Opinion from Dr. Andreas Freund. 21 August 2024
TL/DR
There are platform options for DeFi protocols to combine regulatory compliance with out compromising decentralization. Utilizing blockchain know-how and cryptographic protocols, DeFi protocols can guarantee safe and clear transactions that meet regulatory requirements whereas sustaining consumer privateness. Such protocols implement compliance guidelines on digital belongings and their holders. Subsequently, they’ll present a strong and versatile system to assist DeFi protocols navigate the advanced regulatory panorama, contributing to a safer and extra dependable decentralized monetary ecosystem.
Introduction
Decentralized Finance (DeFi) has taken the monetary world by storm (at the very least within the OpEd pages of Bloomberg and Fortune), providing a permissionless and clear various to conventional monetary establishments with a complete locked worth (TVL), as of this writing, of almost $100Bn. Nonetheless, this very decentralization creates a significant hurdle: compliance. In contrast to standard establishments with central management, DeFi protocols are sometimes ruled by self-executing code and lack a single entity accountable for imposing laws. This raises a crucial query: how can these modern protocols combine compliance guidelines into their DNA with out compromising their core ideas of decentralization and autonomy? This problem lies on the coronary heart of DeFi’s future, as regulators grapple with discovering the correct steadiness between fostering innovation and defending shoppers since almost all of the ~ $100Bn in TVL and billions of {dollars} day by day trades on Decentralized Exchanges (DEXs) in accordance with DeFi Lama haven’t undergone any correct compliance checks. Sadly, and really just lately, regulators have resorted to authorized motion towards the likes of Uniswap, Twister Money, and different DeFi protocols.
After thumbing their noses at regulators for a few years, the organizations constructing DeFi protocols are actually realizing two issues:
The phrases decentralization and No-Management don’t shield towards costly authorized actions.
DeFi mass adoption requires higher UX and compliance enforcement — each monetary and information privateness, and on the similar time.
Even when DeFi protocols wished to implement compliance checks instantly, it will not solely upset their finest shopper’s apple carts however would require protocol rewrites. In different phrases, utterly new variations of the protocol with older variations nonetheless working with none compliance checks. That’s not a tenable scenario, since, very doubtless, the foundations or DAOs governing DeFi protocols would nonetheless be held to account for non-compliant variations of their protocol since “sensible contracts are perpetually” — sure, Marilyn Monroe pun quote supposed.
Fortunately there’s a manner ahead for these protocols. Leveraging blockchain-native compliance mechanisms – a mixture of sensible contracts, and blockchain-verifiable zero-knowledge proofs, representing assertions {that a} consumer and submitted asset transaction are compliant with the relevant legislation in a jurisdiction, yields a complete framework to make sure regulatory compliance, danger administration, and transaction reporting for any digital asset. The instructed framework extends the work initially accomplished by Azgad-Tromer et. al (2023) that mixes sturdy regulatory compliance actions with privateness safety, enabling, for instance, the creation of compliant variations of digital belongings that implement jurisdictional insurance policies whereas being privacy-preserving. The unique framework by Azgad-Tromer et al. preserves digital belongings’ financial worth and technological capabilities whereas guaranteeing that delicate info is selectively seen solely to approved legislation enforcement authorities – Fincen, SEC, OFAC, and so forth. This enhances the safety and integrity of digital asset transactions whereas sustaining privateness for reliable customers. Furthermore, the framework’s compatibility with various kinds of digital belongings corresponding to fungible and non-fungible digital belongings makes it a flexible resolution.
In brief, the framework augments blockchains with further details about actors’ identities and asset provenance in a privacy-preserving method and was first applied by Sealance. This modern method permits the framework to deal with the challenges posed by the decentralized nature of digital belongings. Attaching Compliance-Related Auxiliary Data (CRAI) to transactions involving digital belongings in encrypted kind ensures that crucial compliance information, corresponding to consumer identities, credentials, transaction historical past, and fund provenance, stays safe and tamper-proof – see FinCen steerage on Anit-Cash-Laundering for instance. The framework incorporates cryptographic protocols that may mechanically implement compliance insurance policies assigned to digital belongings — what holders can and can’t do with such a digital asset — and digital asset holders — what belongings people can and can’t maintain and/or commerce. It might probably additionally replace CRAI throughout the recording of transactions on the blockchain. This integration permits real-time compliance monitoring and reporting, enhancing transparency and accountability within the digital asset ecosystem.
