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From YouTube: DXbiz Weekly Gathering [2022-09-23]
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B
It's
recording
now
it's
the
new,
let's
see
it,
it
doesn't
announce
anymore
and
it's
recording
okay,
good,
so
hello,
everyone
and
welcome
to
DX
Styles
weekly
strategy
call
today
is
Friday
September
23rd
and
we
got
yarik
presenting
the
DX
legal
assessment
and
then
once
we
have
some
time
left
till
the
end
of
the
call,
we
will
be
discussing
our
upcoming
events
for
both
the
Colombia
yeah.
You
got
the
stage
now:
okay,.
A
Thank
you
guys,
I'm
already
showing
a
presentation
with
you.
So
just
you
can.
A
That,
okay,
okay,
so
let's,
let's
start
with
the
with
the
presentation.
Thank
you
thank
you
for
for
joining
this
presentation,
based
on
the
paper
that
I
prepared
and
and
which,
which
will
be
shared,
I.
Think
with
all
of
you
and
maybe
on
the
adult
forum
as
well.
So
today,
I'm
going
to
talk
about
the
mlkyc
measures
in
relation
to
the
xdao
I
divided
the
presentation
into
four
parts.
A
I
will
start
with
the
introduction
about
the
topic
and
about
me,
then
I
will
switch
to
risk
factors
which
I
divided
into
three
parts:
the
money
laundering,
terrorist
financing
in
relation
to
Global,
U.S
and
EU
areas,
sanctions
evasion
and
blacklisting.
Then
I
will
talk
about
possible
mlkyc
measures
as
a
response
to
risks
and
then
I
will
briefly
describe
some
approaches
taken
by
by
other
vowels.
A
So,
let's
start
with
with
the
introduction
about
me,
I'm
an
EU
based
alternate
law
admitted
to
Bar
in
Poland
I
I
used
to
work
in
a
financial
special
Supervision
in
Poland.
Then
I
was
a
compliance
officer
in
Bank
in
Western
Financial
company
and
in
brokerage
house.
It
was
also
an
anti-manandering
reporting
officer
in
payment
institutions.
So
a
lot
of
experience
from
the
traditional
Finance,
which
I
think
you
might
notice
during
the
presentation,
because
the
the
approach
and
the
generally
the
the.
A
Series,
it
is,
it
has
its
its
grounds
in
traditional
Finance
and
I'm,
currently
providing
services.
A
Groups,
so
the
aim
of
the
of
the
study
of
the
paper,
so
the
name
of
the
study
of
the
of
the
paper
was-
was
to
provide
the
initial
overview
of
what
the
ex-dial
could
could
be
concerned
with
regards
to
AML
kyc
laws
and
some
suggestions
on
practice.
Measures
to
take
also
review
of
how
different
dials
have
approached
this
this
question.
A
So
the
topic
is
really
Broad
and
I
have
to
have
to
try
to
to
to
describe
it
in
a
manner
that
would
not
be
that
long,
but
would
provide
like
the
most
important
things
that
has
to
be
said,
of
course,
a
disclaimer
which,
which
is
very
popular
in
the
US,
that
none
of
this
is
legal
advice.
A
It's
funny
because
in
Europe,
I
I
don't
really
use
this
disclaimer
in
such
obvious
situations
as
a
presentation
here,
but
anyways,
of
course,
do
not
like
base
any
any
other
decisions
of
what
I'm
about
to
say,
because
it's
not
a
legal
advice
in
case
of
in
case
of
risk
factors,
I
decided
to
to
approach
and
one
one
or
one
thing
also,
because
I
am
seeing
only
my
presentation,
so
I
don't
see
any
direct
direct
messages.
So
in
case
you
have
any
questions
during
the
presentation.
A
Just
please
please
say
cloudy
because
I
don't
read
the
chat
section
right
now,
so
in
so,
let's
start
with
the
with
risk
factors:
I
decided
to
to
analyze
the
applicability
of
of
IML
and
KMC
laws
and
standards
on
the
basis
of
the
regulatory
risk-based
approach.
A
Currently,
as
as,
as
you
know,
there
are
no,
there
are
no
laws
that
can
be
identified
that
require
the
application
of
of
inl
kyc
measures
to
Dallas.
In
general.
Such
laws
exist
among
other
in
relation
to
Banks
to
investment
firms,
investment
funds
Etc.
So,
in
general,
in
relation
to
traditional
finance
and
there's
this
regulatory
risk-based
approach,
it
allows
to
apply
mitigating
measures
directly
in
response
to
the
risk
identified
and
this
this
approach
I
think
is
applicable
to
to
Dao,
because
we
do
not
have
a
specific
set
of
rules
that
could
be
applicable.
A
We
do
not
have
any
legal
and
entity
set
up
in
a
particle
of
your
jurisdiction
so,
depending
on
the
jurisdiction,
depending
on
the
approach
you
might,
we
might
have
certain
different
risks
that
we
should
that
should
that
we
should
take
into
consideration.
A
That's
why
we
we
just
have
to
try
to
to
either
identify
the
risks,
the
most
important
risks
and
then
maybe
come
up
with
some
some
solutions
to
to
address
those
risks
and
those
risk
factors
I
divided
into,
as
I
said,
money,
rendering
sanctions
divisions
and
blacklisting
and
I'll
start
with
manilandric
in
Terrorist
financing.
A
On
from
the
global
point
of
view,
the
most
important
standards
and
reforms
comes
come
from
Financial
action
task
force
and
it's
a
it's
a
global
monetary
money,
money
laundering
and
tourist
financing
Watchdog,
which
sets
which
sets
up
standards
for
for
from
for
for
most
developed
countries
to
follow.
