{ "name": "The on-chain privacy landscape, mapped", "description": "A neutral, sourced directory of the on-chain privacy field: the teams and technologies building confidentiality across FHE, MPC, garbled circuits, ZK and TEE, and the regulation that governs them.", "url": "https://www.sodalabs.xyz/privacy-hub", "license": "https://creativecommons.org/licenses/by/4.0/", "attribution": "Soda Labs (https://www.sodalabs.xyz)", "dateModified": "2026-08-11", "corrections": "https://www.sodalabs.xyz/contact", "technologies": [ { "code": "MPC-GC", "label": "Garbled-circuit MPC", "definition": "Several parties jointly evaluate a function over encrypted inputs using garbled circuits and secret sharing, so no single party ever holds the plaintext.", "sameAs": [ "https://en.wikipedia.org/wiki/Secure_multi-party_computation", "https://en.wikipedia.org/wiki/Garbled_circuit" ] }, { "code": "FHE", "label": "Fully homomorphic encryption", "definition": "Computation is performed directly on ciphertext, so results decrypt correctly without the data ever being decrypted during the computation.", "sameAs": [ "https://en.wikipedia.org/wiki/Homomorphic_encryption" ] }, { "code": "ZK", "label": "Zero-knowledge proofs", "definition": "One party proves a statement about hidden data is true without revealing the data the statement is about.", "sameAs": [ "https://en.wikipedia.org/wiki/Zero-knowledge_proof" ] }, { "code": "TEE", "label": "Trusted execution environment", "definition": "Computation runs inside an isolated hardware enclave whose contents the host operating system cannot read, under a hardware-trust assumption.", "sameAs": [ "https://en.wikipedia.org/wiki/Trusted_execution_environment" ] } ], "market": [ { "slug": "bubble", "name": "Bubble", "summary": "Bubble: Enterprise confidential finance. Built by Soda Labs. Technology: garbled-circuit MPC.", "kind": "project", "category": "Enterprise confidential finance", "by": "Soda Labs", "technology": "MPC-GC", "sodaBacked": true, "description": "Privacy-preserving portfolio management and confidential transactions across any L1, L2 and cross-chain operation. Garbled-circuit MPC with NIST-standard AES-256, measured at roughly 500 confidential transactions per second sustained, end to end, at about 14 cents per million transfers, so confidentiality is not paid for in latency or in fees. Contracts stay standard EVM, nothing has to be rewritten, and disclosure is governed by the contract rather than by an operator. The same engine runs in production on COTI, where it has more than 125 million transactions behind it. Live on Ethereum, Polygon, Arbitrum, Base and COTI.", "tags": [ "enterprise", "treasury", "confidential transfers" ], "sources": [ { "label": "Product", "url": "https://www.sodalabs.xyz/product" }, { "label": "Technology", "url": "https://www.sodalabs.xyz/technology" }, { "label": "Research", "url": "https://www.sodalabs.xyz/research" }, { "label": "Developer SDK", "url": "https://www.sodalabs.xyz/developers" } ], "url": "https://www.sodalabs.xyz/privacy-hub/bubble", "markdown": "https://www.sodalabs.xyz/privacy-hub/bubble.md" }, { "slug": "zama", "name": "Zama", "summary": "Zama: FHE coprocessor.", "kind": "project", "category": "FHE coprocessor", "technology": "FHE", "sodaBacked": false, "description": "Zama did what most of the field assumed was still years out: it brought fully homomorphic encryption to Ethereum at the end of 2025, with confidential tokens whose balances and transfers are computed on while they stay encrypted. Its open-source library, TFHE-rs, is the foundation a large part of the FHE ecosystem now builds on, Zama's own products included. The guarantee is genuinely strong, strong enough that a May 2026 court order to freeze 12.6 million dollars in its confidential USDC wrapper took three days to resolve, because a design that cannot see individual balances cannot freeze one either. Published throughput sits in the low tens of transactions per second, decryption runs through a threshold committee, and academic key-recovery work on the TFHE library led to a parameter change earlier on.", "tags": [ "FHE", "coprocessor", "confidential tokens" ], "website": "https://www.zama.org", "sources": [ { "label": "Litepaper", "url": "https://docs.zama.org/protocol/zama-protocol-litepaper" }, { "label": "TFHE-rs, the open-source library", "url": "https://github.com/zama-ai/tfhe-rs" }, { "label": "fhEVM", "url": "https://github.com/zama-ai/fhevm" }, { "label": "The 2026 freeze, reported", "url": "https://www.theblock.co/post/403091/court-ordered-circle-freeze-traps-12-6-million-in-zama-cusdc-contract-amid-overnight-finance-suit" }, { "label": "Key-recovery paper", "url": "https://eprint.iacr.org/2024/127" } ], "url": "https://www.sodalabs.xyz/privacy-hub/zama", "markdown": "https://www.sodalabs.xyz/privacy-hub/zama.md" }, { "slug": "fhenix", "name": "Fhenix", "summary": "Fhenix: FHE coprocessor.", "kind": "project", "category": "FHE coprocessor", "technology": "FHE", "sodaBacked": false, "description": "Fhenix builds CoFHE, a fully homomorphic encryption coprocessor that lets an ordinary EVM contract hand encrypted work to an off-chain compute layer and get a verified result back. A team can add confidential state to the chain it already ships on instead of migrating to a new one. The architecture came out of the team's own benchmarking: an early plan for a dedicated FHE rollup gave way to the coprocessor once the numbers came in, and a Series A followed the redesign. Encrypted operations resolve asynchronously rather than inside the same block, on the timescales FHE itself sets, and a threshold committee holds the decryption keys. A mainnet first sketched for early 2025 was still running as a testnet through mid 2026.", "tags": [ "FHE", "coprocessor" ], "website": "https://www.fhenix.io", "sources": [ { "label": "CoFHE docs", "url": "https://cofhe-docs.fhenix.zone/fhe-library/introduction/quick-start" }, { "label": "CoFHE contracts", "url": "https://github.com/Fhenixprotocol/cofhe-contracts" }, { "label": "Series A and the timeline", "url": "https://www.theblock.co/post/298443/ethereum-layer-2-fhenix-confidentiality-series-a-funding-testnet" } ], "url": "https://www.sodalabs.xyz/privacy-hub/fhenix", "markdown": "https://www.sodalabs.xyz/privacy-hub/fhenix.md" }, { "slug": "inco", "name": "Inco", "summary": "Inco: Confidential token framework. Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Confidential token framework", "technology": "TEE", "sodaBacked": false, "description": "Inco ships Lightning, a confidential token framework that gives ERC-20 style assets encrypted balances and transfers while keeping the developer experience close to ordinary Solidity, which is the part most confidentiality stacks make hard. That is what makes it usable today: performance and latency that feel normal, because the encrypted state is held inside Intel trusted hardware. A fully homomorphic encryption tier sits on the roadmap for teams that want the guarantee to rest on mathematics rather than on a hardware vendor. It is pre-token, and independent analyses of the trusted-hardware model are worth reading alongside the docs.", "tags": [ "TEE", "confidential tokens" ], "website": "https://www.inco.org", "sources": [ { "label": "Docs", "url": "https://docs.inco.org" }, { "label": "Lightning contracts", "url": "https://github.com/Inco-fhevm" }, { "label": "Independent TEE analysis", "url": "https://blog.sip-protocol.org/blog/tee-encryption-inco-lightning/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/inco", "markdown": "https://www.sodalabs.xyz/privacy-hub/inco.md" }, { "slug": "aztec", "name": "Aztec", "summary": "Aztec: Privacy L2. Technology: zero-knowledge proofs.", "kind": "project", "category": "Privacy L2", "technology": "ZK", "sodaBacked": false, "description": "Aztec has been building private smart contracts for Ethereum since 2017, and along the way it wrote much of the toolchain the wider field now uses. Noir, its circuit language, has become one of the most widely adopted ways to write zero-knowledge programs anywhere. Alpha V5 activated on mainnet in July 2026, bringing private transactions live at fees under five cents, with execution and proving happening on the user's own device so plaintext never leaves it. The road here has been a long one. Aztec Connect, the first product, was retired in 2023, and contracts left deprecated behind it were exploited for 2.1 million dollars three years later. Private state is modeled as per-user notes, an elegant fit for individual confidentiality and a different shape from the shared private state institutions work across.", "tags": [ "ZK", "L2", "smart contracts" ], "website": "https://aztec.network", "sources": [ { "label": "Docs", "url": "https://docs.aztec.network" }, { "label": "Noir, the circuit language", "url": "https://noir-lang.org" }, { "label": "Protocol source", "url": "https://github.com/AztecProtocol/aztec-packages" }, { "label": "Aztec Connect, retired 2023", "url": "https://www.coindesk.com/business/2023/03/13/defi-privacy-bridge-aztec-connect-sunsets-after-less-than-a-year" }, { "label": "Deprecated contract incident, 2026", "url": "https://thedefiant.io/news/hacks/aztec-connect-deprecated-contract-exploit-2-1m-zk-proof" } ], "url": "https://www.sodalabs.xyz/privacy-hub/aztec", "markdown": "https://www.sodalabs.xyz/privacy-hub/aztec.md" }, { "slug": "aleo", "name": "Aleo", "summary": "Aleo: Privacy L1. Technology: zero-knowledge proofs.", "kind": "project", "category": "Privacy L1", "technology": "ZK", "sodaBacked": false, "description": "Aleo is one of the very few teams to have shipped a zero-knowledge Layer 1 with a full stack of its own. Leo, a purpose-built language for writing private applications, runs on snarkVM, its own execution environment, with proofs generated off chain so program state is private by default rather than by opt-in. The cryptography is well regarded by people who read it closely, and mainnet has been running since 2024. Building here means writing for that stack rather than porting existing contracts across, the token has traded well below its launch levels since, and a 2024 mailing error sent some users' identity documents to the wrong recipients.", "tags": [ "ZK", "L1" ], "website": "https://aleo.org", "sources": [ { "label": "Developer docs", "url": "https://developer.aleo.org" }, { "label": "snarkVM, the execution layer", "url": "https://github.com/ProvableHQ/snarkVM" }, { "label": "State of Aleo", "url": "https://messari.io/report/state-of-aleo-q1-2025" }, { "label": "2024 user-data incident", "url": "https://cointelegraph.com/news/privacy-focused-aleo-users-concerned-after-kyc-documents-leak" } ], "url": "https://www.sodalabs.xyz/privacy-hub/aleo", "markdown": "https://www.sodalabs.xyz/privacy-hub/aleo.md" }, { "slug": "railgun", "name": "Railgun", "summary": "Railgun: Private DeFi protocol. Technology: zero-knowledge proofs.", "kind": "project", "category": "Private DeFi protocol", "technology": "ZK", "sodaBacked": false, "description": "Railgun is the most used private DeFi protocol on Ethereum, with 4.5 billion dollars moved cumulatively by early 2026. Its design is notable for keeping the privacy on chain: balances are shielded inside a smart contract and can be spent straight into public DeFi protocols, so users never have to leave the pool to do anything useful. It also ships Private Proofs of Innocence, an on-chain system that lets a user prove their funds are not traceable to a known illicit source without revealing anything else, which is one of the earliest serious attempts at self-service compliance in a shielded pool. Scale of that kind attracts everything: the FBI confirmed that North Korea's Lazarus Group moved over 60 million dollars through it, and compliance vendors now advise treating Railgun-linked flows as elevated risk. As with any shielded pool, privacy strength rises and falls with pool size and user behavior.", "tags": [ "ZK", "shielded pool", "DeFi" ], "website": "https://www.railgun.org", "sources": [ { "label": "Privacy system docs", "url": "https://docs.railgun.org/wiki/learn/privacy-system" }, { "label": "Private Proofs of Innocence", "url": "https://docs.railgun.org/wiki/assurance/private-proofs-of-innocence" }, { "label": "Protocol source", "url": "https://github.com/Railgun-Privacy" }, { "label": "FBI statement, 2022", "url": "https://www.fbi.gov/news/press-releases/fbi-confirms-lazarus-group-cyber-actors-responsible-for-harmonys-horizon-bridge-currency-theft" }, { "label": "Elliptic guidance", "url": "https://www.elliptic.co/blog/analysis/crypto-mixers-and-privacy-protocols-the-sanctions-compliance-implications" } ], "url": "https://www.sodalabs.xyz/privacy-hub/railgun", "markdown": "https://www.sodalabs.xyz/privacy-hub/railgun.md" }, { "slug": "privacy-pools", "name": "Privacy Pools", "summary": "Privacy Pools: Compliant privacy pool. Technology: zero-knowledge proofs.", "kind": "project", "category": "Compliant privacy pool", "technology": "ZK", "sodaBacked": false, "description": "Privacy Pools implements one of the most consequential ideas in the field: association-set proofs, from a paper co-authored by Vitalik Buterin. They let an honest user prove their deposit belongs to a set that excludes illicit funds without revealing which deposit is theirs. It is the clearest answer anyone has offered to the question of how a shielded pool stays compliant without a backdoor, it carries Ethereum Foundation integration, and a year in it holds about six million dollars across some 1,500 users. Membership of the association set is currently determined by one screening provider, which can also revoke it, so that provider sits in the trust model alongside the cryptography.", "tags": [ "ZK", "shielded pool", "compliance" ], "website": "https://privacypools.com", "sources": [ { "label": "The paper", "url": "https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4563364" }, { "label": "0xbow, the implementation", "url": "https://0xbow.io" }, { "label": "Seed round coverage", "url": "https://www.theblock.co/post/379395/0xbow-raises-3-5-million-seed-round-ethereum-foundation-backed-privacy-pools" } ], "url": "https://www.sodalabs.xyz/privacy-hub/privacy-pools", "markdown": "https://www.sodalabs.xyz/privacy-hub/privacy-pools.md" }, { "slug": "zcash", "name": "Zcash", "summary": "Zcash: Shielded-pool L1. Technology: zero-knowledge proofs.", "kind": "project", "category": "Shielded-pool L1", "technology": "ZK", "sodaBacked": false, "description": "Zcash invented shielded payments at scale and handed the rest of the field its foundations. zk-SNARK shielded transactions have been in production since 2016, the Sapling upgrade made them practical on ordinary hardware, and Halo 2 removed the trusted setup and is now used well beyond Zcash itself. It has run its security work in the open too, disclosing counterfeiting vulnerabilities in 2018 and again in June 2026 rather than quietly patching them, and the June 2026 disclosure moved the price by a third in a day. A January 2026 governance dispute saw the core company's staff depart, and shielded usage remains a minority of supply.", "tags": [ "ZK", "payments", "L1" ], "website": "https://z.cash", "sources": [ { "label": "Protocol specification", "url": "https://zips.z.cash/protocol/protocol.pdf" }, { "label": "Reference implementation", "url": "https://github.com/zcash/zcash" }, { "label": "2026 disclosure", "url": "https://decrypt.co/370105/zec-crashes-38-as-zcash-discloses-critical-counterfeiting-vulnerability" }, { "label": "January 2026 governance change", "url": "https://bravenewcoin.com/insights/entire-zcash-development-team-quits-electric-coin-company-after-governance-dispute" } ], "url": "https://www.sodalabs.xyz/privacy-hub/zcash", "markdown": "https://www.sodalabs.xyz/privacy-hub/zcash.md" }, { "slug": "miden", "name": "Miden", "summary": "Miden: Client-side proving chain (upcoming). Technology: zero-knowledge proofs.", "kind": "project", "category": "Client-side proving chain (upcoming)", "technology": "ZK", "sodaBacked": false, "description": "Miden spun out of Polygon with 25 million dollars behind a genuinely different architecture: client-side proving. The user executes and proves their own transaction locally and the network only verifies the proof, so the chain never handles the data at all. That inverts the usual privacy trade-off, in which some operator has to be trusted with plaintext, and it is one of the more ambitious designs anyone is actually building. Mainnet is planned for September 2026, about a year later than first sketched, and because proving on ordinary devices is demanding, the design also supports delegating proof generation to a service for users whose hardware cannot carry it.", "tags": [ "ZK", "upcoming" ], "website": "https://miden.xyz", "sources": [ { "label": "Docs", "url": "https://docs.miden.xyz" }, { "label": "Miden VM source", "url": "https://github.com/0xMiden/miden-vm" }, { "label": "Spin-out coverage", "url": "https://decrypt.co/316869/miden-spins-out-from-polygon-labs-raises-25m-to-launch-own-chain" } ], "url": "https://www.sodalabs.xyz/privacy-hub/miden", "markdown": "https://www.sodalabs.xyz/privacy-hub/miden.md" }, { "slug": "penumbra", "name": "Penumbra", "summary": "Penumbra: Shielded DEX chain. Technology: zero-knowledge proofs.", "kind": "project", "category": "Shielded DEX chain", "technology": "ZK", "sodaBacked": false, "description": "Penumbra is one of the most elegant designs in the field: a fully shielded Cosmos chain where every action is private, staking and trading included. Its DEX batches swaps so trades clear at a shared price and no individual order is ever exposed, and the specification is openly published and holds up to reading. The company that built it wound down in 2025 after the lead developer moved on, and the network now runs as a community project, with liquidity that reflects that.", "tags": [ "ZK", "DEX", "Cosmos" ], "website": "https://penumbra.zone", "sources": [ { "label": "Protocol spec", "url": "https://protocol.penumbra.zone" }, { "label": "Protocol source", "url": "https://github.com/penumbra-zone/penumbra" }, { "label": "Penumbra Labs, 2025", "url": "https://penumbralabs.xyz/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/penumbra", "markdown": "https://www.sodalabs.xyz/privacy-hub/penumbra.md" }, { "slug": "oasis", "name": "Oasis Sapphire", "summary": "Oasis Sapphire: Confidential EVM. Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Confidential EVM", "technology": "TEE", "sodaBacked": false, "description": "Oasis Sapphire is the confidential EVM that has been in production the longest: ordinary Solidity, encrypted state and encrypted calldata, running inside Intel SGX enclaves. The developer experience is deliberately close to a normal EVM chain, which is why teams can ship on it without relearning how to write contracts. Oasis has also been unusually candid about the hardware it stands on, publishing its own analysis of the SGX key-extraction research and, in response to it, restricting the committees that hold encryption keys to vetted operator partners. Value locked on the network is modest, and the strength of the model tracks the strength of the enclave underneath it.", "tags": [ "TEE", "confidential EVM", "L1" ], "website": "https://oasisprotocol.org", "sources": [ { "label": "Docs", "url": "https://docs.oasis.io/build/sapphire/" }, { "label": "Sapphire source", "url": "https://github.com/oasisprotocol/sapphire-paratime" }, { "label": "Oasis on TEE research", "url": "https://oasis.net/blog/how-oasis-protects-privacy-despite-tee-vulnerabilities" }, { "label": "SGX research archive", "url": "https://sgx.fail" } ], "url": "https://www.sodalabs.xyz/privacy-hub/oasis", "markdown": "https://www.sodalabs.xyz/privacy-hub/oasis.md" }, { "slug": "phala", "name": "Phala", "summary": "Phala: Confidential compute network. Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Confidential compute network", "technology": "TEE", "sodaBacked": false, "description": "Phala runs a decentralized confidential compute cloud, where workloads execute inside attested hardware and a customer can verify what is running before trusting it with anything. It is also one of the most operationally serious teams in this corner of the field, and the field's hardest test is where that showed: when researchers extracted SGX attestation keys using a thousand-dollar hardware interposer, Phala shut its entire SGX fleet down, published the reasoning and migrated, rather than wait the news cycle out. Very few operators have moved that decisively against their own installed base. The episode is also the clearest demonstration available of what a hardware root of trust means in practice, which is that everything standing on it moves together.", "tags": [ "TEE", "cloud compute" ], "website": "https://phala.network", "sources": [ { "label": "Docs", "url": "https://docs.phala.network" }, { "label": "WireTap research", "url": "https://www.securityweek.com/wiretap-attack-breaks-intel-sgx-security/" }, { "label": "Phala response", "url": "https://phala.com/posts/response-to-wiretap-sgx-deprecation" } ], "url": "https://www.sodalabs.xyz/privacy-hub/phala", "markdown": "https://www.sodalabs.xyz/privacy-hub/phala.md" }, { "slug": "secret", "name": "Secret Network", "summary": "Secret Network: Confidential L1. Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Confidential L1", "technology": "TEE", "sodaBacked": false, "description": "Secret has run encrypted smart contracts in production longer than anyone else, since 2020, and a good deal of what the industry knows about operating TEE-based privacy at real scale it learned here first. The network has also done that learning in the open: the 2022 consensus-seed research and a June 2026 bridge exploit that minted 4.7 million dollars are both publicly documented, the second with a post-mortem on Secret's own forum. It is now planning a move from Cosmos to Arbitrum, closer to where EVM liquidity and integrations already sit.", "tags": [ "TEE", "L1", "Cosmos" ], "website": "https://scrt.network", "sources": [ { "label": "Docs", "url": "https://docs.scrt.network" }, { "label": "SGX research archive", "url": "https://sgx.fail" }, { "label": "June 2026 bridge post-mortem", "url": "https://forum.scrt.network/t/security-incident-axelar-secret-ibc-bridge-exploit-june-10-2026/7995" } ], "url": "https://www.sodalabs.xyz/privacy-hub/secret", "markdown": "https://www.sodalabs.xyz/privacy-hub/secret.md" }, { "slug": "seismic", "name": "Seismic", "summary": "Seismic: Encrypted EVM L1 (pre-mainnet). Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Encrypted EVM L1 (pre-mainnet)", "technology": "TEE", "sodaBacked": false, "description": "Seismic raised seventeen million dollars from a16z to build an encrypted EVM where confidentiality is a language-level primitive. Shielded types such as suint256 mean a developer marks a variable private and the chain takes care of the rest, which is about as low-friction as confidential smart contracts have ever been made. Two fintech partners are already building on it. The chain runs on Intel TDX, a platform researchers have continued to probe successfully on fully patched hardware, and mainnet, once eyed for the end of 2025, has not yet been re-dated.", "tags": [ "TEE", "L1", "upcoming" ], "website": "https://seismic.systems", "sources": [ { "label": "Docs", "url": "https://docs.seismic.systems" }, { "label": "Source", "url": "https://github.com/SeismicSystems" }, { "label": "TDX research coverage", "url": "https://www.bleepingcomputer.com/news/security/teefail-attack-breaks-confidential-computing-on-intel-amd-nvidia-cpus/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/seismic", "markdown": "https://www.sodalabs.xyz/privacy-hub/seismic.md" }, { "slug": "partisia", "name": "Partisia", "summary": "Partisia: MPC L1.", "kind": "project", "category": "MPC L1", "technology": "MPC-GC", "sodaBacked": false, "description": "Partisia carries as much academic MPC pedigree as anything in this field, tracing back to the Aarhus cryptography group behind several of the foundational secure-computation results. It turned that into a working mainnet, out of beta since 2024, where MPC nodes compute over secret-shared inputs as a first-class chain primitive rather than as an add-on. Contracts are written in a model built for secret-shared computation rather than in general-purpose Solidity, which is a deliberate design choice and a learning curve. Adoption has been quieter than the research record: daily trading volume sits around nine thousand dollars, and the token trades far below its high.", "tags": [ "MPC", "L1" ], "website": "https://partisiablockchain.com", "sources": [ { "label": "Docs", "url": "https://partisiablockchain.gitlab.io/documentation/" }, { "label": "The research lineage", "url": "https://en.wikipedia.org/wiki/Ivan_Damg%C3%A5rd" }, { "label": "Market data", "url": "https://coinmarketcap.com/currencies/partisia-blockchain/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/partisia", "markdown": "https://www.sodalabs.xyz/privacy-hub/partisia.md" }, { "slug": "arcium", "name": "Arcium", "summary": "Arcium: Confidential compute network. Technology: garbled-circuit MPC.", "kind": "project", "category": "Confidential compute network", "technology": "MPC-GC", "sodaBacked": false, "description": "Arcium is the most substantial MPC effort on Solana, running an encrypted execution engine that handles hundreds of thousands of confidential computations a day and already carries third-party products such as the Umbra wallet. The design gives builders a choice of trust model rather than one setting for everyone: a stronger mode that halts rather than continue under a dishonest majority, and a faster mode tuned for honest-but-curious operators. The network is in mainnet alpha on an operator set Arcium permissions, and the team arrived at this design as a second act, after winding down its earlier protocol, Elusiv, and rebuilding around encrypted computation.", "tags": [ "MPC", "Solana" ], "website": "https://www.arcium.com", "sources": [ { "label": "Docs", "url": "https://docs.arcium.com" }, { "label": "How the network works", "url": "https://docs.arcium.com/introduction" }, { "label": "Umbra, built on Arcium", "url": "https://www.theblock.co/post/394892/umbra-opens-privacy-wallet-to-the-public-on-solana-powered-by-arciums-encrypted-execution-engine" } ], "url": "https://www.sodalabs.xyz/privacy-hub/arcium", "markdown": "https://www.sodalabs.xyz/privacy-hub/arcium.md" }, { "slug": "nillion", "name": "Nillion", "summary": "Nillion: Blind-compute network. Technology: garbled-circuit MPC.", "kind": "project", "category": "Blind-compute network", "technology": "MPC-GC", "sodaBacked": false, "description": "Nillion is building blind compute: a network where data is split across nodes and operated on while it stays encrypted. It targets storage and AI workloads rather than another smart-contract chain, which is a corner of the problem almost nobody else is working on. It mixes MPC, homomorphic encryption and trusted hardware and lets each module use the technique that actually fits it, an unusually pragmatic piece of engineering that also gives each module its own trust model to reason about. The token has been volatile since launch, including a sharp fall when a market maker sold without authorization.", "tags": [ "MPC", "blind compute", "AI" ], "website": "https://nillion.com", "sources": [ { "label": "Docs", "url": "https://docs.nillion.com" }, { "label": "Network updates", "url": "https://nillion.com/news" }, { "label": "Market-maker incident", "url": "https://coinjournal.net/news/nillion-nil-price-crashes-50-after-unauthorized-market-maker-sell-off/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/nillion", "markdown": "https://www.sodalabs.xyz/privacy-hub/nillion.md" }, { "slug": "coti", "name": "COTI", "summary": "COTI: Confidential EVM L2 · in production. Technology: garbled-circuit MPC.", "kind": "project", "category": "Confidential EVM L2 · in production", "technology": "MPC-GC", "sodaBacked": false, "description": "COTI runs a confidential EVM in production on Ethereum rails, built on garbled circuits developed with Soda Labs technology, with more than 125 million transactions behind it. It is the strongest existing evidence that the approach holds at public-network scale: standard EVM contracts, encrypted state, live applications, and an Enterprise Ethereum Alliance report singling out the design as production-ready privacy at scale. The engine that powers COTI powers Bubble.", "tags": [ "garbled circuits", "L2", "in production" ], "website": "https://coti.io", "sources": [ { "label": "Developer docs", "url": "https://docs.coti.io" }, { "label": "COTI 2026", "url": "https://cotinetwork.medium.com/coti-2026-taking-privacy-mainstream-67df5c1fe422" }, { "label": "EEA on garbled circuits", "url": "https://www.coti.news/news/enterprise-ethereum-alliance-report-highlights-coti-garbled-circuits-for-production-ready-privacy-at-scale" } ], "url": "https://www.sodalabs.xyz/privacy-hub/coti", "markdown": "https://www.sodalabs.xyz/privacy-hub/coti.md" }, { "slug": "privex", "name": "PriveX", "summary": "PriveX: Private perpetuals DEX. Technology: garbled-circuit MPC.", "kind": "project", "category": "Private perpetuals DEX", "technology": "MPC-GC", "sodaBacked": false, "description": "PriveX is the first exchange powered by garbled circuits, running perpetuals with private execution on COTI's confidential EVM, built on Soda technology. Order flow stays encrypted until settlement, which takes the alpha leak out of trading and removes the front-running surface that public order flow creates. COTI reports more than 20 billion dollars of cumulative volume across its private DeFi stack.", "tags": [ "garbled circuits", "DEX", "perpetuals" ], "website": "https://prvx.io", "sources": [ { "label": "Launch coverage", "url": "https://chainwire.org/2025/06/04/privex-goes-live-on-coti-to-deliver-private-perps-trading/" }, { "label": "Private DeFi on COTI", "url": "https://cotinetwork.medium.com/private-defi-on-coti-9a6df2403a86" } ], "url": "https://www.sodalabs.xyz/privacy-hub/privex", "markdown": "https://www.sodalabs.xyz/privacy-hub/privex.md" }, { "slug": "zoniqx", "name": "Zoniqx", "summary": "Zoniqx: Private RWA tokenization. Technology: garbled-circuit MPC.", "kind": "project", "category": "Private RWA tokenization", "technology": "MPC-GC", "sodaBacked": false, "description": "Zoniqx tokenizes real-world assets on COTI's confidential EVM, keeping cap tables, registers and positions off the public record while staying inside a compliance framework. That combination is precisely what has kept most regulated issuers off public chains. It is built on the same garbled-circuit engine, developed with Soda technology, that runs Bubble. Early stage, and growing with the private RWA market around it.", "tags": [ "garbled circuits", "RWA" ], "website": "https://www.zoniqx.com", "sources": [ { "label": "Tokenization platform", "url": "https://www.zoniqx.com/solutions" }, { "label": "COTI ecosystem", "url": "https://cotinetwork.medium.com/private-defi-on-coti-9a6df2403a86" } ], "url": "https://www.sodalabs.xyz/privacy-hub/zoniqx", "markdown": "https://www.sodalabs.xyz/privacy-hub/zoniqx.md" }, { "slug": "umbra", "name": "Umbra", "summary": "Umbra: Shielded wallet on Solana. Technology: garbled-circuit MPC.", "kind": "project", "category": "Shielded wallet on Solana", "technology": "MPC-GC", "sodaBacked": false, "description": "Umbra is a private wallet and shielded pool on Solana, public since March 2026, and the clearest evidence yet that Arcium's encrypted execution engine can carry a consumer product. Send, receive and hold with balances and amounts hidden, in an interface that behaves like an ordinary wallet. Building the first real application on a new MPC layer is a harder engineering problem than it looks. It inherits the trust assumptions of that execution layer, which is still in alpha, and it serves Solana rather than the EVM environments most institutions integrate with first.", "tags": [ "MPC", "Solana", "wallet" ], "website": "https://www.umbra.cash", "sources": [ { "label": "Launch coverage", "url": "https://www.theblock.co/post/394892/umbra-opens-privacy-wallet-to-the-public-on-solana-powered-by-arciums-encrypted-execution-engine" }, { "label": "Arcium, the engine underneath", "url": "https://docs.arcium.com" } ], "url": "https://www.sodalabs.xyz/privacy-hub/umbra", "markdown": "https://www.sodalabs.xyz/privacy-hub/umbra.md" }, { "slug": "panther", "name": "Panther Protocol", "summary": "Panther Protocol: Compliant private DeFi. Technology: zero-knowledge proofs.", "kind": "project", "category": "Compliant private DeFi", "technology": "ZK", "sodaBacked": false, "description": "Panther shipped its shielded pool on Polygon in May 2026 with disclosure designed into the protocol rather than bolted on afterwards. A user can prove what a counterparty or a regulator needs proven without opening the rest of their position. It got there after years of research and a deliberately capped 2,000-user beta, which is a careful way to open a pool that handles other people's money. It runs on one chain today, and as with every shielded pool, the privacy deepens as the anonymity set grows.", "tags": [ "ZK", "shielded pool", "Polygon" ], "website": "https://www.pantherprotocol.io", "sources": [ { "label": "Docs", "url": "https://docs.pantherprotocol.io" }, { "label": "Launch coverage", "url": "https://news.bitcoin.com/programmable-privacy-is-live-panther-protocol-deploys-on-polygon/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/panther", "markdown": "https://www.sodalabs.xyz/privacy-hub/panther.md" }, { "slug": "fluidkey", "name": "Fluidkey", "summary": "Fluidkey: Private payments.", "kind": "project", "category": "Private payments", "sodaBacked": false, "description": "Fluidkey wraps stealth addresses in a payments product polished enough that people actually use it, across seven EVM chains, with real traction for receiving funds privately. Every incoming payment lands on a freshly generated address with its own smart account, derived automatically from the user's viewing and spending keys, so a shared payment link never becomes a public ledger of everything it has ever received, and the user still sees one unified balance. What it delivers is unlinkability: amounts and activity stay readable on chain, which is a different and far lighter guarantee than encrypting them.", "tags": [ "stealth addresses", "payments" ], "website": "https://www.fluidkey.com", "sources": [ { "label": "FAQ", "url": "https://docs.fluidkey.com/readme/frequently-asked-questions/" }, { "label": "Product", "url": "https://www.fluidkey.com" }, { "label": "Stealth addresses (ERC-5564)", "url": "https://eips.ethereum.org/EIPS/eip-5564" } ], "url": "https://www.sodalabs.xyz/privacy-hub/fluidkey", "markdown": "https://www.sodalabs.xyz/privacy-hub/fluidkey.md" }, { "slug": "hinkal", "name": "Hinkal", "summary": "Hinkal: Private DeFi layer. Technology: zero-knowledge proofs.", "kind": "project", "category": "Private DeFi layer", "technology": "ZK", "sodaBacked": false, "description": "Hinkal took shielded balances further than most, letting users hold assets privately and then deploy them directly inside DeFi protocols across several chains, rather than shielding transfers alone. An access check put compliance in front of the pool rather than after it. In July 2026 an exploit drained roughly 820 thousand dollars, close to the value locked in the protocol at the time, and no post-mortem has been published since. Listed here for completeness of the map.", "tags": [ "ZK", "DeFi" ], "website": "https://www.hinkal.io", "sources": [ { "label": "Hinkal", "url": "https://www.hinkal.io" }, { "label": "July 2026 incident", "url": "https://www.cryptopolitan.com/hinkal-privacy-protocol-exploited-for-820000-as-attacker-funnels-stolen-funds-through-tornado-cash/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/hinkal", "markdown": "https://www.sodalabs.xyz/privacy-hub/hinkal.md" }, { "slug": "int-metamask", "name": "MetaMask", "summary": "MetaMask: Wallets. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Wallets", "sodaBacked": true, "description": "Self-custody through the wallet most of the market already uses. The signing key never leaves MetaMask; Bubble only handles the encryption material, so a confidential transfer feels like any other transaction to the user.", "tags": [ "wallet", "self-custody" ], "website": "https://metamask.io", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-metamask", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-metamask.md" }, { "slug": "int-privy", "name": "Privy", "summary": "Privy: Wallets. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Wallets", "sodaBacked": true, "description": "Embedded self-custody wallets for apps that onboard users with an email address. Privy handles the key, Bubble handles the confidentiality, and the app ships private balances without asking anyone to install anything.", "tags": [ "wallet", "embedded" ], "website": "https://privy.io", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-privy", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-privy.md" }, { "slug": "int-turnkey", "name": "Turnkey", "summary": "Turnkey: Wallets. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Wallets", "sodaBacked": true, "description": "Wallet infrastructure for teams that run signing at scale. Turnkey policies govern who can sign; Bubble keeps what they sign confidential on chain.", "tags": [ "wallet", "infrastructure" ], "website": "https://www.turnkey.com", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-turnkey", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-turnkey.md" }, { "slug": "int-silence-labs", "name": "Silence Laboratories", "summary": "Silence Laboratories: Wallets. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Wallets", "sodaBacked": true, "description": "MPC wallets meet MPC privacy. Threshold signing on the wallet side, garbled-circuit computation on the chain side, and no single machine ever holds either the full key or a plaintext balance.", "tags": [ "wallet", "MPC" ], "website": "https://www.silencelaboratories.com", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-silence-labs", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-silence-labs.md" }, { "slug": "int-gnosis", "name": "Gnosis", "summary": "Gnosis: Wallets. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Wallets", "sodaBacked": true, "description": "Smart-contract wallets with programmable policies. Account logic stays on chain and public where it should be; balances and transfer amounts stay private where it matters.", "tags": [ "wallet", "smart accounts" ], "website": "https://www.gnosis.io", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-gnosis", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-gnosis.md" }, { "slug": "int-private-erc20", "name": "Private ERC-20", "summary": "Private ERC-20: Standards. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Standards", "sodaBacked": true, "description": "Our own standard. Full 256-bit amounts stored as two ciphertexts, standard ERC-20 semantics, verifiable settlement on a public explorer. The world sees that a transaction happened and settled, and learns nothing else.", "tags": [ "standard", "confidential tokens" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-private-erc20", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-private-erc20.md" }, { "slug": "int-erc3643", "name": "ERC-3643", "summary": "ERC-3643: Standards. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Standards", "sodaBacked": true, "description": "The permissioned-token standard behind most institutional RWA issuance, maintained by the ERC-3643 Association. With Bubble underneath, eligibility stays enforced while positions and transfers stop being public signals.", "tags": [ "standard", "RWA" ], "website": "https://www.erc3643.org", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-erc3643", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-erc3643.md" }, { "slug": "int-erc7943", "name": "ERC-7943 (uRWA)", "summary": "ERC-7943 (uRWA): Standards. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Standards", "sodaBacked": true, "description": "The universal RWA interface, integrated with Brickken. Issuers keep the compliance controls the standard defines and gain confidential balances for the assets themselves.", "tags": [ "standard", "RWA" ], "website": "https://www.brickken.com", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-erc7943", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-erc7943.md" }, { "slug": "int-erc7984", "name": "ERC-7984", "summary": "ERC-7984: Standards. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Standards", "sodaBacked": true, "description": "The confidential-token standard drafted with OpenZeppelin. A common interface for encrypted-amount tokens, so wallets and protocols integrate confidentiality once instead of per vendor.", "tags": [ "standard", "confidential tokens" ], "website": "https://www.openzeppelin.com", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-erc7984", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-erc7984.md" }, { "slug": "int-x402", "name": "x402", "summary": "x402: Standards. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Standards", "sodaBacked": true, "description": "The agentic payment protocol. Machine-to-machine payments are exactly the flows nobody wants published, and Bubble gives x402 settlements confidential amounts by default.", "tags": [ "standard", "agentic payments" ], "website": "https://www.x402.org", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-x402", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-x402.md" }, { "slug": "int-gnosis-safe", "name": "Gnosis Safe", "summary": "Gnosis Safe: Vaults & platforms. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Vaults & platforms", "sodaBacked": true, "description": "Treasury vaults with multi-signer policies. The Safe keeps its governance; Bubble keeps the treasury's balances and flows off the public record, which is usually the point of having a treasury policy at all.", "tags": [ "vault", "treasury" ], "website": "https://safe.global", "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-gnosis-safe", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-gnosis-safe.md" }, { "slug": "int-tokenization", "name": "Tokenization platforms", "summary": "Tokenization platforms: Vaults & platforms. Works with Soda Bubble, so balances and transfers stay confidential on chain.", "kind": "integration", "category": "Vaults & platforms", "sodaBacked": true, "description": "Issuance platforms integrate Bubble to keep subscriptions, redemptions and holder registers confidential. Case studies are available on request.", "tags": [ "platforms", "RWA" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/int-tokenization", "markdown": "https://www.sodalabs.xyz/privacy-hub/int-tokenization.md" }, { "slug": "iexec", "name": "iExec", "summary": "iExec: Confidential compute network. Technology: trusted execution environments (TEEs).", "kind": "project", "category": "Confidential compute network", "technology": "TEE", "sodaBacked": false, "description": "iExec has been running decentralized confidential computing since 2017, with a network of trusted-execution nodes and a data-governance layer that lets someone monetize access to a dataset without ever handing over the data itself. That combination of confidential compute plus enforceable usage rules is a more complete answer than either half alone, and the project has sustained it across many years and several hardware generations. The guarantees rest on the enclave vendors underneath, which is the standing trade in trusted hardware.", "tags": [ "TEE", "compute", "data" ], "website": "https://iex.ec/", "sources": [ { "label": "Website", "url": "https://iex.ec/" }, { "label": "Docs", "url": "https://docs.iex.ec/" }, { "label": "Whitepaper", "url": "https://github.com/iExecBlockchainComputing/whitepaper/blob/master/V3/iExec-WPv3.0-English.pdf" }, { "label": "Source", "url": "https://github.com/iExecBlockchainComputing" }, { "label": "Explorer", "url": "https://explorer.iex.ec/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/iexec", "markdown": "https://www.sodalabs.xyz/privacy-hub/iexec.md" }, { "slug": "mina", "name": "Mina", "summary": "Mina: Succinct blockchain. Technology: zero-knowledge proofs.", "kind": "project", "category": "Succinct blockchain", "technology": "ZK", "sodaBacked": false, "description": "Mina keeps the entire blockchain small enough to verify on a phone, using recursive zero-knowledge proofs so that a constant-size proof stands in for the whole chain history. It is one of the most elegant applications of recursive proving anywhere, and it makes verification genuinely accessible rather than something only well-resourced nodes can do. Its smart contract layer, written in TypeScript, is a distinctive developer story. Privacy on Mina comes from what applications choose to prove rather than from shielded state by default.", "tags": [ "ZK", "L1", "recursive proofs" ], "website": "https://minaprotocol.com", "sources": [ { "label": "Website", "url": "https://minaprotocol.com" }, { "label": "Docs", "url": "https://docs.minaprotocol.com/" }, { "label": "Whitepaper", "url": "https://minaprotocol.com/wp-content/uploads/technicalWhitepaper.pdf" }, { "label": "Source", "url": "https://github.com/MinaProtocol/mina" }, { "label": "Explorer", "url": "https://minascan.io/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/mina", "markdown": "https://www.sodalabs.xyz/privacy-hub/mina.md" }, { "slug": "namada", "name": "Namada", "summary": "Namada: Multi-asset shielded L1. Technology: zero-knowledge proofs.", "kind": "project", "category": "Multi-asset shielded L1", "technology": "ZK", "sodaBacked": false, "description": "Namada runs a single shielded pool that works for any asset, native or bridged, so every token shares one anonymity set instead of each having its own thin one. That is a real cryptographic and economic insight, since privacy in a shielded pool is a function of how many people are in it, and pooling assets makes the set far larger than it would otherwise be. It also pays shielding rewards to keep the set populated. The network launched relatively recently and its bridged asset coverage is still expanding.", "tags": [ "ZK", "shielded pool", "Cosmos" ], "website": "https://namada.net", "sources": [ { "label": "Website", "url": "https://namada.net" }, { "label": "Docs", "url": "https://docs.namada.net/" }, { "label": "Whitepaper", "url": "https://specs.namada.net/" }, { "label": "Source", "url": "https://github.com/namada-net" }, { "label": "Explorer", "url": "https://namada.valopers.com/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/namada", "markdown": "https://www.sodalabs.xyz/privacy-hub/namada.md" }, { "slug": "noir", "name": "Noir", "summary": "Noir: ZK programming language.", "kind": "project", "category": "ZK programming language", "technology": "ZK", "sodaBacked": false, "description": "Noir is a domain-specific language for zero-knowledge circuits that made writing provable programs feel like writing Rust, and it has become one of the most widely adopted ways to build zero-knowledge applications anywhere. It is backend-agnostic, so a circuit written once can target different proving systems rather than locking a team to one. Much of the tooling on this map is built with it. It is a language and toolchain rather than a network, so it provides the means to build confidentiality rather than a deployed guarantee.", "tags": [ "ZK", "language", "tooling" ], "website": "https://noir-lang.org/", "sources": [ { "label": "Website", "url": "https://noir-lang.org/" }, { "label": "Docs", "url": "https://github.com/noir-lang/noir/tree/master/docs" }, { "label": "Source", "url": "https://github.com/noir-lang" } ], "url": "https://www.sodalabs.xyz/privacy-hub/noir", "markdown": "https://www.sodalabs.xyz/privacy-hub/noir.md" }, { "slug": "shutter-network", "name": "Shutter Network", "summary": "Shutter Network: Threshold encrypted mempool. Technology: garbled-circuit MPC.", "kind": "project", "category": "Threshold encrypted mempool", "technology": "MPC-GC", "sodaBacked": false, "description": "Shutter encrypts transactions until they are already ordered, using threshold cryptography and distributed key generation so a committee can only decrypt after the block is fixed. That closes front-running at the protocol level rather than policing it afterwards, and the same mechanism protects voting from bribery and sealed-bid auctions from leaking. It is live and integrated with real chains and governance systems. The guarantee rests on the keyper set staying honest and available, which is the standing assumption in threshold schemes.", "tags": [ "threshold encryption", "MEV", "governance" ], "website": "https://www.shutter.network/", "sources": [ { "label": "Website", "url": "https://www.shutter.network/" }, { "label": "Docs", "url": "https://docs.shutter.network" }, { "label": "Whitepaper", "url": "https://blog.shutter.network/shutter-in-depth-explanation-of-how-we-prevent-frontrunning/" }, { "label": "Source", "url": "https://github.com/shutter-network/" }, { "label": "Explorer", "url": "https://explorer.shutter.network/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/shutter-network", "markdown": "https://www.sodalabs.xyz/privacy-hub/shutter-network.md" }, { "slug": "chain-ethereum", "name": "Ethereum", "summary": "Ethereum is a public blockchain network. Confidentiality on Ethereum: Bubble live · no native privacy.", "kind": "chain", "category": "Bubble live · no native privacy", "sodaBacked": true, "description": "The base layer is transparent by design and will stay that way, so every privacy option here is opt in at the application layer. Aztec's private rollup reached alpha in March 2026, Railgun's shielded pool carries most of the volume, and the Ethereum Foundation is wiring its Kohaku SDK into wallets. Bubble runs on Ethereum through the Soda SDK: contracts stay standard EVM, amounts live on chain as ciphertexts, and disclosure is governed by the contract.", "tags": [ "Soda live", "no native privacy", "third-party layers" ], "sources": [ { "label": "The product", "url": "https://www.sodalabs.xyz/product" }, { "label": "EF privacy roadmap", "url": "https://ambcrypto.com/ethereums-2026-roadmap-puts-institutional-privacy-front-and-center-details/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-ethereum", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-ethereum.md" }, { "slug": "chain-polygon", "name": "Polygon", "summary": "Polygon is a public blockchain network. Confidentiality on Polygon: Bubble live · third-party privacy.", "kind": "chain", "category": "Bubble live · third-party privacy", "sodaBacked": true, "description": "Polygon PoS has no native privacy, but it has one of the deeper third-party ecosystems. The official Polygon wallet added a Privately Send option in May 2026, powered by Hinkal's shielded pools for USDC and USDT, alongside Railgun and Fluidkey. Those routes are KYT gated with a discretionary kill switch and small anonymity sets. Bubble runs here through the Soda SDK, and real confidential transfers are verifiable on Polygonscan today: the amount field holds two ciphertexts and nothing more. Polygon zkEVM, worth noting, was wound down: its Mainnet Beta sequencer stopped producing blocks on July 3, 2026, with an asset-claim window open through December 2027.", "tags": [ "Soda live", "no native privacy", "third-party layers" ], "sources": [ { "label": "The product", "url": "https://www.sodalabs.xyz/product" }, { "label": "Private payments on Polygon", "url": "https://polygon.technology/blog/private-payments-are-live-on-polygon" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-polygon", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-polygon.md" }, { "slug": "chain-arbitrum", "name": "Arbitrum", "summary": "Arbitrum is a public blockchain network. Confidentiality on Arbitrum: Bubble live · no native privacy.", "kind": "chain", "category": "Bubble live · no native privacy", "sodaBacked": true, "description": "Arbitrum's 2026 roadmap sketches three confidentiality models, and its own FAQ confirms network-level confidential execution is not live yet, with the Arbitrum One variant subject to a DAO vote. Today privacy is app layer: Railgun and Fluidkey, plus Renegade's dark pool for matching. Hinkal was exploited for roughly $820,000 in July 2026 and has its contracts paused pending investigation, so it is not a live option right now. This is also where we run our benchmarks: 15,000 private ERC-20 transfers in July 2026, around 500 confidential transactions per second sustained and 750 at peak, measured end to end including chain confirmation.", "tags": [ "Soda live", "no native privacy", "third-party layers" ], "sources": [ { "label": "Benchmarks", "url": "https://www.sodalabs.xyz/research" }, { "label": "Arbitrum on confidentiality", "url": "https://blog.arbitrum.io/confidentiality-for-the-programmable-economy/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-arbitrum", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-arbitrum.md" }, { "slug": "chain-base", "name": "Base", "summary": "Base is a public blockchain network. Confidentiality on Base: Bubble live · enterprise-gated native option.", "kind": "chain", "category": "Bubble live · enterprise-gated native option", "sodaBacked": true, "description": "Base is shipping Base Ledgers, a private settlement rail where balances stay off public explorers while funds settle on Base, currently in early access and operator run with its own KYC. Inco's TEE-based Lightning went live on Base mainnet in June 2026. Both are gated or hardware trusting rather than open cryptographic privacy. The gap that matters most here is agentic: x402 payments settle on Base by the tens of millions and embed resource, description and reason fields in plaintext, which is exactly the leak Bubble closes, since we support x402 with confidential amounts.", "tags": [ "Soda live", "gated native privacy", "agentic payments" ], "sources": [ { "label": "Bubble and x402", "url": "https://www.sodalabs.xyz/solutions" }, { "label": "Base Ledgers", "url": "https://www.base.org/ledgers" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-base", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-base.md" }, { "slug": "monero", "name": "Monero", "summary": "Monero: Private-by-default cryptocurrency.", "kind": "project", "category": "Private-by-default cryptocurrency", "sodaBacked": false, "description": "Monero is the most used private cryptocurrency in existence and the field's most thoroughly battle-tested design. Ring signatures, stealth addresses and confidential transactions hide sender, receiver and amount on every transaction, with no optional transparent mode to thin the anonymity set. It has a decade of adversarial scrutiny behind it, a research lab that publishes openly, and a fair launch with no premine. Its regulatory position is contested, and several exchanges have delisted it.", "tags": [ "ring signatures", "stealth addresses", "payments" ], "website": "https://www.getmonero.org", "sources": [ { "label": "Website", "url": "https://www.getmonero.org" }, { "label": "Docs", "url": "https://docs.getmonero.org/" }, { "label": "Whitepaper", "url": "https://web.getmonero.org/resources/research-lab/pubs/whitepaper_annotated.pdf" }, { "label": "Source", "url": "https://github.com/monero-project" }, { "label": "Explorer", "url": "https://xmrchain.net" } ], "url": "https://www.sodalabs.xyz/privacy-hub/monero", "markdown": "https://www.sodalabs.xyz/privacy-hub/monero.md" }, { "slug": "chain-coti", "name": "COTI", "summary": "COTI is a public blockchain network. Confidentiality on COTI: Bubble live · garbled-circuit EVM in production.", "kind": "chain", "category": "Bubble live · garbled-circuit EVM in production", "sodaBacked": true, "description": "COTI's V2 mainnet has run a garbled-circuit confidential EVM since March 2025, the first on-chain implementation of the technique, built with Soda Labs. Contracts stay Solidity, privacy arrives as parameters rather than a rewrite, and selective disclosure is built in. The live surface includes COTI's Privacy Portal with seven private ERC-20s and a confidential MetaMask Snap. The honest limit is reach: the privacy is real but confined to COTI's own chain, and the multichain Privacy-on-Demand plan has not shipped yet.", "tags": [ "Soda live", "native privacy", "garbled circuits" ], "sources": [ { "label": "Case studies", "url": "https://www.sodalabs.xyz/case-studies" }, { "label": "COTI 2026", "url": "https://cotinetwork.medium.com/coti-2026-taking-privacy-mainstream-67df5c1fe422" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-coti", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-coti.md" }, { "slug": "nym", "name": "NYM", "summary": "NYM: Mixnet for metadata privacy.", "kind": "project", "category": "Mixnet for metadata privacy", "sodaBacked": false, "description": "Nym runs a mixnet that defends the layer encryption leaves exposed: not what you said, but who you talked to, when and how often. It adds cover traffic and timing obfuscation so that even a network-level observer watching every packet cannot reconstruct the pattern, and it ships a consumer VPN built on that foundation. The research behind it is peer-reviewed and open. Mixing costs latency and bandwidth by construction, which is the price of defeating traffic analysis.", "tags": [ "mixnet", "metadata", "VPN" ], "website": "https://nymtech.net", "sources": [ { "label": "Website", "url": "https://nymtech.net" }, { "label": "Docs", "url": "https://nymtech.net/docs" }, { "label": "Whitepaper", "url": "https://nymtech.net/nym-whitepaper.pdf" }, { "label": "Source", "url": "https://github.com/nymtech" }, { "label": "Explorer", "url": "https://www.mintscan.io/nyx/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/nym", "markdown": "https://www.sodalabs.xyz/privacy-hub/nym.md" }, { "slug": "chain-starknet", "name": "Starknet", "summary": "Starknet is a public blockchain network. Confidentiality on Starknet: Native shielded tokens.", "kind": "chain", "category": "Native shielded tokens", "sodaBacked": false, "description": "Starknet is the clearest counterexample to the idea that ZK rollups are private by default. It built privacy deliberately: the STRK20 note-based framework reached mainnet in June 2026, shielding balances and hiding sender, receiver and amount for any ERC-20, with client-side STARK proofs and encrypted viewing keys for disclosure. Private swaps went live on AVNU in July. The constraint is the anonymity set, thin enough that timing and amount correlation remain plausible.", "tags": [ "native privacy", "ZK", "confidential tokens" ], "sources": [ { "label": "Privacy on Starknet", "url": "https://www.starknet.io/blog/privacy-live-on-starknet/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-starknet", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-starknet.md" }, { "slug": "renegade", "name": "Renegade", "summary": "Renegade: On-chain dark pool. Technology: garbled-circuit MPC.", "kind": "project", "category": "On-chain dark pool", "technology": "MPC-GC", "sodaBacked": false, "description": "Renegade runs a dark pool where orders are matched under multi-party computation, so that no one, including the operators, sees an order before it executes, with zero-knowledge proofs confirming the match was valid. This is the most cryptographically serious answer to trading privacy on chain: not hiding the order in a queue, but making it unreadable while it is matched. It is live on Arbitrum and Base. Matching under MPC constrains order types and throughput compared with a transparent order book.", "tags": [ "MPC", "ZK", "dark pool" ], "website": "https://renegade.fi", "sources": [ { "label": "Website", "url": "https://renegade.fi" }, { "label": "Source", "url": "https://github.com/renegade-fi" }, { "label": "Blog", "url": "https://renegadefi.substack.com" } ], "url": "https://www.sodalabs.xyz/privacy-hub/renegade", "markdown": "https://www.sodalabs.xyz/privacy-hub/renegade.md" }, { "slug": "chain-solana", "name": "Solana", "summary": "Solana is a public blockchain network. Confidentiality on Solana: Native confidential tokens.", "kind": "chain", "category": "Native confidential tokens", "sodaBacked": false, "description": "Token-2022 confidential transfers are live on mainnet, using ElGamal encryption with an optional auditor key. Amounts are hidden while addresses stay public. Arcium's MPC network and the Umbra wallet built on it add shielded transfers on top. The gap is adoption: proof generation still needs Rust backends, which keeps the feature ahead of the wallets that would use it.", "tags": [ "native privacy", "ZK", "confidential tokens" ], "sources": [ { "label": "Confidential balances", "url": "https://www.theblock.co/post/350076/solana-developers-launch-new-confidential-balances-token-extensions-to-improve-onchain-privacy" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-solana", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-solana.md" }, { "slug": "chain-aptos", "name": "Aptos", "summary": "Aptos is a public blockchain network. Confidentiality on Aptos: Native confidential assets.", "kind": "chain", "category": "Native confidential assets", "sodaBacked": false, "description": "Aptos shipped its Confidential Asset framework and a confidential APT to mainnet in April 2026 after a near unanimous governance vote, built on twisted ElGamal encryption with governance-controlled auditor keys. Amounts are encrypted, sender and receiver addresses are not, so transaction-graph analysis still works. It is opt in and only months old, so shielded supply remains small.", "tags": [ "native privacy", "ZK", "confidential tokens" ], "sources": [ { "label": "Aptos docs", "url": "https://aptos.dev/build/smart-contracts/confidential-asset" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-aptos", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-aptos.md" }, { "slug": "chain-sui", "name": "Sui", "summary": "Sui is a public blockchain network. Confidentiality on Sui: Encryption and access control.", "kind": "chain", "category": "Encryption and access control", "sodaBacked": false, "description": "Sui's Seal provides threshold encryption with on-chain access policies, and Nautilus adds confidential compute inside AWS Nitro enclaves, still on testnet. What Sui does not offer is confidential transfers. Its own privacy documentation describes encryption, access control and selective disclosure rather than hiding balances or amounts.", "tags": [ "access control", "TEE", "no confidential transfers" ], "sources": [ { "label": "Seal", "url": "https://seal.mystenlabs.com/" }, { "label": "Sui privacy", "url": "https://www.sui.io/privacy" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-sui", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-sui.md" }, { "slug": "semaphore", "name": "semaphore", "summary": "semaphore: Anonymous signalling protocol. Technology: zero-knowledge proofs.", "kind": "project", "category": "Anonymous signalling protocol", "technology": "ZK", "sodaBacked": false, "description": "Semaphore is the primitive a large part of this field is built on: prove you belong to a group and broadcast a signal, exactly once, without revealing which member you are. It is small, audited, well documented and reused everywhere from anonymous voting to whistleblowing tools, which is the highest compliment a cryptographic library can receive. It is a building block from Privacy and Scaling Explorations rather than an application, so what it protects depends on how it is used.", "tags": [ "ZK", "groups", "voting" ], "website": "https://semaphore.pse.dev", "sources": [ { "label": "Website", "url": "https://semaphore.pse.dev" }, { "label": "Docs", "url": "https://docs.semaphore.pse.dev" }, { "label": "Whitepaper", "url": "https://semaphore.pse.dev/whitepaper-v1.pdf" }, { "label": "Source", "url": "https://github.com/semaphore-protocol" }, { "label": "Explorer", "url": "https://explorer.semaphore.pse.dev/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/semaphore", "markdown": "https://www.sodalabs.xyz/privacy-hub/semaphore.md" }, { "slug": "chain-near", "name": "NEAR", "summary": "NEAR is a public blockchain network. Confidentiality on NEAR: Confidential execution in TEEs.", "kind": "chain", "category": "Confidential execution in TEEs", "sodaBacked": false, "description": "Confidential Intents launched in February 2026, executing cross-chain swaps inside trusted execution environments so trade details stay hidden from observers. The protection is hardware based rather than cryptographic, and it covers swap execution rather than account balances. Volume is modest against NEAR's overall intents traffic.", "tags": [ "TEE", "intents" ], "sources": [ { "label": "Launch coverage", "url": "https://www.coindesk.com/markets/2026/03/02/near-token-jumps-17-after-confidential-intents-launch-outpaces-privacy-tokens-sector" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-near", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-near.md" }, { "slug": "session", "name": "Session", "summary": "Session: Metadata-resistant messenger.", "kind": "project", "category": "Metadata-resistant messenger", "sodaBacked": false, "description": "Session is an encrypted messenger that needs no phone number and no email address, routing messages through an onion network so that even the servers cannot see who is talking to whom. Most secure messengers protect content while still collecting the social graph through phone-number registration, and Session removes that at the root. The published research behind it is peer-reviewed. Decentralized routing means messages can be slower to deliver than on centralized alternatives.", "tags": [ "messaging", "onion routing", "no-phone-number" ], "website": "https://getsession.org", "sources": [ { "label": "Website", "url": "https://getsession.org" }, { "label": "Docs", "url": "https://docs.oxen.io/oxen-docs/products-built-on-oxen/session" }, { "label": "Whitepaper", "url": "https://arxiv.org/pdf/2002.04609" }, { "label": "Source", "url": "https://github.com/oxen-io" }, { "label": "Explorer", "url": "https://oxen.observer/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/session", "markdown": "https://www.sodalabs.xyz/privacy-hub/session.md" }, { "slug": "chain-avalanche", "name": "Avalanche", "summary": "Avalanche is a public blockchain network. Confidentiality on Avalanche: Encrypted token standard.", "kind": "chain", "category": "Encrypted token standard", "sodaBacked": false, "description": "Ava Labs publishes Encrypted ERC, a token standard combining zk-SNARKs with partially homomorphic encryption and client-side proving, usable on the C-Chain and on custom L1s. It is a standard rather than a protocol feature, so nothing is confidential unless an issuer adopts it, and public deployments are thin. Permissioned Avalanche L1s offer opacity through restricted validator sets, which is a different thing from cryptographic privacy.", "tags": [ "token standard", "ZK", "opt-in" ], "sources": [ { "label": "Encrypted ERC", "url": "https://github.com/ava-labs/EncryptedERC" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-avalanche", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-avalanche.md" }, { "slug": "chain-bnb", "name": "BNB Chain", "summary": "BNB Chain is a public blockchain network. Confidentiality on BNB Chain: Native privacy on the roadmap.", "kind": "chain", "category": "Native privacy on the roadmap", "sodaBacked": false, "description": "Native privacy is planned rather than present. BNB Chain's 2026 technical roadmap targets testnet by the end of 2026 and mainnet in early 2027, with selective disclosure for transfers and contract calls. Until then privacy comes from third parties, mainly Railgun's shielded pool and the newer Gh0st protocol.", "tags": [ "roadmap", "third-party layers" ], "sources": [ { "label": "BNB 2026 