 So, I've started recording and I would like to start by giving two small announcements. One is that we are operating under the antitrust policy of Linux Foundation and we are also for anyone who wants to know that in greater detail can go to the hyperledger wiki and find more about that. The other announcement is about the code of conduct which is basically you can disagree with people without being disagreeable and also be agreeable with people without being disagreeable. Basically, be nice, that is the short and long of it. And I want to introduce Igor Yorshpa and I have one question, I mean he is from Nordnickle. You've seen his bio is caught 15 plus years in the industry now he's working with Nordnickle and I will leave Igor to talk more about Nordnickle and the other basic stuff. So, before we start Igor, do you want me to do the sharing or you can do the sharing because you should be free to share the screen if you go to the bottom. Yeah, actually if you don't mind I'll just do this swiping myself if that's okay with you. Yeah, of course, there is Jan from Nordnickle who's just joined and I know him for a while and even before he joined Nordnickle so anyway, it's good to see you Jan, anyway, so can you share your screen and start the presentation please, thanks for showing up. Just one second, so let's see, let's do it like this because Zoom is glitching, so no peeking all right. The obligatory Zoom question, can you see my screen? Yes. Okay, perfect. So, thank you Vipin and good time of day or night everyone wherever you are. The Swiss DLT bill recently came to our attention and we had a brief chance to look into it, so I wanted to share some thoughts about it and why I think it's an important topic for hyperledger community because it presents in my opinion, it presents us with an opportunity to both promote our technology and take DLT adoption to a next level, possibly worldwide. Now lack of regulation or well poorly described legal frameworks are known to be the key stuff factors for any tech adoption and while it's not an obstacle to some, the institutional segment is surely always looking for more clarity before they move on. Another existing challenge that's been going on for ages really is that legal and tech, they well, they don't always talk on the same language which may create miscommunication and it's no wonder because those are two highly sophisticated fields but as a result we sometimes end up in situations where the pace of the technology is limited by existing legal frameworks which is understandable but it doesn't really have to be that way. So we have definitely seen some positive dynamics in various jurisdictions of the world over the past few years and it certainly does look like an upward trajectory. Now we must nevertheless keep in mind that when a jurisdiction refers to itself as being crypto friendly, well actually no, I don't want to use the word crypto because it has so many wrong meanings today. When it refers to itself as being DLT friendly, it doesn't mean that you're going to get an easy pass. It's not like, you know, getting a driver license, you go take a thought and take the test. No, all it means is that the regulatory framework is open for consideration of your case but it's still your legal obligation to show them and to prove them how your case is license worthy. So the latest contribution in this regulation is the Swiss DLT bill that came out recently actually in the beginning of this year for recall which is really a big step forward towards general DLT adoption because this particular bill penetrates various affected fields of law making adjustments that were really mapped around the actual existing technology and this I think is a very big and notable step forward. When we get not some, well it's called a vague guidelines but rather something that considers the way that technology is actually meant to be operating. So obtaining a license especially in the field of dealing security is never easy but when you add a new technology which essentially becomes the backbone of your trading venue of your system it doesn't make it any easier. So one needs to create a lot of specific materials, a lot of info decks, what not, showing how you feel fulfill all the regulatory requirements and you never get a like a step-by-step manual or instruction. It's up to you to figure your SDLT processes or your disaster recovery plan or how you're going to back up your information which sounds especially funny when we talk about DLT systems or how you're going to create fair and secure conditions for all your users in your trading venues. I mean common best practices obviously apply but there is always room for maneuvers and now imagine this situation from the other side from the regulatory when you have like 50 different applications coming in with venues that are essentially using the same backbone technology but they're trying to explain it in their different terms in their own way so it never helps. However there are several things that can be done to address this challenge which should and could make things a little easier for both sides in my opinion. So one is we could look into certifying hyper ledger fabric as a Swiss DLT lock compliant solution. Now this obviously for many reasons could prove to be highly challenging right and one of the reasons is well hyper ledger fabric it's not really a blockchain right it's a framework for creating blockchains. However if we could achieve this this would really be game changer in my opinion because