Notice, that earlier work on this space was carried out by Kaira et al. in 2021 for the case of a centrally managed Hedge Fund. Whereas complementary to this dialogue, it doesn’t contact on KYC/AML compliance, which is the central query we’re discussing on this paper.
How one can make DeFi Protocols Regulatory Compliant
So how does such a framework function within the context of DeFi protocols, given that the majority belongings on these platforms should not natively regulatory compliant?
Fig. 1: Excessive-Stage DeFi (ZKP) Compliance Structure as an extension of Azgad-Tromer et al.
The important thing perception within the extension of the Azgad-Tromer et al. framework is {that a} sensible contract pockets used, for instance, in Account Abstraction (see EIP-4337) as a consultant of a number of Entity Owned Accounts (EOA) has considerably extra flexibility as a result of its programmability than an EOA. If a wise contract pockets is mixed with different sensible contracts that implement compliance guidelines and work together with a DeFi protocol now we have all of the substances we’d like. Consider a wise contract pockets as functionally equal to a conventional Dealer-Vendor, a regulated and registered entity, that locations trades for his or her purchasers, and a DeFi protocol with a number of compliance imposing sensible contracts as a registered inventory or commodity change with its buying and selling and compliance capabilities. Notice {that a} Dealer-Vendor is a *registered entity* that may be a *authorized delegate* of an everyday investor to put trades on the investor’s behalf and implement commerce compliance guidelines. The inventory change is one other *registered entity* – registered with regulatory authorities such because the SEC or Fincen – and its compliance and buying and selling capabilities are separate by design — separation of considerations is a major compliance rule.
With this analogy in thoughts, we are able to now assemble a regulatory-compliant DeFi protocol stack built-in with a compliance framework such because the one pioneered by Sealance via coverage supervisor contracts with related compliance insurance policies, and a compliance coverage and compliant account registry. Essentially the most easy implementation is thru “sensible contract hooks” in DeFi protocols as they permit customized compliance enforcement extensions to the protocol, for instance, Uniswap V4 or Seaport. Nonetheless, this doesn’t clear up the problem for DeFi protocols that wouldn’t have such capabilities; presently nonetheless the bulk.
There’s a common secure sample to work together with DeFi protocols that wouldn’t have contract hooks for compliance checks when a consumer receives a yield-bearing instrument such because the Compound yield token (YT) e.g. cDai. In our description beneath, we implicitly assume that DeFi protocol contracts such because the Uniswap Router or Place Supervisor are registered contracts such that the compliance coverage enforcement mechanism embedded in “compliant” belongings can establish them as compliant and never require an extra zkp compliance assertion to be embedded with, for instance, a switch perform.
Fig. 2: Instance zkp-Compliance Stack utility with Unsiwap and compliant sensible contract pockets
A compliance-safe DeFi interplay sample is described beneath utilizing the instance of including liquidity to a Uniswap Liquidity Pool for specificity:
A consumer (EOA) calls a DeFi Protocol compliance (wrapper, also called a logical abstraction) contract instantly or via the consumer’s Sensible Contract Pockets in an account abstraction state of affairs.Notice: the sensible contract pockets has already been given a Energy-Of-Lawyer certificates via an accepted KYC/AML supplier, corresponding to a financial institution or an change. This certificates is utilized in the identical method as a real-world Energy-Of-Lawyer works; it marks the sensible contract pockets as in a position to make use of the zero-knowledge proof (zkp) assertions of compliance that the zk-based compliance platform creates for a consumer’s asset transactions.
The DeFi (wrapper) contract verifies the submitted zkp compliance assertions utilizing the zk-based compliance stack – a wise contract system see Fig 1 – routing compliance assertions within the type of zk-proofs to (compliance) coverage enforcement factors (PEP) – sensible contracts as a part of the zk compliance stack) the place proofs are verified and actions aka transactions are both allowed or denied. If the compliance checks are profitable, liquidity is added to a pool — both a pool of compliant or uncompliant belongings — on behalf of the consumer by the DeFi (wrapper) contract. Let’s assume for the next a compliant asset pool
The DeFi compliance (wrapper) contract receives the YT and creates a compliant YT asset using one of many zkp assertions offered by the consumer.
