A conversation with Rebecca Rettig from Polygon Labs, Michael Mosier, former Acting Director of FinCEN, Jai Ramaswamy from a16z, and TRM's own Ari Redbord.
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In April, the U.S. Treasury Department issued its 42-page “Illicit Finance Risk Assessment of Decentralized Finance," laying out various money laundering risks in the DeFi ecosystem and asserting that the Bank Secrecy Act — the U.S. anti-money laundering regime — applies to DeFi “services.”

- “What factors should be considered to determine whether DeFi services are a financial institution under the BSA?”

- “How can the U.S. government encourage the adoption of measures to mitigate illicit finance risks?”

- “Are there additional recommendations for ways to to clarify and remind DeFi services that fall under the BSA of their existing AML/CFT regulatory obligations?”

- “How can the U.S. AML/CFT regulatory framework effectively mitigate the risks of DeFi services that currently fall outside of the BSA definition of a financial institution?”

- “How should AML/CFT obligations vary based on the different types of services offered by DeFi services?”

In this TRM Talks, TRM’s Ari Redbord is joined by some of the foremost experts on DeFi regulation, including Rebecca Rettig, Chief Policy Officer, Polygon Labs; Michael Mosier, Espresso Systems and former Acting Director of FinCEN; and, Jai Ramaswamy, Chief Legal Officer, A16Z, and former DOJ money laundering chief to discuss the questions posed in the DeFi Risk Assessment.

Chief Policy Officer, Polygon Labs
Rebecca Rettig is the Chief Policy Officer at Polygon Labs, a software development company that builds blockchain scaling solutions and complementary technology, ,where she oversees all global policy matters and regularly meets with policymakers and regulators across the globe.

Prior to joining Polygon Labs, Rebecca was the Chief Legal & Policy Officer at the Aave Companies, a software development company that builds web3 applications, where she handled all legal matters and spearheaded DeFi policy work by developing novel theories of regulation for web3 software technologies, and advocating for positive policies for decentralized web3 technology.

Rebecca served as outside counsel for many years, beginning her career at Cravath, Swaine & Moore LLP, where she handled a variety of litigation matters, including those relating to peer-to-peer file sharing technology. After Cravath, Rebecca was a partner at various law firms, where her practice focused on clients in the crypto and blockchain space, including many well-known DeFi software development companies at their respective Seed Series or Series A stage(s) and beyond. Rebecca represented clients in litigation and regulatory enforcement matters, and provided regulatory advice to clients on decentralized blockchain-based software, capital formation in web3 space, decentralization and DAOs, among other things.

Rebecca serves on the Board of the DeFi Education Fund, a 501(c)(4) that advocates for and educates about sound policy for decentralized finance, and as an advisor to Electric Capital.
In 2019, Rebecca was named one of the top 100 women lawyers in New York by Crain's New York Business.
former Acting Director, FinCEN
Michael Mosier is a co-founder of Arktouros pllc, a niche law firm dedicated to emergent technology, civil society, and risk management. He is also a partner in ex/ante, an early-stage venture fund investing in technology that advances democracy and resilience. He has twice been the first in-house counsel at web3 companies: EspressoSystems, developing configurable private computation, and previously at Chainalysis blockchain analytics.

In public service, Michael served as Acting Director (Deputy Director and first Digital Innovation Officer) of the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN). He also was Counselor (Cybersecurity & Emerging Technology) to the Deputy Secretary of the Treasury; an Associate Director of Treasury’s Office of Foreign Assets Control (OFAC); a Deputy Chief at the Department of Justice’s Money Laundering Section; a Director at the White House National Security Council; and a prosecutor with the Manhattan District Attorney’s Office.
Chief Legal Officer, a16z
Jai currently oversees the legal and compliance functions at Andreessen Horowitz as Chief Legal Officer. He was previously the Chief Risk & Compliance Officer at cLabs, working on Celo, a mobile-first platform that makes financial dApps and crypto payments accessible to anyone with a mobile phone. Jai also spent several years in the financial services industry as the Head of Enterprise Risk Management at Capital One and the Global Head of AML Compliance Risk Management at Bank of America/Merrill Lynch. Before joining the private sector, he served for over a decade at the Justice Department, as a white collar crime prosecutor in the Southern District of New York, at headquarters in the Computer Crime and Intellectual Property Section, and later as Chief of the Asset Forfeiture and Money Laundering Section — a role in which he oversaw the prosecutions of BNP Paribas and HSBC for Bank Secrecy Act, Patriot Act and sanctions violations. Jai has an undergraduate degree in government and economics from Harvard University, a law degree from the University of Pennsylvania Law School and a doctorate in social and political science from Cambridge University, U.K.
Global Head of Policy, TRM Labs
Ari Redbord is Head of Legal and Government Affairs at TRM Labs, a blockchain analytics company. Prior to joining TRM Labs, he served as a Senior Advisor to the Deputy Secretary and the Under Secretary for Terrorism and Financial Intelligence at the United States Department of Treasury. In this capacity, he worked with teams from the Financial Crimes Enforcement Network (FinCEN), Office of Foreign Assets Control (OFAC), and other Treasury and interagency components on issues related to sanctions, the Bank Secrecy Act, cryptocurrency, and anti-money laundering strategies.

Previously, Mr. Redbord served as a Senior Assistant United States Attorney for the District of Columbia, where he investigated and prosecuted cases related to cryptocurrency, terrorist financing, sanctions evasion, export control, child exploitation and human trafficking. He has received numerous awards from FinCEN, the FBI, and the United States Attorney's Office, including the Attorney General's Award for leading an interagency task force dedicated to prosecuting those who abuse and exploit children.