it would create a new really a new market standard. Obviously it would strengthen hyper ledger position worldwide greatly and it would aid with further adoption across the globe. Now yes obviously it would require individual certification jurisdiction by jurisdiction but the actual preparation work would only need to be done once for the most part. Now why worldwide is because well we sometimes see cases where regulators of different jurisdiction try to adapt things that proved to work in their friendly environments so it will just make an easier transition to other countries eventually. Another option which may be a little easier is creating certain how to call them template info decks addressing how the HLF components fulfill one or the other requirement found among the articles in the DLT bill and I'm going to talk about how in my opinion HLF is almost like a natural fit for this bill in just a moment. Now you may say well you're not really very far seeing are you just go to the wiki download the documentation and be happy be done well yes I could do that and actually incredible work has been done by the community in creating and drafting all that incredible technical documentation but unfortunately to make it useful for this particular cause it needs to be remapped into a language understood by regulatory and terms generally accepted by them. Now I will give you a simple example when we talk about tokens we all talk the same language we understand what they are but if you take FIMA for example one of the first things they did they classified tokens into different categories payment utility and asset and each of this category of token is allowed to do particular things so when you talk to them you know when you mention tokens you need to be very careful and very specific about what you do and this is exactly the type of alignment I'm talking about that you know would be great to get done here because once we start speaking the same language just it gets things moving at a different pace and such standardized in fact they would be standardized info decks would not only make HLF a solution more attractive for easier adoption for for any user but but also make it easier for the regulators because they would be working with standardized documents so it's just easier on both sides. Now let's look at how Hyperledger Fabric fits inside the existing Swiss DOT framework and why I think that it is indeed a kind of a natural fit so to do that we're going to take some of the articles found in the in the bill obviously not all of them given the little time we have today but I try to pick those that I feel are the most crucial and important and we're going to see how Hyperledger fits against them so the bill tells us that we need to create conditions where independent parties ensure that no unauthorized modification occurs well okay makes sense and in fact I will come back to this point a little later down the presentation because this is very important but let's look at this from a glance for now so Hyperledger Fabric separates transaction validation block creation and ledger book keeping into different type of nodes ensuring separation of duties and data access on the eternal basis so that's number one nodes of each type may be operated by independent entities so there is no single point of change the final decision is based on the consensus between the validators that's two the ledger including smart contracts is stored independently by multiple validators making local changes well essentially pointless so that's two the actual out that's three for those of you keeping count the ledger snapshot can be compared with other nodes in the same organization or in fact different organizations to verify the consistency and integrity of the ledger on each peer so the way I see it it's a good fit so far so I would put a check mark here let's move on smart contracts the bill asks us to store information on the ledger well pretty self-explanatory now in the case with hlf smart contracts are natively built into it in a form of chain code so no off-chain logic is needed for transaction processing I see this as another check let's move on due diligence well this is what we commonly know and it's already part of everybody's life probably it's the KYC KYB AML procedures uh and essentially uh this is this is common for because the user identification and permissions are the fundamental elements of hyper ledger fabric architecture because it was designed as a permission system from from from origin so another check uh transferency so this talks about you know being able to access store information making sure that it's valid all right let's look at this by providing bookkeeping only nodes or commuters or peers for that matter hlf makes it possible for every participant to personally monitor the ledger contents and integrity without participating in resource consuming endorsement process so okay that's one way of doing it ledger snapshots which is a neat function that appeared in the ledger in the later i believe two point x versions they can be used to verify the consistency and integrity of entire validators network at the same time data privacy is secured by cryptographical means ensuring that only transacting parties can clearly identify the records related to themselves so if you have some really sensitive information just you know run it in the private channel and the programming code of hyper ledger fabric smart contracts is written in how do I put it with general purpose programming