Why Regulatory Clarity for Developers Will Decide Where Capital Flows: DEX in the City

But the average American feels like they were rubbed. They were told that this is going to be a force for financial freedom and all it is is just online sports betting without a regulator. That's stupid and everyone in crypto should be ashamed of that.

Hi all. Welcome to Dex in the City. I may look different today cuz I am not Katherine Kirkpatrick, but we are still Dex in the City where the wallets are cold and the takes are hot. KK is out today and I don't have her gorgeous red locks, but I'm going to try and fill her shoes. I'm your temporary host Jesse Brooks from Rubic Capital and luckily I'm here with my co-host be today. Filling the shoes of KK is our wonderful guest Peter von Vulcanberg from Coin Center. He does not need any introduction so I won't do it. I'm sure you all know about all the amazing work that he's done to protect software developers in the crypto industry, which we will get into in detail.

V is going to also ask him some specific questions about what's happening with the crypto market structure bill. There's a White House meeting happening right now about it. And so we'll get into all the details there. Although I cannot believe that we're still talking about it.

But before we get going, remember we're lawyers, but we're not your lawyers. Nothing you hear on Dex in the City is legal or financial advice, and it doesn't create an attorney client relationship. For the fine print, always check unchained crypto.com.

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Okay, we're back. Let's get going. So, first, the lay of the land so you just know what to expect today. First, we're going to give you the playbyplay on market structure and let Peter sort of do his thing, walk through what he's been working on, and ask him a bunch of questions about it, maybe challenge him a little bit. And then we're going to jump into what this means for the DOJ and then hopefully hit on some Super Bowl crypto fund, hear what V thought about the halftime show, and then maybe get Yeah, totally get to AI agent security if we have time.

So, V, I'm going to turn it over to you to get us going.

So cool. Thanks. So, Peter, you've been at Coin Center for a while now. We're so happy to have you on today. You're actually, I think, one of the first people I started following when I joined the industry, like over four years ago, and I've honestly learned so much from you over the years. And I got to know you a little bit better because you were really helpful in the Samurai Wallet case where the developers there were charged by the DOJ for conspiracy to operate an unlicensed money transmitter and conspiracy to commit money laundering. And they're both now in prison. So, we'll talk a little bit more about that today.

But, you were just so helpful to the defense team in that process. And so just in addition to all of the work that you've done for Coin Center over the years, around developer rights and civil liberties more generally, it's just really great to have you on. So, for those of you who who aren't those of our listeners who aren't as familiar with you and Coin Center, can you give us just some really quick background on what you guys do and what your focus is these days?

Thanks, V. That was very kind of you. Right. I've been working in this space for 11 years. So, Coin Center was founded in 2014. It's actually my first job out of law school. Uh, my first like big job out of law school. And at the time, you know, there wasn't really a mature voice explaining and educating and representing these open source technologies in Washington DC. And Coin Center's mission was to fill that void, was to be a voice for the technology, which at the time was, you know, primarily Bitcoin.

That's really all we got questions about when we would go into a congressional office or into an agency. This was before the Ethereum ICO and before Ethereum launched. This was before ICO summer, NFT summer, DeFi summer, name your summer, you know. So, we've been around for a long time. We're mission driven. So, you know, there are now a number of mature and some of them quite successful trade associations in Washington DC that represent crypto interests. But Coin Center is not a trade association. We think of ourselves and we are a civil liberties firm that's focused simply on guaranteeing that people who want to develop the free and open source software that makes these technologies the open innovations that they are are protected from undue prosecution or regulatory treatment.

We're not nihilists to quote Senator Warner actually in a in a recent hearing who suggested that there are some people in the industry who are nihilists who don't want any regulation or that might have been Bessant actually it was in an exchange between the two of them it was really interesting exchange we do believe in common sense regulation of trusted persons in the space of companies like Coinbase and even of projects that claim to be decentralized and trust minimized but actually are still performing basically the roles of the centralized financial institution.

What we are against is attempts to license and permission software development or the operation of truly neutral infrastructure. And we sort of modeled ourselves after the Electronic Frontier Foundation, which for those of you who who don't know is this amazing internet policy focused civil liberties organization that started in the '9s by great like John Perry Barlo that fought to say look, you know, aspects of the internet deserve regulation, but just connecting computers together and making a global network possible and writing the software to do it is not something that we should police into the ground because otherwise we'll lose this beautiful new freedom that we have in a global communications network.