roadmap", "url": "https://www.bnbchain.org/en/blog/tech-roadmap-2026" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-bnb", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-bnb.md" }, { "slug": "chain-cosmos", "name": "Cosmos Hub", "summary": "Cosmos Hub is a public blockchain network. Confidentiality on Cosmos Hub: Privacy lives on neighbouring chains.", "kind": "chain", "category": "Privacy lives on neighbouring chains", "sodaBacked": false, "description": "The Hub itself has no privacy, and the 2026 stack roadmap still lists it as research. Confidentiality lives on separate chains reachable over IBC: Penumbra's shielded DEX, Namada's multi-asset shielded pool and Secret's TEE contracts. All three had a difficult 2026, with Namada's pool drained of roughly 600 thousand dollars unnoticed and Secret losing 4.67 million through a bridge exploit.", "tags": [ "no native privacy", "IBC" ], "sources": [ { "label": "Cosmos stack roadmap", "url": "https://cosmos.network/blog/the-cosmos-stack-roadmap-2026" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-cosmos", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-cosmos.md" }, { "slug": "chain-cardano", "name": "Cardano", "summary": "Cardano is a public blockchain network. Confidentiality on Cardano: Privacy via the Midnight sidechain.", "kind": "chain", "category": "Privacy via the Midnight sidechain", "sodaBacked": false, "description": "Cardano's privacy answer is Midnight, a separate partner chain that reached federated mainnet in March 2026 with a dual ledger, ZK proofs and selective disclosure. It is not Cardano mainnet, and it is not yet permissionless: nodes are operated by a named federation while decentralization is phased in. Attention and adoption have been quiet since launch.", "tags": [ "sidechain", "ZK" ], "sources": [ { "label": "Midnight launch", "url": "https://yellow.com/news/midnight-mainnet-cardano-launch" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-cardano", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-cardano.md" }, { "slug": "chain-polkadot", "name": "Polkadot", "summary": "Polkadot is a public blockchain network. Confidentiality on Polkadot: Confidential compute only.", "kind": "chain", "category": "Confidential compute only", "sodaBacked": false, "description": "Polkadot has no shielded transactions, and its privacy footprint is contracting rather than growing. Manta's ZK privacy parachain wound down when its slot expired in August 2026, and Phala left the ecosystem entirely in November 2025 to run its own Ethereum L2. Integritee's TEE-based confidential compute is what remains, and it protects computation, not balances.", "tags": [ "no native privacy", "TEE" ], "sources": [ { "label": "Integritee", "url": "https://parachains.info/details/integritee_polkadot" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-polkadot", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-polkadot.md" }, { "slug": "chain-tron", "name": "Tron", "summary": "Tron is a public blockchain network. Confidentiality on Tron: Shielded standard never shipped.", "kind": "chain", "category": "Shielded standard never shipped", "sodaBacked": false, "description": "Shielded TRC-20 was specified back in 2020, using zk-SNARKs to hide addresses and amounts, and it never left the Nile testnet in any meaningful form. Tron moves enormous stablecoin volume across a fully transparent ledger, and its own quarterly reporting no longer covers the shielded standard at all.", "tags": [ "no live privacy" ], "sources": [ { "label": "Shielded TRC-20 spec", "url": "https://github.com/tronprotocol/documentation-en/blob/master/docs/mechanism-algorithm/shielded-TRC20-contract.md" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-tron", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-tron.md" }, { "slug": "chain-bitcoin", "name": "Bitcoin", "summary": "Bitcoin is a public blockchain network. Confidentiality on Bitcoin: Coordination-based privacy only.", "kind": "chain", "category": "Coordination-based privacy only", "sodaBacked": false, "description": "Bitcoin has no confidential transactions. Privacy depends on coordination techniques such as CoinJoin, PayJoin and silent payments, and that layer took heavy legal damage: Samourai's founders were sentenced and zkSNACKs closed its coordinator, leaving smaller anonymity sets behind. Bitcoin Core still ships no wallet-level support for silent payments.", "tags": [ "no native privacy", "coinjoin" ], "sources": [ { "label": "Tool comparison", "url": "https://www.spark.money/tools/bitcoin-privacy-tools-comparison" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-bitcoin", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-bitcoin.md" }, { "slug": "chain-ton", "name": "TON", "summary": "TON is a public blockchain network. Confidentiality on TON: No financial privacy today.", "kind": "chain", "category": "No financial privacy today", "sodaBacked": false, "description": "TON has no shielded transactions. Catchain 2.0 sped up on-chain proof verification in April 2026, which enables future privacy work rather than delivering it. In practice the ecosystem offers a small Tornado-style mixer and Telegram's Cocoon network for confidential AI inference, which protects computation rather than money.", "tags": [ "no native privacy" ], "sources": [ { "label": "Catchain 2.0", "url": "https://www.kucoin.com/blog/ton-catchain-2-upgrade-telegram-mini-apps-guide" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-ton", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-ton.md" }, { "slug": "chain-monad", "name": "Monad", "summary": "Monad is a public blockchain network. Confidentiality on Monad: Third-party privacy pool.", "kind": "chain", "category": "Third-party privacy pool", "sodaBacked": false, "description": "Monad launched in November 2025 as a transparent parallel EVM. Privacy arrived in June 2026 through Unlink, a third-party pool where balances are held encrypted and moved with ZK proofs. It is portable EVM infrastructure rather than anything chain specific, and it is still measured in weeks rather than years.", "tags": [ "third-party layers", "ZK" ], "sources": [ { "label": "Unlink on Monad", "url": "https://blog.monad.xyz/blog/privacy-comes-to-monad-with-unlink" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-monad", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-monad.md" }, { "slug": "chain-optimism", "name": "Optimism", "summary": "Optimism is a public blockchain network. Confidentiality on Optimism: Vendor-gated privacy.", "kind": "chain", "category": "Vendor-gated privacy", "sodaBacked": false, "description": "Privacy on the OP Stack arrived in April 2026 through Sunnyside Labs' Privacy Boost, a hybrid of ZK proofs and trusted execution offering confidential transfers and sanctions screening. It runs on OP Mainnet for that vendor's customers rather than as a protocol default, and nothing privacy related sits in the OP Stack or Superchain standards. So the guarantee rests on one vendor's hardware assumptions on top of a transparent base layer.", "tags": [ "third-party layers", "TEE", "ZK" ], "sources": [ { "label": "Privacy on the OP Stack", "url": "https://www.optimism.io/blog/privacy-comes-to-the-op-stack" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-optimism", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-optimism.md" }, { "slug": "chain-zksync", "name": "zkSync Era", "summary": "zkSync Era is a public blockchain network. Confidentiality on zkSync Era: Privacy only on permissioned instances.", "kind": "chain", "category": "Privacy only on permissioned instances", "sodaBacked": false, "description": "Public zkSync Era has no confidentiality. Its ZK proofs serve scaling, and the Atlas upgrade is about throughput. The privacy option is Prividium, a licensed permissioned L2 whose data stays off the public chain while proofs settle on Ethereum, first deployed with Deutsche Bank. In other words, privacy on zkSync today means leaving the public chain for an instance you have to license.", "tags": [ "no native privacy", "permissioned" ], "sources": [ { "label": "Prividium", "url": "https://docs.zksync.io/zk-stack/prividium/overview" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-zksync", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-zksync.md" }, { "slug": "chain-linea", "name": "Linea", "summary": "Linea is a public blockchain network. Confidentiality on Linea: No privacy live today.", "kind": "chain", "category": "No privacy live today", "sodaBacked": false, "description": "Linea's reputation for privacy is largely inherited from zkEVM branding and its Consensys enterprise heritage. Nothing shielded is live: the 2026 work is Type-1 zkEVM, a RISC-V pivot and sequencer decentralization, while the Status merge promises gasless ephemeral accounts rather than hidden amounts. Institutional pilots citing selective disclosure remain pilots. User transactions are fully public today.", "tags": [ "no native privacy" ], "sources": [ { "label": "Linea", "url": "https://linea.build" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-linea", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-linea.md" }, { "slug": "chain-celo", "name": "Celo", "summary": "Celo is a public blockchain network. Confidentiality on Celo: Enterprise pilots only.", "kind": "chain", "category": "Enterprise pilots only", "sodaBacked": false, "description": "Celo became an OP Stack L2 in 2025, fully transparent at the base layer. Ligero's integration in July 2026 brought KYC-gated private payments aimed at payroll and treasury, and the older SocialConnect service still protects phone-number lookups rather than payments. Meanwhile roughly 16 million MiniPay wallets transact in full public view, which is the real measure of the gap.", "tags": [ "third-party layers", "KYC-gated" ], "sources": [ { "label": "Ligero on Celo", "url": "https://blog.celo.org/ligero-integrates-celo-unlocking-compliant-private-payments-on-cryptos-leading-stablecoin-network-03017df1d874" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-celo", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-celo.md" }, { "slug": "chain-scroll", "name": "Scroll", "summary": "Scroll is a public blockchain network. Confidentiality on Scroll: No privacy work.", "kind": "chain", "category": "No privacy work", "sodaBacked": false, "description": "Scroll has no privacy features and no privacy roadmap, so confidentiality there means Ethereum's ordinary pseudonymity. The wider context is a chain under strain: total value locked is down sharply from its 2024 peak, a major protocol migrated away, and governance has been cutting scope through 2026.", "tags": [ "no native privacy" ], "sources": [ { "label": "Scroll", "url": "https://scroll.io" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-scroll", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-scroll.md" }, { "slug": "chain-berachain", "name": "Berachain", "summary": "Berachain is a public blockchain network. Confidentiality on Berachain: No privacy story.", "kind": "chain", "category": "No privacy story", "sodaBacked": false, "description": "Berachain has no privacy features, no privacy partnerships and nothing privacy related on its 2026 roadmap. There is an architectural reason as well as a scheduling one: Proof of Liquidity depends on liquidity and emissions data being public, which makes confidentiality awkward to retrofit.", "tags": [ "no native privacy" ], "sources": [ { "label": "Berachain", "url": "https://www.berachain.com" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-berachain", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-berachain.md" }, { "slug": "chain-xdc", "name": "XDC Network", "summary": "XDC Network is a public blockchain network. Confidentiality on XDC Network: Bubble live · no native privacy.", "kind": "chain", "category": "Bubble live · no native privacy", "sodaBacked": false, "description": "XDC Network is an EVM-compatible layer 1 built around trade finance and tokenized real-world assets, running delegated proof of stake with fast finality and near-zero fees. It ships no native confidentiality: balances, counterparties and amounts are public, which is a hard blocker for the trade-finance flows it targets. Bubble adds encrypted balances and confidential transfers at the application layer with the standard Solidity toolchain.", "tags": [ "Soda support", "no native privacy", "trade finance" ], "sources": [ { "label": "XDC Network", "url": "https://xdc.org" } ], "url": "https://www.sodalabs.xyz/privacy-hub/chain-xdc", "markdown": "https://www.sodalabs.xyz/privacy-hub/chain-xdc.md" }, { "slug": "tok-paypal", "name": "PayPal", "summary": "PayPal: Stablecoin issuer. Confidentiality status: Pilot.", "kind": "token", "category": "Stablecoin issuer", "privacyStatus": "pilot", "privacyStatusLabel": "Pilot", "sodaBacked": false, "description": "PYUSD is the clearest example of privacy that exists on paper only. Solana's confidential transfer extension was initialized on the PYUSD mint at launch in 2024 and has never been switched on, so balances and amounts stay public. PayPal frames it as optionality pending regulatory clarity, which is exactly the gap a compliant confidentiality layer is meant to close.", "tags": [ "stablecoin", "PYUSD" ], "sources": [ { "label": "PayPal on token extensions", "url": "https://developer.paypal.com/community/blog/pyusd-solana-token-extensions/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-paypal", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-paypal.md" }, { "slug": "tok-jpmorgan", "name": "JPMorgan", "summary": "JPMorgan: Bank · deposit tokens and payments. Confidentiality status: Pilot.", "kind": "token", "category": "Bank · deposit tokens and payments", "privacyStatus": "pilot", "privacyStatusLabel": "Pilot", "sodaBacked": false, "description": "The deepest privacy research programme among the banks. Project EPIC is an explicit proof of concept in JPMorgan's Kinexys sandbox combining zero-knowledge proofs and fully homomorphic encryption with several vendors. Serious work, not yet production.", "tags": [ "bank", "R&D" ], "sources": [ { "label": "Project EPIC", "url": "https://www.jpmorgan.com/kinexys/content-hub/project-epic-enterprise-privacy-identity-composability" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-jpmorgan", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-jpmorgan.md" }, { "slug": "tok-hsbc", "name": "HSBC", "summary": "HSBC: Bank · tokenized deposits. Confidentiality status: Pilot.", "kind": "token", "category": "Bank · tokenized deposits", "privacyStatus": "pilot", "privacyStatusLabel": "Pilot", "sodaBacked": false, "description": "HSBC is among the seventeen banks in SWIFT's shared ledger pilot for tokenized deposits, where privacy and data localisation are named as open challenges and zero-knowledge proofs are cited as a possible answer rather than a shipped component.", "tags": [ "bank", "payments" ], "sources": [ { "label": "Pilot coverage", "url": "https://www.fintechfutures.com/blockchain-crypto-digital-assets/swift-launches-blockchain-ledger" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-hsbc", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-hsbc.md" }, { "slug": "tok-ripple", "name": "Ripple", "summary": "Ripple: Payments and stablecoin issuer. Confidentiality status: Announced.", "kind": "token", "category": "Payments and stablecoin issuer", "privacyStatus": "announced", "privacyStatusLabel": "Announced", "sodaBacked": false, "description": "Ripple Research published a Confidential MPT design in March 2026, using EC-ElGamal encrypted balances with zero-knowledge proofs to hide amounts while keeping sender, receiver and total supply auditable. It is a proposed amendment rather than a live feature, and RLUSD is transparent today.", "tags": [ "stablecoin", "XRPL" ], "sources": [ { "label": "The paper", "url": "https://eprint.iacr.org/2026/602" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-ripple", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-ripple.md" }, { "slug": "tok-mastercard", "name": "Mastercard", "summary": "Mastercard: Payments network. Confidentiality status: Exploring.", "kind": "token", "category": "Payments network", "privacyStatus": "exploring", "privacyStatusLabel": "Exploring", "sodaBacked": false, "description": "Mastercard's Multi-Token Network is a permissioned environment for tokenized deposits, and its Verifiable Intent work uses selective disclosure so each party sees only what it needs. Both are identity and data-minimization layers rather than confidential amounts or balances on chain.", "tags": [ "payments" ], "sources": [ { "label": "Mastercard newsroom", "url": "https://www.mastercard.com/news/media/5zmixdjy/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-mastercard", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-mastercard.md" }, { "slug": "tok-uniswap", "name": "Uniswap", "summary": "Uniswap: Decentralized exchange. Confidentiality status: Exploring.", "kind": "token", "category": "Decentralized exchange", "privacyStatus": "exploring", "privacyStatusLabel": "Exploring", "sodaBacked": false, "description": "Every swap, amount and liquidity position on Uniswap is public. A third-party proposal to add execution privacy through v4 hooks reached technical review in mid 2026 with no prototype or deployment, and the private Uniswap experiences people cite are all external wrappers. Order flow protection is not the same as confidentiality.", "tags": [ "DeFi", "DEX" ], "sources": [ { "label": "The proposal", "url": "https://gov.uniswap.org/t/rfc-native-execution-privacy-in-the-uniswap-interface-via-v4-hooks-and-uniswapx/26208" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-uniswap", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-uniswap.md" }, { "slug": "tok-tokeny", "name": "Tokeny", "summary": "Tokeny: Tokenization platform · ERC-3643. Confidentiality status: Exploring.", "kind": "token", "category": "Tokenization platform · ERC-3643", "privacyStatus": "exploring", "privacyStatusLabel": "Exploring", "sodaBacked": false, "description": "Tokeny created the permissioned token standard behind much of institutional RWA issuance, and its identity layer stores hashes rather than personal data. Balances and transfers stay fully public, which the company itself calls the last blocker for open finance, saying it is working with privacy providers. Nothing has shipped.", "tags": [ "RWA", "standards" ], "sources": [ { "label": "Their position", "url": "https://tokeny.com/transaction-privacy-the-last-blocker-for-massive-open-finance-adoption/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-tokeny", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-tokeny.md" }, { "slug": "tok-backed", "name": "Backed Finance", "summary": "Backed Finance: Tokenized equities. Confidentiality status: Exploring.", "kind": "token", "category": "Tokenized equities", "privacyStatus": "exploring", "privacyStatusLabel": "Exploring", "sodaBacked": false, "description": "Backed mints its tokenized stocks on Solana with confidential balances initialized but switched off, the same pattern as PYUSD. The capability is permanently baked into the token and unused, while compliance runs through transfer hooks and a permanent delegate instead.", "tags": [ "RWA", "equities" ], "sources": [ { "label": "Case study", "url": "https://solana.com/news/case-study-xstocks" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-backed", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-backed.md" }, { "slug": "tok-anchorage", "name": "Anchorage Digital", "summary": "Anchorage Digital: Custody · federally chartered bank. Confidentiality status: Exploring.", "kind": "token", "category": "Custody · federally chartered bank", "privacyStatus": "exploring", "privacyStatusLabel": "Exploring", "sodaBacked": false, "description": "Anchorage's researchers publish on zero-knowledge techniques, and its venture arm explicitly asks founders for systems that prove KYC or reserve adequacy without exposing metadata. That is research and investment interest; the custody product has no confidential transfer capability.", "tags": [ "custody", "research" ], "sources": [ { "label": "Request for startups", "url": "https://www.anchorage.com/insights/anchorage-digital-ventures-request-for-startups" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-anchorage", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-anchorage.md" }, { "slug": "tok-ethena", "name": "Ethena", "summary": "Ethena: Synthetic dollar protocol. Confidentiality status: No privacy yet.", "kind": "token", "category": "Synthetic dollar protocol", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "USDe is a plain ERC-20 with fully transparent balances and no public confidentiality work. The documentation covers whitelist gating for mint and redeem, and openly describes collecting on-chain data. For a product whose whole mechanism is a hedged position, public flows are strategy leakage.", "tags": [ "stablecoin", "DeFi" ], "sources": [ { "label": "Docs", "url": "https://docs.ethena.fi/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-ethena", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-ethena.md" }, { "slug": "tok-agora", "name": "Agora", "summary": "Agora: White-label stablecoin issuer. Confidentiality status: No privacy yet.", "kind": "token", "category": "White-label stablecoin issuer", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Agora issues institutional digital dollars across several chains with no privacy features, no confidential transfer extension and no public statements on the topic. The product story is reserves, yield sharing and interoperability.", "tags": [ "stablecoin" ], "sources": [ { "label": "AUSD", "url": "https://www.agora.finance/product/ausd" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-agora", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-agora.md" }, { "slug": "tok-firstdigital", "name": "First Digital", "summary": "First Digital: Stablecoin issuer. Confidentiality status: No privacy yet.", "kind": "token", "category": "Stablecoin issuer", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "FDUSD moves significant volume with nothing public on transaction privacy. The messaging is reserves, attestations and transparency, and the only confidentiality language in its materials concerns corporate data protection rather than on-chain amounts.", "tags": [ "stablecoin" ], "sources": [ { "label": "FDUSD", "url": "https://www.firstdigitallabs.com/fdusd" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-firstdigital", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-firstdigital.md" }, { "slug": "tok-blackrock", "name": "BlackRock", "summary": "BlackRock: Asset manager · tokenized fund. Confidentiality status: No privacy