languages uh in other words it's easily readable by any interested party whether it's the obligator the creditor or or or an external auditor for that matter so another check um okay so we've talked about validations few slides before and that there were no visible challenges so far but if we dive a little deeper we see that the bill is talking about and I quote you can see it on the screen joint management by several independent participants and we're not really told how independent they need to be from each other but if you ask me I am definitely getting some wipes of a public blockchain reference here so if that's the case done we need a consensus mechanism and yes you could use a natively built-in raft but this would mean that you as the dlt operator would need to guarantee that each and everyone in your validator pulls a trusted party why well because raft it's uh well it's really a crash tolerance mechanism more than anything because it was meant initially for the private dlt applications where you know for a fact that every party is trusted so do you really want to take on such responsibility well I'm not sure and um this is where BFT comes into play now a little retrospective little history so a few years back we have introduced our BFT solution to the community as as a plugin that allows building public permission blockchain some hyper ledger fabric and we presented it on a bootcamp that was hosted in Moscow now I can't tell you how many crazy looks we got I mean people were going like what what are these guys smoking I mean why are you taking something that was initially designed and originated as a private permission blockchain and why do we try to make something out of it that was never meant to be well some years have passed and now we not just have a use case for it but we have a legislation to support that so just something to keep in mind uh information on BFT is publicly available actually included the link in the presentation that will be shared later on with you so just keep that in mind okay now those are the key probably things I wanted to highlight with respect to how HLF fits within the swiss dlt law and in my opinion it really looks like a natural fit being permissioned by design and with the help of the BFT I mean if you want to build a public blockchain well there you go there's your solution there is something else I wanted to share with you and also it doesn't really kind of quite fit directly into our HLF like legal fitment discussion those are nevertheless interesting things to keep in mind if you wish to operate under the swiss dlt law or just you know we never know which other jurisdiction might may adopt it so the first thing that that caught my attention is the relationship between the dlt operator and the issuer essentially the way the legislation is mapped now it doesn't make the distinction between the two so what does that mean if you are an issuer and you're just taking some dlt system to make all the transaction well that's fine however if you're trying to build something else something bigger if you're trying to build a kind of an open but permissioned ecosystem where you would introduce an invite a variety of different issuers well this means according to the law that these issuers are now obliged to perform a lot of actions that would ensure the sustainability and operation of the dlt system essentially all of the requirements we spoke before the issuer is responsible for that which I don't think is fair if you're trying to work you know PAS PAS well I mean platform as a service kind of a type of setup so this is the way it's done now this this is the way it's mapped and explained now however in the future it's very possible that we will see that this roles and responsibility will be split as more use cases appear another thing is the new kind of license that we now have I mean before we had this license so you were still you know fully capable of operating a dlt system and trading digital securities on it under different type of regulations however now we have a specific one tailored around the dlt systems but what I found interesting about it or at least the way the way I have an impression about it is that it's really mapped this particular license the dlt trading facility license around systems with order book order management system and auto matching essentially you're playing classical exchange so which is fine which is perfect this this is most of the cases that we see on the market today however if you wish to build something else a different kind of trading venue I don't know some kind of a semi-automated holy c desk well you may need to get creative and careful about it so keep that in mind dlt on the real world yeah so essentially what the legislation tells us now is that your traditional kind of a signature prevails over your private signature private key signature um is that a bad thing well not necessarily so what this means right now is that the regulators recognize this as a essentially uh applicable way and formal way and of sign and transaction but for now they're just being a little cautious and as we will trust it is possible that we will see eventually that those two will be given the same rights uh wallet recovery now this one this one is interesting so when we talk about blockchains we are accustomed to the logic that if you lose your private key well too bad it's gone but not in this particular case so what the swiss dlt law tells us is that we as the operator or as the issuer as I said they're a little