A
The
path
has
already
issued
several
documents
relating
to
Virtual
assets
that
have
influenced
on
global
regulatory
regime
in
relation
to
to
Virtual
assets
and
still
as
for
now,
those
are
not
directly
considered
as
virtual
asset
service
providers
like
that.
But
this.
A
But
but
in
terms
of
the
definition,
there
are
some
nuances
that
might
be
that
might
might
result
in
a
in
qualification
of
of
of
certain
dials
or
certain
defy
as
as
little
asset
service
providers,
because
the
definition
of
virtual
asset
service
provider
includes
safe
keeping
administration
of
virtual
assets
or
instruments
enabling
control
over
visual
assets
and
fat
explains
that
the
safekeeping
consists
of
the
service
of
holding
Capital
asset
or
the
private
keys
to
the
virtual
asset
on
behalf
of
another
person,
and
also
the
term
Administration
could
include
the
concept
of
managing
virtual
assets
for
or
on
behalf
of
another
person.
A
So
this
this
is
just
a
part
of
the
of
the
definition,
but
fat
considers
the
definition
of
the
withdrawal
asset
service
provider
to
be
brought
and
in
in
consequence,
according
to
Fat
any
entity
that
has
the
ability
to
exercise
control
over
virtual
assets
may
qualify
to
be
considered
as
spiritual
asset
service
provider
and
in
simplest.
In
simplest
terms,
fat
describes
safekeeping
as
a
service
of
holding
virtual
asset
or
the
private
key
to
to
the
virtual
asset
on
behalf
of
another
another
person.
A
So
this
is
something
that
we
have
to
take
into
consideration
when,
when
thinking
about,
whether
Dao
might
be
might
be
influenced
by
a
structure
definition,
especially
that
fat
provides
standards
that
that
are
followed
by
other
countries
but
might
be
changed
or
might
be,
might
be
implemented
in
a
certain
way.
That
might
differ
slightly
from
what
fat
describes
and
also
one
of
the
most
important,
more
important
areas
of
of
regulation
in
in
terms
of
fat
or
is
the
regular?
Is
the
recommendation
16
this?
A
This
recommendation
relates
to
to
wire
transfers,
and
this
recommendation
also
forms
basis
for
other
countries
to
to
follow,
and
it
requires
both
financial
institutions
and
virtual
asset
service
providers
to
collect
personal
data
on
participants
in
transactions
exceeding
1000
dollars
or
Euro.
So,
in
consequence,
any
entity
consider
it
as
due
to
our
service
provider
might
be
subject
to
such
obligations
following
the
implementation
in
in
local
laws.
A
I'll
also
mention
this
later
on
talking
about
the
regulatory
developments
in
the
European
Union,
so
in
case
of
of
risks
in
case
of
risks
related
to
Global
developments
I.
My
my
take
and
my
Approach
is
that
that
the
broadening
of
of
virtual
asset
service
provided
definition,
as
is
one
of
those
risks
and
it
it
might
include,
for
example,
natural
persons
holding
private
keys
to
those
treasury.
So
that's
one
of
the
of
the
ways
such
a
such
a
definition
might
be,
that
might
be
might
be
changed
or
further.
A
Further
further
change
and
also
National
interpretations
of
travel
rule
is
one
is
also
one
of
the
risks,
as
does
this
kind
of
interpretation
might
require
the
provision
of
personal
data
from
The
Originators
of
crypto
transfers
coming
from
Deep
style
treasury,
also
introduction
of
recommendations
requiring
the
provision
of
information
on
more
parties
involved
in
crypto
transfers,
as
well
as
on
the
source
of
funds
in
such
transfers,
and
also
introduction
of
new
approach
to
defy
including
requirements
for
entities
interacting
with
protocols
and
for
for
protocols
for
protocols
than
themselves.
So,
unfortunately,
these
are.
A
These
are
broad
subjects,
and
these
are
just
devagations,
but
these
are
the
the
risk
that
I
think
any
doubt
should
take
into
consideration.
I
should
and
should
observe
in
terms
of
local
developments
and
and
on
in
terms
of
what
particle
jurisdictions
adopt
on
the
basis
of
of
of
of
certain
rules
and
recommendations
of
fat
and
and
then
now,
let's
switch
to
the
US
and
risk
factors
in
in
the
form
of
money
laundering
and
terrorist
financing
in
the
in
terms
of
of
us.
A
So
there
are
the
regulatory
sorry
just
so,
as
as
you
might
know,
in
terms
of
General
supervision,
there
are
certain
certain
supervisory
authorities
in
the
US
and
there's
this
none
and
there's
no,
not
one
Authority,
that
that
would
be
responsible
for
the
supervision
or
the
digital
assets.
So
we
have
Securities
and
Exchange
Commission.
We
have
Commodities
and
future
trading
commission.
We
have
Consumer
Financial,
Protection
Bureau
and
in
terms
of
of
IML
and
sections,
there
are
two
primary
laboratory
agencies.
A
So
my
take
is
that
and
the
risk
factors
in
in
case
of
of
the
U.S
U.S
market
and
U.S
jurisdiction
is
connected
to
how
the
supervisory
and
general
government
agency
work,
because
in
March
2022
the
executive
order
on
ensuring
responsible
development
of
digital
assets
was
signed
by
President
Biden,
and
it
is
a
focus
on
mitigating
finance
and
National
Security
Risk
by
directing
I
guess
and
called
unprecedented
focus
on
coordinated
action
across
U.S
government
agency
and
I
was
really
curious.
A
How
in
which,
in
which
direction
this
is
going
to
to
develop-
and
it
is
still
yet
to
be
seen
how
exactly
this
Focus
would
influence
actions
of
all
government
agency
in
terms
of
AML
but
I
think
that
and
the
most
recent
exam
example
of
a
penalty
by
cftc
on
b0x.
