The Death of Crypto Privacy? with Jake Chervinsky

Hey Bankless Nation, welcome to another episode of State of the Nation. We've got a meaty subject to dig into today with a crypto legal mind, Jake Travinsky. Our question, the top of mind question, I think, for crypto is have we seen the death of crypto privacy? Recent OFAC uh sanctions against Tornado Cash, we'll get into that. The arrest of an open source developer. We'll talk about what that means. Is code speech? A lot of questions that we've had over the last couple of weeks in crypto and at Bankless. And what we really wanted to do was bring Jake into the episode, who is a legal mind and can give us some legal commentary on these things. Of course, he'll be first to disclaim that none of this is legal advice and we'll allow him to do that. But uh he is one of our favorite crypto lawyers and thinks about these things deeply and has a great sense of of where things are going. Uh, David, what else are we in store for in this episode?

There's a we've had these conversations both on the weekly roll-up and in actual other podcasts, and other podcasts have done this as well. It's talk about tornado cash and the future of crypto privacy. And I we're not gonna begin at the very beginning because that conversation has definitely been had. I think we really want to fast forward and see how this plays out and see where this all goes when we kind of go to this logical conclusion. And there's lessons from history to pull from. And I think that's really where we want to start is we can actually go back before the advent of cryptocurrency and go back to cryptography and take a leaf out of the lessons of history and kind of extrapolate from there. Like if we won these battles before, can we win them again? Uh and overall, there's also just the general landscape of regulation in crypto. Like, what what is the Congress? What's the state of Congress in the White House and in Capitol Hill and the state of crypto regulation there? Uh and so we will get into all of these subjects and more with Jake Travinsky.

David, I'm gonna start with the question I always ask in these episodes, what is the state of the nation today, my friend?

The state of the nation, Ryan, is lawyering up. We are lawyering up right now. And so this is the state of crypto in this present moment. As we have some legal fights ahead of us. And so we are going to we're consulting with our lawyers. Although Jake Travinsky is not your lawyer, nor is he ours. But he's still a lawyer. And so we are going to uh talk to Jake as uh the resident lawyer of crypto Twitter what we need to do to move forward in this industry.

Okay, who knows uh legal s legal could be a public good, but we are hitting the gym today and lawyering up uh and getting ready for this privacy battle ahead of us. Guys, we're gonna get right into the episode with Jake Travinsky. But before we do, we want to thank the sponsors that made this episode possible. Hey guys, welcome back. Oh, digging into the subject is crypto privacy dead. We have Jake Travinsky on to help us answer that question. Jake is Crypto Twitter's favorite lawyer. I think he's Bankless's favorite lawyer, maybe, although we're credibly neutral, okay?

Favorites.

We we don't have too many favorites. Every lawyer we have on Banklist is our favorite, but Jake's our most favorite. He's the head of policy at the Blockchain Association, where he and many other legal minds are actually working to defend crypto against unjust laws and policies. This is the legal layer of our fight. He's been on Banklist many times, of course. And uh, Jake, I know you're gonna ask, so I want you to uh be able to do the disclaimer up front because you are definitely not our lawyer. Any anyone who's listening to this, Jake is not your lawyer. Uh, what do you want to uh disclaim before we get into the episode?

Well, you covered it pretty well and thanks for having me back. It's always great to talk to you guys, although usually it's uh, you know, under uh less than optimal circumstances that we get together. But

no, hey, look, that's what I'm here for. And it's like it's an honor to be considered uh, you know, in the conversation uh for you know, first among equals of the lawyers who come on here. So I appreciate that. Um, no, but I mean, I guess the quick disclaimer, as you said, is I am a lawyer, but I don't represent you guys or anyone else who's listening. So we may discuss some legal issues, but nothing that I say is intended as a legal advice. And if anybody out there has concerns about what they should be doing in order to comply with the law, then they should, you know, find their own lawyer to give them personalized advice. Um, so that's that's all there is there.

Well, you know we're a little bit scared or something bad has happened, as you said, Jake, because you're on the episode and David, uh, I know you've got the details to maybe speedrun, but we are talking of course about OFAC sanctions, Tornado Cash. Could you just speed speedrun uh what's happened recently and uh we could do maybe a recap with Jake real quick for for folks who've missed it.