The DeFi compliance (wrapper) contract then transfers the now compliant YT to the EOA or the sensible contract pockets — this additionally requires a zkp compliance assertion.
This prevents customers from buying and selling non-compliant YTs except the consumer manually unwraps the asset. Notice that each one the yield now accumulates to the compliant YT. A variant of this method is utilizing DeFi compliance library contracts with the identical performance as a compliance wrapper contract whereas not requiring belief within the preliminary wrapper contract deployment.
For DeFi protocol transactions of compliant belongings (e.g. lending, swaps) or compliant belongings with non–compliant belongings (e.g. swaps), there’s an extra sample:
A Person (EOA) can make the most of an authority delegation coverage expressed as a PEP for its sensible contract pockets such that the sensible contract pockets can work together with a compliant asset with out being required to supply a zkp compliance assertion. This may be achieved by the consumer making a delegating zkp compliance assertion (delegation to sensible contract pockets) and submitting it to the zk-based compliance stack to be validated after which registered with a particular Energy-Of-Lawyer coverage inside a PEP. Energy-of-attorney-type insurance policies can exist at a jurisdictional stage, by asset class, and even on the stage of particular person belongings.Key Level: An authority delegation coverage to be utilized in a transaction is on the asset stage, not the extent of a payee, a payer, or an authorizer stage. This permits an asset to establish if a payer or payee is permitted to work together with it, with out being required to supply a zkp compliance assertion.
Recognized DeFi protocol sensible contracts e.g. Uniswap Router, or an Aave Lending Pool supervisor can, subsequently, additionally make the most of a Proof Delegation coverage as described above. The first distinction is that on this context the entity creating the delegation zkp compliance assertion (regulatory whitelisting of a Defi protocol sensible contract), and the registration is completed by a certified coverage creator or registrar corresponding to a KYC supplier throughout the zk-based compliance ecosystem.Key Level: As within the case of an EOA, this registrar-proof-delegation coverage is on the stage of the asset, and may differentiate jurisdiction, asset class, and even particular person asset. Nonetheless, it’s of a special authority delegation coverage kind as a result of the requester has one other ecosystem position. Subsequently, the compliant asset should have each sorts of authorization delegation insurance policies hooked up to it as a result of each a wise contract pockets, a Defi protocol compliance wrapper, and a Defi Protocol sensible contract will work together with the compliant asset.
Conclusion
In abstract, to make sure the longevity and acceptance of DeFi protocols by mainstream customers, these protocols should transfer in the direction of regulatory compliance. The described compliance platform, an extension of the framework proposed by Azgad-Tromer et al. and applied by Sealance, provides a sensible resolution permitting DeFi protocols to include compliance measures whereas sustaining decentralization. It makes use of blockchain know-how and superior cryptographic protocols for clear, safe transactions that meet regulatory necessities, all whereas preserving consumer privateness. It enforces compliance guidelines on digital belongings and their homeowners, offering a strong and versatile system. The important thing advantages of the described compliance framework for DeFi protocols are:
Regulatory Compliance: The framework permits DeFi protocols to stick to regulatory requirements with out compromising their decentralized nature (although KYC is essentially nonetheless accomplished by centralized entities).
Threat Administration: The framework permits mechanisms for efficient danger administration and transaction reporting for numerous digital belongings.
Privateness Safety: The framework incorporates cryptographic privacy-preserving options corresponding to zkps guaranteeing that delicate consumer info utilized in compliance credentials and in creating zkp compliance coverage assertions stays confidential, with private info saved and accessible solely by KYC/AML or different compliance credential suppliers corresponding to banks or exchanges
Safety: Leveraging secure cryptographic protocols, the framework can improve the safety and integrity of digital asset transactions by imposing advanced enterprise guidelines.
Versatility: It’s appropriate with various kinds of digital belongings, together with fungible and non-fungible tokens, making it a flexible resolution for the DeFi ecosystem.
Transparency and Accountability: The framework promotes transparency and accountability within the DeFi area via real-time compliance monitoring and reporting (via onchain submitted, totally encrypted experiences).
Such a framework can help DeFi protocols in navigating the intricate regulatory atmosphere, contributing to a safer and extra reliable decentralized monetary ecosystem.
Dr Freund will be contacted through electronic mail at [email protected]