A
So
these
are,
these
are
the
risks
and
unfortunately,
these
are
the
risks
that
do
not
result
from
the
already
existing
laws,
as
you
might
know,
but
this
risks
result
from
the
approach
taken
by
those
agencies
by
the
not
on
the
on
the
on
the
on
not
on
the
last
themselves,
but
rather
on
the
interpretation
by
enforcement.
A
So
this
is
this
is
something
that
especially
the
the
last
example
would
be
zero
X.
This
is
something
that
that
is
going
to
to
have
a
lot
of
focus
of
the
crypto
Community,
because,
as
I
said,
it
is
not
based
on
it.
A
Is
it's
not
based
on
on
any
on
any
existing
laws
that
that
this
even
the
b0x
could
could
follow,
but
it's
rather
the
interpretation
as
far
as
I
know
of
of
of
of
other
roles
and
and
how
they're
applicable
to
to
to
Dao
and
to
to
protocols,
and
now,
let's
switch
to
to
the
EU,
also
and
I'll
start
with
with
the
provision
of
of
some
background,
so
the
the
Airman
regime
in
Europe
is
different
than
than
that
of
of
the
US
to
some
extent
because
we
have
in
the
US.
A
There
are
some
some
state
laws
regarding
digital
assets
and,
and
there
are
federal
laws
in
in
case
of
of
European
Union,
we
have,
we
have
local
laws,
we
have
directives,
you
you
direct
this.
We
have
also
your
regulations,
so
your
directives
are
implemented
and
when
they
are
implemented
they
are
sometimes
changed
and
and
the
term
gold
plating
is
also
also
connected
to
to
the
implementation.
Certainly
you
direct
this
one.
Certain
new
parts
and
new
regulations
are
added,
but
in
case
of
your
EU
regulations,
they
are
directly
applicable.
A
You
know
on
all
member
states,
and
so
so
in
case
of
of
of
of
of
the
approach
of
your
authorities.
We
can
see
that
the
shift
towards
regulations
and
we
see
more
and
more
brand
laws
in
the
form
of
regulation
in
order
to
to
align
the
the
AML
regime
in
in
Europe
So.
A
Currently,
there
are
four
key
elements
which
needs
to
be
which
need
to
be
taken
into
account
and
which
might
have
effect
on
on
cryptos
service
times,
and
we
trust
service
providers
and
a
crypto
community
in
general.
So
the
proposal
for
regulation
establishing
the
anti-money
laundering
Authority
for
the
whole
EU.
So
this
is
something
like
totally
totally
new.
The
proposal
for
the
AML
UI
regulation
also
and
the
the
big
change,
because
currently
we
have
each
and
every
country
has
its
own
laws.
On
my
ML
and
now
they're.
A
There
is
a
plan
to
to
align
all
those
laws
under
the
regulation.
There's
this
new
sixth
directive
on
IML
CFT,
because
still
local
laws
would
be
needed
and
they
have
to
be
directed
by
the
way.
The
directive,
and
also
the
amendment
of
the
transfer
of
funds
regulations
which
I
and
this
transfer
funds
is,
is
a
new
regulation.
That
is
also
based
on
the
fact
of
recommendation
that
I
mentioned
that
I
mentioned
previously.
A
So,
under
the
new
regime
of
virtual
asset,
service
providers
will
have
to
monitor
its
users
for
suspicious
activity
and
they'll
have
to
report
such
activity.
So
again,
it's
really
important
what
the
virtual
asset
service
provided
definition
with
the
code,
because
there's
already
a
build
up
of
of
obligations
towards
the
tour
asset
service
providers,
when
we
are
still
not
sure
which
entities
are
on
which,
which
parts
better
say
it's
better.
A
It's
about
which
parts
of
the
of
the
community
will
be
covered
by
it,
and
this
new
regime
will
require
to
provide
on
request
of
competent
authorities,
information,
repair,
Stones
involved
in
crypto
asset
transactions.
Also
this.
What
is
what
this
region
will
require
would
be
to
adopt
policies,
procedures
even
consoles
to
ensure
compliance
with
with
sanctions
and,
additionally,
retail
asset
service
providers.
We
need
to
obtain
and
submit
information
on
the
transactions,
originator
and
beneficiary
when
sending
aggressive
in
crypto
assets
foreign.
A
So
what
are
the
risks
that
I
see
and
that
I
that
I
think
that
that
have
to
be
taken
into
consideration?
So,
together
with
the
draft
regulation
of
of
Mika,
so
markets
in
cryptos
and
circulation,
which
is
about
to
be
finalized,
the
regulatory
packaging
in
Europe
will
drastically
change
how
the
money
rendering
regime
will
be
shaped
in
the
coming
years
in
relation
to
crypto
industry.
A
Unfortunately,
it
is
still
difficult
to
predict
a
possible
future
developments
in
relation
to
defy
and
Dallas
and
that's
connected
with
the
with
the
exit
definition
of
of
the
advanced
service
provider
and
in
so
it
in
particle.
So
it
depends
on
the
on
the
final
shape
of
of
it
depends
on
the
on
which
entities
will
be
covered.
A
Certain
changes
in
relation
to
definition
of
money
laundering
are
plant
in
iml-6
directive
and
they
might
result
in
a
consideration
of
some
activities
involving
the
transfer
of
digital
assets
involving
the
use
of
certain
protocols
as
aiding
abetting
inciting
or
attempting,
because
currently
it
depends
on
the
particular
country
whether
certain
certain
actions
are
considered
as
aiding
abetting
inciting
or
attempting,
but
I'm
also's
directive
versus
the
general
definition
of
money
laundering
to
include
anything
exciting
or
attempting.