mixed we must create conditions uh upon which if the user uh if the obviously the user that was verified and kbc loses access to his wallet so he loses his private key for example we must create through organizational and technical uh means and measures conditions where we would be able to restore that so let me give a different example uh for example I bought one million or one million dollar worth of tokens in palladium right so what does this mean this means that there is a one million dollar of palladium sitting somewhere in the world because well if not then I probably chose our own service provider so if I lose my private key what happens to that metal it doesn't disappear it doesn't vanish it's still sitting there and essentially what the law tells us is that if I am able to prove my identity which is possible once again going back to what we discussed permission system KYB KYC okay I can prove it's me then I need to prove that I indeed was the rightful owner of those tokens in that amount which is once again possible by looking at the ledger and confirming that particular number and the class of tokens was assigned to a particular private key then uh the dlt operator well he just or the issuer reissues these tokens he burns the old ones essentially it's it's totally up to you how you want to mitigate and how you want to solve it uh I mean if you want to take it to a different step to a higher level you can ensure the transparency and security of this let's call it restoration process so it can be moved on chain and require consensus of the dlt operator officer maybe your KYC provider maybe your custodian somebody else so it's totally up to you so those are the things I wanted to talk about today uh there are open points obviously to this whether it makes sense at all to investigate this direction and see if it would be possible and worthwhile to make hyper ledger fabric dlt law compliant but I just want to repeat myself and say once again that the way it's mapped now this with dlt law is really mapped around the existing tech making it very valuable and it is my understanding that some members of our community from Switzerland have been heavily involved and active about that and so that's the case I really want to extend my gratitude and say thank you you've done an amazing job so now it is up for us as the community to figure out how far we want to take this thank you for your attention great um so we have a lot the thing that we have here is lots of time to discuss and ask questions please ask any questions that you may have to uh Igor and hopefully he'll be able to answer if not someone else will step in whatever whatever the way is that we conduct these discussions on capital market sig can I first address the community if I may so and ask the question like what do you think about this idea of trying to make hlf essentially compliant to the swiss dlt law because if we can pull that off uh we can do the same thing for example under nydfs and other regulations and this would put us as a community and given how much time we invest into this technology you know supporting this we will leave just everybody behind yeah I mean in fact a couple of people who jim has put a comment in the in the chat but he unfortunately had to drop otherwise he would have asked questions I'm sure he says excellent presentation mapping fabric to dlt law with consideration um money now is asking is there any solution on identity that is currently mapped in hyper ledger uh I know that there are but uh Igor you have a answer to money many can you elaborate a little bit in order to you know meet let's call the swiss law of wallet recovery you have to have your identity first established on the dlt that associate that identity to whatever assets that are being used are processed in the dlt so the question really is what kind of an identity solution exists currently in hyper ledger that you could then leverage and then say hey now you know we solved the identity problem now it's just a matter of looking at assets and asset lifecycle okay thank you so uh hyper ledger fabric is essentially a permission system by default so it is implied that we always know all of the parties inside there and uh from organizational means of the legal entity it's a matter of adding the kyc kyv steps so that when we register a new user in our system we always know who that user is because once again it's permissioned we don't have any anonymity so once we do that uh that user establishes a pair of keys that public and private private is something that only he's aware of public is something that we can see once again in a public blockchain so we as the dlt operator have the means of linking those two together and we know the identity of the public of the public address and if uh for example i lost my private key and i can prove that hey i'm in delivery or span you know here go like KYC me again go i'll go through video identification or whichever measures it's up to the company to decide what measures are sufficient uh then it's a matter of just pulling up the ledger and looking at the tokens that were assigned to my uh public key does this make sense um you mean still the current you know the current architecture in most dlts is address mapped onto mapped assets on ledger but not identity right and that's the big difference so um the only way you could as you said the only way you could establish your identity is going to a centralized uh dlt administrator and now you're back to decentralization so it's all