Somehow this is not the first time that Barlo has come up on this podcast.

Good. He should he should come up on every podcast. I guess there's something good there.

I have a question for you on the sort of coin center foundation and thesis because we are going to get into AI agents. We talk about it all the time here. When you guys talk about protecting software developers, is it purely related to blockchain and crypto or are you beginning to expand sort of to other areas? Because in my mind, and you know, I've touched on it before. You know, I've engaged on the market structure bill on this issue too. Like it's hard to separate the two as you know, AI and crypto both become part of infrastructure. I think it's hard to separate.

Coin Center, I think part of what's made Coin Center successful over the last 10 years is that we have this narrow mission. We're not here to represent, you know, quasi centralized online casino for, you know, pers or something like that. We're here to represent like an actual open source tool for privacy. And we're also not here to opine on a whole bunch of other technologies. We're supposed to be cryptocurrency focused, blockchain focused. Maybe you could call it decentralized computing focused. So, there are touch points there with AI.

Like, frankly, I would be more comfortable if the way AI was built out over the next few years was as much as possible through decentralized systems for both like who owns the compute resources and and how do we reward, you know, training data and things like that. It would be great if that was built on on on more decentralized protocols because I think it's a decent use case for blockchains. But on the question of just like AI and liability for developers who are building these models, I I think we would shy away from that. But it would also be hard to because the exact same precedents that will be set in the world of crypto like whether your smart contract for privacy is worthy of first amendment protections when you publish it or deploy it to the blockchain are going to be identical as far as legal standards that are developed under the first amendment as whether you can write the same code and publish it widely or distribute it widely for AI.

Right? So there's a lot of overlap but we take as our mission defense of the crypto stuff specifically.

We've talked about the, you know, the bills that have been going through and the updates, etc. pretty much on every episode over the past few weeks. Why don't you tell us what's been going on in the past week or so when it comes to developer protections and particularly 1960, which for everybody who somehow hasn't heard that in the crypto space, that is a statute that has been used to prosecute unlicensed money transmission federally. It's complicated statute. There's not a lot of precedent associated with it. It was associated with the samurai wallet case that V was talking about, tornado cash, but also a bunch of very useful cases that we'll get into associated with cartels and also like centralized mixers. So, yep. Know that that has had a centralized acting position in this bill and especially in the past week or two.

Well, so it's interesting. So, you know, back in 2017, I think we published a a long form report arguing that the state money transmission licensing regime is a strange fit for crypto businesses. Like, it's odd that a Coinbase would be regulated exactly the same as a moneygram or a Western Union, right? because their risk profiles are different, consumer protection issues are different, and it's inefficient to force these companies to go get 53 licenses from different states and territories that all independently regulate their activities. Right? So, the question back then was why don't we have a federal framework? And that's mostly what market structure is about. It's about can we establish and house at the SEC and the CFTC some unified national oversight for trusted companies that hold people's crypto that are deserving of regulation because people trust them with their crypto and they trust them with say best execution in a trade or something like that.

And mostly that's something that Coin Center supports but doesn't get deeply involved in because if you walk like a duck and you quack like a duck, if you're kind of like a bank or other financial services provider, we just think there should be equal treatment. You know, we don't think the banks should get special treatment. We don't think the companies in the crypto space should get special treatment. Where we get really involved though is on this developer liability question. So if you're not a traditional trusted entity, you know, someone who's taking custody of funds or someone who's making, you know, enforcable promises of things like best execution, if instead you're just providing software that allows people to transact on their own, you know, relying on your tools but not relying on your discretion or judgment. Can you be regulated as a money transmitter and forced to get a license before you publish that software? Can you be regulated as a broker dealer under the SEC?

Our argument is that when you're truly just publishing software or providing truly neutral, non-discretionary infrastructure that other people are using, you should not be forced to register or license. And there may even be actually pretty serious constitutional issues with forcing you to license or register before publishing your software because that would be a prior restraint on your constitutionally protected speech rights. Additionally, those regulations setting aside the constitutional concerns are not usually fit for purpose. Broker dealer registration is about information asymmetries as is most of the SEC's you know statutory purpose. And in a world where your software is simply scraping publicly available information automatically and allowing a person to find say a trading partner somewhere online using that publicly available information. You are an information broker. You're not a stock broker in the traditional sense. And so the information asymmetries that we would normally worry about in a broker registration context like are you going to find the best trading pair or are you actually going to prefer someone uh that is you know internal to your brokerage firm or your larger fund. Uh are you going to make public the information that you based your decision on how to route an order? Those questions start to fall away when we're talking about truly decentralized systems.