A
A
So,
as
with
other
questions,
you
have
to
wait
and
see
what
shape
will
it
take
and
as
it
is
as
this,
this
definition
is
provided
in
ims6
directive.
It
will
be
implemented
by
each
and
every
country.
So
again
the
interpretation,
the
the
implementation
might
differ
depending
on
the
country,
but
still
such
a
risk
should
be
should
be
identified.
A
Okay,
so
let's
now
switch
to
risk
to
sanctions,
evasions
and
as
one
of
risk
factors
and
to
provide
some
background.
So,
as
you
might
know,
the
US
and
the
U
have
imposed
and
and
I'm
precedented
a
number
of
sanctions
on
Russia
since
2014,
so
not
only
since
this
year,
but
but
it's
been
since
the
the
first
since
the
war
started
in
the
world
to
be
on
the
south
of
2014..
A
So
in
case
of
the
US,
there
are
four
major
sanction
programs
and
the
Au
has
since
adopted
six
packages
of
sanctions
in
response
in
response
to
the
to
the
invasion
and
the
response
of
the
to
the
recognition
of
of
non-government
controlled
areas
of
the
donuts
or
blasts
and
outside
the
EU
and
the
U.S
other
Western
Allied
countries
also
imposed
on
post
sanctions
on
Russia.
So
we
have
some
programs
from
UK,
Canada,
Japan
or
Australia
as
well
as
well.
A
A
First
of
all,
authorities
might
decide
to
sanction
individual
individual
wallet
addresses
related
to
the
xdao,
its
contributors
or
or
products.
It
also
might
be
established
that
certain
texts
takes
their
holders
or
contribution.
Contributors
are
sanctions,
persons
or
entities
or
persons
coming
from
sanctioned
countries
such
as
iron
or
North
Korea.
A
It
also
is
possible
that
it
might
be
established
that
the
exact
treasury
consists
of
some
assets
originating
from
from
sanctions,
sanctions
entities,
the
third
risk
factor
and
that
I
wanted
to
discuss
is
a
blacklisting,
as
as,
as
you
might
know,
there's
certain
issuers
of
cryptocurrencies
and
stable
coins
such
as
dollar,
US,
dollar,
usdcr
or
theater
have
ability
to
block
certain
blockchain
addresses
from
accessing
particular
digital
assets.
A
Center
Consortium
LLC,
which
stands
behind
the
usdc
in
forms
in
its
Center
Consortium
Network
backlistic
policy,
which
they
have
that
it
has
the
ability
to
block
individual
ethereum
blockchain
addresses
from
sending
and
receiving
stable
coins
usdc,
and
it
calls
it
blacklisting
and
according
to
the
policy,
when
the
address
is
black
listed,
it
can
no
longer
receive
usdc
and
all
of
the
usdc
controlled
by
this
address
are
blocked
and
cannot
be
transferred
on
chain
and
Center
decides
on
blacklisting
by
majority
Vault
of
its
support
of
and
the
following
circumstances
are,
are
described
in
the
policy.
A
So
the
failure
to
Grant
the
blacklisting
request
presence
a
threat.
The
security
Integrity
reliability
of
this
usdc
network
and
the
other
one
which
is
of
which
is
more
important
to
us,
is
whether
is
is
when
the
blacklisting
is
to
comply
with
the
law
regulation
of
legal
order
from
a
duly
recognized
U.S
authorized,
Authority,
U.S,
Carter,
competent
jurisdiction
or
other
government
Authority
with
jurisdiction
over
Center.
A
So
so,
frankly,
this
this
means
that
that
the
the
circumstances
when
such
blacklisting
is
possible
are
very
nuanced
and
and
and
it's
it's
really
not
possible
to
to
to
really
decide
which
exactly
which
which
which
which
agencies
or
which,
which
institutions
exactly
have
power
to
to
to
to
request
such
such
blacklisting.
So
the
risks
the
risk
us
as
Falls
decision
might
be
made
by
stable
coin,
insurers
to
Blacklist
addresses
related
to
day
style.
A
It's
contribute
contributors
or
products
following
sanctions
imposed
by
us
or
other
competitive
Authorities
on
the
x-star,
its
products
or
addresses
that
happen
to
be
somehow
connected
to
other
sanctioned
entities
and
to
take
down
the
same
time
and
Blacklist.
The
problem
is
that
that
is
that,
that
is,
that
blacklisting
would
most
probably
be
done
without
any
notice.
So
there
will
be
no
time
to
to
prepare
the
properly
prepare
in
advance,
including
the
qualification
of
the
grounds
of
sanctions
in
possible
litigation
and
in
in
terms
of
litigation.
A
A
So,
as
we
said,
as
I
said,
no
explicit
laws
apply
to
the
extra
that
would
require
the
introduction
of
of
such
measures
and
in
such
actions,
might
result,
probably
from
the
intention
and
and
subsequent
Vault
of
unreal.
Relevant
proposal
regarding
this
and
one
of
the
possible
approaches
that
I
see
taking
into
consideration
with
the
complication
of
working
as
a
down
and
being
a
Dao
is
to
distinguish
between
a
voluntary
and
mandatory
okay
kyc
measures
at
the
egg
Style.
And
what
I
mean
by
this
is
that
it
might
be
possible.
A
It
could
be
discussed
whether
to
to
introduce
the
the
certain
measures
and
certain
mechanics
that
would
make
the
mlkyc
measures
measures
welcomed
by
by
possible
persons
that
would
be
subject
to
such
such
measures
and
the
introduction
of
of
such
voluntary
mlkyc
could
be
aligned
with
certain
incentives
from
the
eggs
down
and
it.