up to that one person or a committee or whatever you want to call that determines that who you are and how you are mapped that defeats yes correct kind of like defeats the purpose of decentralization yes i agree with you it's a very good point and you know it's always about a compromise like how far do you want to go with decentralization uh while sustaining your business needs and make it kind of a compliant uh can i present another perspective on this uh i also chair the identity working group and we had a presentation there of carry which is uh uh an architecture that is a decentralized architecture that allows me to create a recovery situation by having a forward key that can be integrated with any system including this that would bring back decentralization i mean the uh idea of carry is that i declare a forward key but do not use it and uh that means i declare a forward public key that i do not use right now but i'm declaring that this is what i'm going to use in case i need to recover the key and that key obviously has a private key behind it which will then be stored offline or somewhere else if you can integrate a system like that into this then you could have decentralized recovery obviously nobody wants to remember or or custody their own keys so the availability of a good wallet solution will also be necessary for this it is a little little uh you know involved for me to go into the details of this but it does exist of course uh there are problems with that too the other other way is to have an identity behind the public key and then have an already established owner key or something like that that doesn't appear on the ledger but which can be used off ledger in a provable way to change the key uh Ron has a question also oh yeah sure he's saying uh the same thing that you're saying i'd like to discuss the wallet recovery aspect more i find that concerning yeah i think and vipin thanks a lot and you got a great presentation i think i'm just kind of expanding on or kind of aligning with some of man's concerns and almost from an operational or a a product perspective i find that the wallet recovery aspect seems to put a very heavy burden on the issuer which opens up to me a whole bunch of risks around i know we talked about identity and vipin there's a lot of work that you've been doing in the identity space i i just as we look at the digitization of financial markets around and securities i that whole wallet recovery aspect is a little concerning that comes you know mani vipin we've been in financial markets for a long time um i find that hard to bake into how operations occur in the security space at least currently and mani i think i'm building on some of the stuff you previously said as well yeah anybody else has uh comments on this particular aspect of wallet recovery it's it's definitely something new it's a great zone to be defined and a best practice to be established and uh yeah if there are solutions it's definitely interesting to look into them and see how they fit while maintaining decentralization one other thing that i just had an idea is to make it a little more decentralized so let's imagine a case where we have the DOT operator that like runs a lot of different issuers that runs the permission system so all of his users are kyc kyb et cetera et cetera so um this particular legal entity the DOT operator is obviously he has his trusted third parties one of which is the one that provides the kyc kyb services another one could be the one provided an audit or something else so the DOT operator could build a little kind of a consensus in between those trusted parties that could be validating this unusual activity so to get away a little bit out of decentralization i mean obviously it doesn't solve it completely because one could claim well you know me as an authorized user i can take advantage of it and i can't participate in the validation of course you can't because this is sensitive information this is PII data we're talking about and uh it needs to be stored securely so that that's another case we need to consider Igor can i just dive into that a little bit more and again i'm sorry that i'm fixating on the wallet recovery but from the issuer perspective if a beneficiary claims private key loss there's i mean i you know you all know the technology better than i do but there's no there's no way to prove that claim correct it is yeah it's a very good point uh in it's illegal how to say um not an office but and i'm illegal anomaly because you can't really prove something that you don't have you can prove something that you have but you can't prove something that you don't have so in that case you need to create some kind of technical measures so that you either block his his private key somehow you blacklisted or you burn the tokens it still needs to be investigated a little more with the better approaches this way there is no double spending if that's kind of what you are aiming at i mean several people have proposed those solutions meaning the operator burns the token and reissues that means our operator token always overrides anything else that means it is basically a multi-state kind of situation where the operator's signature is enough to burn the token and then reissues to the new to the new private key i mean to the new public key of the of the person who suffered the loss this has been proposed the other one which i said carry if you look into it in detail you'll find that that has already got the seeds of this idea that you somehow create