Risk Management and Crypto KYC & AML Solutions

Transcript

thank you really nice to be here to talk about risk management from from another perspective I'll just enjoy invite my co-panelists to come up and join the stage with me we definitely have um a really interesting panel for you today I mean all the topics have been absolutely wonderful so far um but I have heard from um quite a few of the discussions that compliance tends to be one of the sticking points um one of the issues where we either need more education or it's one of the um one of the elements that needs to be addressed before we we can grow um we need more information with regards to uh knowledge transfer we need to continue to work with Regulators um internal buildup of

knowhow on compliance is is not easy um so we're going to talk about that in the context of risks um with my steam panel and I'll just allow them each to quickly introduce themselves and the products that they offer in the crypto space so do you want to have a a start Lucas go right ahead okay thank you I'll keep it short I'm in Bitcoin since 11 years I've work in this industry since 10 years and since four years ago we found a 21 analytics where we provide a software solution for transfer in and out meaning travel Rule and ownership roof that's our core uh solution so when we talk about private wallet wallets Banks interacting with private wallets and they have a solution

for you yeah hello I'm I'm a CE of SC SC has been business okay it's better there I'm Pi CE of scorain uh Scot has been the business since 2015 we are a blockchain analytics platform mainly providing a kyt no transaction solution for U uh any customers having to deal with HL and CFT uh we are based in Luxembourg we are purely European and active in more than 40 five countries today and also working with companies like 21 analytics one two okay hi my name is Ilia I'm a chief growth officer at suub

uh we are a large kyc ml compliance provider working with over 2,000 clients about half of them are crypto so we're very big with big in crypto we offer services all the way from pre- onboarding screening to onboarding kyc AML as well as well as ongoing compliance and transaction monitoring travel is another product we offer we also work with 21 analytics know them very well so yeah happy happy to be here thank you Chris and good to be here as well my name is Mark Aria I work at at alytic another blockchain analytics firm so it basically helps you visualize the transactions due diligence all these kind of things that we've been talking about today when it relates to analytics I work in the regulatory team uh before

this I was really a long-term regulator at the UK's Financial conduct Authority I was in Capital Market but also introduce the crypto asset changes to the UK's money laundering R so I see it's from sort of both sides of the fence but good to be here great so this session we'd like to make it a little bit more interactive if if possible we'll kick it off with a couple of questions but then we'll open it up to the audience so if you have any questions for AML experts or service providers in the AML space this is your time so um the topic for today is obviously risk management in the in the AML space so I'll just kick it off by asking our Este gentleman here to to maybe share your views on how risk management specifically in the financial services area um and perhaps even

specifically for banks has evolved over time what are you hearing from your clients what are you seeing in terms of Trends and how a man risk is is managed who would like to start us off I'm happy to kick it off um so so I think there's many things which are similar to traditional risk management um but there are some things which are different so the traditional criminals bad actors are criminals so therefore the behaviors the characteristics so we call them typologies are very similar when you think of traditional finance and you think of crypto where crypto changes it's me it's because it dis intermediates transactions with with banking transactions it's typically bank to bank and there's kyc but in the

crypto world there's distance to mediation and there's analytics companies which gives you site of the whole ecosystem and that whole ecosystem you need to understand what risk is and how do you manage that so your compliance framework has to develop in that basis I think those are broadly where I see similarities and differences yeah maybe I can I can add that um the main difference is how it is implemented uh I like to say that if you traditional Finance you you see the banks you see the actors but you don't see the transactions and in the blockchain is totally the opposite you see all the transactions but you don't know who is behind and first of all you have to identify to assess the risk for each wallet and if to have to to monitor all the addresses of an exchange for

instance Kraken we are monitoring millions of addresses of exchanges like Kraken in real time so um the the implementation at the end you have they have to complier from a bank or for an exchange or or in a bank um dealing with with crypto um uh they have to identify the origin of fund and the the risk of counterparties to assess all these kind of risk but the architecture the underlying implementation of the technology is different and this is why it's a new paradigm and they have to we have to teach them they have to learn a lot and but at the end of the day it's the same um same job yeah I just want to add as well what

we're seeing in the market in terms of banks I think there's sort of two main areas one is uh Banks taking on Fiat bank accounts of AAS and that's going to come from MAA if you're not a credit institution or a payments firm then you as an exchange have to put your money overnight with a credit Institution we see different jurisdictions also doing that so the first one is just due diligence before you take on a Fiat bank account the other aspect is again something that's been discussed here as a custodian how do I look at uh my deciding whether I'm going to act for a particular vasp uh and the last thing is actually is in terms of the travel rule you can also look at proportionality in terms of risk who are my most um if you like interested counterparties how do I