Similar with money transmission and anti-moneyaundering rules. When you are in a position of trust, visa v your customers, your Moneygram, Western Union, PayPal, Coinbase, it is a fair bargain, I think, to then obligate you to know those customers and report some of their information to the government for crime fighting purposes. But when you are a stranger to those people, you are more like a person who wrote a really good book that a bunch of people are reading. the thought that we would force you to learn all the people who bought and read your book and report them to the government. it starts to look very Orwellian and it's problematic I think uh fundamentally so where we have truly decentralized activities truly softwarebased activities I think we need to avoid prior restraint and registration that's not to say that there's no regulations that apply is the last thing I'll add to this there are things like unfair deceptive acts and practices so if you publish software and it turned out it it did things that you said it didn't do either because you were negligent And certainly if you were intentionally committing fraud or deceiving the users of your software, you should be prosecuted, right? And and there is jurisdiction to do that under unfair and deceptive acts and practices at the FTC and at other agencies. But registration and licensing is a is a step beyond that. It actually starts to get into the realm of prior restraint.

Can we can we drill down a little on the the concept of truly decentralized? Right. So like in the market structure bill, the 1960 provision and the the BRCA, they both like kind of turn on this concept of control, right? Which is a which is a concept that I think like we've all been struggling with for years in in crypto. So like what what does control actually mean, right? So from from my perspective as the GC of the DeFi company, this is something I think about like literally every day, right? In our case, we operate vaults, which are just programmable smart contracts that users can connect their self-hosted wallets to, and then the vaults deploy those funds into DeFi yield strategies. So, one of the questions we're constantly grappling with is how do you maintain the non-custodial nature of of this kind of arrangement? Like, what does it mean to have control? Um, you know, if if we can upgrade the vault, does that constitute control? Um what if we can pause withdrawals in order to respond to security instance? Does that constitute control? What if you um have something that is not 100% immutable because there are certain admin functions you need to have just to like be able to operate the thing. Um, so like do you do you read the provision the proposed language in in the market structure bill to mean that something really does have to be like 100% autonomous and immutable to constitute no control or if you have any and he whatsoever. Does that mean that you're subject to regulation?

So there's a couple different moving parts actually. It's a big bill and this is part of what's made it difficult for it to move through the Senate because a lot of people have a lot of education to do before they can get comfortable with it. But there's a couple different provisions. The first provision to focus on for this question is the Blockchain Regulatory Certainty Act, which was a separate standalone piece of legislation that began in the House in 2018, I believe, when Representative Tom Emmer, now Majority Whip Tom Emmer, introduced this piece of legislation. And it was intended with Darren Sto at the time. So it was bipartisan as a Democrat and Republican. And it was intended to create a safe harbor from unlicensed money transmission prosecutions for people who are truly not doing money transmission as defined by Fininsen at the time, the relevant federal regulator for figuring out who is a money transmitter. Fininsen had issued guidance. Um at the time it was multiple letters to multiple companies who asked for for further information for administrative rulings and later it was official guidance in 2019 on all different kinds of entities in the crypto space. And Fininsson said if you do not accept and transmit by which we understand at some point in between you'll have independent control over customer funds. If you don't do that, you're not in our jurisdiction, which I think was a very good and faithful reading of the underlying regs for the Bank Secrecy Act, which is our financial surveillance rules, and the Bank Secrecy Act itself. And so Tom Emmer's bill, the Blockchain Regulatory Certainty Act, simply took that Fininsen guidance and codified it and said, "We're going to make this a statutory rule so that it can't be ignored." Because guidance is guidance and it's it's important. Companies sometimes rely upon it, but prosecutors can ignore it. They can say the underlying statute is different and the guidance shouldn't be followed. And in fact, that's exactly what the prosecutors said in the tornado cash prosecution when they went after Roman storm. They said, "Yeah, Fininsen said you're not a money transmitter if you don't have total independent control." But Fininsson's only defining only offering guidance on the statutory definition at 5330, the bank secrecy act, and we're talking about the criminal code where we think money transmission is basically whatever we want it to be.