A
It
could
also
be
applicable
in
case
of
of
some
smaller
risk,
so
medium
or
low
risk
identified
in
relation
to
takes
down
and,
on
the
other
hand,
and
in
general
and
in
general,
the
mlkyc
measures
might
include
as
little
as
due
diligence
of
the
ex-style
treasury,
which
was
already
proposed
and,
and
these
due
diligence
would
could
be
in
terms
of
transaction
history
and
sanctions
addresses
and
the
other.
A
The
other,
on
the
other
hand,
like
the
the
most
complicated
version
of
this,
would
be
the
general
kyc
requirement
for
the
textile
stakeholders,
which,
to
be
honest,
I,
don't
think,
would
be
possible
taking
into
consideration
what
of
what
what
Dao
is
and
why
people
join
joined
our.
But
these
are
like
two
sides
of
the
of
the
spectrum
and
in
in
case
of
okay.
So
this.
A
Later
and
just
check,
yeah,
okay,
so
so
ml,
AML
and
measures
could
be
discussed
in
relation
to
particle
services,
and
should
they
each
they
should
be
discussed
rather
in
relation
to
particle
Services
than
in
relation
to
to
Dao
in
general,
because,
to
be
honest,
my
right
now
my
opinion
is
that
the
introductions
of
any
like
ammo
measures,
in
addition
to
Dao
in
general,
is
frankly
not
not
possible
visible.
It
can
might
be
discussed,
but
it
would
be
such
a
cumbersome
thing
to
do
that.
I,
I,
don't
I!
A
Don't
believe
that
that
such
a
general
approach
would
be
would
be
possible
and,
to
be
honest,
it
would
be
I
think
the
first
dial
that
would
try
to
do
something
like
this,
which
I'm
afraid
could
end
up
with
a
with
the
end
of
the
dial
itself.
So
that's
why
I
I
think
that
the
the
the
one
of
the
possible
approaches
could
be
the
the
application
of
certain
measures
to
certain
products.
A
So,
in
case
of
omen,
the
problem
is
the
risk
is
that
the
prediction
markets
might
be
considered
subject
to
regulatory
approval
or
they
are
illegal
in
certain
jurisdictions.
So
ml
capability
measures
might
be
considered,
for
example,
mandatory
to
apply
in
order
to
exclude
certain
users
from
such
jurisdictions.
In
case
of
flows
of
assets,
mandatory
kyc
measures
might
be
applicable
from
certain
levels
of
funds
locked.
So
this
is
also
an
example
of
the
risk-based
approach
in
case
of
Mesa.
A
Trading
interface
might
be
considered
as
a
service
use
for
trading
in
assets
which
might
be
considered
Securities
in
case
of
U.S
or
financial
instruments.
In
the
EU,
that's
monetary
ml
kyc
measures
might
be
applied
when
certain
trading
thresholds
are
rich
in
order
to
continue
using
the
service
in
case
of
carrot,
a
platform
that
allows
projects
to
create
Community
Driven
programmable
incentives
seem
to
post
little
ml
risks.
A
Therefore,
for
example,
voluntary
mlkyc
matters
might
be
considered
in
relation
to
certain
higher
risk
initiatives-
rating,
for
example,
to
finances
to
sports
events,
so
resembling
betting
in
case
of
swapper
automatic
Market
maker
might
be
subject
to
regulatory
scrutiny
as
an
unregistered
swap
execution
facility,
as
it
is
called
in
the
US
or
investment
firm,
operating
OTS
or
organized
trading
facility
in
the
EU.
So
mlkyc
measures
might
be
considered
mandatory,
for
example,
in
order
to,
and
at
least
some
extent
address,
typical
requirements
applicable
to
such
regulated
entities.
A
And
so
what
about
approaches
taken
by
other
dials?
To
be
honest,
I
was
hoping
to
find
some
doubt
that
would
that
would
be
similar
to
the
egg
style.
But
we
know
that
it's
it's
rather
not
possible
and
and
I
couldn't
find
any
and
I
was
also
hoping
to
find
a
dial
that
has
some
already
developed
IMO
measures,
and
this
for
just
maybe
in
part
similar
to
to
what
the
x-dow
is
but
I
it
to
be.
A
To
be
honest,
I
couldn't
find
any,
but
nevertheless,
in
case
of
of
of
those
that
I
that
I
checked
uni
swap
so
no
kyc
is
required
to
open
the
account
and
start
using
uni,
Swap
and
now
kyc
is
required
to
obtain
hold
unit
swap
token
and
in
case
of
of
legal
wrapper
and
some
institution,
because
this
is
this
might
be
also
important.
A
Okay,
in
terms
of
of
that,
this
is
that
that's
that's
why
I
also
checked
whether
any
other
any
any
institution
was
set
up
with
the
Dao
or
for
the
or
by
the
Dao.
So
in
case
of
uni,
swap
in
August
this
year's
this
year,
a
proposal
was
submitted
and
voted
in
favor
to
create
unisa
foundation,
and
it
was
task
for
admission
to
support
the
centralized
growth
and
sustainability
of
the
of
the
protocol
and
it's
supporting
ecosystem
and
community.
A
So
there
is,
there
is,
then,
an
entity
that
was
set
up
last
last
month
in
case
of
xdao
Nokia
is
required
to
become
member
and
in
case
of
in
terms
of
of
institution
and
entities
like
this
is
an
incorporated
non-profit
Association
under
the
loss
of
Wyoming
SG
Dao,
which
I
am
a
member
of
it's
an
investment
Tower.
So
that's
that's
why
they
they
introduced
the
full
kyc
and
this
full
kyc
is
required
to
become
a
member
of
Dao.