assess risk and what kind of due diligence do I need to use that so it's not just about knowing a transaction is also about do I want to take this person on as a customer what I really like about the crypto space is um the a lot of the industry actors have um been quite active in addressing some of those risks when we talk about travel rule lots of solutions have become available on the market when we talk about assessing um counterparty vas risk we have tools available like the virtual asset uh due diligence questionnaire that's been put out from the wol Wolfsburg group or together with um other gdf and other big players so we've we've we've collaborated quite a bit as a as an industry to to address some of those risks um would you like to to add some thoughts on I agree with beer said

that you know the completely different technology stack I think presents the most challenge specifically for banks I think because they are coming off years or if not Decades of built-in Legacy systems and processes and to marry it with kind of real time uh and fully remote dealing with individuals and also businesses is a completed different Paradigm so I agree that like the whole stack needs to be rebuilt and and the and the particular challenge as well is from the regulatory side A lot of times it's unclear how do you take them and apply regulations that have been built for pretty much a traditional Financial system and apply them to a system where it almost doesn't work and we can talk about things like again uh can you identify individuals or or

wallets without um without passing personal data for example right so these are questions Maybe for a couple steps further down the line but even today it's hard to uh take traditional regulation appli to the crypto space so maybe just to make it very practical for people who are in the audience who themselves have to manage risk or have to make decisions about solutions to M manage risk um we've talked about what the risks are where the challenges are maybe what we could do is do just a quick round to talk about how your particular product or solution is helping or would help a bank or financial institution to address one of those particular risks maybe name

just one or two where you could say hey if you come to us this is what um this is this area of risk where we will be able to help you out would you like to start Lucas yeah sure um I think the the great thing about Bitcoin or crypto in general but I always say Bitcoin is that you actually get freedom to transact from with anyone right I can send from my theoretical from my bank of account Bitcoins to cisis leer that's something I can't do in the Fiat world I can tell my bank send some cash to like physical cash to Chris so that's something you can do in Bitcoin but scan something the regulator more or less killed a bit at least with the travel Rule and everything um because you now you need

to provide proof that you actually control this wallet or Chris would have to do that to my bank and she would have to on board with my bank just to receive money from our bank so long story short that's a bit the sad part um what we do is we give you a solution that your customer still very conveniently can provide the proof that he himself actually controls that wallet so the transfer in and out um yeah with selfhosted wallets mostly I think that's the easiest with travel rule it's possible but it's very difficult because most likely your counterparty will not play around along so yeah so what what's nice is um because finma was very ambitious with regards to AML very early

on since 20 sort of 18 199 uh with the payment on the blockchain guidance that we have been innovating quite a bit I believe in Switzerland and um 21 analytics is one of these firms that has has come out with a solution a software solution for identifying the owners of private keys so if you've heard from your compliance team or you've you've read within regulations that private wallets require require identification this is one of the services um aop that can support you with that P you want to continue um yeah there's a lot of innovation today in the as you all know and uh so even the regulation is trying to follow the regulation for instance the MAA in Europe is not addressing nft today it will be potentially in the next

MAA regulation maybe 20 25 or later so uh we need still to bring a lot of flexibility and this is how we are for for instance C is dealing with all the configuration so we provide we are doing due Diles on vasp and getting a lot of information doing our own um due diligence of wallets and trying to ident ify as the r giving risk scoring this kind of stuff but we let the also the key of the um the parameters to the customers and uh because depending on the compliance policy depending of the regulation in which countries are regulated uh they need to adapt and to um uh to to be able to to change some threshold or to decide that this is a

medium risk or low risk so today uh for for Scotland the approach is to Dev uh and sometime with additional um Partners some some Partners like big four for instance if we are working with a large bank and but at the end they get Ober the ability to to change a lot of customization and to Define their own rules uh that uh will directly follow the internal requirement I think that's very helpful because in um in I think it was last year the fatf just updated their guidance and in this this latest version of the guidance it's the first time where they really stated very clearly that there's an expectation that um vasp do counterparty due diligence so if