Yeah, and like I said in the intro, the this topic has been around the content sphere for a while now. And so we're gonna speedrun through some of the some of the beginning stuff and get through some of the further along parts of this conversation. And so, Jake, I just want to kind of highlight some of the high-level themes of this whole entire episode and just make sure that we're on the same page about what the big questions are. Uh so the first one, and obvious, is Tornado Cash is now banned for US citizens, which really brings up the question: does the rights of OFAC to prevent North Korea from accessing money come before the rights of individuals to access privacy tools? Are OFAC rights superior to individual rights? I think that's the big one big question that we have. And also, you know, along with that question is why should we lose our rights so that OFAC can sanction bad actors? I think that's one big theme. Another big theme is that this whole incident is unique because Tornado Cache is not an entity or a person, it's a smart contract, which begs the question: is it even legal to ban a smart contract? Um, so that's one big theme as well. Uh Alex Persov, uh the Tornado Cache developer, was arrested in the Netherlands. Is it now illegal to write open source software? Uh is open source code illegal now if it's used by nefarious actors? That's another big theme. And then perhaps the last one is now the industry is really taking a look at what else is risk at risk in DeFi? Like what else is under perhaps the the under the crosshairs of other regulatory agencies and at risk of censorship? Is this is this just the beginning? And if so, where does this end? So these are the big themes that I see. I'm wondering if there's any others that you know that are floating around in your brain or anything you want to like double tap on.

Uh no, look, I mean, those are the big questions, not just of the day, but I think the big questions of crypto in general, right, as sort of a movement. I think, you know, in a way, this is a perennial question. How do we balance the interests of national security against the individual rights of citizens? And it's a hard question, and it's it's one that we've struggled with long before crypto came up. Um, and it's one that I think we'll be battling for a long time. I think the only other thing that we should maybe touch on, in addition to I think those sort of philosophical concepts, is what do we actually do, right? As a community, as a group of builders, as advocates, how can we try to advance the interests of civil rights and the rights of US persons to use these permissionless technologies in a way that isn't going to get us in even more trouble with policymakers who, frankly, don't always agree with us about how we rank the priorities when we deal with these issues. So no, I think the list you uh you gave is exactly the right uh right set of topics for us to be thinking and talking about.

Jay, can I ask you just base level question? Like, were you surprised by this course of events? Like, because I know you you're thinking about all sorts of intersections between law and uh and crypto, uh, and then suddenly we've got smart contracts on the OFAC sanction list. But did this surprise you?

Um, yes, it did actually. And I I say that uh fully realizing that that might mean I wasn't doing my job as well as I should have. Because look, I'm, as you said, I'm the head of policy for the blockchain association. My job is to represent the interests of our members, which cover the full range of the crypto industry here in the US, with respect to what is coming down the pipe uh from government. And the issue of privacy is one that we talk about and think about all the time, because one of the issues that the government tends to have with crypto is the perception that it can be used for illicit activity more easily than the traditional financial system or traditional financial instruments like cash. So we spend a lot of time thinking and talking about this illicit finance issue and how we can get policymakers to understand that the benefits of crypto outweigh those risks. And so OFAC is one of the agencies, one of the departments within the Treasury Department that we think about a whole lot. And sanctions is something that's on our radar. Nonetheless, I would tell you that I did not imagine that OFAC would sanction a piece of software as opposed to sanctioning persons or entities or their property. I knew that, and all of us have sort of known that tornado cash has been a concern for anti-money laundering regulators and for law enforcement, right? Folks have identified uh the use of tornado cash by the Lazarus group, which is the hacking group affiliated with North Korea for a long time. So we knew that this was sort of an issue that the government was looking at. But the idea that they would go after the software itself was a huge surprise to me, and I think left a lot of people uh who you know work on these issues all day, every day, pretty surprised.

One thing that uh strikes me is I I sort of thought that we were okay with privacy uh blockchains in the US because we've had Zcash for like ever.

Right. And I thought, okay, the first action we might see against OFAC or or Treasury or anyone in government might be the delisting of assets like Zcash asset, the Zek asset from centralized exchanges. We haven't seen any of that yet. And Zcash has been, you know, fully private blockchain that's been in production working for a while. So this was not on my radar either, Jake. And I'm wondering if you think it it just rose in importance, is because, like, well, North Korea wasn't using Zcash in order to uh do some illicit transactions, do some kind of money laundering and cover their tracks, but they were using Tornado. So that's when government picks its head up and says, oh, this thing, like, this thing cannot be allowed to exist. And then they went through the process of sanctioning smart contracts. What do you think?