A
They
use
persona
for
kyc,
so
it's
a
verification
on
the
basis
of
selfie
and
ID,
and
it
has
two
legal
entities.
The
first
one
is
a
c
that
houses
the
investing
portion
of
the
dial
and
it's
it's.
A
It
is
structured
as
a
typical
Venture
Capital
fund,
and
the
second
entity
is
a
Colorado
based,
limited
Cooperative
Association,
so
they
have
both
Association
and
LLC
in
case
of
battles
now
which
I'm,
also
a
member
of
and
no
kyc,
is
required
to
become
a
member
of
The
Tao
and
no
legal
entity
serves
as
a
legal
dropper
for
the
doll
Mary
silker
now
same
Nokia
YC
required
there
is
a
company
set
up
where
it's
so-called
LTD
and
and
then
it
hosts
the
the
Dow
development
team
stake
down,
and
that's
that
was
one
interesting
thing
that,
because
the
staked
our
privacy
policy
relates
to
the
to
collecting
personal
information,
and
that
consists
of
through
legal
name,
address
email
phone
number
date
of
birth
Etc,
but
no
kyc
requirements
could
be
found
to
be
applicable
in
relation
to
new
users.
A
So
I
know
why.
But
it
seems
that,
although
the
policy
relates
to
such
to
to
the
obtaining
such
data,
this,
this
kind
of
requirements,
requirements
are
are
not
are
not
introduced.
A
Another
interesting
thing
is
that
the
privacy
policy
describes
this
taken
down
as
a
company,
but
I
couldn't
find
any
other
references
to
any
legal
wrapper
related
to
stake
down.
So
it
might
be
possible
that
that
that's
such
such
a
such
entity
does
not
exist
or
it
or
just
I
couldn't
I
could
I
couldn't
find
it
the
shape
shift
down.
It's
also
Financial
power
kyc
is
not
required
to
use
the
service
and
the
fox
foundations
was
formed
with
the
chapter
of
overseeing
the
decentralization
of
the
trading
platform
and
its
assets.
A
Mantra
Dao
was
another
dial
that
I
checked,
and
here
also
no
kyc
is
required
to
use
its
services,
but
again,
similarly
to
other
other
dials.
The
Mantra
Foundation
was
established
alongside
the
Dao,
oh
so
so
that
that
was
the
the
last
dial
that
I
checked.
So,
as
you
can
see,
it
seems
that
that
there
are,
there
are
no
no
similar
doubts.
That
would
have
already
covered
the
mlkyc
topic
and
there
are
no
similar
dials
that
we
could
check
and
we
could.
A
We
could
use
as
a
point
of
of
reference,
so
so
just
as
in
other,
like
areas
of
activity,
I
guess
the
any
approach
to
the
mlkyc
and
and
and
and
and
this
this
topic.
This
would
be
something
that
we
would
have
to
do.
First,
ourselves,
I
would
like
to
to
end
with
some
some
optimism,
so
so
I
guess
I
guess,
although,
although
like
the
regulatory
situation
right
now,
my
my
might
look
like
difficult.
A
On
the
other
hand,
my
Approach
is
that
the
more
regulations,
the
more
regulation
is
that
the
remote,
the
more
litigation
like
show,
UPS
the
more
we
know
because
it's
always
like,
but
it's
always
better
to
to
to
know
to
know
the
the
loss,
not
the
the
the
point
of
view
of
the
regulation
of
regulators,
then
to
to
get
to
know
them
from
the
litigation
to
ourselves.
So
I
just
hope
that
so
the
the
upcoming
years
will
just
provide
more
rules.
That
would
be
easy
to
that.
A
Would
we
could
use
as
a
point
of
reference
that
would
allow
us
to
to
even
just
to
find
ourselves
in
the
system,
because
right
now,
as
as
I
think
as
you
could
like
read
and
see
from
my
from
my
presentation,
there's
still
many
unknowns
and
and
just
risks
that
we
have
to
live
live
with
and
that
that
we
might
try
to
to
address
so
and
I
think
that
would
be
all
thanks.
It's
45
minutes,
sorry
guys.
Thank.
B
You
very
much
ending
on
a
cliffhanger
a
lot
of
unknowns
actually
known
unknowns.
We
all
know
that
it's
unknown
what
Our
Fate
is
when
it's
in
the
hands
of
someone
else,
yeah.
A
B
We're
just
trying
to
figure
out
what
the
best
path
forward
would
be
so
that
it's
mutually
beneficial.
We
we
are
Cooperative.
We
wish
to
cooperate
with
Regulators,
but
when
there's
uncertainty
it
seems
like
they
don't
want
to
cooperate
with
us.
Has
anyone
got
any
questions?
Foreign.
C
Great
kind
of
a
question
is
more
of
you
know.
Over
the
last
couple
years
there
have
been
I
recall
a
lot
of
different
projects
that
we're
almost
trying
to
offer
kyc
or
AML
services,
and
you
know
I
think
you
could
do
this
pretty
easily,
where
you
have
someone
who
does
kyc
AML
and
then
they
like
give
a
token.
C
Maybe
it's
a
non-transferable
token
to
a
certain
address
and
then
that
like
addresses,
kyc'd
or
whitelisted
or
whatever,
and
then
that
service
could
be
used
by
other
decentralized
exchanges
and
all
you
would
have
to
do
or
or
any
other
service
Deep
by
protocol
you
had.
All
you
would
have
to
do
is
check
to
see
whether
they
have
this
token
or
this
like
non-transferable
thing
and
so
I,
guess
that
my
question
is
like:
why?
Don't
you
think
any
of
the
kyc
AML
stuff
has
like
moved
on
chain?