Hold on. To back up my unchar to back up my uncharitable reading though, they said a frying pan transfers heat even though it doesn't control heat, which is to me verging on chicainery. I understand for I'm not sitting up for the DOJ in this prosecution or that brief, which I disagreed with a lot of it. I think that the bigger problem of that charging of tornado cash was the fact that they weren't specific enough with the facts because tornado cash obviously changed over time and they should have charged it accordingly but you have here just I want to make sure that yes I'm challenging you in the ways that like that let me close the loop quickly on the market structure discussion because I know I go off on these tangents. So the BRCA ultimately got attached in the house to clarity the house's market structure legislation and that was important for Coin Center because we basically said look we want trusted companies to be regulated in a sensible way but part of the bargain for our support and for like what we care about is that you offer some clarity to software developers that they're not going to get unjustly prosecuted and the House passed that with the BRCA attached. Then it came to the Senate, which is why we're discussing it now, and it got subtly changed in ways that I'm generally comfortable with. But at now at this last moment where we're sort of dithering on the precipice of maybe getting a vote in Senate banking to get it out of committee to get it voted on a the larger Senate, there are renewed doubts by some folks who were going to need the support of to get the vote count to actually pass this thing as to whether we're unduly restricting the ability of prosecutors to go after bad actors by providing this insulation from liability for software developers.

Yeah. Yeah. Sorry. No, that's really helpful background. I think like the the frustration for like someone in my position, right, where I'm actually trying to advise like developers and builders around like, you know, if we have an admin key, like what actual functionality can we retain or give up, right, in order to constitute no control. And right now like and I get that it's the statute and so it's not necessarily going to drill down on what like the different factors are like that will come with rulemaking I assume but that's what I think is frustrating and and and it's it's hard right because until we understand how control is actually defined it's the language right now is not actually that helpful for us like we are potentially at risk of being criminally executed.

I think the BRCA's definition of non-controlling blockchain service or service provider or or software developer is much clearer than anything we've had in the past except maybe that 2019 Fininsson guidance and and or in line with that 2019 Fininsson guidance. And so this will hopefully codify what has become a clear standard had it not been for some prosecutions from the Southern District of New York like the tornado cash prosecution that I think went off the rails or were prosecuted in the wrong way to be to be fair to Jess's excellent point which there there probably were good ways to prosecute this and this happened to not be one of them. And then the other thing I'd say to answer your question on sufficiently decentralized and admin keys and you know emergency security councils and things like this, I think the BRCA gives you a fair amount of clearance that if if what your admin key allows you to do is rewrite the smart contract in certain discrete ways. You don't have day-to-day ongoing control of customer funds and so you're not a money transmitter. But there's more. You might be a broker dealer. you might be uh a digital commodities um broker dealer which will be soon within the jurisdiction of the CFTC. And so there's a secondary question. The BRC gets you out from money transmission liability if you don't have control, but are you regulated at the federal level by these other um competent authorities that will require registration and licensing?

And so in the Senate banking amendment in the ANS draft, all this jargon, yeah, there's section 301, which is an interesting thing to look at if if you're a lawyer working in the space, which is about um nondecentralized protocols. And so that sets up effectively a rule making for determining what is a non-deentralized protocol with a number of important factors for what might be non-deentralized. If you are deemed non-deentralized after that rulemaking sets up those factors, you can then also be deemed obligated under existing securities laws or existing uh treasury rules like the bank secrecy act as an obligated entity either as a broker dealer for securities or as a money transmitter or not as a money transmitter or as a some some other BSA regulated entity under the bank secrecy act. But if you are insulated by the BRCA, you can't be treated as a money transmitter. So this non-deentralized rulemaking is important and one thing that I you know the first time I saw this text from its drafters um I was concerned because there's a lot in there and there's a lot you see technical terms in legislation you think well this probably won't age well or it won't create the clarity that you hope it should be more of a a principlesbased standard rather than a specific technical standard but once I dug through it I got comfortable with it there's things that I would potentially change if I was you know if I was the Senate to quote Star Wars. Uh but I'm not the Senate and the process of legislation is a process of compromise. And so I think where that ended up is pretty good.