I think a few things. It's, I mean, first of all, it's a really good point. Tornado Cash is one tool that allows people to get privacy in the crypto ecosystem. It's not the only one by far, and it's not the first one, right? We've had other privacy technologies for much longer than Tornado Cash, which launched in 2019. I think here's maybe one way to understand this. And I'll preface this by saying it's hard to sort of psychoanalyze policymakers from a distance. So I always hesitate to sort of read their minds. So I am I'm speculating a little bit here. But I think, first of all,

Monero, more so than anything else, Monero and also Zcash, but other privacy preserving technologies, have been on the minds of regulators for a long time. They haven't taken such aggressive action against any of them as they have here with Tornado Cash by literally making it illegal for US persons to use the technology. But they have, at least reportedly, put pressure on centralized exchanges to delist assets like Monero to limit the ability of people to access those assets. For example, the Department of Justice put out a framework related to cryptocurrency investigation and prosecution maybe one or two years ago. And they talked about what they call AECs, anonymity enhancing cryptocurrencies. And basically what they said to exchanges in that public guidance was you should think very hard before you list any of these AECs, because it may be impossible for you to comply with your legal obligations if you have these things, you know, these assets listed. So it was kind of a um a light but very clear and not so subtle message to exchanges that we do not like this technology that provides privacy to any people who can get access to those assets. The thing is with Tornado Cash.

I wonder, and this is where I'm gonna speculate a little bit, I wonder if

OFAC was really trying to signal a consequential shift in policy that privacy technology is not allowed, or if there's some other explanation for why this happened. One of them is what you mentioned. North Korea was using this tool quite a lot. Not the majority of use, right? All of the stats that we have about the use of Tornado Cash say North Korea accounted at least recently for maybe 30 to 40% of volume through Tornado Cash. That's a lot, but it's it's still a minority of total volume, right? The majority of volume in Tornado Cash was legitimate. Nonetheless, that's a lot of illicit use. And I think that.

puts tornado cash just as a factual matter in a different category from something like Zcash where you don't see that type of of abuse by bad actors. The other thing is, um, and this is sort of inside baseball in DC, but

Typically, when you have a pronouncement of a big policy shift, it comes from the people who are really in charge of making policy, right? In this case, we would expect it to come from perhaps the director of OFAC or the deputy director, you know, someone who's really working on this within OFAC. Instead, the announcement was made by political appointees, by Brian Nelson, who is the under-secretary for terrorism and financial intelligence in the Treasury Department. That's a position that is nominated and appointed by the president. And then also by Secretary Blinken, who's the Secretary of State, not even related to the Treasury Department, that made the decision. And I think what this signals is that this might have been more of a political decision than it was an attack on crypto, right? It may be that someone on the National Security Committee in the Biden administration said, hey, we need to signal that we are tough on North Korea. What options are legally available to us? And they were presented with a menu of potential options. And one of them was sanction Tornado Cash. And in sort of a hasty manner, that was the solution that was picked. So I know I'm going on and on here, but I think the point is we don't know yet what the government's view on privacy preserving technologies broadly are. And there's some weird things about the fact that Tornado Cash gets sanctioned here and not any other technologies that signify, you know, maybe this slope isn't quite as slippery as we think. Maybe privacy isn't totally dead. This is just, you know, sort of a one off situation that we need to figure out how to address.

That's definitely some of the conclusions that I've been thinking about that it's it is obvious that there are there are other privacy tools out there, as you said, uh that are not untouched uh in this present moment. And that there's no real coincidence that it was Tornado Cash and North Korea. North Korea really seemed to be a having a centerpiece. Tornado cash, it's definitely used for like petty money laundering too, but that really wasn't a centerpiece of this whole story. That wasn't really, didn't really come up in any of the verbiage used by OFAC or any of the surrounding uh political spheres unless unless I'm missing something. And now there's uh this conversation of Monero, which uh if you're telling me that like the previously regulators went over to exchanges and it was like, yo, yo, yo, be be careful about listening Monero, tells me that they're actually pretty technically adept in understanding Monero and that level of privacy and what it means to, at least loosely what it means to have base layer privacy. But they didn't ban Monero based off of its usage, they banned Monero or didn't ban Monero, they