C
I
guess
the
AML
stuff
maybe
has
with
you,
don't
really
need
it
with
like
usdc
and
all
the
stable
coins,
because
you
can
track
it
there,
but
I
guess
I'm
a
little
surprised
that
there
hasn't
been
any
like
kyc
projects
that
like
exist
on
chain
in
like
D5
there.
So
any
kind
of
thoughts
on
why
that
hasn't,
risen
or.
A
I
think
that's
like
the
first
of
all,
I
was
I
when
I
referring
to
mlkyc
I'm,
referring
to
the
already
existing
Solutions
and
it's
another
topic
of
the
of
all
the
solutions
that
are
being
developed
and
all
the
solutions
that
might
be
developed.
That
would
be
different
at
what
we
know
right
now
that
we
have
to
show
to
each
institution
our
idea
to
show
my
my
face,
Etc
and
so
so.
A
I
hope
that
in
the
in
the
in
the
years
to
come-
and
we
may
be
in
the
months
to
come,
the
more
and
more
solutions
that
would
that
would
be
more
tolerable
to
typical
users
would
show
up,
and
then
thank
maybe
thanks
to
such
solutions.
That
would
allow,
for
example,
me
to
just
to
docs
and
to
to
to
do
the
kyc
myself
once
and
it
would
allow
me
to
use
the
many
many
services
in
the
in
the
cryptosphere
without
like
providing
all
my
details
and
doing
the
kyc
all
over
again.
A
A
There
are
risk
of
of
of
getting
some
sanctions
getting
penalties.
So
this
is
when,
when
the
institutions
really
decide
to
implement
everything-
and
you
know
when
when
this
is
when
this
is
the
case
when,
when
the
when
the
companies
that
that
deal
with
kyc,
they
see
that
the
money
is
there.
So
that's
when
they
start
to
develop
this
kind
of
of
services.
So
I
think
this.
This
bear
Market.
A
It
might
be
my
result
with
the
with
some
some
new
developments
in
the
is
fair,
because
Regulators
are
just
going
to
to
to
to
force
more
and
more
the
industry,
the
crypto
industry
just
to
to
to
to
to
to
really
use
the
the
kyc
and
and
one
day,
maybe
it
will
just
be
required
by
law.
So
but
unfortunately
you
know
this
is
what
I
think
will
be
the
case,
but
of
course
I
would
hope.
You
know
that
we
could
come
up
with
a
voluntary,
kyci
I
believe
there
are
some.
A
There
are
many
people
that
that
they
just
just
use
the
services
and
they
they
don't
mind
doing
the
kyc,
because
they
so
that's
not
that's,
not
the
problem
for
for
them.
I'm,
I'm
dogs,
I'm,
I,
I,
do
the
kyc
everywhere,
but
but
I
think
that's.
The
real
shift
would
be
when
this
kind
of
solutions
would
be
really
required
by
law.
B
C
Yeah,
it's
it's
kind
of
I,
don't
know
if
my
microphone
is
a
little
better
now,
but
yeah
I
think
one
of
the
things
for
the
kyc
angle
and
really
like
in
general.
As
you
see,
the
melding
of
the
worlds
of
you
know,
crypto
and
real
world
that
the
most
effective
way
that
the
existing
world
can
regulate,
crypto
or
have
an
influence
on
crypto
is
to
build
something
that
is
native
in
crypto.
That
represents
something
off
chain,
but
still
operates
in
the
in
the
crypto
World.
C
A
C
Thinking
about
the
kyc
angle,
it's
kind
of
like
wondering
what
me
why
I
see
might
try
to
be
implemented
that
will
actually
be
operating
in
the
crypto
in
the
blockchain
world,
because
in
the
end
I
think
that's
actually
the
only
way
you
end
up
regulating
it
because
they
are
I
mean
unless
you
can
shut
down
like
the
blockchains
themselves.
They
are
sovereign
entities
and
I
think
there
are
things
from
the
outside
world
that
are
very
much
needed
in
the
blockchain
world
and
give
it
to
more
legitimacy.
C
But
I
think
there
will
be
instances
of
like
what
is
the
KY.
What
is
the
usdc
of
kyc
AML?
C
A
It's
a
little
bit
different,
but
that
that's
what
I
think
would
be
the
likely
path
forward.
A
So
any
animal
questions
comments
in
relation
to
this
topic.
I
will
share
the
the
report,
I
think
in
key
base.
We
already
have
a
legal
channel,
so
I
told
me
we
might.
We
might
continue
the
discussion
there,
and-
and-
and
thank
you
thank
you.
Thank
you.
Thank
you
all
for
for
for
listening
and
yeah.
C
A
And
to
be
honest,
because
it
was
published
in
the
like
in
the
in
the
morning
my
time
so
I
I
could
I
didn't
really
read
the
the
order
and
and
the
papers
so
so,
unfortunately,
I
cannot
like
address
this
and
besides
that,
he
as
soon
as
I
saw
it
I.
Just
you
know,
I
just
thought
about
this
executive
order
and
I
just
didn't
mentioned.
You
know
the
the
meetings
between
those
agencies
and
and
frankly,
I
I
think
they.
A
They
really
know
that
it's
far-fetched
they
they're,
trying
to
to
get
a
very
small
small
dial
as
far
as
I
know
that
maybe
there
as
far
as
I,
read
that
the
treasure
is
like
forty
thousand
dollars
or
something
like
that,
something
like
this
and
they
are
just
going
I.
Think
for
the
relatively
easy
case,
maybe
to
set
up
the
president,
and
unfortunately,
this
is
what
I
read
is
a
regulation
by
by
enforcement
and
I'm.
Also
I'm.
