Dear Executive Secretary Lewis,
On behalf of the Global DeFi Coalition and its members, ACCESS (Singapore), Bitcoin Association (Switzerland), Blockchain Association (United States), Blockchain for Europe (EU), CryptoUK (United Kingdom), and the International Association for Trusted Blockchain Applications (INATBA), we would like to reach out to you on behalf of our 350+ member companies and partners concerning the ongoing debates about the latest FATF guidance on a risk-based approach to virtual assets and virtual asset service providers and the potential implications for the Decentralised Finance (DeFi) sector.
Representatives of the DeFi sector from all over the world came together in this initiative to support regulatory bodies in finding well-balanced approaches towards regulating the various actors in DeFi. To this end, we have formulated six principles that we encourage you to recognize when drafting recommendations that concern Decentralized Finance.
An effective mitigation of money-laundering risk and terrorist-financing risk in Decentralized Finance should be based on the insight that DeFi is qualitatively different from traditional finance as it lacks the financial intermediaries AML-regulation is usually attached to. While recognizing the gate-keepers to DeFi as financial intermediaries works well, risk mitigation for the financial activity that happens in between gate-keepers requires new paradigms to ensure society can enjoy the benefits of DeFi while simultaneously satisfying law enforcements’ needs. We therefore respectfully propose the following principles (attached) to guide the regulation of DeFi.
Thank you for considering this request and we are looking forward to your response. Our team is glad to get in touch with you and your colleagues to discuss any further details.
Sincerely, on behalf of the Global DeFi Coalition
Luzius Meisser Board member Bitcoin Association Switzerland |
Kristin Smith Executive Director Blockchain Association |
Maria Minaricova Chair of the Board Blockchain for Europe |
Robert W. Kopitsch Secretary-General Blockchain for Europe |
Ian Taylor Executive Director CryptoUK |
Marc Taverner Executive Director INATBA |
Anson Zeall Chairman of the Board ACCESS |
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