a pathway for recovery right up front right in the beginning so that you are not locked into the private key because after all the the spending check and the validation check is the one checking the key so if they check that okay do you have the private key of the token of the asset public key or do you have a valid way of proving that you possess the new key these these are you know two the other is the like Igor said the operator intruding by burning the token and reissuing so these these are you know some of the ways in which this can be done and i think this quest for decentralization is kind of it is not a binary thing you know according to me anyway centralized slash decentralized is not a binary thing it is a spectrum even in bitcoin you know there is in fact there is a lot of asset centralization less than two percent of the public key own like 80 percent of the coin less than you know there is geographic centralization in miners there is centralization among developers there is you know there's no getting around this centralization decentralization problem i mean it is not a binary it is not it is a gray area and that is my opinion by the way and i know that the maximalist bit coiners would jump down my throat if i said this in public but i am basing this on my observations of all of these different infrastructures which they claim are totally decentralized thank you by by the way to give you a little of an insight so to call it with regards to this wallet recovery when we started looking into the tokenization and started talking to you know various industrial and big constitutional companies the losing my axis was probably one of the top three questions that they always asked so it is a little really concerned and i don't think that there is a way to get around it if we really want to kickstart this technology i mean in the future it may be different but this way it's an easier it just provides an easier and safer turns the entrance Igor one more question if i could i think one of the earlier slides um was talking about acquires and i think i saw the phrase bonafide acquires does the swiss dlt law is that tied specifically to kyckyb or is there more to quote unquote modified acquirer uh no just essentially they say that uh in an event when you have you own a certified security and you have your signature somewhere on a piece of paper and there is somebody else for example me owning this digitized security that i signed with a private key well uh you have the better you have the more right because the traditional signature still prevails as well at least for now well there are no uh signatures today because securities are dematerialized in most locations uh but but it seems like the traditional way of custodying has precedence over the ledger way that's what i read from this anyway uh Igor i have a question on the uh on this particular slide about mtf otf can we get get back look at that for a second yes certainly just let me pull it up back again it's not working i can see this slide yeah but for some reason when you you know when you uh share a document over you're going we just go itch incredibly the one before just now we saw that this one right yes um we all understand about mtf and otf um but what happens if this appeared to appear because you know you and me on and whipping can trade independently and list and trades uh whatever assets amongst ourselves are we saying that that's not that is not an organized facility that means that somehow this dlt has to be now uh get approved by the exchange and who owns the the the ledger it's all nobody well uh the dlt trading facility licenses issued to a legal entity that wishes to use the beauty of the dlt system and build trade and a venue on top of it uh so it really follows uh it's very similar to what i found in the otf back in the day to be honest it's at least it's an organized trading facility the thing is that is who owns the dlt if there's a single ownership we have lots of issues with that if it is owned by a group of dealers then you know it doesn't mean that it is an organized facility by default well no because you can't really share the license as far as i can understand it at least you can't say uh that okay i have a bunch of decentralized folks and i want to get the license so who exactly is getting the license then you know name me one who will be the legal entity bearing the responsibility uh so it would be your legal entity and then it's up to you how you want to organize all of the requirements that we have talked about today can we have um a bunch of people who have licenses allowing a application level access to people like me and uh money and i and you and who can then trade uh between ourselves and they allow some kind of a let us say um an algorithmic uh market making or uh matching or uh discovery or you know all those things that are not i mean that's how most things are those things are under the control of certain entities um but what if you have this on the blockchain itself in which only the legal entities that are allowed to trade are running the nodes and allowing the access but then they are allowing uh this kind of peer-to-peer trading on top of it i don't know i mean i'm just coming up with some no it's a really good question uh the way i see it and once again i'm not a lawyer i can be wrong about this but uh a dlt is when you just want to operate an exchange bill on top of dlt right using for example some dlt system so you get this particular license and then you're obliged by