually look at the FATF website and you look at the imaginations of the thing, which is what I did when I was trying to research it before, I should have just talked to people like you, really. But, you know, I wouldn't. Yeah, it's always more efficient just to talk to the subject matter experts, surprise, surprise. So, you know, Fattif does have,

this blacklist and they've got a gray list. The blacklist, I think, has two countries on it right now, North Korea and Iran, if I'm not mistaken. And then the gray list has maybe a half dozen countries. But what you're saying is those mechanistic things aren't really how the fat of recommendations are instrumentalized. It's this much more informal process and it's more a function of it being in the best interest of many of these financial institutions to minimize their contact with certain places if they're not conforming to these established standards. Yeah, and above that, I would say it's U.S. regulations because of the way the world works with the dollar and so we still have the Brettonwood system, U.S. regulators control dollar clearing.

At the end of the day, that's the key to it is. What is NYDFS and the ability to me? maintain dollar clearing. That's the big key of it. Not many banks have that. And that's the key to most of the correspondent banking because to move the money around the world, oftentimes it requires dollar clearing in New York. You need to transfer it and have that right. And NYDFS controls who has that right. So you have to keep those. And also one more point I would like to make is that if you read the actual laws, if you read the Patriot Act, if you read Bank Secrecy Act, Act, they don't say exactly what banks should be doing. They lay out the rules more or less you need to develop, for example, the Patriot Act,

a transaction monitoring rule. Here's some concerns about it. But the banks figure it out on their own. So the banks look to FATIF for guidance, you know, and it just becomes a norm about how your compliance program should work. It's not a law, so to speak. And the norm carries a lot more weight in the U.S. So on some level, it's like FATF is, I don't want to say it's an arm of the U.S.,

But at the end of the day, if the U.S. enforces it on the banks that all need to operate in the U.S., including foreign banks that need to keep this dollar-faring mechanism, that's really the function of it. You know, and so if you listen to a lot of people who are at these FATIF meetings, they'll tell you that it was something the U.S. push for more than anybody else did, the travel rule. I think you can see why crypto-native people might find this incredibly unsatisfying. the fact that the apparent rules for behavior banks are heavily norm-based and kind of implicit understandings of what the government wants, not even necessarily spelled out in laws, as opposed to being codified and transparent.

And it seems like that would be highly exclusionary if it's based on just your membership in some club whereby you have a full understanding of what those expectations are. Yeah, and if I could write a tell-all book about it that would teach everybody about it, what goes on inside the banks, I think that'd be great. But again, I can't do that. And even if I did, it changes so fast, I don't think it would still be that helpful. When you're retired and you don't have bridges to burn anymore, I think we're all going to expect that from you. Yeah, for sure, obviously.

I'll have to go somewhere where by then maybe there will be some sort of chip put in my brain that makes you the legal. for me to say these things out loud. Only if you get the vaccine, you get the check. Right, exactly. So I feel like we're closing in on the question that is on most people's minds, which is clearly the noose is being tightened somewhat, not to use apocalyptic terminology or anything, but clearly there's a much more concerted effort to characterize crypto institutions

and to assign them certain codes or standards of behavior. So what is your current take on the imposition, in particular of the travel rule, on VASPs, but just more generally on the level of intrusion we can expect from these fat of guidelines in the crypto industry, and what does that necessarily mean for these exchanges and their users? Yeah, I think, well, I didn't we just see Bitmex announced KYC yesterday, I think. Yeah, yeah.

So, yeah, I think basically it's a golden handcuffs thing for the big successful exchanges. It's, you know, if you listen to CZ a year ago, he was saying, we're never going to do this. We don't care. And then a few months later, they spun off all the U.S. users and did finance U.S. I think it's done in many ways through incentives. What I will say is that I think the way that it, the counterweight to it, there's a couple of them. One are the fact that it's easier and easier to build an exchange,

and it feels less and less scary to go use it. So you look at like, remember what it was like on Polonex or PtCE in the early days. It was like, you just got your money on there and got it out. petrified of anything happening. Most people said that was their experience with it. Especially for BTCE that was completely warranted in the end. Right. And I'm not even saying it's not warranted of you.