A
Also,
you
know
wondering
you
know
how
and
how
any
any
any
and
any
authorities
in
the
EU
could
react
to
something
like
this,
because
we
can
see
that
this
Regulatory
and
enforcement
storm
is
just
based
in
the
US.
A
Of
course,
it
results
from
the
fact
that
the
crypto
industry
is
located
there,
but
I
wonder
you
know,
because
there
are
many
many
many
similar
dial
similar
protocols
which
are
not
based
in
the
in
the
US
and
I
wonder
you
know
how
this
this
kind
of
approach
and
this
U.S
approach
would
influence
our
other
projects
that
are
not
based
in
the
U.S.
So
but,
as
I
said,
I
I
couldn't
I
didn't
have
any
any
time
today,
just
to
read
through
through
those
papers,
so
I
I
don't
know
any
specifics.
Unfortunately,
yet.
C
C
Think
like
what
we're
thinking
now
is
much
more
of
like
what
are
the
regulatory
incentives
here
or
The
Regulators
incentives
right,
we're
talking
about
the
cfdc
and
sec,
we're
in
the
European
regulator
like
what
are
the
reasons
that
they
are
going
to
act
or
to
push
things
forward
and
I
actually
think.
If
you
look
at
the
U.S,
I
I,
usually
don't
think
it's
as
much
about
trying
to
coordinate
as
much
as
it
now
is
about
staking
out
territory.
C
C
Don't
know
the
cfdc
has
been
a
little
bit
more
I
thought
laid
back
in
terms
of
like
kind
of
how
this
is
developed,
but
it
seems,
like
I
could
see
this
as
just
another
way
of
them
trying
to
cement
their
authority
over
digital
assets.
Just
because
you
know
people
want
people
want
to
control.
More
institutions
want
more
more
power.
A
It
is
interesting
because
you
know
the
my
opinion
is
that
in
the
Europe
I
can
say
from
say
something
in
relation
to
Poland
and
but
also
in
case
of
other
other
European
countries.
A
I
see
that
that
the
approach
of
the
of
this
agents
of
the
of
the
regulatory
authorities
that
just
to
Mark
when
their
Authority
ends
so
I,
can
I,
don't
see
right
now
this
this
kind
of
like
approach
of
the
US
that
they're
trying
to
to
grab
some
some
some
some
some
actors,
some
some
entities
that
that
are
outside
of
the
scope
of
their
Authority.
A
But
rather
they
try
to
like
to
show
to
limit
their
their
area
of
concern
to
certain
entities
and
and
then
leave
the
rest
outside
of
it,
which
doesn't
I
could
change
the
fact
that,
in
case
of
consumer
protection,
there
are
authorities
dealing
with
the
consumer
protection
in
Europe
which
are
going
after
some
influencers,
which
advertise
certain
certain
crypto
schemes.
A
Ponzi
schemes
Etc
so
in
case
of
of
the
pro
consumer
protection
I,
see
certain
actions
of
of
authorities,
but
but
on
the
on
the
not
not
not
in
a
way
like
similar
to
to
the
to
the
to
the.
A
There
are
some
cases
like
already
being
discussed
in
the
Euro,
but,
but
so
you
have
like
our
legal
system
is
different.
A
Your
your
base
is
rather
on
the
your
right
side,
because
Chris
is
from
the
US
based
on
the
on
the
president,
so
my
take
is
that
maybe
this
this
case
should
be
is
meant
to
end
up
in
the
court
and
then
is
meant
to
be
some
sort
of
precedent
in
in
relation
to
to
to
Dao,
maybe
that
a
Google
thing
that
it
will
end
up
in
court
and-
and
we
will
see
you
know
what-
where
where
this.
A
This
is
where
this,
where
this
thing
where
this
case
will
end
up
eventually
after
it
is,
but
on
the
other
hand,
you
know
this
as
far
as
I
read
these
contributors,
this
these
guys
that
they
they
they
they
they
play
Bergen.
They
agreed
to
to
be
fine,
so
I
I'm,
not
sure.
B
So
is
it
safe
to
say
that
the
focus
of
regulators
would
be
organizations
that
have
had
like
class
action
or
some
kind
of
litigation
between
the
parties
involved?
Because
you
know
people
felt
like
the
project
was
a
Ponzi
or
there
has
been
a
hack
that
people
want
more
clarity
on
like
who's
been
involved.
Why
it
happened
like?
B
Is
it
safe
to
consider
that
a
project
that
is
safe
from
such
happenings
is
safe
or
there's
no
guarantee.
A
I
hope,
but
of
course,
there's
no
guarantee
but
I
hope
this
that
they
they
also
have
to
have
some
sort
of
approach
that
that
that
allows
them
to
focus
on
cases
that
are
easier.
A
So
if
we
have
a
case
when
there
is
a
potential
potential,
when
there
are
potential
problems
with
the
code
itself,
when
there
is
when
there
is
some
negligence
of
of
some
core
contributors,
when
when
we
have
a
project,
when
we
can
really
know
who
the
contributors
were
when
we
have
some
some
companies
that
that
that
that
they
develop
the
code
and
then
then
also
earn
something
on
on
such
a
project,
then
this
this
sort
of
cases
seem
seem
like
better
just
to
handle
from
the
supervisory
perspective
and
and
go
after
and
in
case
of
projects
such
as
the
Exile,
with
no
with
no
such
such
problems.
A
A
B
Oh,
thank
you
very
much
Eric
and
thanks
for
everyone
attending
it
is
nice
to
see
people
interested
in
learning,
more
I
think
we
could
call
it
at
the
top
of
the
hour.
I
wish
everyone,
a
lovely
Friday,
cheers
everyone:
okay,.