this particular law to follow a lot of procedures provide discretionary not discretionary rules safe and fair conditions equal to everybody yada yada yada etc etc uh so then you onboard your clients but your clients don't need to have any kind of licensing uh i mean you probably want to verify them and because once again i always push for permission system and these applications not for full potentializations so that's the way i see it and by the way when it comes to peer-to-peer trading uh this is something that can be done um policy without the otf because when price discovery happens outside of your platform you don't really need an otf for that yeah but it all depends on what you mean by otf is it only the guys who are allowing you to trade on their platform because they have verified that you are a uh a qualified investor that all all this stuff that checking goes on and then if somebody else is another qualified investor then uh you know then all the trading can happen peer-to-peer if the facilities provide that uh that feature again you know this is uh one of those decentralization centralization questions mm-hmm you know it's it's it's not a uh it's not black and white or uh very distinct binary option um maybe ron can you throw some light on this thing since you're working with other you know the lawyers and all the BLTs and your cc regulations how do they view this at dlts from a regular just point of view from the perspective of the lawyers that we work with and just for you know many thank you for that for the clarity uh you know around letting everyone know our legal working group is um i spend an unhealthy amount of time with lawyers many as you know it's over 150 lawyers um in our group and one of the things they focus on really is from a uh leveraging dlt from a trading facility perspective is and a lot of them are stateside is very complicated and they're always defaulting straight to um existing ats regulations for example or atf regulations and what they're finding is that they're struggling to explain some of the capabilities uh to the regulatory to the regulators around how this could be used i just want to stop there man because i want to make sure i just i distracted for a moment i want to make sure i'm answering the right questions um but but the lawyers particularly um they spend quite a bit of time educating regulators uh around what what is meant to be accomplished leveraging the dlt capabilities you know the the question simply is an r of q is a peer-to-peer protocol yep can it happen on a dlt yeah it's a good question man and i i i don't immediately have the answer that i i for our next capital markets gig i'd love to invite one of our our capital markets lawyers if you and vipin and everyone's comfortable they could probably answer some of those questions as well yeah that'd be great i mean i mean even the even the definition of who owns the dlt it doesn't have to be attached to a specific legal entity can it not be owned by a consortium yes i think it it can be i'll get into governance conversations though right manian vipin i mean because one of the questions they ask is if who owns the the the dlt who manages and created the governance around access to the dlt right these are these are these are pretty in-depth conversations yes but you have those kind of venues in multiple where multiple parties participate i know that you know for example exchanges or wherever you know that those i mean i know that legal entities have to be established but once you are on board like you will run one of the nodes or are you you are one of the dealers on that platform that immediately puts you you know you have to have this you have to be a regulated institution to be allowed to run that and the craziest thing about this is that there's so much automated program trading going on between market makers that somehow you know some kind of a programmatic matchmaking between peers is not allowed it seems like you know they have to somehow come up with a understanding of how can how it can be allowed in a in a permission setting the other question i have is um what about you showed all the examples in europe is there anything in the in the u.s i mean i know that the occ has published the stuff about custodying and and people running the nodes in fact that is where i take most of my uh most of my thinking from uh occ has already published something saying that regulated institutions can run uh the what do they call it IVNs um so is there any other law in the united states in in process this might be a question for ron yeah i'm i'm happy to answer that vipin and you're absolutely right the occ item is front and center for a lot of colleagues in the financial market space i think it's important and again i realize ego we were talking about the swiss dlt but mapping and comparing uh with what vipin's talking about in the states there are two things that i think are really important both out of the sec sorry one out of the sec one out of fincen the sec just posted to the federal register which is when the clock starts ticking on a 60 day comment period around the the trading and holding of uh digital currencies or virtual currencies by what they call a special corpus broker dealers and if anyone hasn't had an opportunity to read that brief proposed rule it's really worth it because it impacts how broker dealers can custody hold share and exchange virtual currencies and the kind of walls they have to put up around around trading and holding the virtual currencies