yet.", "kind": "token", "category": "Asset manager · tokenized fund", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "BUIDL is the most cited example of the transparency problem in tokenized funds. Every mint, transfer, redemption and holder balance is readable on a block explorer, and the allowlist that gates participation is access control rather than confidentiality. Coverage through 2026 has treated this openness as a structural liability once institutional desks trade at scale.", "tags": [ "asset manager", "fund" ], "sources": [ { "label": "The privacy paradox", "url": "https://www.forbes.com/sites/digital-assets/2026/04/02/the-privacy-paradox-in-on-chain-finance/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-blackrock", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-blackrock.md" }, { "slug": "tok-fidelity", "name": "Fidelity", "summary": "Fidelity: Asset manager · tokenized fund. Confidentiality status: No privacy yet.", "kind": "token", "category": "Asset manager · tokenized fund", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Fidelity's tokenized treasury fund launched on public Ethereum in 2025 with balances visible on chain, and no privacy technology, partnership or public statement has followed.", "tags": [ "asset manager", "fund" ], "sources": [ { "label": "Launch coverage", "url": "https://www.coindesk.com/business/2025/09/09/fidelity-s-tokenized-money-market-fund-rolled-out-on-ethereum-with-ondo-holding-usd202m" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-fidelity", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-fidelity.md" }, { "slug": "tok-wisdomtree", "name": "WisdomTree", "summary": "WisdomTree: Asset manager · tokenized funds. Confidentiality status: No privacy yet.", "kind": "token", "category": "Asset manager · tokenized funds", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "WisdomTree's tokenized funds allow peer to peer transfers between onboarded wallets while the transfer agent holds the official register. That is gating and off-chain bookkeeping rather than confidentiality: what happens on chain remains visible.", "tags": [ "asset manager", "fund" ], "sources": [ { "label": "WisdomTree Connect", "url": "https://www.wisdomtreeconnect.com/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-wisdomtree", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-wisdomtree.md" }, { "slug": "tok-hamiltonlane", "name": "Hamilton Lane", "summary": "Hamilton Lane: Asset manager · private markets. Confidentiality status: No privacy yet.", "kind": "token", "category": "Asset manager · private markets", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Hamilton Lane's tokenized credit funds run across several public chains, and recent work has increased visibility rather than reduced it, extending composability and multichain reach. No privacy work is public.", "tags": [ "asset manager", "private credit" ], "sources": [ { "label": "Fund overview", "url": "https://securitize.io/learn/press/hamilton-lane-funds" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-hamiltonlane", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-hamiltonlane.md" }, { "slug": "tok-apollo", "name": "Apollo", "summary": "Apollo: Asset manager · private credit. Confidentiality status: No privacy yet.", "kind": "token", "category": "Asset manager · private credit", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Apollo's tokenized private credit fund trades on public infrastructure with no privacy feature or public statement on confidentiality, so allocations and movements are observable by anyone who cares to watch.", "tags": [ "asset manager", "private credit" ], "sources": [ { "label": "Launch coverage", "url": "https://www.coindesk.com/business/2025/01/30/apollo-unveils-tokenized-private-credit-fund-as-blockchain-deepens-tradfi-links" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-apollo", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-apollo.md" }, { "slug": "tok-securitize", "name": "Securitize", "summary": "Securitize: Tokenization platform · transfer agent. Confidentiality status: No privacy yet.", "kind": "token", "category": "Tokenization platform · transfer agent", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "The largest tokenization platform solves confidentiality by keeping the holder register off chain at the transfer agent while on-chain tokens use permissioned allowlists. It works, but it means the register's privacy depends on a database rather than on cryptography, and everything that does happen on chain stays public.", "tags": [ "RWA", "transfer agent" ], "sources": [ { "label": "Platform news", "url": "https://www.ledgerinsights.com/securitize-to-be-first-digital-transfer-agent-for-nyse-tokenized-securities-platform/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-securitize", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-securitize.md" }, { "slug": "tok-aave", "name": "Aave", "summary": "Aave: Onchain lending. Confidentiality status: No privacy yet.", "kind": "token", "category": "Onchain lending", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Balances, health factors and liquidation thresholds are public on Aave, which is precisely the data that gets positions hunted. Privacy work has been limited to trials of private governance voting, and shielded deposits exist only through third-party wrappers.", "tags": [ "DeFi", "lending" ], "sources": [ { "label": "Governance trial", "url": "https://governance.aave.com/t/arfc-private-voting-for-aave-governance-2-month-trial/12730" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-aave", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-aave.md" }, { "slug": "tok-curve", "name": "Curve", "summary": "Curve: Stableswap exchange. Confidentiality status: No privacy yet.", "kind": "token", "category": "Stableswap exchange", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "No privacy product, research track or governance proposal on confidential swaps. Curve's pools, trades and positions are fully public, and its most famous incident involved a founder's visible position being liquidated as the market watched.", "tags": [ "DeFi", "DEX" ], "sources": [ { "label": "Curve", "url": "https://curve.finance" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-curve", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-curve.md" }, { "slug": "tok-lido", "name": "Lido", "summary": "Lido: Liquid staking. Confidentiality status: No privacy yet.", "kind": "token", "category": "Liquid staking", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Stake sizes, rewards and vault activity are all public, and Lido's 2026 work centres on modularity and vaults rather than confidentiality. For institutions staking at scale, the position is a public disclosure.", "tags": [ "DeFi", "staking" ], "sources": [ { "label": "stVaults", "url": "https://lido.fi/stvaults" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-lido", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-lido.md" }, { "slug": "tok-centrifuge", "name": "Centrifuge", "summary": "Centrifuge: Tokenization platform · credit. Confidentiality status: No privacy yet.", "kind": "token", "category": "Tokenization platform · credit", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Centrifuge's privacy language refers to the off-chain exchange of loan documents on its older chain rather than transaction confidentiality. Since the 2025 migration to its EVM-native V3, vaults, net asset values and holders are visible to whitelisted wallets rather than fully public, and the roadmap is institutional integration rather than privacy.", "tags": [ "RWA", "credit" ], "sources": [ { "label": "V3", "url": "https://centrifuge.io/blog/centrifuge-v3-1" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-centrifuge", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-centrifuge.md" }, { "slug": "tok-superstate", "name": "Superstate", "summary": "Superstate: Tokenized funds and equities. Confidentiality status: No privacy yet.", "kind": "token", "category": "Tokenized funds and equities", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Superstate keeps its share register off chain and markets real-time shareholder visibility to issuers, which is the opposite of holder confidentiality. No zero-knowledge, FHE or enclave work has been published.", "tags": [ "RWA", "fund" ], "sources": [ { "label": "Opening Bell", "url": "https://docs.superstate.com/issuers/opening-bell" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-superstate", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-superstate.md" }, { "slug": "tok-swarm", "name": "Swarm Markets", "summary": "Swarm Markets: Regulated DeFi venue. Confidentiality status: No privacy yet.", "kind": "token", "category": "Regulated DeFi venue", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Swarm's private offers gate who can see an order rather than encrypting anything, so settlement, amounts and addresses remain public on chain with KYC applied at the perimeter.", "tags": [ "RWA", "regulated" ], "sources": [ { "label": "dOTC paper", "url": "https://swarm.com/swarm-markets-dotc-white-paper/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-swarm", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-swarm.md" }, { "slug": "tok-brickken", "name": "Brickken", "summary": "Brickken: Tokenization platform · SMEs. Confidentiality status: No privacy yet.", "kind": "token", "category": "Tokenization platform · SMEs", "privacyStatus": "none", "privacyStatusLabel": "No privacy yet", "sodaBacked": false, "description": "Brickken's material covers onboarding, dividend distribution and information security rather than on-chain confidentiality. Its privacy commitments concern data handling, not what the ledger publishes about issuers and holders.", "tags": [ "RWA", "issuance" ], "sources": [ { "label": "Platform", "url": "https://www.brickken.com/securities-tokenization" } ], "url": "https://www.sodalabs.xyz/privacy-hub/tok-brickken", "markdown": "https://www.sodalabs.xyz/privacy-hub/tok-brickken.md" } ], "regulation": [ { "slug": "why-travel-rule", "name": "The travel rule binds institutions, not ledgers", "summary": "The travel rule binds institutions, not ledgers: The rule everyone assumes ends on-chain confidentiality. Region: Global.", "kind": "theme", "region": "Global", "category": "The rule everyone assumes ends on-chain confidentiality", "description": "The most common objection to confidential transfers is that the travel rule forbids them. Read the standard and it does not. Recommendation 16 obliges the institution to obtain, hold and transmit originator and beneficiary details to the counterparty institution. Nothing requires that data to be written into the transaction, and in practice it never is: compliant systems move an IVMS101 payload over a separate channel while value settles on chain. On a transparent chain the names are already off-chain. Making the value leg confidential changes neither the duty nor the ability to discharge it. What stays genuinely hard is the other side: due diligence toward self-hosted wallets, where there is no counterparty institution to message, and the sunrise problem of uneven adoption between jurisdictions.", "instruments": [ { "label": "FATF Recommendation 16", "note": "obliges financial institutions and VASPs to obtain, hold and transmit originator and beneficiary data to the counterparty institution" }, { "label": "IVMS101", "note": "the interVASP messaging standard the data actually travels in, carried by TRISA, TRP or OpenVASP over a separate channel" }, { "label": "Revised at the June 2025 plenary", "note": "broadened to fraud and proliferation financing, with implementation expected by end-2030" } ], "tags": [ "travel rule", "IVMS101", "off-chain messaging", "sunrise problem" ], "sources": [ { "label": "FATF best practices on travel rule supervision", "url": "https://www.fatf-gafi.org/content/dam/fatf-gafi/recommendations/Best-Practices-Travel-Rule-Supervision.pdf" }, { "label": "OpenVASP Travel Rule Protocol", "url": "https://gitlab.com/OpenVASP/travel-rule-protocol/-/blob/master/core/specification.md" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-travel-rule", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-travel-rule.md" }, { "slug": "why-erasure", "name": "Erasure against an append-only ledger", "summary": "Erasure against an append-only ledger: The one collision with no clean answer yet. Region: Global.", "kind": "theme", "region": "Global", "category": "The one collision with no clean answer yet", "description": "This is the collision that does not dissolve on closer reading. European regulators treat a public key as personal data wherever it can identify someone, and are explicit that encryption does not take data outside the rules, nor does hashing. Against that sits an append-only ledger. The EDPB's answer is architectural rather than doctrinal: keep personal data off chain, and design so that on-chain data can be rendered effectively anonymous when erasure is requested. It concedes this is technically demanding while insisting technical impossibility is no defence. Destroying a decryption key is treated as making data unintelligible rather than erased. Commitments fare better, since deleting the original and its witness leaves something genuinely useless behind. No supervisor or court has yet tested either in a contested case.", "instruments": [ { "label": "EDPB Guidelines 02/2025, §26", "note": "public keys are personal data where they can identify individuals by means reasonably likely to be used" }, { "label": "§§51-52", "note": "encrypted personal data is still personal data, and a hash will also be considered personal data" }, { "label": "§50 and §103", "note": "deletion may be technically impracticable, but technical impossibility cannot be invoked to justify non-compliance" }, { "label": "§53", "note": "cryptographic commitments treated more favourably, since once the original data and its witness are deleted, the commitment persisting on chain is useless" } ], "tags": [ "GDPR Article 17", "immutability", "commitments", "key destruction", "unresolved" ], "sources": [ { "label": "EDPB Guidelines 02/2025 (final, 7 July 2026)", "url": "https://www.edpb.europa.eu/system/files/2026-07/edpb_guidelines_202502_blockchain_v2_en.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-erasure", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-erasure.md" }, { "slug": "why-viewing-keys", "name": "Selective disclosure as a compliance primitive", "summary": "Selective disclosure as a compliance primitive: Bilateral disclosure versus publishing to everyone. Region: Global.", "kind": "theme", "region": "Global", "category": "Bilateral disclosure versus publishing to everyone", "description": "Supervisory access, external audit and suspicious activity reporting are all bilateral disclosures to a named party under a legal duty. Public-ledger transparency is something else entirely: universal, unauthorised disclosure to everyone, permanently. No other part of the financial system is asked for the second in order to satisfy the first. Viewing keys are the oldest worked example, letting a holder share visibility of shielded activity without surrendering the ability to spend, and they are already used for exchange deposit detection and custodian-to-auditor disclosure. Threshold decryption generalises this to a quorum. Two honest caveats. We found no regulator that has endorsed the pattern in guidance, so this is an argument from structure rather than from authority. And viewing keys are blunt: per address, retrospective and prospective at once, with no revocation once shared.", "instruments": [ { "label": "Zcash viewing keys", "note": "derived from the spending key; an incoming viewing key detects deposits, a full viewing key exposes value, memo and target address without exposing the spend key" }, { "label": "Threshold and auditor keys", "note": "generalise the same idea to a quorum, removing the single point of failure a lone disclosure key creates" } ], "tags": [ "viewing keys", "selective disclosure", "auditor access", "no regulator endorsement yet" ], "sources": [ { "label": "Electric Coin Company on viewing keys", "url": "https://electriccoin.co/blog/explaining-viewing-keys-2/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-viewing-keys", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-viewing-keys.md" }, { "slug": "why-privacy-pools", "name": "Proving where funds did not come from", "summary": "Proving where funds did not come from: Association sets, and the Tornado Cash aftermath. Region: Global.", "kind": "theme", "region": "Global", "category": "Association sets, and the Tornado Cash aftermath", "description": "The 2023 Privacy Pools paper made a design argument that has held up: instead of hiding everything, let a depositor prove in zero knowledge that their withdrawal belongs to a chosen set of deposits, or does not belong to a flagged one. Honest users dissociate from illicit funds without revealing which deposit is theirs, and the policy judgement moves to an identifiable, contestable curator rather than sitting in the protocol. A mainnet implementation launched in 2025. The contrast with Tornado Cash is instructive rather than settled: the Fifth Circuit held in November 2024 that OFAC had exceeded its authority because nobody controls an immutable contract, and the sanction was lifted in March 2025. The criminal case against Roman Storm is a separate matter and remains live, so treat anything you read about it as provisional.", "instruments": [ { "label": "Privacy Pools (Buterin, Illum, Nadler, Schär, Soleimani, September 2023)", "note": "prove in zero knowledge that a withdrawal comes from a chosen association set, or not from a flagged one, without revealing which deposit is yours" }, { "label": "Van Loon v. Department of the Treasury (5th Cir., November 2024)", "note": "OFAC exceeded its authority; immutable deployed contracts are not property of a foreign national because no one controls them" }, { "label": "Tornado Cash delisted March 2025", "note": "following the ruling; the Roman Storm prosecution is separate and still live" } ], "tags": [ "privacy pools", "association sets", "Tornado Cash", "live litigation" ], "sources": [ { "label": "Blockchain Privacy and Regulatory Compliance (SSRN)", "url": "https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4563364" }, { "label": "0xbow Privacy Pools launch coverage", "url": "https://www.theblock.co/post/348959/0xbow-privacy-pools-new-cypherpunk-tool-inspired-research-ethereum-founder-vitalik-buterin" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-privacy-pools", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-privacy-pools.md" }, { "slug": "why-central-banks-build-privacy", "name": "Central banks are building confidentiality themselves", "summary": "Central banks are building confidentiality themselves: What the people writing the rules do when they design money. Region: Global.", "kind": "theme", "region": "Global", "category": "What the people writing the rules do when they design money", "description": "The strongest evidence that public authorities do not equate confidentiality with wrongdoing is that they keep building it. The BIS Innovation Hub's Tourbillon prototypes, developed with the Swiss National Bank, were designed around payer anonymity: a consumer pays without revealing personal information to the merchant, to the banks or to the central bank, while the payee remains identified to their own bank. The BIS presents this as compatible with anti-money-laundering aims rather than in tension with them, precisely because the receiving side stays legible. The Bank of England has run comparable work on offline digital pound payments. Read together with the digital euro's offline design, the pattern is consistent: asymmetric privacy, where the party being paid is known and the party paying is not, is a design regulators actively pursue.", "instruments": [ { "label": "BIS Project Tourbillon (final report, November 2023)", "note": "retail CBDC prototypes built around payer anonymity, where the central bank sees the amount but not the consumer or the merchant, while the payee stays identified to their own bank" }, { "label": "Bank of England digital pound offline payments report (2025)", "note": "assessed pseudonymisation, ephemeral key management and confidential computing with commercial partners" } ], "tags": [ "CBDC", "Project Tourbillon", "payer anonymity", "precedent" ], "sources": [ { "label": "BIS Project Tourbillon", "url": "https://www.bis.org/about/bisih/topics/cbdc/tourbillon.htm" }, { "label": "Bank of England offline payments experiment", "url": "https://www.bankofengland.co.uk/report/2025/digital-pound-experiment-report-offline-payments" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-central-banks-build-privacy", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-central-banks-build-privacy.md" }, { "slug": "why-institutions-need-it", "name": "Why regulated institutions cannot use a transparent ledger", "summary": "Why regulated institutions cannot use a transparent ledger: The demand side, which is usually left out of the debate. Region: Global.", "kind": "theme", "region": "Global", "category": "The demand side, which is usually left out of the debate", "description": "The compliance debate usually asks whether institutions are permitted to use confidentiality. The prior question is whether they can function without it. An institution operating on a fully transparent ledger publishes its order flow, inviting anyone to trade ahead of it; its counterparty set and exposures; its treasury positions; its payroll; and its clients' commercial terms. Where counterparties are people, it also publishes personal data that data protection law obliges it to minimise. No regulator asks for any of this. Public visibility is a property of the ledger, not a supervisory requirement, and the two are constantly confused. The revealed preference shows up in architecture: institutional settlement has concentrated on permissioned networks whose main selling point is that only the transacting parties see the trade.", "instruments": [ { "label": "Order flow and positions", "note": "a public ledger publishes trading intent ahead of execution, and counterparty exposures continuously" }, { "label": "Commercial and personal data", "note": "payroll, client terms and counterparty identity, which the institution is separately obliged to minimise under data protection law" }, { "label": "No rule requires it", "note": "no supervisor anywhere asks a bank to publish its balances to the public; the transparency is an artefact of the ledger, not a regulatory demand" } ], "tags": [ "front-running", "commercial