you're offering services like know your vasp I know some of your competitors are as well but I I think yours is is very well reputed um that's helpful for for people like us at the six side who are implementing due diligence of of vasp we can use the vdq to help us do our counterparty due diligence but having services like yours definitely gives us that second voice um and and the Analytics behind our our analysis yeah that's helpful uh so we started historically from kind of the side of on boarding individuals and we've done this for now for eight years on boarded probably over 300 million for now and doing 10 million per year in crypto space that means that we see a lot of fraud coming to our clients and so over time our product has

developed into pretty much a full cycle compliance platform that starts with rest on three pillars one is on boarding second one uh is anti and third one is compliance and all of this tied together we kind of believe that the only way to stay complainant could have to see the full picture about the individual catch out the fraud and and connect this with with compliance tools so that's what we're really building so that's why say travel rule fits into the comp pure compliance there's lots of kind of internally built AI technologies that help us fight all types of fraud you know uh mules uh fraud networks uh deep fakes is the the hot topic for the last 12 months so all of that but then uh

part of what we're trying to do is to build it into a comprehensive system so actually uh and actually we do integrate uh you know companies blockchain analytics companies uh there's something that we're soon maybe hopefully do something together with T andix so we're trying to build this into one product so that the customer crypto company or financial institution can use the whole platform and minimize their integration costs and maintenance cost and upgrade costs but benefit from the whole platform of uh customers that we have so you started as an identity and verification platform and it's only grown since then very much so yeah great and so um as an anal analytics FM it's very similar to Pierre I think for me

the way I look at it is that analytics is a tool it depends on how you build your compliance framework so we deal with firms we deal with Regulators we deal with law enforcement they all use it slightly differently it's a subset of a tool which is your toolkit for risk mitigation I think where I see it you have the vanilla you have transactions come in you screen it quarantine it you then let it go to the hot wallet you screen a wallet before you send it to to avoid any kind of sanctions risks that you might be uh if you like exposing your your custodian to you do your D diligence that's your uh initial due diligence the ongoing due diligence um but that due diligence I call it either first party third party so that could be who am I interacting with but also a

custodian an exchange can use it to look at themselves have they set their risk tolerance to the right level are they interacting with Bad actors that you don't want to that you set around set out your risk objective that you won't do so again as I say it's a tool and depends on your compliance framework you can use it in different ways the challenge is always um developing the CL compliance framework having the qualified expertise within house um on compliance to address those questions and to to make the correct risk assessment it's not uh easy to to Define skill set inhouse um or to develop it but it's definitely worth it and it's nice to know that there are tools available on the market to support um no panel I guess in 2024 would be

complete without asking a question on AI so um I think IIA you mentioned certainly I guess on the identification and verification part of things I guess deep fakes is very very present for you can you tell us a little bit more about how you are managing just the amount and the sophistication of the of sort of deep fakes that we're seeing now yeah I mean we've actually been quite vocal about this we've seen I think more than 10x rise in you know deep fake attempts uh on on our services and the only way you can fight is to having like a Swiss cheese kind of approach with many layers of protection and so it's trying to catch out people using virtual cameras uh similar backgrounds art digital

artifacts and all of those you know ultimately add up to us being able with very high confidence being able to say whether it's a deep fake or not um so yeah I mean it's really depends on you know developing internal Technologies and also having the flow of of of these uh fraud attempts to be able to um to spot them that's only in the in the Deep fake area we use Ai and machine learning in many other areas it's things like detecting say for example mule networks you know you have real people trying to pass kyc with real documents but actually the only way to catch them is because they're using similar locations the same IP addresses or maybe even the same background like a table or the window behind you for passing those and

that's the only way you can catch it out so actually kind of AI and machine learning is sits behind everything that we do uh throughout the whole process yeah so it's it's very prevalent any other comments on AI generally uh uh yeah we started AI machine learning back in 2017 with for Bitcoin clustering identification uh so but and now we are reinvesting uh we are launching new project because there are so many information that you have to deal with you have to monitor you know dozens of blockchains of and very complex blockchain like Sol for instance so machine learning could be very helpful in terms of how we can identify patterns also for all the cost chain I know when you are moving an asset from a

blockchain to another blockchain we can identify Pat machine learning can can also help us in in the detection and also we're thinking how we can facilitate the um uh the usage of scorain from a compliance officer we can use natural language or we can define a prompt uh I I would like to monitor all the transaction between two wallets in 24 hours for an amount of €10,000 and and directly um the configuration will um The Prompt will build the rules behind oh I love that that would be helpful uh it could be helpful obviously there's a lot of uh of checks and we need to to validate this but it's also U uh something on on Project we are we are