on behalf of clients i'm a little concerned about some of that because some of it reflects what we were talking about earlier kind of a lack of understanding on how private keys might be held or managed not a fully vetted out perspective on custody etc and i'm happy i don't have it in front of me vipin but i'm happy to share that with anyone on the call separately the other is and i'm not sure um it's been put on hold for the time being but as you probably all know very late last year as fincen put forward um the ability to manage virtual currencies or trade virtual currencies through hosted or unhosted wallets which really put a potentially very heavy burden on on financial market participants in the virtual currency space and it really missed a whole bunch of stuff around um unhosted wallets enforcing firms to report identifying information of other parties and so many to your your point earlier in a in a transaction that is quote-unquote off exchange the the exchange would have the obligation of reporting above a certain limit who received that crypto um and that's a very heavy burden and really strikes the heart of decentralization so that's a bit of a problem i'm concerned as well uh ron are you referring to the travel rule i'm referring to the original fincen nprm on um yet well the three thousand ten thousand dollar travel rule stuff and one is is is record keeping at three thousand one is quote-unquote immediate reporting at ten thousand but i think with the incoming with the biden administration coming in i know that they put several rules on hold for review um the special purpose broker dealer rule is moving forward and i think the last date for commentary publicly is april 27th and we're planning on commenting if anyone would like to collaborate on that or or work collectively together happy to pull you all into that conversation vip in many obviously your expertise as well as welcome yeah i thought i am unfortunately uh in sympathy with that fincen because it is proportionate regulation right meaning if you're sending money somewhere or if you're receiving money from somewhere else uh today you're bound by those rules meaning you can't just say i got it from my uncle and you know wherever um i have to say uh you know i have to it's it's in the end the beneficial owner of the entity that i sent it to has to be outside a proscribe list all of that stuff so i think they're trying to extend that into the into the digital currency space which is not used to that regulation because you don't you know obviously exchanges do not look at where the money where the crypto is coming from or the where the crypto is going to they don't have anything to do with that wallet which is the source or the destination and and that's you know if you want to keep the same regulation as you have in traditional markets then you got to you got to have that otherwise it would be very difficult yeah and i i agree with you vipin in principle i'm you know no one at my organization does advocating fully decentralized there should be no regulations at all i agree with you i think the concern we have is and again it applies specifically to institutions i i'm operationally i'm just concerned about how that how that works and i i don't know of any neat solutions that make that type of immediate reporting or at least recording of unhosted wallet identifying data easily done well i mean there are there are ways to uh for example with SSI it's possible to deposit a proof that you are an authorized receiver recipient or a transmitter without revealing who you are i mean there are there are ways to do this the problem is the regulator's thoughts do not go into that uh into the arena of how we can prove this i mean in the end you have to see why are you doing this because you don't want money to go to guys who are going to uh you know either for money laundering or other terrorist purposes whatever so if you can stop that so you have to you have to look at the spirit of the law and can see if new methods technology can create that circumstance with which you can apply the law in a frictionless manner meaning not not impose the huge operational burden on the operators and uh service this need anyway it's it's it's it's another one of those things as he's so ego or i think there have been lots of questions it's wonderful that you came and you presented and there are many more questions of course which you would like to ask maybe on email or on the wiki page and we have come to 11 o'clock anybody else has any other burning questions we can always go over by a couple of minutes no but just to clarify vip and i have no rich uncles sending me a lot of bitcoin from unhosted wallet so i'm not personally concerned about fincent but uh you make some very good points well i mean you know it's i can say whoever is sending me but i have to prove that that person sending me this stuff is it is not you know doing it from the democratic republic of conco having gotten a bribe from some israeli mining company you know which is proven just now anyway so it's it's all you know it's it's we have to explore the space to create technological solutions to a certain extent and convince the regulators that they have the same effect the regulations they have today agreed um anyway um i think the next call will be at i think at 11 a.m or maybe 10 a.m i don't know because i think the clocks are switching this weekend um and uh we are going to have people so so i think the new crew is coming on i'm going to stop the recording