




Feb 1, 2021 - 45min
Unhosted Wallets and the Future of Cryptocurrency Regulation
The concerns swirling around unhosted or self-hosted wallets and FinCEN's recent notice of proposed rulemaking (NPRM) on the topic have captivated and consumed the cryptocurrency industry and regulators around the world. Unhosted wallets provoke questions of privacy and security at the heart of the promise of cryptocurrency. TRM Talks with Former DOJ Money Laundering Chief and Current Celo Compliance head Jai Ramaswamy, author of How I Learned to Stop Worrying and Love Unhosted Wallets, and FinCEN Deputy Director Michael Mosier on unhosted wallets and the challenges of threading the needle between privacy and financial integrity in crypto regulation.
About the guests

Jai currently oversees the legal, compliance, and government affairs 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.

Michael Mosier co-founded Arktouros, a boutique law firm of former senior officials and in-house counsel dedicated to emergent technology and civil society. He twice has been the first in-house counsel at tech companies: Chainalysis (blockchain analytics) and EspressoSystems (configurable privacy & cross-chain composability). In public service, Michael served as Acting Director of FinCEN (the U.S. Financial Intelligence Unit & administrator of the Bank Secrecy Act); head of Sanctions Compliance & Enforcement at Treasury's Office of Foreign Assets Control (OFAC); Deputy Chief in the Department of Justice's Money Laundering & Asset Recovery Section; and a Director at the White House National Security Council.
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