Mica & TFR: An open letter to EU representatives

Ultimate
3 min readMay 5, 2022

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Foster open innovation, job creation, privacy and financial freedom through sensitive regulation of crypto technologies.

Web3 and DeFi

Dear politicians,

the >2,000 signatories of this letter represent a significant part of the web3 community. We gathered some of the leading innovators, companies and projects behind this initiative.

We are sharing an open letter with you, our democratically elected representatives. We’d like to create a forum for an open, continuous and productive dialogue around the upcoming Markets in Crypto Assets and Transfer of Funds (MiCA, TFR) and other regulations targeting digital assets and their underpinning technologies.

We are aware that most European policymakers did not have any interactions with our community or if so — mostly negative ones. The signatories of this letter are condemning the partially provocative, threatening and misplaced comments of some individuals on social media. Our intention is to start a humane and respectful interaction around the topics we deeply care about.

We acknowledge the efforts already undertaken up until this point. Our community is 100% aligned with the goal of turning Europe into a frontrunner of web3 innovation to attract talent and capital. We appreciate the intentions and goals behind the MiCa framework. Our industry and techno-social movement needs clear regulations and consumer protection to flourish. We share the desire to limit technical failures, financial fraud and other criminal activities while protecting civil liberties and data sovereignty of EU citizens. Crypto is a frontier technology at the vanguard of the global innovation curve and we share your ambitions to turn Europe into a crypto powerhouse to attract world class talent and capital.

Before discussing the vast potential of crypto technologies (A.), clarifying common misconceptions (B.) and suggesting alternative policies (C.) more granularly, we’d like to summarize our core suggestions for a more balanced regulatory approach around MiCa and TFR:

(1) The travel rule should not be applied in cases of CASP to non CASP transactions. Regulation should not go beyond the FATF guidance.

(2) Even if the travel rule is applied in cases of CASP to non CASP transactions a privacy preserving risk based approach (risk score of public key addresses) should be applied over the approach of collecting personally identifiable data.

(3) Even if a risk based approach is not pursued, a privacy preserving method for identity verifications should be used (Digital ID, SSI, zero knowledge).

(4) No transactions should be reported to the authorities unless there is a clear indication of fraudulent or criminal activity. This should equally apply to transactions below or above the de-minimis EUR 1,000 threshold.

(5) Only transactions which are indicative of financial fraud or other criminal activities should be reported to authorities. Broader reporting obligations would discriminate crypto users and drown the authorities in meaningless transaction reports with the effect of obfuscating actual crimes.

We’re happy to discuss and explain each and every topic in detail. We want to make Europe the best place on earth to start a business in crypto.

Please read the full paper with all details and all signers in the PDF below.

Please share, like, repost and distribute individually.

Yours sincerely,
the web3 community

Contact: wagmi@unstoppable.fi

Unstoppable Finance is building a DeFi Super App with the mission to become the universal consumer gateway to Web3. A multi-chain, fully non-custodial wallet that makes investing into web3 truly mass-ready. Say goodbye to complexity. Say hi to DeFi. Launching soon.

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Ultimate

Building the Ultimate DeFi wallet to bring DeFi to the masses! Live at ultimate.app