I'm just saying it's easier to set these up than it used to be. So there's that mechanism. And then also there's dexes. So, you know, if you can get the dexas off the ground, if you can get these truly decentralized tools for transacting and swapping around off the ground in such a way that they can't really shut them down. There's no centralized parties. That could act as a counterweight.

But again, I think the problem is just that it's too usable, you know, the big exchanges. And so if you have finance and everybody else doing this and everybody, you know, we're not committing crimes. I don't see a reason not to use them. I mean, full disclosure, I don't, you know, I don't use skeezy exchanges. I use the big exchanges because I'm not, you know, they don't have anything to hide, really. and I think that's most people. So, you know, to what extent are we going to see the little ones pop up, the dexas pop up?

And again, what you'll end up seeing is in that world, it'll be even further concentrated money laundering people, right? So that's overall, that's kind of the trend is you'll have the bigger ones buy into it, the smaller ones and smaller ones popping up. And, you know, the decks is popping up that don't have a clear AML kind of focus. will get more money laundering on them and not do anything about it. And then ultimately, you might end up seeing a wall put between the big, legit exchanges and smaller ones. In the same way we saw a very informal wall that, quote, unquote, never existed between the banks and everything in crypto over the past decade or so. So, Zach, you've been striking both an optimistic and a pessimistic tone kind of, depending on the topic, what's your current outlook for the crypto industry?

I mean, what's it going to look like to be a crypto anarchist over the next 10 years? Is that something which you can possibly be or is it going to be stifled effectively by these international organizations? Yeah, I think so it's like this. It depends on which direction the world order kind of goes. If it becomes increasingly multilateral, which has really not been the direction. but we can see that happen. I think it looks pretty bleak.

It's along that scenario I described before. If it becomes more nationalistic, if we have a rise of nationalism, you have kind of this interesting dynamic where on an individual country by country basis, there's a real reason for these countries to not like crypto. And this has kind of been what we've seen with the kind of schizophrenic approach from places like China and Russia and, you know, large countries that are in this, in the kind of periphery of the global monetary system, but also heavily involved in it. They don't have the banks.

They don't have dollar clearing, but their big country is important politically. For them to maintain their national currency and everything else, it's bad for them. But at the same time, it's probably worse for the U.S. So if you look at, for example, the U.S.-China trade relations in the past few years, it's been much worse for China than for the U.S. because of the fact that China is worth like 60% international trade. The U.S. is like 5% of its GDPs from trade. So it's the U.S. headbutting China, so to speak, and hurting itself, but hurting China more.

This is kind of a similar dynamic with these countries that it hurts their own currency to adopt and proliferate crypto, but they know that it hurts the multilateral order in the U.S. much, much more. So it's like a headbut against the system, so to speak, to embrace it more and more. But we're not there yet. So my point is if we keep moving in a nationalist direction, we've seen it happen. I mean, Brazil, you could argue that Trump in many ways, at least on a political level, represents that. A lot of European countries have been doing this.

A lot of smaller countries around the world. You know, you could even argue Modi in India. So it's happening. So if that trend continues, you know, the countries that are not benefited by this order and are not integrated into the order in the same way will tend to when a head butted by embracing crypto. At the very least, as a settlement tool, at the very least in kind of like a collective, you know, what's that, what's that the Chinese finger trap thing where, you know, if they'll try to,

if they try to pull out, if the world, as the world tries to become more nationalistic, the Bitcoin coin, the same way that gold used to operate, becomes this international settlement tool that they're all kind of advantaged by using. So I can see that is more the way it's headed if the world becomes more nationalistic. But again, if it becomes more multilateral instead, if it were, if it maintains kind of current levels of multilateralism, I think we'll see more travel rule. I think we'll see more, you know, not just the travel rule, but then, you know, I think the exchanges will be encouraged not to work with exchanges that don't have the travel rule.