To your specific point, there is a section in 301 that deals with uh admin keys used for cyber security vulnerabilities, things like a pause function to address a known bug. And so they don't they don't intend to call that non-deentralized. They intend to say like we don't want to disincentivize this good security practice. We just want to go after the people who are calling themselves DeFi but are really just you know your traditional broker and dealer and securities.

Yeah. And I I think that's important to clarify right that like decentraliz sufficiently decentralized and like not having control does not mean you have to be 100% like immutable and autonomous. There actually is some room in there for some admin functionality. And I think that like that, you know, that was kind of the right that was the feedback that I gave some of the staff on that which is that we should want to incentivize just kind of like ordinary responsible um measures that honestly every DeFi protocol out there pretty much is already doing a lot of this stuff now, right? like like this might be a surprise to some people who talk about this in the abstract a lot, but there actually aren't that many DeFi protocols out there today that are 100% autonomous and mutable. So like this would really protect no one if if control meant or no control meant that you really just have no admin functions at all.

B, you've said this before, but I think that part of the problem that the crypto industry and lawyers in the crypto industry, so we are to blame as well, have created is this binary conversation of control and not control. And that puts developers like the the place that you work and many other developers in this place of when I build this project, how do I build it to be secure from prosecution and ensure that I'm protecting myself? But it simultaneously I think puts policy makers in an odd situation because like when you talk to the Dems that really want to get this done like a Mark Warner who supposedly said this week that he's in crypto hell that is trying to figure out how do we like all of us. Yeah. How to ensure that he's in you know protecting national security and also like speaking for victims which I definitely want to touch on here as well. like he's trying to come up with rules that protect national security and ensure that, you know, billions of dollars don't continue to be stolen by, you know, DPRK, just to name one aspect of this. Um, and so the concept of binary doesn't really work for them either. And when you have conversations with, you know, Warner staff and other Democrats, they they seem to be really trying to find a solution that allows developers to succeed and protect first amendment rights, but simultaneously like ensure the proper protections are in place. And what I struggle with is there are a lot of ideas out there and I know like Peter, you and I have talked about liability um statutes before like maybe it's using money laundering more than 1960. like maybe that solves a lot of it if you just take 1960 out which we can get to but you know just sort of saying like well if you're completely decentralized and you're you know not touching anything it's protected by first amendment and if you're not you're not like I think that sort of escapes um addressing a lot of the intermediary side because you know the book analogy you talked about is like one that I think is really interesting and like strictly in the first amendment you can publish a book But if you publish a book with, you know, plans to build a bridge, maybe this isn't a great analogy, but like I'm I sort of came up with it a few minutes ago. Um, you know, to build a bridge and the bridge has all these problems with it and you set up a toll on it that automatically collects some sort of fees and the bridge collapses. Like where at what point in those steps do you become responsible? And I I don't know if there's an answer. I don't know when. for that. It's funny when you actually like reached into the physical world and built the bridge.

Totally. Yeah. Yeah. So, but I take your point. Yeah. Yeah. So, I'm not quite sure what to say back to, let's say, a Mark Warner. I'm I'm not meaning to pick on him, but he definitely No. One, he was my first job was interning for him. Oh, really? Yeah. Totally. I mean, I think I was in high school, but um uh I you know, he's really seems to be trying to get this done while simultaneously keeping the space safe and he seems focused on the national security side. So, like what for him?