I don't know what you would call it, they uh v communicated s uh suggesting restraint of using Monero to from these exchanges based off of the technical properties of Monero rather than who is actually using these things. Now there's uh and and this is w goes back to something that Mirai and I have said about just like the concept of privacy, is that privacy is actually better suited as an application rather than a layer one chain. Uh because that's and that that has actually, I think, shown up in this particular case where you combine the liquidity of Ether or the liquidity of USDC inside of Ethereum with the application of Tornado Cash, which instantiates privacy into those assets. And all of a sudden you have a really strong use case that uh North Korea latched on to. And so that makes me think that really this the battleground for privacy is actually going to exist in the actual app layer where you combine the highly illiquid assets in in DeFi, you know, DAI, USEC, Ether, uh, with very strong cryptography that you would find in Tornado Cache. But I also want to like bring up this conversation of like Aztec as a layer two, Aztec, another privacy tool on Ethereum that uh has just as strong as security properties and privacy properties as Tornado Cache, if not better, but not used by Tornado Cache. And so I I'm wondering, Jake, just like what what you're thinking about like the peripheral application services that are are in uh adding privacy that aren't another layer one blockchain. Something that that gives you privacy on any asset uh that exists on Ethereum that isn't like another layer one blockchain like Monero, like uh that's not being used by North Korea. Like, how at risk do these players seem to you?

It's a great question and it's a great point. I mean, the short answer is I don't know. And I think one of the big challenges of this decision about Tornado Cash is it raises this question of at what point is OFAC going to decide that a neutral tool is being used too much by the bad guys that nobody gets to use it anymore, right? We need to sort of understand where the line is. I mean, like I said, Tornado Cash.

Was about 30 to 40%, according to the numbers we have, used by North Korea. That's still a minority. What if it was 25%? What it was, what if it was 20%, right? At what point does North Korea get to decide, hey, if we use something too much, then nobody in the United States is going to get to use it anymore? I don't think we want to empower one of our largest foreign adversaries with the ability to shut down any technology in the US just by deciding to use it a lot, right? What if they decide that they want to use Aztec a whole lot? Does that mean that even though uh, you know, no legitimate uses of Aztec have changed, right? There's still people who are using it for all of the good reasons why we want privacy, does the fact that North Korea is using it mean that it has to get banned? I think that's not uh you know a world that we can live in. I just one other point though.

Um

I think it's important to to note to your point about

Government having a pretty good, sort of sophisticated understanding of the technology, that I think that they do understand quite well that they cannot shut down Ethereum and they cannot shut down the Tornado Cash smart contracts. So I think people who are coming out and saying, look at these stupid policymakers, they don't understand that this decentralized technology is out of their reach. I don't think that's what they're thinking. I think what they're thinking is, although we can't shut these systems down, what we can do is limit access to them, thereby limiting how effectively they can be used to launder money or carry out illicit financial activity. And I think in the Tornado Cash context, given how Tornado Cash works, in theory, limiting US persons from using Tornado Cash will limit the anonymity set, which means it will be easier for the government to identify bad actors who are using it, right? The fewer legitimate uses there are for tornado cash, the more effectively they think that they will be able to identify the bad actors. So it's not totally.

crazy that they would have made this decision. It's just that it, in my mind anyway, violates sort of the core tenets of what we are trying to build in crypto, which is a a permissionless, open, inclusive financial system that anyone can use, right? A neutral tool like any other.

And just to drill down on that, Tornado Cash and Tornado Cache users achieve privacy by pooling themselves all together. Uh and so if you take out all of the legitimate actors out of the pool, you only have nefarious illicit actors left in the pool. And so it doesn't really matter that if you put your ether through Tornado Cache, if the only people putting their ether through Tornado Cache are like North Korea drug runners and like tax evaders, like, sweet, you're just commingling all of your ether or die or whatever with all the other illegal people of the world. Uh and so the this just like much easier to trace down uh these transactions when everyone going through these things is illegal. But it still begs the question is like, sweet, now we don't have any privacy tools as like good, honest people of the world. And I I'm wondering like this the outcome of privacy and crypto, I don't think there's any way around this. As in, if we have privacy and crypto, we are by definition commingling honest users who just want their basic freedoms and privacy with money launderers, drug runners in North Korea. Like, I don't really think there's any alternative outcome. So naturally, this must end up in the courts, right? If that if that is a uh a premise of an argument, is like, yes, in order to have privacy, you're putting honest people right next to North Korea. The only way that we really have like clarity on this is if we actually like make that explicit and also win that, win that outcome that we're allowed to do this in the courts. Would you agree with that, Jake?

