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TRM Talks: Unhosted Wallets and the Future of Cryptocurrency Regulation

Feb 1, 2021 - 45min

EPISODE 5

TRM Talks: Unhosted Wallets and the Future of Cryptocurrency Regulation

With Jai Ramaswamy,  and Michael Mosier,  and  and

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 Ramaswamy
Andreessen Horowitz

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
Arktouros PLLC

Michael Mosier is a co-founder of Arktouros PLLC.  He has twice been the first in-house counsel at emergent technology companies:  Chainalysis (blockchain analytics/investigations) and Espresso Systems (cross-chain composability & configurable privacy).   He has served as an independent board director and chair of the Government Security Committee for an artificial intelligence and autonomous vehicle systems public company operating under a Committee on Foreign Investment in the United States (CFIUS) National Security Agreement.

In public service, Michael was Acting Director, Deputy Director, and the first Digital Innovation Officer of the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN), where he worked closely with federal, state, and international counterparts on the development and implementation of policy and regulation, as well as launching digital identity and privacy-enhancing technology initiatives to advance personal sovereignty and opportunity.  He also was Counselor (Cybersecurity & Emerging Technology) to the Deputy Secretary of the Treasury.

Previously, Michael served as Associate Director and Acting Deputy Director of Treasury’s Office of Foreign Assets Control (OFAC), leading the Office of Compliance & Enforcement and Office of Sanctions Policy & Implementation.    

Before Treasury, Michael was a Deputy Chief in the Department of Justice’s Money Laundering Section, where he created and led the Special Financial Investigations Unit.  He also served at the White House National Security Council as Director for Transnational Organized Crime.  

Michael has been an adjunct professor (Advanced Evidence for Trial) at Georgetown University Law Center and began his public service as a prosecutor with the Manhattan District Attorney’s Office.

Michael is also an investor with ex/ante, an early-stage venture fund investing in technology that advances human agency and democratic resilience.

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