Yeah, I'll say I'm I'm very grateful for Mark Warner's involvement in this. Actually, I I told I said at the beginning that uh to to to Jesse and V that I wasn't going to mention any members or staffers by name, but I will do it in the positive in that like Mark Warner has been a very honest broker on these topics and it it does feel like he's genuinely trying to get to a good place and it and the what you teed up is exactly the difficulty and I you know Coin Center is even guilty of this in that we focus pretty narrowly on like truly open- source software. ware than doing things in the world and people being held liable for publishing the open source software and that I think is black and white that should be off the table for any kind of permissioned regulation but that makes me sound like an absolutist unless you realize that that's a very small segment of the crypto space that is actually a narrow carve out like that's like Bitcoin core developers Ethereum core developers probably some other L1 core four developers, but I won't name names because this starts to get very, you know, uh, you know, dodgy. Um, it's a small number of people and and and you know, we also stand up for miners and validators who are truly not in a discretionary position visa v like the users of their protocols that they are, you know, maintaining by mining and validating transactions. This is not a wide swath of people that we think are truly off the table. Then there's this giant intermediary gray area of people who are you know building DeFi tools h they retain some control they may make certain promises to their users this set of people there are hard questions over and I think they may not be protected by the BRCA and I I want to like make that clear to if there's any staffers for any of the offices that are noodling on this text. I don't think all of those people are protected by the BRCA. The BRCA is meant to be a very narrow piece of clarity for just people who are truly engaged in activities that don't engender trust from their users that don't trigger the normal regulatory obligations that we would expect because it's more like software development in a pure sense or infrastructure in a pure sense. For the people who are actually in some position of quasi trust, they may not be excluded by the BRCA from anything and they're going to fall into or out of this 30 301 rulemaking on non-deentralized protocols. If they if as Treasury and the SEC develop this 301 rulemaking, they develop it in a way that catches some of those people, those people will be treated as obligated entities for things like the Bank Secrecy Act. And then in general, there's also all of the truly centralized businesses out there who don't pretend to be decentralized, but previously have been regulated in a somewhat ad hoc manner by by squeezing them into existing regulatory structures like money transmission. This bill will create new categories of fally regulated financial institution that will have BSA AML obligations. So this bill is not a deregulatory bill. It's actually a strongly regulatory bill that will create a lot of new data and data collection for law enforcement by the creation of these new BSA obligations for these new types of entities like digital commodity brokers and dealers. The part that we're now discussing that carves some people out from a licensing requirement and a surveillance requirement is really limited to carving out just those people who never should have been obligated to collect information on the users before because it would be like asking an author to collect information on the people who read their books.

Yeah, I mean I think that's a great point. We obviously haven't solved anything yet, but we do need to take an ad break. So I'm going to jump in and let us do that and maybe when we're back we'll have all the answers.

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Okay, we're back. Turning it over to V to talk a little bit about how money laundering fits into all this.

So we we mentioned um you know that there have been various charges in cases like tornado cash and Samurai Wallet, right? So there's the the 1960 conspiracy to operate an unlicensed money transmitting business. But I I wanted to focus on the conspiracy to money launder charge. um has the reason I think it's important is because like you know even if we totally got rid of 1960 wouldn't developers still be exposed to criminal liability under in my view the very broad and incorrect way that the prosecutors have been applying the conspiracy to moneyaunder charge. Right? So just for background like the developers you know they wrote and published non-custodial software the software I think you know this isn't in dispute right the software can be used to facilitate illicit finance and it was by bad actors the developers in some of these cases knew that that was happening and they didn't do anything to shut the protocol down block users um redesign it to to help like stop elicit activity, right? So, I think it's important to note that the DOJ here did not allege that the developers in any way actually coordinated with the illicit actors. Like they didn't come to an agreement with them to moneyaunder. They didn't direct moneyaundering activity. Um they didn't share any of the profits from the moneyaundering. Right? So what they're basically saying is if you continue to maintain or publish software after learning that elicit activity is happening using the software, you've joined a conspiracy to money launder. Right? So to me that was always really highly problematic a highly problematic reading of the federal conspiracy statutes which like if you guys don't know right just on a very basic level it requires an agreement between two or more people to commit a crime. It requires knowing and intentional participation in that in that agreement and it requires an overt act in furtherance of the conspiracy. Right? So, like if you went to law school, you probably remember covering this in criminal law. And I just I've never seen how we have all of those elements in these cases, right? Like where was the agreement between Roman Storm and Lazarus Group? Where was the knowing and intentional participation? So, like I I feel like we just haven't we haven't focused on that part of these cases enough as an industry. Um especially because in my view I actually think that if this issue ever got to the Supreme Court that they would agree that this is a radical application of the federal conspiracy law and it has implications for like more than just how it's been applied to these crypto developers.

I want to be very careful here because it is my hope that actually some you know staffers on the hill are actually listening to this and are thinking about the block regulatory certainty act and whether it should stay in market structure or not. And one thing that uh I will say is like when Coin Center has talked about these issues, we emphasize how the BRCA doesn't change 18 USC 1956, which is the moneyaundering statute. It only changes 18 USC 1960. And it doesn't get rid of 1960 to your earlier point V. It simply says, look, 1960 is something that can continue to be prosecuted for things like uh hala, which is actually kind of what originated 1960 was fears over um these networks of quasi money transmitters in in communities to move money from person to person ultimately to a destination