I I think that's right. I I guess two points on that. One is

I think there is a false belief that using Tornado Cash is commingling your assets with the assets of bad actors. That's not technically true. And I think as a legal matter, this is a really important and significant distinction, right? If we view the pool as having many participants, all counterparties of each other, then indeed it's not unreasonable to say it is illegal for you, David, to put your assets in Tornado Cash because you are transacting with a North Korean entity. The North Korean entity is sanctioned. It's illegal for you to transact with that party. If that party is your counterparty in the pool, then sure, the US government has a legal justification for banning access to the pool. That's not really how Tornado Cash works. And in fact, this is an issue that crosses many different types of DeFi protocols that use pools, whether it's an AMM in a decentralized exchange protocol or a pool in something like Compound or Ave, right? A borrowing protocol.

I think it is factually incorrect to say that all users of this pool are counterparties of each other. When you supply assets to Tornado Cash, you withdraw your own assets. You are not actually mixing your assets with anybody else. The fact that there are other users creates an anonymity set, but it does not mean that you are transacting with a sanctioned party. And I think as a legal matter, that's a really important distinction, maybe a bit of a sort of wonky one, but I wanted to at least say that. So my my intent.

Ten ether going into Tornado Cache is the same ten ether that I withdraw, as in that the buckets of water do not get poured into the same bucket.

Exactly. You are not getting North Korean ether, and the North Koreans are not getting your ether. That is fundamentally technologically not how something like Tornado Cash works. And I think that's that's pretty important. Um

the the

Yeah, and I forget what the second thing I was gonna say, so I'll let you know if I remember that.

Well, yeah, so the what's important is uh this is similar to how Zcash works too, right? The the more kind of users of Zcash, the stronger the the the pool for anonymity, right? It's not, you know, the the this is a a central premise of some of these um zero-knowledge privacy solutions. And so back back to what David was saying is like if OFAC doesn't want US citizens to go use Tornado, which by the way was like a fantastic tool for protecting your privacy on chain. I don't know of any other tool that allows us to do that. So my question to Treasury is cool, what do you want us to use then? What should we use? What's legal to use instead, Treasury? Are you saying we are not as American citizens entitled to privacy of our transactions on chain? Is that what you're saying? Because it sure feels like that if you start banning the only practical privacy tools that uh we we could actually use.

Yeah, um

and that reminds me of what I was gonna say before, and and exactly to that point. Um, do we have to end up in court over this issue, right? Is there some reasonable

I want to say compromise, but really what I mean is common ground that we can find with policymakers who have these concerns about national security and bad actors at using the crypto ecosystem that will still preserve our privacy without us having to run to court. And I think the answer to that question is maybe, I'm not sure yet. But I think we have to explore those options. So let me say a couple of words about David's question does this end up in court so that we can protect our privacy? I think

The answer is probably yes, ultimately. And here's why. We've always struggled, at least in the last 50 years since the Bank Secrecy Act was adopted in the 1970s. And we've talked about the Bank Secrecy Act on prior podcasts, so I'll skip sort of the background about that. We've struggled with this question of warrantless surveillance, right? How much will we allow the government to intrude on our privacy for the purpose of detecting and prosecuting bad actors? And in the digital era, the pendulum has swung very far in favor of government surveillance and against individual privacy. And the problem there is.

The idea of privacy is we should have the right of financial privacy, even though bad actors will also have that right. This is sort of like a core fundamental part of our Fourth Amendment right to privacy, right? The Constitution basically says the government cannot search your persons, houses, papers, and effects without a warrant. And that's true for bad guys too, right? The government can't just come barging into your house without justifying that search.

even if you might be doing something illicit, right? The right to privacy matters more than the right of the government to surveil everything that we do to catch every single, you know, uh person who might be violating some law. And I think that

crypto has presented a a a really um

A really stark challenge for us because, on the one hand, we are now dealing with a disintermediated financial system.

This is very different from how anti-money laundering and counterterrorist financing laws have worked in the past. They typically deputize intermediaries in the financial system, right? Banks and money transmitters and other institutions that are processing transactions for us and forces them to surveil us on behalf of the government. It deputizes intermediaries. Here we're building a disintermediate mediated financial system. There are no intermediaries to play that role. That's a huge challenge to the way that these anti money laundering or counterterrorist financing laws work.

