A digital asset intermediary is an entity that facilitates transactions or provides services related to digital assets on behalf of others. This includes cryptocurrency exchanges, custodians, brokers, and certain lending platforms. These intermediaries often hold user funds or manage private keys, connecting users to the broader digital asset market.
Context
The regulatory treatment of digital asset intermediaries remains a critical area of policy development globally, with jurisdictions seeking to define their roles and obligations. Debates often focus on licensing requirements, anti-money laundering compliance, and capital adequacy standards to mitigate systemic risk. The balance between fostering innovation and ensuring consumer protection continues to shape the operating landscape for these entities.
The proposed regulatory framework fundamentally redefines permissionless finance, forcing protocols to choose between US market access and core decentralization principles.
The proposed intermediary classification would fundamentally re-architect DeFi, mandating KYC/AML and broker-level compliance for nearly all US-facing protocols.
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