confidentiality", "permissioned networks", "demand side" ], "sources": [ { "label": "Kinexys and MIT DCI on public blockchains for regulated institutions", "url": "https://www.jpmorgan.com/payments/newsroom/kinexys-mit-dci-public-blockchain-adoption" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-institutions-need-it", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-institutions-need-it.md" }, { "slug": "why-sanctions-screening", "name": "Sanctions screening on a confidential ledger", "summary": "Sanctions screening on a confidential ledger: The genuinely open problem. Region: Global.", "kind": "theme", "region": "Global", "category": "The genuinely open problem", "description": "Worth stating plainly rather than glossing: this is the weakest part of the case for confidential ledgers. Sanctions liability under the US regime attaches without knowledge or intent, so any design that leaves a regulated intermediary unable to determine whether it dealt with a designated party hands that intermediary unmanaged legal risk. That mechanism, more than any explicit prohibition, is what drives delisting. The architectural answer is that screening does not require public amounts and parties, only that somebody with the duty can screen: at the on-ramp and off-ramp where identity already exists, inside the state machine as issuer policy, or through authorised disclosure. The unsolved parts are real. Designations are retroactive while proofs are historical, and a shielded transfer between two self-custodied parties has no intermediary at all. We found no regulator guidance and no enforcement precedent on any of it.", "instruments": [ { "label": "Strict liability", "note": "OFAC liability attaches without knowledge or intent, so a design that leaves an intermediary unable to tell whom it dealt with transfers unmanaged legal risk to that intermediary" }, { "label": "Where screening can still happen", "note": "at the regulated on-ramp and off-ramp where identity already exists, inside the confidential state machine as issuer policy, or by disclosure to the obliged entity" }, { "label": "What has no clean answer", "note": "designations are retroactive while proofs are historical, and a shielded peer-to-peer transfer has no intermediary to do the screening" } ], "tags": [ "sanctions", "OFAC", "strict liability", "open problem" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-sanctions-screening", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-sanctions-screening.md" }, { "slug": "why-programmable-confidentiality", "name": "Anonymity is not the same thing as confidentiality", "summary": "Anonymity is not the same thing as confidentiality: Why two privacy designs get treated differently. Region: Global.", "kind": "theme", "region": "Global", "category": "Why two privacy designs get treated differently", "description": "Regulators keep drawing a line that the debate tends to flatten. What the instruments actually turn on is who holds the disclosure lever, not how strong the cryptography is. A protocol with mandatory, protocol-level anonymity leaves a regulated intermediary with no compliant posture at all, because it cannot produce records it has no mechanism to obtain. A design with encrypted state and a disclosure path leaves that intermediary roughly where it sits in conventional finance: data confidential from the public, available to the authorised party. Two caveats we would rather state ourselves. This is our reading of the drafting, not a position any regulator has published. And issuer-retained control is a real centralisation risk, not a free win. The EU's key phrase, increased obfuscation of transactions, is undefined, and AMLA guidance will decide how far it reaches.", "instruments": [ { "label": "AMLR Article 79 turns on the account", "note": "it prohibits obliged entities from keeping accounts allowing anonymisation of the holder, or anonymisation or increased obfuscation of transactions" }, { "label": "The lever, not the cryptography", "note": "protocol-level mandatory anonymity leaves an intermediary with no compliant posture; optional shielding with disclosure keys leaves a workable one" }, { "label": "This cuts both ways", "note": "issuer-retained disclosure control is itself a centralisation and abuse surface, and encrypted personal data is still personal data" } ], "tags": [ "anonymity vs confidentiality", "Article 79", "our reading", "undefined terms" ], "sources": [ { "label": "Regulation (EU) 2024/1624, Article 79", "url": "https://eur-lex.europa.eu/eli/reg/2024/1624/oj/eng" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/why-programmable-confidentiality", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/why-programmable-confidentiality.md" }, { "slug": "reg-mica", "name": "MiCA", "summary": "MiCA (European Union · ESMA): Market licensing · Regulation (EU) 2023/1114. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Europe", "category": "Market licensing · Regulation (EU) 2023/1114", "authority": "European Union · ESMA", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "MiCA carries exactly one operative anonymity rule, and it is narrower than its reputation. Article 76(3) requires a trading platform's operating rules to prevent admission of crypto-assets with an inbuilt anonymisation function, unless the platform can identify the holders and their transaction history. It binds trading venues only: custody, transfer, exchange and execution are untouched, no coin is named, and \"inbuilt anonymisation function\" is left undefined. ESMA has issued no guidance interpreting it, so national competent authorities apply it with varying strictness, which is where listing fragmentation across the bloc comes from. Titles III and IV applied from 30 June 2024, the CASP regime from 30 December 2024, and national grandfathering closed for good on 1 July 2026.", "instruments": [ { "label": "Article 76(3)", "note": "trading platforms may not admit assets with an inbuilt anonymisation function unless holders and transaction history can be identified" }, { "label": "Recital 22", "note": "services provided in a fully decentralised manner without any intermediary fall outside scope" }, { "label": "Grandfathering ended 1 July 2026", "note": "no member state may extend national transitional regimes further" } ], "tags": [ "MiCA", "Article 76(3)", "CASP licensing", "trading venues" ], "sources": [ { "label": "Regulation (EU) 2023/1114", "url": "https://eur-lex.europa.eu/eli/reg/2023/1114/oj/eng" }, { "label": "ESMA MiCA hub", "url": "https://www.esma.europa.eu/esmas-activities/digital-finance-and-innovation/markets-crypto-assets-regulation-mica" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-mica", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-mica.md" }, { "slug": "reg-fatf", "name": "FATF", "summary": "FATF (Financial Action Task Force): The source of almost every travel rule on earth. Region: Global. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Global", "category": "The source of almost every travel rule on earth", "authority": "Financial Action Task Force", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Nothing else in this section has as much reach. FATF sets standards rather than law, but the mutual evaluation process and the grey list make adoption close to compulsory, which is why the same travel rule appears in every jurisdiction below. Recommendation 15 brought virtual assets into scope in 2018, and its interpretive note carries the transfer threshold. The July 2026 targeted update found peer-to-peer transfers through self-hosted wallets treated as high risk in 88% of responding jurisdictions. Two things cut the other way and are usually missed: the 2025 revision of Recommendation 16 is not applied directly to virtual asset providers, and FATF's own July 2026 report on information sharing concludes that data protection law, not technology, is the main barrier to cooperation.", "instruments": [ { "label": "Recommendation 15 and INR.15", "note": "extended the standards to virtual assets and VASPs in 2018; the interpretive note carries the travel rule above USD/EUR 1,000" }, { "label": "Seventh targeted update, 16 July 2026", "note": "83% of responding jurisdictions now have travel rule legislation, up from 73%, but only 34% are largely compliant with R.15" }, { "label": "DeFi report, 21 July 2026", "note": "applies a control-or-sufficient-influence test rather than accepting decentralisation claims; 93% of jurisdictions have not implemented R.15 for DeFi" }, { "label": "R.16 revision, June 2025", "note": "effective end-2030, and explicitly not applied directly to VASPs" } ], "tags": [ "travel rule", "Recommendation 15", "grey list", "self-hosted wallets" ], "sources": [ { "label": "Seventh targeted update on VAs and VASPs", "url": "https://www.fatf-gafi.org/en/news/targeted-updated-va-vasps-2026.html" }, { "label": "Targeted report on decentralised finance", "url": "https://www.fatf-gafi.org/en/publications/Virtualassets/targeted-report-decentralised-finance-2026.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fatf", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fatf.md" }, { "slug": "reg-eu-travel-rule", "name": "EU Transfer of Funds Regulation", "summary": "EU Transfer of Funds Regulation (European Union · EBA): Travel rule · Regulation (EU) 2023/1113. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Europe", "category": "Travel rule · Regulation (EU) 2023/1113", "authority": "European Union · EBA", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "This, not the privacy-coin headline, is what actually ends unattributed transfers at the EU perimeter. The recast travel rule attaches originator and beneficiary name, address and account identifier to every crypto transfer between providers, with no de minimis threshold at all, where the fiat regime it recasts has one. Above EUR 1,000 to or from a self-hosted address, the provider must take adequate measures to establish that its own customer owns or controls that address. Self-hosted wallets are not banned and peer-to-peer transfers between two of them sit outside the regulation entirely. Applicable since 30 December 2024, operationalised by EBA guidelines that specify the data fields, it is the reason EU exchanges now ask who owns the withdrawal address.", "instruments": [ { "label": "No de minimis threshold", "note": "originator and beneficiary data travel with every CASP-to-CASP transfer regardless of amount" }, { "label": "Articles 14(5) and 16(2)", "note": "transfers above EUR 1,000 to or from a self-hosted address require the CASP to verify its own customer controls that address" }, { "label": "EBA/GL/2024/11", "note": "travel rule guidelines specifying the data fields and the missing-information procedures, applicable 30 December 2024" } ], "tags": [ "travel rule", "no threshold", "self-hosted wallets", "IVMS101" ], "sources": [ { "label": "Regulation (EU) 2023/1113", "url": "https://eur-lex.europa.eu/eli/reg/2023/1113/oj/eng" }, { "label": "EBA Travel Rule Guidelines", "url": "https://www.eba.europa.eu/sites/default/files/2024-07/6de6e9b9-0ed9-49cd-985d-c0834b5b4356/Travel%20Rule%20Guidelines.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-travel-rule", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-travel-rule.md" }, { "slug": "reg-genius-act", "name": "GENIUS Act", "summary": "GENIUS Act (US Congress · Treasury · FinCEN · OFAC): Stablecoins · censorability as a licensing precondition. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Americas", "category": "Stablecoins · censorability as a licensing precondition", "authority": "US Congress · Treasury · FinCEN · OFAC", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The most restrictive thing in current US law on this subject, and it is architectural rather than procedural. A payment stablecoin may only be issued if the issuer has the technological capability to comply with any lawful order, and a lawful order is defined as one requiring it to seize, freeze, burn or prevent transfer. In other words the ability to censor is a precondition of the licence, designed into the token rather than imposed on the operator afterwards. Foreign issuers face the same test or lose access to US secondary trading. There are narrow counterweights: the word privacy appears once, requiring FinCEN to weigh privacy risks in what it collects, and the implementing proposal does not require issuers to monitor secondary market activity.", "instruments": [ { "label": "Section 4(a)(6)(B)", "note": "a stablecoin may be issued only if the issuer has the technological capability to comply, and will comply, with the terms of any lawful order" }, { "label": "Lawful order defined", "note": "an order requiring the issuer to seize, freeze, burn or prevent the transfer of its stablecoins" }, { "label": "Section 8", "note": "extends the same capability test to foreign issuers, on pain of a secondary trading ban in the United States" }, { "label": "Not yet effective", "note": "enacted 18 July 2025; effective on the earlier of 18 January 2027 or 120 days after final implementing rules, none of which had been published as of August 2026" } ], "tags": [ "GENIUS Act", "freeze and seize", "stablecoins", "architectural constraint" ], "sources": [ { "label": "Public Law 119-27", "url": "https://www.govinfo.gov/content/pkg/PLAW-119publ27/html/PLAW-119publ27.htm" }, { "label": "FinCEN and OFAC implementing proposal", "url": "https://www.govinfo.gov/content/pkg/FR-2026-04-10/html/2026-06963.htm" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-genius-act", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-genius-act.md" }, { "slug": "reg-eu-amlr", "name": "EU AMLR Article 79", "summary": "EU AMLR Article 79 (European Union · AMLA · national FIUs): Anti-money laundering · Regulation (EU) 2024/1624. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Europe", "category": "Anti-money laundering · Regulation (EU) 2024/1624", "authority": "European Union · AMLA · national FIUs", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Reported almost everywhere as an EU ban on privacy coins from 1 July 2027. Two things are wrong with that. The date is 10 July 2027, when the AMLR begins to apply. And the prohibition binds obliged entities, not people: banks, financial institutions and licensed crypto providers may not keep anonymous accounts, or accounts that anonymise the holder or obfuscate transactions including through anonymity-enhancing coins. It creates no offence for holding or spending such an asset, outlaws no protocol, and leaves self-custody standing, which the recitals treat as a risk factor to be assessed rather than something barred. What it does mean is that regulated European venues will almost certainly drop support. How far it reaches assets with optional privacy will be settled by AMLA guidance, not by this text.", "instruments": [ { "label": "Article 79(1)", "note": "bars credit institutions, financial institutions and CASPs from keeping anonymous accounts, including any account allowing anonymisation or increased obfuscation of transactions through anonymity-enhancing coins" }, { "label": "Applies from 10 July 2027", "note": "the 1 July 2027 date repeated across crypto media is wrong; AMLD6 transposition shares the 10 July 2027 deadline" }, { "label": "Recitals 29 and 30", "note": "self-hosted wallet transactions are treated as a risk factor to assess, not as prohibited" } ], "tags": [ "AMLR", "Article 79", "anonymity-enhancing coins", "obliged entities", "commonly misread" ], "sources": [ { "label": "Regulation (EU) 2024/1624", "url": "https://eur-lex.europa.eu/eli/reg/2024/1624/oj/eng" }, { "label": "AMLA", "url": "https://www.amla.europa.eu/index_en" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-amlr", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-amlr.md" }, { "slug": "reg-mas", "name": "Monetary Authority of Singapore", "summary": "Monetary Authority of Singapore (MAS): The regulator that priced the risk instead of banning it. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Asia-Pacific", "category": "The regulator that priced the risk instead of banning it", "authority": "MAS", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Worth reading closely because it is the road not taken elsewhere. Faced with the same assets that Dubai and Malaysia prohibited outright, Singapore's regulator chose enhanced obligations instead, and said so in Parliament: privacy coins, privacy wallets and mixers are to be risk-assessed and monitored, not barred. Firms are told to pay special attention to technologies that favour anonymity, which is a supervisory expectation rather than a listing rule. MAS has also observed that most licensed providers decline to offer such assets anyway, which is the market making a commercial choice rather than the regulator making it for them. The transfer rules are strict in the other direction, with no minimum value at all.", "instruments": [ { "label": "Notice PSN02", "note": "providers must risk-assess privacy tokens before dealing and pay special attention to technologies that favour anonymity, with enhanced transaction monitoring, but no prohibition" }, { "label": "The position stated in Parliament, October 2022", "note": "privacy coins, privacy wallets and mixers attract enhanced obligations rather than prohibition" }, { "label": "No de minimis on transfers", "note": "at or below SGD 1,500 originator and beneficiary names and account numbers still travel; above it the originator's identity must be verified" }, { "label": "COSMIC, live since 1 April 2024", "note": "a statutory carve-out from banking confidentiality letting six banks share customer risk information with each other rather than publicly" } ], "tags": [ "risk-based", "no prohibition", "zero threshold", "information sharing" ], "sources": [ { "label": "MAS Notice PSN02", "url": "https://www.mas.gov.sg/regulation/notices/psn02-aml-cft-notice---digital-payment-token-service" }, { "label": "MAS parliamentary reply on privacy coins", "url": "https://www.mas.gov.sg/news/parliamentary-replies/2022/reply-to-parliamentary-question-on-prevalence-and-regulation-of-cryptocurrency-transactions" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-mas", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-mas.md" }, { "slug": "reg-vara", "name": "VARA", "summary": "VARA (Dubai Virtual Assets Regulatory Authority): The most explicit prohibition in any rulebook. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Middle East & Africa", "category": "The most explicit prohibition in any rulebook", "authority": "Dubai Virtual Assets Regulatory Authority", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Most regimes reach anonymity-enhanced assets sideways, through listing criteria, liquidity gates or traceability tests. Dubai's regulator simply writes it down: issuance of such assets, and every activity related to them, is prohibited in the Emirate. That makes VARA the clearest counterexample to the pattern running through this section, and it is quoted far beyond the UAE precisely because so few instruments are this direct. Two things temper it. The prohibition binds licensed activity in Dubai rather than individuals, and self-custody survives: providers must document how they handle transfers involving unhosted wallets, which is a diligence obligation and not a ban.", "instruments": [ { "label": "Regulations 2023, Part II Section C", "note": "states that the issuance of anonymity-enhanced cryptocurrencies and all virtual asset activities related to them are prohibited in the Emirate" }, { "label": "Travel rule above AED 3,500", "note": "originator name, wallet address or account number and address, plus beneficiary name and wallet address" }, { "label": "Unhosted wallets are not banned", "note": "providers must document how they handle non-obliged entities and anonymity-enhanced transactions, which is a diligence duty rather than a prohibition" } ], "tags": [ "explicit prohibition", "named in rulebook", "AED 3,500", "unhosted permitted" ], "sources": [ { "label": "VARA rulebook, prohibited virtual assets", "url": "https://rulebooks.vara.ae/rulebook/c-prohibited-virtual-assets" }, { "label": "VARA rulebook, FATF travel rule", "url": "https://rulebooks.vara.ae/rulebook/g-fatf-travel-rule" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-vara", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-vara.md" }, { "slug": "reg-ofac", "name": "OFAC and Van Loon", "summary": "OFAC and Van Loon (US Treasury · Office of Foreign Assets Control): Sanctions · where the law found a limit. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Americas", "category": "Sanctions · where the law found a limit", "authority": "US Treasury · Office of Foreign Assets Control", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The most severe action ever taken by a government against privacy tooling, followed by the most significant legal retreat from one. Sanctioning Tornado Cash in 2022 meant that touching a set of immutable contracts became a strict-liability violation, with no intent requirement. The Fifth Circuit held that unlawful in November 2024 on a narrow but durable ground: property under the statute means something someone can own or control, and nobody can own an immutable contract. Treasury delisted in March 2025. Read the limits carefully before drawing comfort from it. The holding binds one circuit, it says nothing about mutable or upgradeable contracts, and OFAC's appetite for designating people and addresses is undiminished.", "instruments": [ { "label": "Tornado Cash designation, 8 August 2022", "note": "made interacting with a set of immutable Ethereum contracts a strict-liability sanctions violation" }, { "label": "Van Loon v. Department of the Treasury (5th Cir., 26 November 2024)", "note": "OFAC exceeded its statutory authority; immutable smart contracts are not property under IEEPA because nobody can own, control or alter them" }, { "label": "Delisting, 21 March 2025", "note": "Treasury removed the addresses from the SDN list; no re-designation has been reported" }, { "label": "The limit is narrow", "note": "binding in the Fifth Circuit only; OFAC may still designate people, mutable contracts and addresses, and has continued to do so" } ], "tags": [ "Tornado Cash", "Van Loon", "IEEPA", "strict liability" ], "sources": [ { "label": "Van Loon slip opinion", "url": "https://www.ca5.uscourts.gov/opinions/pub/23/23-50669-CV0.pdf" }, { "label": "CourtListener docket", "url": "https://www.courtlistener.com/opinion/10284289/van-loon-v-trea/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-ofac", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-ofac.md" }, { "slug": "reg-fincen", "name": "FinCEN", "summary": "FinCEN (US Treasury · Financial Crimes Enforcement Network): Bank Secrecy Act · the deepest US constraint. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Americas", "category": "Bank Secrecy Act · the deepest US constraint", "authority": "US Treasury · Financial Crimes Enforcement Network", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Registration, identity verification and suspicious activity reporting for anyone acting as a money transmitter in crypto all originate here, and none of that has loosened. What has changed is the perimeter around it. The two most aggressive proposals aimed at self-custody were both withdrawn: the 2020 unhosted wallet rule in 2024, and the plan to lower the cross-border transfer threshold to USD 250 in 2025. The 2019 guidance also still distinguishes providing an anonymising service from publishing anonymising software, which matters a great deal to developers. The open question is the 2023 proposal to treat mixing as a class of transactions of primary money laundering concern. Nearly three years on it is neither finalised nor abandoned.", "instruments": [ { "label": "31 CFR 1010.410(f)", "note": "the travel rule, attaching transmittor name, address, account number and amount to transfers of USD 3,000 or more" }, { "label": "FIN-2019-G001, 9 May 2019", "note": "consolidated guidance treating exchangers and administrators as money transmitters, while preserving the distinction between an anonymising service provider and an anonymising software provider" }, { "label": "Unhosted wallet proposal withdrawn April 2024", "note": "and the proposal to cut the cross-border travel rule threshold to USD 250 withdrawn in April 2025" }, { "label": "The mixing rule is dormant, not dead", "note": "the 2023 proposal to designate convertible virtual currency mixing as a class of transactions of primary money laundering concern drew over 2,200 comments and is now classified a long-term action with final action to be determined" } ], "tags": [ "Bank Secrecy Act", "travel rule", "Section 311", "mixing rule pending" ], "sources": [ { "label": "Travel rule text, 31 CFR 1010.410", "url": "https://www.law.cornell.edu/cfr/text/31/1010.410" }, { "label": "Section 311 mixing proposal", "url": "https://www.federalregister.gov/documents/2023/10/23/2023-23449/proposal-of-special-measure-regarding-convertible-virtual-currency-mixing-as-a-class-of-transactions" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fincen", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fincen.md" }, { "slug": "reg-hk-sfc", "name": "Hong Kong SFC", "summary": "Hong Kong SFC (Securities and Futures Commission): Retail exclusion achieved without naming anonymity. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Asia-Pacific", "category": "Retail exclusion achieved without naming anonymity", "authority": "Securities and Futures Commission", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "A useful case study in how a market gets closed without a rule that mentions the thing being closed out. The Hong Kong regime bars retail access to any asset that is not an eligible large-cap virtual asset, defined by presence in two acceptable indices from separate providers. Monero and Zcash fail that liquidity test, so they never reach retail investors, and yet the guidelines contain no reference to anonymity, privacy coins or mixers anywhere in the text. Anyone citing Hong Kong as having banned privacy assets is describing an effect rather than an instrument. The distinction matters when arguing about what regulators have actually decided.", "instruments": [ { "label": "Trading platform guidelines, paragraph 7.8", "note": "retail clients may only be offered eligible large-cap virtual assets, meaning assets included in at least two acceptable indices from two different providers, one of them IOSCO-compliant" }, { "label": "The guidelines never mention anonymity", "note": "read in full, the text contains no reference to privacy coins, anonymity or mixers; the exclusion is a consequence of the liquidity test" }, { "label": "Case-by-case appeal", "note": "paragraph 7.8 leaves room for a platform to make the case for an asset directly to the regulator" } ], "tags": [ "large-cap gate", "no anonymity language", "index test", "retail perimeter" ], "sources": [ { "label": "SFC virtual asset trading platform operators", "url": "https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-hk-sfc", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-hk-sfc.md" }, { "slug": "reg-nydfs", "name": "NYDFS", "summary": "NYDFS (New York State Department of Financial Services): The most privacy-restrictive US regulator, state or federal. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Americas", "category": "The most privacy-restrictive US regulator, state or federal", "authority": "New York State Department of Financial Services", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Where federal policy has softened around non-custodial software, New York has not moved at all. Its licensees must run blockchain analytics across onboarding, monitoring and sanctions screening, tracing the flow of funds through the chain and treating anything processed through a mixer as a monitored typology. The listing guidance is the most explicit anti-anonymity language from any US regulator: a coin cannot be self-certified if it has features designed to facilitate obfuscation or concealment of identity. The framework was extended to all New York banking organisations in 2025. To its credit the guidance is honest about its own limits, conceding that analytics may not identify underlying owners without off-chain verification.", "instruments": [ { "label": "Guidance on the use of blockchain analytics, 28 April 2022", "note": "licensees must trace the flow of funds through the blockchain, and it names virtual currency processed through a mixer or tumbler as a monitored typology" }, { "label": "Listing guidance, 15 November 2023", "note": "a coin cannot be self-certified if it is designed or substantially used to circumvent laws, or has features designed to facilitate the obfuscation or concealment of the identity of an individual or entity" }, { "label": "Extended to banking organizations, 17 September 2025", "note": "the analytics framework now applies to all New York banking organizations" }, { "label": "A candid limitation", "note": "the guidance concedes analytics may not identify underlying owners absent further off-chain verification" } ], "tags": [ "BitLicense", "blockchain analytics", "self-certification bar", "Greenlist" ], "sources": [ { "label": "Guidance on blockchain analytics", "url": "https://www.dfs.ny.gov/industry_guidance/industry_letters/il20220428_guidance_use_blockchain_analytics" }, { "label": "Guidance on listing virtual currencies", "url": "https://www.dfs.ny.gov/industry_guidance/industry_letters/il20231115_listing_virtual_currencies" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-nydfs", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-nydfs.md" }, { "slug": "reg-japan-fsa", "name": "Japan FSA and JVCEA", "summary": "Japan FSA and JVCEA (Financial Services Agency · Japan Virtual and Crypto assets Exchange Association): A traceability test, applied by the industry body. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Asia-Pacific", "category": "A traceability test, applied by the industry body", "authority": "Financial Services Agency · Japan Virtual and Crypto assets Exchange Association", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Japan is the clearest example of a rule written against untraceability rather than against named assets, and of that rule being applied by an industry body rather than a regulator. The self-regulatory handling rules have barred members since 2018 from dealing in any asset whose transfer records cannot be traced or are markedly difficult to trace, which is why the well-known privacy assets have been absent from Japanese venues for years without any instrument naming them. The 2026 legislation moves crypto into the securities framework, but leaves the substance of that test to a Cabinet Office Ordinance that has not yet been written.", "instruments": [ { "label": "JVCEA handling rules, Article 4(3)", "note": "members must not handle a crypto asset whose transfer records cannot be traced, or are markedly difficult to trace" }, { "label": "The Green List", "note": "as updated on 5 August 2026 it carries 30 assets and none of Monero, Zcash or Dash, though it is a widely-handled list rather than the permitted universe" }, { "label": "Moving into statute", "note": "legislation enacted 15 July 2026 shifts crypto from payments law into the securities framework, with the handling criteria delegated to Cabinet Office Ordinance rather than written into the act" } ], "tags": [ "traceability test", "self-regulation", "Green List", "ordinance pending" ], "sources": [ { "label": "JVCEA Green List", "url": "https://jvcea.or.jp/statistics/document/greenlist/" }, { "label": "FSA bill materials", "url": "https://www.fsa.go.jp/common/diet/221/02/03.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-japan-fsa", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-japan-fsa.md" }, { "slug": "reg-irs-broker-reporting", "name": "IRS broker reporting", "summary": "IRS broker reporting (US Internal Revenue Service): Tax · live at the custodial perimeter, dead beyond it. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Americas", "category": "Tax · live at the custodial perimeter, dead beyond it", "authority": "US Internal Revenue Service", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The clearest illustration of the US perimeter split. Custodial reporting arrived exactly as planned and is now in its first year of cost-basis reporting, which means identity, proceeds and acquisition history all flow to the tax authority for anyone using an intermediary. The attempt to extend the same duty to non-custodial software went the other way entirely: Congress nullified the DeFi broker rule by joint resolution in April 2025, and because it used the Congressional Review Act, no substantially similar rule can be issued without fresh legislation. That is a stronger form of repeal than a withdrawal, and it is the single most durable win for non-custodial software in US law so far.", "instruments": [ { "label": "Form 1099-DA", "note": "custodial brokers report customer identity and gross proceeds; the regime went live on schedule with 2025-transaction forms filed in early 2026, and basis reporting began for 2026 transactions" }, { "label": "The DeFi rule was repealed", "note": "the trading front-end broker rule was nullified by joint resolution enacted 10 April 2025, and the Congressional Review Act now bars any substantially similar rule without new legislation" }, { "label": "Current IRS position", "note": "the final regulations do not include reporting requirements for brokers commonly known as decentralized or non-custodial brokers" }, { "label": "Section 6050I still unimplemented", "note": "the reporting of digital assets received in a trade or business, where officials have acknowledged concerns that it may reveal personal information the IRS would not otherwise have" } ], "tags": [ "1099-DA", "broker reporting", "DeFi rule repealed", "Section 6050I pending" ], "sources": [ { "label": "IRS digital assets", "url": "https://www.irs.gov/filing/digital-assets" }, { "label": "Public Law 119-5, repealing the DeFi broker rule", "url": "https://www.govinfo.gov/content/pkg/PLAW-119publ5/html/PLAW-119publ5.htm" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-irs-broker-reporting", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-irs-broker-reporting.md" }, { "slug": "reg-oecd-carf", "name": "OECD CARF", "summary": "OECD CARF (OECD · Global Forum): Tax reporting · the fastest-moving instrument in this section. Region: Global. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Global", "category": "Tax reporting · the fastest-moving instrument in this section", "authority": "OECD · Global Forum", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The quiet instrument that will do the most to end pseudonymity at the intermediary layer, and it arrives before the AML rules do. Providers must collect self-certifications of identity and tax residence and report exchanges and transfers, including transfers to unhosted wallets, with no minimum on either. First exchanges begin in 2027 on 2026 data across 46 jurisdictions. The privacy architecture sits in the agreement rather than the reporting: Section 5 subjects exchanged data to confidentiality rules and to personal-data safeguards the sending authority can specify, and Section 7(5) lets a competent authority suspend exchange immediately where those safeguards are breached. Data protection is an enforceable precondition to receiving data, which is more than most AML instruments offer.", "instruments": [ { "label": "Published 10 October 2022, finalised with the amended CRS June 2023", "note": "providers collect self-certifications of identity and tax residence and report exchanges, transfers including to unhosted wallets, and retail payments above USD 50,000" }, { "label": "CARF-MCAA", "note": "earliest signature 21 October 2024, main ceremony 26 November 2024; 56 signatories as of 3 March 2026 against 76 committed jurisdictions" }, { "label": "First exchanges 2027", "note": "46 jurisdictions exchange in 2027 on 2026 data, 29 in 2028, the United States in 2029" }, { "label": "Amended CRS", "note": "brings e-money providers and central bank digital currencies into the depository account definition" } ], "tags": [ "CARF", "automatic exchange", "unhosted wallets", "DAC8", "data safeguards" ], "sources": [ { "label": "CARF commitments list", "url": "https://www.oecd.org/content/dam/oecd/en/networks/global-forum-tax-transparency/commitments-carf.pdf" }, { "label": "CARF-MCAA text", "url": "https://www.oecd.org/content/dam/oecd/en/topics/policy-issues/tax-transparency-and-international-co-operation/text-carf-mcaa.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-oecd-carf", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-oecd-carf.md" }, { "slug": "reg-uae-free-zones", "name": "DFSA and ADGM FSRA", "summary": "DFSA and ADGM FSRA (Dubai Financial Services Authority · Abu Dhabi Global Market): The regulators that went after the tools, not just the assets. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Middle East & Africa", "category": "The regulators that went after the tools, not just the assets", "authority": "Dubai Financial Services Authority · Abu Dhabi Global Market", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The two financial free zones inside the UAE regulate separately from Dubai's virtual assets authority, and they went a step further than it did. Where most instruments in this section reach assets, the DIFC rulebook reaches the tool: it bars the use of a privacy device, meaning mixers and tumblers, in or from the zone. Abu Dhabi's regulator put the prohibition on privacy tokens into its rules in June 2025 and separately refuses simplified customer due diligence for virtual assets on the ground that clients and transactions are pseudonymous. Anyone structuring in the UAE is dealing with three distinct perimeters, not one.", "instruments": [ { "label": "DFSA GEN 3A, in force 12 January 2026", "note": "prohibits regulated activity in privacy tokens and bars the use of a privacy device, meaning mixers and tumblers, in or from the DIFC" }, { "label": "Firm-led token screening", "note": "the DFSA abolished its list of recognised tokens, so firms must determine on a reasoned and documented basis whether each token meets the criteria" }, { "label": "ADGM FSRA amendments, 10 June 2025", "note": "enshrine in rules the prohibition on using privacy tokens within ADGM, alongside a streamlined acceptance process for other assets" }, { "label": "No simplified due diligence", "note": "the FSRA declines simplified customer due diligence for virtual asset activity, citing the pseudonymity of clients and transactions" } ], "tags": [ "privacy devices", "mixers barred", "firm-led screening", "financial free zones" ], "sources": [ { "label": "ADGM FSRA framework amendments", "url": "https://www.adgm.com/media/announcements/adgm-fsra-implements-amendments-to-its-digital-asset-regulatory-framework" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-uae-free-zones", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-uae-free-zones.md" }, { "slug": "reg-basel-sco60", "name": "Basel Committee, SCO60", "summary": "Basel Committee, SCO60 (Basel Committee on Banking Supervision): Bank capital · the sharpest traceability rule anywhere. Region: Global. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Global", "category": "Bank capital · the sharpest traceability rule anywhere", "authority": "Basel Committee on Banking Supervision", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The single most privacy-restrictive sentence in global financial regulation is probably here. To qualify for the favourable capital treatment, a network must be well-defined such that all transactions and participants are traceable. A chain that obscures the transaction graph cannot satisfy it. Worth being precise about what this does and does not mean: it binds banks, not protocols, and sets a capital cost rather than a legality question. But the effect is that permissionless-chain assets fall into Group 2, capped at 2% of Tier 1 capital, which is why bank balance sheets stay away. The standard itself concedes the Committee will keep reflecting on whether those risks can be mitigated enough for Group 1. A targeted review is under way; nobody has said whether it touches the traceability condition.", "instruments": [ { "label": "SCO60.17(2), classification condition 3", "note": "all key elements of the network must be well-defined such that all transactions and participants are traceable" }, { "label": "Group 2 cap", "note": "exposures capped at 2% of Tier 1 capital, which is where permissionless-chain assets land" }, { "label": "Took effect 1 January 2026", "note": "deferred once from 2025; the industry request for a further delay in August 2025 was not granted" }, { "label": "Targeted review expedited November 2025", "note": "endorsed by GHOS on 9 March 2026, with an update due before end-2026; its scope is not public" } ], "tags": [ "bank capital", "SCO60", "traceability", "permissionless", "under review" ], "sources": [ { "label": "Prudential treatment of cryptoasset exposures", "url": "https://www.bis.org/bcbs/publ/d545.pdf" }, { "label": "GHOS deferral announcement", "url": "https://www.bis.org/press/p240513a.htm" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-basel-sco60", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-basel-sco60.md" }, { "slug": "reg-fsb", "name": "Financial Stability Board", "summary": "Financial Stability Board (FSB): Financial stability · and explicitly not the privacy body. Region: Global. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Global", "category": "Financial stability · and explicitly not the privacy body", "authority": "FSB", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Included here mainly to correct a common misattribution. The FSB coordinates national authorities on financial stability, and its 2023 framework is frequently cited in arguments about on-chain surveillance, but it expressly scopes both AML/CFT and data privacy out of its coverage, and its own peer review confirms that anti-money-laundering work sits outside its mandate. What it does ask for is authority access to data from issuers and providers as necessary and appropriate, and cross-border information sharing, with the qualification that data systems must conform to applicable data-retention, security and privacy regulation. Its October 2025 review does treat secrecy and data privacy laws as barriers to cooperation. Traceability rules come from FATF, not from here.", "instruments": [ { "label": "Global regulatory framework, 17 July 2023", "note": "high-level recommendations for crypto-asset activities plus revised global stablecoin recommendations" }, { "label": "Scope exclusion", "note": "the framework does not cover AML/CFT or data privacy, and Recommendation 6 requires data systems to conform to applicable data-retention, data-security and data-privacy regulation" }, { "label": "Thematic peer review, 16 October 2025", "note": "implementation incomplete and uneven; notes that secrecy or data privacy laws may pose significant barriers to cooperation" } ], "tags": [ "financial stability", "non-binding", "scope exclusion", "stablecoins" ], "sources": [ { "label": "FSB global regulatory framework", "url": "https://www.fsb.org/2023/07/fsb-global-regulatory-framework-for-crypto-asset-activities/" }, { "label": "Thematic review, October 2025", "url": "https://www.fsb.org/2025/10/thematic-review-on-fsb-global-regulatory-framework-for-crypto-asset-activities/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fsb", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-fsb.md" }, { "slug": "reg-iosco", "name": "IOSCO", "summary": "IOSCO (International Organization of Securities Commissions): Securities regulation · the one body that calls transparency a risk. Region: Global. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Global", "category": "Securities regulation · the one body that calls transparency a risk", "authority": "International Organization of Securities Commissions", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "IOSCO pulls in both directions, which makes it more interesting than most. Its DeFi work treats pseudonymity as an obstacle, citing participants who use multiple addresses to obfuscate activity, and answers by identifying responsible persons. But its November 2025 tokenisation report is the only text from a financial standard-setter that names over-transparency as a risk in its own right. It records an inherent conundrum between data privacy and transparency, warns that ledger immutability could cause unintended user confidentiality breaches and collide with requirements such as the GDPR right to be forgotten, and notes that visible transaction flows can worsen a redemption run. That is a securities regulator arguing that too much publicity is a market-integrity problem, not just a privacy one.", "instruments": [ { "label": "Policy Recommendations for Crypto and Digital Asset Markets, FR11/2023", "note": "18 recommendations on conflicts, custody, market abuse, disclosure and cross-border cooperation, followed by nine DeFi recommendations in December 2023" }, { "label": "Tokenization of Financial Assets, FR/17/25, November 2025", "note": "records an inherent conundrum between data privacy and transparency, and cites GDPR erasure conflicts directly" }, { "label": "Thematic review FR/13/25, 16 October 2025", "note": "assessed 20 jurisdictions; information sharing under the MMoU and EMMoU is largely limited to enforcement" } ], "tags": [ "securities", "tokenisation", "pseudonymity", "GDPR conflict" ], "sources": [ { "label": "Policy recommendations for crypto and digital asset markets", "url": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD747.pdf" }, { "label": "Tokenization of financial assets, FR/17/25", "url": "https://www.iosco.org/library/pubdocs/pdf/IOSCOPD813.