are working on it um so back end on the back end we can improve the data qualification and monitoring and on front end how we can facilitate the usage of the of the product great um I did promise that we would open up to some questions does anybody have um any questions for this compliance panel I think it's the only compliance panel so if you have a question on AML or on travel rule or on anything related to compliance don't be shy okay

okay okay let me make the ice breaker would you say in general that risk management becomes simpler in a blockchain environment because it's so much technology driven it's so much more automated it's a shared Ledger globally uh maybe same standards globally or is it just that new risks arise and uh you know what got simpler now gets more complex again and Net Zero it's the same it's just different or could it really become simpler in the end I actually think we're it's becoming simpler if you use the right tools because there's much more transparency um much more automation so you actually can minimize a lot of the edge cases and focus the compliance officers on dealing with like really

really edge cases as opposed to just manually reviewing millions of you know false false positives so I think actually that should make it uh easier that being said of course that requires learning and implementation of the right tools and setting up properly and I think that's the paradigm shift that that that will take some investment and as I mentioned before it also will take acknowledgement from the regulator side that the tools you use and the proed follow are are acceptable so I think it will come from both ways but it will make for sure much much easier I I would agree that it's an interesting question because I think when you look to the really bad stuff sanction terrorist financing is so much easier and even talking to the UK

Regulators easy to identify where there's bad stuff and then you can stop it and that's the whole point of financial crime mitigation is to stop money going to the really bad people I think on the edges where it's may be to the dark web to ATMs to gambling where you may have a different risk tolerance I think you're right it's about risk configurability as Pier said we need to fine-tune it and you need to understand how best use the tool and I'm sure that's what Pier does that's what we do we talk with the the the firms in terms of trying to help them understand how best to to do that but in the first instance they must understand their risk profile and that's actually one of the most challenging bit what is my risk profile to do with uh doing that once you have then you can walk through how

to set it and how to test it and then how to speak to your regulator a lot of this data is there anyway so the question is how do you utilize it before somebody else utilizes it really great I'd like to disagree a little bit um I think the tools you Lucas the tools are definitely going to make e easier but you know I mean how many of you know what the utxo is okay because I mean to in my opinion stuff like that you probably should know if you work in compliance I mean all the differences between how the account based system versus inputs uh or spending utxos works how the different mixers work so all the knowledge side

you need to build up and I mean that's the main Challenge from what I hear from our customers probably the same for you the main what they really want from me is uh being a head hunter giving them compliance offices who already know crypto that's my number one request I get but can I just counter that as well say I don't think you do need to know what utx somebody might need to but I don't think your compliance team needs to know what your compliance needs to know is what is risk what is your exposure to risk what what's your tolerance to that risk they need they don't need to know the underlying technology they need to understand what the mixer is and what risk that poses but they don't need to know the technology of a mixer so I think they're different levels I mean you need to have

some people who can do investigations in crypto that's where you need experience so I think it's you know horses for courses as we'd say different training different skill sets for front office middle office audit and I think that's how I would um split it sorry I had to disagree with you maybe from a practical perspective somebody who actually is managing a team of compliance people who are learning those skills I would have to say that it definitely is it requires both you need a compliance officer to understand what what are the risk typologies what what is financial crime and that same person has to be able to say okay well it happened three hops back it was six months ago the likelihood that the beneficial owner is the same is XYZ um the sanctions happen actually beforehand

and therefore the risk has been mitigated so it's it's the mix I think you're both right um other questions from the audience gentlemen over here okay yeah yes y so this is a question regarding travel rules here um yeah so what we are observing as is that each solution is more expert of a different jurisdiction and uh today those companies that are operating globally they need to combine multiple Solutions so could you talk about the blockers of building something Global and uh whether you're thinking for example of building

like a Consortium or something excellent question I mean yes the reason in my opinion that we have so many different solution is because they like to be the middleman you know you have a you start a company and then all the travel rule information go to that company that company takes a cut that company controls Network so you have different solution who play that then we actually have an open standard from the open was Association where crazy is the president um is called the tierp so we 21 analytics we Implement TP some sub has TP so you have different players who implement the same protocol uh and that's our goal hopefully have a decentralized ecosystem again but it

will take I think it will stay a mess for years until we have one clear winning standard because there the incentives are so different like it's great to be in the middle if you're the the new middleman in a decentralized world right that's what many of those companies want especially I guess if you have a VC behind you that pushes you to be the middleman and and I would add to that so partly why that happened because What's called the sunrise problem so these regulations kicked into different countries in different times so there are you know local solutions that are specific to a country because they needed to do it because before everything else worked that's the case of Korea Japan other places so uh uh what we're doing about what Lucas is saying is we're integrating other