They'll be encouraged to only allow you to transfer money to other exchanges and things like that. And again, I'm not saying I'm not saying this has happened and I have inside information. I'm just saying I think that that will be the general trend. I mean, you can look at the Bank Secrecy Act in 1970. Well, okay, thanks, you've got to keep track of this stuff. There's a lot of criminals here. We want to know what's going on. You've got the mafia, blah, blah, blah.

Then by the late 90s, oh, yeah, yeah, by the way, when you transfer with each other, you got to put all the info on the ticket so everybody knows what's going on. Then a few years later with the Patriot deck, oh, by the way, yeah, you're going to need look at all your customers, keep track of what they're doing on a daily basis. And if they do anything suspicious, you've got to tell us. So it is a movement in that direction, right? And so I think the travel rule is just the first step. Yeah, you can see the progressive growth of expectations with regards to banks and their client data.

Well, of those two scenarios, one of them is clearly more appetizing to me. We'll see how it shakes out. In terms of praxis, how does your firm intersect with these ideas? You clearly have certain normative views on the way the world should be. Are you instrumentalizing those? What's your role to play here? Like I was saying earlier, we're focused more on litigation work in the U.S. It's like a, like this stuff that I'm talking about has, I mean, granted, we, we advise countries.

It's like something that we like to do. We know which countries are more attractive and not. But mostly we're doing litigation work. The stuff I'm talking with you on the podcast is more of my personal experience, not really firm related, so to speak. And I'm, you know, it's like an interest of mine. It's something I write about or talk about. But I don't, we're not really focused on it beyond the fact that we understand where, you know, what are the places it's incorporated what's going to happen down the line and these things are happening really,

really quickly. But again, their focus is primarily litigation. Are there historical cases that you can talk about that you're particularly proud of in terms of the outcome? The problem is all the cases have turned out where it was settled before it got there. But, you know, we basically were prepared to go to court on all of them. I mean, I'll say that we had a number of cases that would have been the big cases in crypto that just got settled before they got there. I want to give you some color on what we do, but it's mostly people that are harmed in one way or the other, whether the contracts are violated or whether they have rights that were not granted to them, whether they experienced a tort. We're talking about investors and projects, as well as people working for projects, founders of projects. You know, the crypto space is a very snagy space, as we know.

It's not a controversial point to make. So the stuff, it's like for me to sit here and pontificate on these other issues is what I do. out of my own interest. But the problem is that there aren't any true experts because you really need to know all of the laws of so many different countries in a very in-depth way. For me, it's more how does the system work? But yeah, like I said, our focus in terms of the relationship to these things that we've spoken about are more helping with international structuring, decision-making on a corporate

level, but our focus is more litigation. Well, Zach, how do you recommend that people follow your work and how should they get in touch with you if they want to engage your services? Well, we have a website. It's www.common.org. You can email me at info at kelman. If you want to follow me on Twitter, it's at Z Kelman. I'm on a clubhouse. I don't know. That's right. We ran into each other on there. It's great. I just got an invite. I feel like I'm, part of a semi-exclusive club now. Well, Zach, this has been really fantastic. I learned a lot. I always try to learn as much as possible, but I feel like we've unearthed some pretty deep truths today. And I want to thank you for coming on. Hey, it's my pleasure. And as I noted, this is one of my favorite podcasts. So it's an honor to be here with you. I love it when the guests say that.

They don't always say that. But thank you for saying it. It really isn't. You know, it's like, I think that you're one of the really, you know, like fair arbiters who's just trying to get it the truth. You don't really seem to care so much about the fame or attention or whatever. Don't seem very ideological so much. Or maybe it's just that I have similar ideological bias. But, yeah, I get that sense. So that's why I like the podcast, a depth of knowledge, too.

So I don't see that elsewhere. Yeah, I'm not to say that none of them are like that. But for me, it's the kind of right mix. So I like it long. Well, I'm going to take what you just said and turn it into an ad for the podcast. All means. Go ahead. All right. Well, thanks again.

It's been great having you. Thanks, thank you.