On the other hand, however, government has been pretty comfortable with crypto for the last 10 years because the blockchains are public and they can surveil transactions anyway. They don't need an intermediary within the crypto ecosystem to do that surveillance. They use the intermediaries at the edges, the fiat on-ramps and off-ramps, to KYC, right, to identify all of the participants in the ecosystem. And then using a forensics firm like Chainalysis or TRM Labs, they can trace all of the transactions as they move through the crypto ecosystem. So even though it's disintermediated, they're not really losing anything. Tornado Cash changes all of that, right? These privacy-preserving technologies fundamentally challenge the ability of government to continue with this warrantless surveillance program that they've come to be very comfortable with and that they want to continue. And that I think is where we may end up having to go to court to fight this battle, to say, even though you've enjoyed the ability to surveil everyone's transactions for the last roughly 50 years, that's just not going to happen anymore. And we need to come up with new ways to do law enforcement, right? To detect and prosecute the bad guys who make no mistake, we want to be detected and prosecuted and punished, right? We're not supporters of the North Korean dictator here. It's a brutal regime. They are our foreign adversaries for good reason. We want to undermine and work against them, but we can't be sacrificing our privacy, you know, just in the name of doing that.

That's uh warrantless search is a great name for that. If we if we don't have privacy on uh the base layer blockchain, that's essentially what we're subjected to. And I guess what's interesting about this is um the US and other governments have had the ability to uh do the enforcement through intermediaries to date, through crypto exchanges. Even something like Zcash or Monero. What's interesting about Ethereum is it is an economy and a financial system unto itself. So what I find interesting as David was describing earlier, of like um like North Korean shuttling money to Tornado Cash, is they didn't go through an exchange first and buy their ETH in order to like shuttle it through Tornado Cash. That that was actually like funds procured through a hack, likely the Ronan sidechain or like other multi-million dollar hacks. So it completely ratted around and bypassed the centralized intermediaries. And I wonder if USGov and Treasury is just like, oh shit, wow, they could do this? I like I thought we were comfortable with our posture on crypto, and now they're realizing that um what can be like the centralized intermediaries can be completely bypassed, and so they are just spinning some stuff out as a result and seeing where their power lies. Something like that could have happened.

Yeah, I totally agree. I think I guess two things. One is uh Ronin is exactly the right um event to point to as I think a major contributing factor, not just in this decision to sanction Tornado Cash, but in a political, if not a foreign policy shift uh in how the US government views crypto.

North Korea

Is a rogue nation state, right? It's one that everyone in the world is quite concerned about. And in terms of US foreign policy, there are really three countries that the foreign policy establishment in DC is most concerned about. Maybe four. That's Russia, Iran, China, and North Korea, right? So there is a lot of thought given in DC to how do we address the threat from North Korea, specifically the threat of them developing a nuclear program, right? No one is sure whether Kim Jong-un is crazy enough to use a nuclear weapon if he feels like it's necessary in order to stay in control of that regime. And typically the way that North Korea has been prevented from developing nuclear weapons is number one, by trying to prevent other countries from giving them aid. This is a big problem with China right now, which has taken sort of a supportive view toward North Korea. But secondly, by cutting off their sources of funding, right? And this gets back to the purpose of sanctions in the first place. The purpose of sanctions is to deprive a foreign adversary or some other foreign actor who's doing something the US government doesn't like from having access to the US economy and to the extent possible from having access to the global economy to starve them for money. And the Ronin hack was a very material amount of funding for North Korea. There's no way around that.

Hundreds of thousands like sorry uh hundreds of millions of dollars we're talking about.

I think it was six hundred and forty million dollars.

Six hundred and forty million. And this is like so putting on your national uh defense, national security cap, you're like, we had choked North Korea off of the global economy, and now because DeFi was sloppy, with one hack, suddenly they've got six hundred and forty million dollars to go fund weapons uh against uh you know the US and its allies.

Exactly. And that's the second point I was going to make, which is all roads lead back to DeFi, right? We love DeFi. We see all of the amazing benefits and features of it. We see how it's a revolutionary upgrade on an analog financial system. What the government sees is this is financial infrastructure that North Korea can use. And it was somewhat hypothetical until something like the Ronin hack. And if you add up the Ronan hack with others that the Lazarus group pulled off, I think they made over a billion dollars in one year. That's like 10 times more than they had made in the year previous from all illicit financial activity that they were doing in all contexts around the world. So this is material. And I think it's important to recognize that, just to understand where the Treasury Department is coming from when they sanction something like Tornado Cash. It's not necessarily an attack on software developers' free speech rights or on our financial privacy rights. It might be, and we have to take that threat very seriously, but we also have to understand what the sort of well meaning, valid motivations are behind that decision as well.

And yet we have an open source developer who has also been arrested

as a result of all of this, which is kind of some mixed signalling, uh, Jake.

I it's it's either mixed or um or entirely confused and unintentional. And I I think um