protocols so I think the next two three months we'll announce at least three Integrations with other protocols so we see us as a solution above the protocol level of course like between our clients there is a built-in protocol because they have to communicate but other than than that we want to be and we are protocol agnostic I think there are uh there are some pools or players that do want to build that Monopoly and I think that will change uh if two thing one of the two things happen either the industry pushes those players to open up because they don't want to be integrating three solutions because they need to talk to vasp globally or what I think is actually more likely that The Regulators will come in and say like with open banking look if you're a provider of uh travel

Ru services or protocol you have to have an open API and that will I think will force ultimately the industry to at least be able to talk to each other then you can choose just based on your geography and service and price and everything and just to add in there so we're not a traval solution but I co-chair a working group in the UK which Lucas and his team are also on on the Travel Rule and we're coming out with good practice guides and I think that sort of the areas of challenges they face is the fragmentation the sunrise Clause the lack of interoperability and as an EXT reggulator I mean I've already seen it in sort of the derivatives region it's a similar kind of thing regulation comes out there's no kind of interoperability to to do that and I think the third thing I I do question this sort of due

diligence inance to what standard due diligence you again you're having fragmentation of due diligence some will have no due diligence some might have the wolburg question a full due diligence which is of a banking due diligence and then this Middle Ground fat the sort of the uh sort of the international standard seter talks about due diligence but there's General due diligence and there's travel rule due diligence what does that mean I mean and then that's what I'm trying to work at least with the UK regulator to try and Define what are the tram lines so that people aren't EXP spending energy when actually the counterparty risk is slightly different when you only have an occasional style transaction for travel rule but your your question is well received and it does reflect I think a

sentiment within the industry um that we um we know that there's a need to continue to interoperate and we are working on that but the reality is that commercially there are some Enterprises that have an interest to keep a ringed fence around the players that they allow within their ecosystem to transmit information um between the counterparties and we have some other great services that are coming up in the market that are really working hard on topics like interoperability and supporting um the the ecosystem we have not toeni here we have 21 analytics um open vasp is an O is an open source version of that but we are we are listening we're working on it and we probably don't have trust in the room I don't know if we do but trust by

coinbase is the main party as far as I'm aware from the the industry that is willing to build and is building a closed closed ecosystem not willing to integrate to anyone so I hope I put a little bit of pressure on them by this uh rent for sure Pelle you had a question yeah maybe not a uh not so much a question but as I just an an additional comment into it as I'm from notaba the the third travel rule uh service provider here today the big issue just to answer uh the question from behind uh on this roll out globally it's not actually so much in the protocols in my point of view because the protocols is just a small technical

detail the hardest thing is actually getting compliance teams to create the workflows and then deal with the differences and complexities within different jurisdiction so this is really what our team has been entirely focused on and with this we have 130 companies live sending millions of transactions a month and all of these kind of things today on because that's where the focus has been on where we are protocol agnostic as well but we actually think the protocols is really the least important aspect of this and we AG I agree trust coinbase is a big issue they're trying to use this as a global market way of controlling the market and locking the other big players out of the

market but that's a it's a separate issue but the big thing to roll it out globally to answer the question of of the previous person it's not about protocols it's figuring out how to build build these tools up for that industry or associations are really important Mark what you're doing in your team is really really good and Chris as well and with Nota Ben co-chairing as well I think the other aspect of the travel rule which needs to be addressed is actually how do you identify which legal entity you're interacting with now it's quite a complicated mechanism of doing so having some kind of legal entity identify that you have in a myid world but if you can replicate that and I know steps are being taken it makes that identification of I'm actually dealing

with this jurisdiction I know what the travel rule obligation is in that jurisdiction rather than having to sort of piece your way through it I think that's another big piece of the puzzle yeah and I would maybe add to what you said is that actually uh what I think people don't realize in cryptos space that to implement travel rule compliance you need to reengineer a lot of your internal fund flow processes so it's not just a compliance tool that you it actually changes the whole uh philosophy right in in in crypto you transa first think after that here you actually have to put a stop on your transactions based on this travel rule information exchange I think well that's what a lot of people are not realizing so with the Mika kicking in at the end of the year I mean

actually now is the time to start preparing for it because firms that do take it seriously and we've been working with some of our clients it takes actually months to reengineer those processes on their side internally and I think just to just to add on it's sort of a speculation here it's sort of it's really simp simple piece of law but it has a big impact in terms of operation the question is where do The Regulators legislators go once it's implemented you're interacting with a ecosystem that may not be a registered person so what do they do decentralized exchanges all these kind of things no one's touching it right now but what happens in three four years time what is your risk so come to back to your compliance framework everything you do needs to be set out in a compliance framework you're

dealing with some things which may not have kyc what does your framework do to be the mitigant to those risks mhm P you wanted to add yeah just want to add that travel rule has been like some kind of copy of what has been done in traditional finance and without understanding really uh the uh the new technology and the philosophy not philosophy in terms of how the technology is used and we can directly transact with with someone and I think this is a big big mistake from travel Ru that has been the like five years I think very long and we see that very difficult to implement and if you if we think now about how we can Implement travel Ru in D5 so you should mean that we would like to have to whitelist all all the the other counterparties first so um I think very

complex I'm happy not to be directly in the DAV Ru industry but I know we have to deal with yeah customers every day because they are lost don't understand protocols the different providers and also how then have to to re rebuild all the processes because all the flows are different I agree with that P and I think I think it's important to to spend some time to demystify um maybe in the last few minutes some of the some of the more sticky topics that we see in the area of compliance we haven't had a chance to touch about defi but we should probably mention a couple of comments I think it's important also that um to note that generally speaking Regulators have been very heavy-handed and giving out guidance um not necessarily in favor

of privacy mechanisms I think um it's important for for me and also for the open vasp Association and for various hats that we all wear that we continue to be um aware of of the importance of supporting um education around privacy mechanisms not all privacy mechanisms are necessarily inherently bad and if you are in the compliance spacee or if you are in the risk management risk assessment space it's important to work closely with your engineers to really understand um what is a mechanism for example that really has the only intent to off escate um the the trail of funds and which privacy mechanisms nevertheless allow for compliance and for visibility of transactions because

there are some out there available on the market so on that note defi what could you say how what would you like to tell the audience about how defi is making strides in terms of AML kyc you wouldn't think but there are actually a lot of ways in which um we are infusing and bringing in visibility and transparency into the defi space I'm happy to go again U so I think the world has changed in terms of the player and whereas before maybe they just didn't think about regulation I think defi pools and dii smart contract they're building it into their protocols now in terms of some kind of kyt at least in terms of Assessments it might be zero proof or kyc so I think they're building it I think regulation has to

catch up with it because I think zero proof is just not quite there yet when I'm looking at the UK law um that I was closely um amending I think the other part of it is looking at um risk exposure of a pool if you're a a big us Investment Bank and you want to interact because you want to have 24/7 transacting and you want to avoid certain costs who are you actually transacting with will the SEC allow you to do that you know that's the questions that are coming in but again there are mechanisms of actually looking at risk of D5 pools and as I said some of the defi the contracts are actually building in some kind of kyt before you onramp into the pools and then when you offramp yeah I think well we as some would be coming at this clearly from the

identity point of view and the kyc which is I think the the biggest question how do you do kyc in defy space and we've spoken to many many um companies that have develop technological solutions to solve this problem whether it's zero knowledge based or soulbound tokens uh the issues that you still need to identify the person first and there has to be some sort of source of trust and secondly how do you make that compliance so for now unfortunately that link is missing and I think there will need to be a kind of a public private discussion on how do you change the rules to uh not break the system right you know it still needs to be you know based on Smart contracts and and decentralized and uh you need to be able

to enable you know compliance there as well so hopefully we'll we'll be able to bring that Gap as as the probably one of the biggest players in the space great thank you Lucas P just we only have one minute just quick quickly as main challenge would be to to to bring all information on Chen because you are dealing with terabytes of information of chain to monitor everything and the challeng how we can bring directly at the level of the protocol of the smart contract or this information but maybe it could be an opportunity uh that directly smart contract defy will Implement um rules regulatory rules within the protocol is not for tomorrow but maybe in a few years we can imagine this kind of implementation but this comes back to private public this is

where regulators and Industry need to discuss to understand how Mitigation Of to that risk is happening I think Lucas just I'd like to say do mixing ask your engineers how it works let them show it how it works it's totally compliant it can be 100% legal it's good for your privacy it's good for the privacy of your customer you should really do onchain mixing it's called an exchange actually that's the best mixer inde all right thank you ladies and gentlemen