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-iosco", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-iosco.md" }, { "slug": "reg-gdpr", "name": "GDPR", "summary": "GDPR (European Union · national data protection authorities): Data protection · Regulation (EU) 2016/679. Region: Europe. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Europe", "category": "Data protection · Regulation (EU) 2016/679", "authority": "European Union · national data protection authorities", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "The law most often described as a problem for blockchain is also the strongest European argument for building with privacy technology. Article 25 requires data protection by design and by default, and Article 5(1)(c) requires minimisation, which is a legal instruction to publish less, not more. The friction is real in two places: Article 17 erasure against an append-only ledger, and whether a wallet address counts as personal data under Article 4(1). Worth holding onto in the AML debate, GDPR does not authorise blanket collection either. Processing for anti-money laundering still has to clear necessity and proportionality under Article 6 and the Charter. A Commission Digital Omnibus proposal from November 2025 would amend the identifiability test; treat it as pending.", "instruments": [ { "label": "Article 5(1)(c) and Article 25", "note": "data minimisation and data protection by design and by default, the strongest legal basis in Europe for building with privacy technology" }, { "label": "Article 17", "note": "the right to erasure, in direct tension with an append-only ledger" }, { "label": "Article 4(1)", "note": "whether a wallet address is personal data turns on this definition of identifiability" } ], "tags": [ "GDPR", "erasure vs immutability", "privacy by design", "data minimisation" ], "sources": [ { "label": "Regulation (EU) 2016/679", "url": "https://eur-lex.europa.eu/eli/reg/2016/679/oj/eng" }, { "label": "EDPB", "url": "https://www.edpb.europa.eu/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-gdpr", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-gdpr.md" }, { "slug": "reg-edpb-blockchain", "name": "EDPB blockchain guidelines", "summary": "EDPB blockchain guidelines (European Data Protection Board): Data protection guidance · Guidelines 02/2025. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Europe", "category": "Data protection guidance · Guidelines 02/2025", "authority": "European Data Protection Board", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The reference text on how European data protection law lands on a ledger, final since 7 July 2026. Its positions are demanding: a public key is personal data whenever it can be associated with an identifiable person, encrypted or hashed on-chain data is not automatically outside GDPR, and unsalted hashes are treated as insufficient on a public chain. On erasure the Board offers architecture rather than a doctrinal exemption. Keep personal data off-chain, delete the off-chain identifiers, or render the on-chain data effectively anonymous, which it concedes is technically demanding. It prefers permissioned designs and treats permissionless ones as needing justification. Zero-knowledge constructions and commitments are acknowledged as mitigations, not exemptions. Guidelines are not binding law, but supervisors follow them.", "instruments": [ { "label": "Adopted 7 July 2026", "note": "version 2.0, following the draft consulted on between 14 April and 9 June 2025" }, { "label": "Public keys as personal data", "note": "a wallet address qualifies whenever it can be associated with an identifiable person; unsalted hashes do not escape GDPR on a public chain" }, { "label": "Off-chain by default", "note": "the Board urges keeping personal data off-chain and expressly prefers permissioned architectures" } ], "tags": [ "EDPB", "Guidelines 02/2025", "permissioned preference", "soft law" ], "sources": [ { "label": "Guidelines 02/2025 (final)", "url": "https://www.edpb.europa.eu/system/files/2026-07/edpb_guidelines_202502_blockchain_v2_en.pdf" }, { "label": "Consultation page", "url": "https://www.edpb.europa.eu/our-work-tools/documents/public-consultations/2025/guidelines-022025-processing-personal-data_en" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-edpb-blockchain", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-edpb-blockchain.md" }, { "slug": "reg-bis-innovation-hub", "name": "BIS Innovation Hub", "summary": "BIS Innovation Hub (Bank for International Settlements): Central bank prototypes that build privacy on purpose. Region: Global. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Global", "category": "Central bank prototypes that build privacy on purpose", "authority": "Bank for International Settlements", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "If you want evidence that the institutions writing the rules do not equate confidentiality with crime, this is where to look. Tourbillon concluded that it is feasible to implement a CBDC providing payer anonymity while combating illicit transactions, with the consumer disclosing nothing to the merchant, the banks or the central bank, and compliance handled at the merchant's bank instead. Agorá goes further on the wholesale side, and its finding is the one worth quoting: a shared ledger does not require shared data. Each institution runs its own sanctions and anti-money-laundering screening locally and shares only a binary pass or fail with the group. That is compliance without data pooling, demonstrated by the central banks' own research arm rather than argued by vendors.", "instruments": [ { "label": "Project Tourbillon, 29 November 2023", "note": "eCash prototypes giving payer anonymity (no personal information disclosed to merchant, banks or central bank) with quantum-safe blind signatures at a 200x throughput cost" }, { "label": "Project Agorá, 27 May 2026", "note": "seven central banks and 40+ institutions; a shared ledger does not require shared data, with each institution screening locally and sharing only binary pass or fail outcomes" }, { "label": "Project Aurum 2.0", "note": "with the Hong Kong Monetary Authority, testing pseudonymisation and zero-knowledge proofs for retail CBDC privacy" } ], "tags": [ "CBDC privacy", "blind signatures", "payer anonymity", "compliance without pooling" ], "sources": [ { "label": "Project Tourbillon", "url": "https://www.bis.org/publ/othp80.pdf" }, { "label": "Project Agorá report", "url": "https://www.bis.org/publ/othp110.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-bis-innovation-hub", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-bis-innovation-hub.md" }, { "slug": "reg-digital-euro", "name": "Digital euro", "summary": "Digital euro (European Central Bank · co-legislators): Central bank digital currency · COM(2023) 369. Region: Europe. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Europe", "category": "Central bank digital currency · COM(2023) 369", "authority": "European Central Bank · co-legislators", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "A central bank designing confidentiality into money on purpose is the most direct evidence that European regulators do not equate privacy with illegality. The design is two-tier. Online payments are pseudonymous to the Eurosystem, with intermediaries rather than the ECB holding identity. Offline payments are meant to be cash-like: the data stays between payer and payee, with no intermediary or central bank visibility. The EDPB and EDPS pushed for exactly that in their 2023 joint opinion. Critics fairly note that the online tier still leaves a full intermediary-held record, and that holding and transaction caps will decide how much cash-likeness survives. Parliament confirmed its negotiating mandate on 9 July 2026; the ECB targets a pilot from 2027 and possible issuance in 2029.", "instruments": [ { "label": "Offline mode", "note": "transaction data stays between payer and payee, with no intermediary or central bank visibility; designed to be cash-like" }, { "label": "Online mode", "note": "pseudonymous to the Eurosystem; intermediaries, not the ECB, hold identity" }, { "label": "EDPB-EDPS Joint Opinion 02/2023", "note": "the supervisors pressed for genuinely cash-like offline privacy" } ], "tags": [ "digital euro", "CBDC", "offline privacy", "in trilogue" ], "sources": [ { "label": "ECB digital euro", "url": "https://www.ecb.europa.eu/euro/digital_euro/html/index.en.html" }, { "label": "EDPB-EDPS Joint Opinion 02/2023", "url": "https://www.edpb.europa.eu/system/files/2023-10/edpb_edps_jointopinion_022023_digitaleuro_en.pdf" }, { "label": "Procedure file 2023/0212(COD)", "url": "https://oeil.europarl.europa.eu/oeil/en/procedure-file?reference=2023/0212(COD)" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-digital-euro", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-digital-euro.md" }, { "slug": "reg-us-treasury-pwg", "name": "US Treasury and the Working Group", "summary": "US Treasury and the Working Group (US Treasury · President's Working Group on Digital Asset Markets): The first federal endorsement of privacy technology. Region: Americas. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Americas", "category": "The first federal endorsement of privacy technology", "authority": "US Treasury · President's Working Group on Digital Asset Markets", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "The most significant shift in this section, and the one most easily overstated. Official US government documents now treat privacy-preserving technology as part of the compliance toolkit rather than an obstacle to it. The 2025 Working Group report prioritises privacy and civil liberties, encourages privacy-preserving digital identity for customer verification, and concedes the technical and legal difficulty of enforcing obligations on privacy-enhancing protocols. Treasury's March 2026 report to Congress goes further, describing zero-knowledge credentials as a way to streamline compliance without over-collecting, and commits to issuing guidance on verifiable credentials. Read it as direction of travel and not as permission: every pro-privacy statement sits alongside an intact anti-money-laundering obligation, and the guidance has not been published.", "instruments": [ { "label": "Working Group report, 30 July 2025", "note": "Strengthening American Leadership in Digital Financial Technology; prioritises privacy and civil liberties, encourages privacy-preserving digital identity tools for customer verification, and acknowledges the difficulty of enforcing obligations on privacy-enhancing protocols" }, { "label": "Treasury request for comment, 18 August 2025", "note": "issued under GENIUS Act section 9, asking about portable digital identity credentials designed to maximise user privacy and about the privacy risk of what is collected" }, { "label": "Report to Congress, March 2026", "note": "describes credentials using zero-knowledge proofs as having the potential to streamline compliance without over-collecting information" }, { "label": "The adopted commitment", "note": "Treasury will issue guidance to financial institutions on using verifiable digital credentials consistent with existing customer identification programmes; not yet issued" } ], "tags": [ "zero-knowledge proofs", "digital identity", "verifiable credentials", "guidance pending" ], "sources": [ { "label": "Working Group report", "url": "https://www.whitehouse.gov/wp-content/uploads/2025/07/digital-Assets-Report-EO14178.pdf" }, { "label": "Treasury request for comment", "url": "https://www.govinfo.gov/content/pkg/FR-2025-08-18/html/2025-15697.htm" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-us-treasury-pwg", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-us-treasury-pwg.md" }, { "slug": "reg-eidas2", "name": "eIDAS 2 and the EU Digital Identity Wallet", "summary": "eIDAS 2 and the EU Digital Identity Wallet (European Commission · member states): Digital identity · Regulation (EU) 2024/1183. Region: Europe. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Europe", "category": "Digital identity · Regulation (EU) 2024/1183", "authority": "European Commission · member states", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "The clearest counterexample to the idea that regulators are uniformly against cryptographic privacy: here EU law names the technology and requires it. Recital 14 says member states should integrate privacy-preserving technologies such as zero knowledge proof, so a relying party can validate that a statement is true without seeing the data behind it. Recital 32 requires providers to be unable to see the details of users' transactions. Recital 59 requires selective disclosure of individual attributes. Member states are to make wallets available to all citizens and residents by the end of 2026. The same legal order that will bar anonymous exchange accounts in July 2027 is putting zero-knowledge credential technology into roughly 450 million hands.", "instruments": [ { "label": "Recital 14", "note": "member states should integrate privacy-preserving technologies such as zero knowledge proof into the wallet" }, { "label": "Recital 32", "note": "wallet providers must be unable to see the details of users' transactions, a property known as unobservability" }, { "label": "Recital 59", "note": "technical support for selective disclosure of attributes, including across attestations from several sources" } ], "tags": [ "eIDAS 2", "EUDI wallet", "zero-knowledge proofs", "selective disclosure", "privacy mandated" ], "sources": [ { "label": "Regulation (EU) 2024/1183", "url": "https://eur-lex.europa.eu/eli/reg/2024/1183/oj/eng" }, { "label": "EUDI regulation overview", "url": "https://digital-strategy.ec.europa.eu/en/policies/eudi-regulation" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eidas2", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eidas2.md" }, { "slug": "reg-cjeu-identifiability", "name": "CJEU on identifiability", "summary": "CJEU on identifiability (Court of Justice of the European Union): Case law · is a wallet address personal data. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Europe", "category": "Case law · is a wallet address personal data", "authority": "Court of Justice of the European Union", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Whether a blockchain address is personal data is not a settled question, and the two European institutions answering it are drifting apart. The Court's line is contextual. Breyer held in 2016 that data are personal to a party who has means reasonably likely to be used to identify the person, and in September 2025 the Court sharpened this considerably: the same pseudonymised dataset can be personal data for the controller holding the re-identification key and non-personal for a recipient with no realistic path to re-identify. That is the strongest available argument that an address is not personal data to everyone who can see it. The EDPB's blockchain guidelines take a markedly broader view. This gap is the most consequential open question for anyone building on-chain in Europe.", "instruments": [ { "label": "Breyer, C-582/14 (19 October 2016)", "note": "established the relative test, under which data are personal to a party with means reasonably likely to be used to identify the person" }, { "label": "EDPS v SRB, C-413/23 P (4 September 2025)", "note": "pseudonymised data may be personal to the holder of the re-identification key and non-personal to a recipient who cannot reasonably re-identify" } ], "tags": [ "identifiability", "pseudonymisation", "Breyer", "unresolved" ], "sources": [ { "label": "C-413/23 P", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62023CJ0413" }, { "label": "Breyer, C-582/14", "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62014CJ0582" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-cjeu-identifiability", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-cjeu-identifiability.md" }, { "slug": "reg-third-party-doctrine", "name": "The third-party doctrine", "summary": "The third-party doctrine (US federal courts): Why chain analysis needs no warrant. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Americas", "category": "Why chain analysis needs no warrant", "authority": "US federal courts", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Any account of US financial privacy that stops at statutes misses the layer that actually decides things. Because records handed to a third party carry no constitutional protection, chain analysis combined with a subpoena to the exchange is a lawful warrantless route from an address to a name. The Fifth Circuit blessed exactly that sequence in 2020, noting that agents used a commercial clustering vendor and then served a grand jury subpoena on Coinbase rather than seeking a warrant. The First Circuit followed in 2024, and the Supreme Court declined to hear the appeal in June 2025. The 2018 cell-site decision narrowed the doctrine for location data while leaving the financial records line untouched. This floor has not moved.", "instruments": [ { "label": "United States v. Miller (1976) and Smith v. Maryland (1979)", "note": "information voluntarily conveyed to a third party carries no reasonable expectation of privacy, the foundation for subpoenaing exchange records" }, { "label": "United States v. Gratkowski (5th Cir., 30 June 2020)", "note": "no reasonable expectation of privacy in Bitcoin blockchain records or in Coinbase account records; agents used clustering analysis plus a grand jury subpoena rather than a warrant" }, { "label": "Carpenter v. United States (2018)", "note": "narrowed the doctrine for historical cell-site location data as qualitatively different, while expressly preserving Miller" }, { "label": "Harper v. Werfel (1st Cir., 24 September 2024)", "note": "Coinbase account information falls squarely within the third-party doctrine; certiorari denied 30 June 2025" } ], "tags": [ "Fourth Amendment", "Gratkowski", "chain analysis", "subpoena" ], "sources": [ { "label": "United States v. Gratkowski", "url": "https://www.ca5.uscourts.gov/opinions/pub/19/19-50492-CR0.pdf" }, { "label": "Harper v. Werfel", "url": "https://www.ca1.uscourts.gov/sites/ca1/files/opnfiles/23-1565P-01A.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-third-party-doctrine", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-third-party-doctrine.md" }, { "slug": "reg-apg", "name": "APG", "summary": "APG (Asia/Pacific Group on Money Laundering): How the global standards actually reach Asia. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Asia-Pacific", "category": "How the global standards actually reach Asia", "authority": "Asia/Pacific Group on Money Laundering", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Standards do not travel by themselves, and this is the machinery that moves them across Asia. The regional body assesses its 41 members against the FATF Recommendations, and it is those assessments, rather than any direct FATF instruction, that turn the travel rule and the virtual asset provider regime into domestic law across the region. Read the jurisdiction entries for Asia in this section and the common shape is visible: the same obligations, arriving at different speeds, in the order that evaluations fell. The fifth global round began in 2024, so the next set of national rules is being shaped through it now.", "instruments": [ { "label": "The largest FATF-style regional body", "note": "41 member jurisdictions, the biggest of the regional groups both by membership and by the size of the region it covers" }, { "label": "Mutual evaluation is the mechanism", "note": "it assesses members against the FATF Recommendations and the 2022 methodology, which is how the travel rule becomes a domestic obligation across the region" }, { "label": "The global fifth round began in 2024", "note": "run jointly by FATF and the regional bodies, so the next wave of national crypto rules across Asia is being shaped through these assessments now" } ], "tags": [ "FATF-style regional body", "mutual evaluation", "41 members", "transmission mechanism" ], "sources": [ { "label": "APG mutual evaluations", "url": "https://www.apgml.org/mutual-evaluations/mutual-evaluations" }, { "label": "FATF on the APG", "url": "https://www.fatf-gafi.org/en/countries/global-network/asia-pacific-group-on-money-laundering--apg-.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-apg", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-apg.md" }, { "slug": "reg-menafatf", "name": "MENAFATF", "summary": "MENAFATF (Middle East and North Africa Financial Action Task Force): The same machinery, across the Gulf and North Africa. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Middle East & Africa", "category": "The same machinery, across the Gulf and North Africa", "authority": "Middle East and North Africa Financial Action Task Force", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The regional counterpart to the Asian body, and the reason the Gulf entries in this section rhyme with one another. Its members include every UAE and Gulf jurisdiction covered here, along with Egypt, Morocco, Tunisia and Algeria, and its evaluations are the route by which the global standards become national obligations. It is worth knowing about when reading the Gulf rulebooks, because the striking thing about them is not that they follow the standards but that several went further than the standards required, prohibiting anonymity-enhanced assets by name when the FATF recommendations ask only for risk-based treatment.", "instruments": [ { "label": "Formed in 2004 at Manama", "note": "established by agreement among member governments as the FATF-style regional body for the region" }, { "label": "Members", "note": "including the UAE, Saudi Arabia, Qatar, Bahrain, Kuwait, Oman, Jordan, Egypt, Morocco, Tunisia, Algeria and others" }, { "label": "Active on virtual assets", "note": "it has run regional work on new payment methods and virtual assets, including a practical session on the misuse of virtual assets and providers for terrorist financing" } ], "tags": [ "FATF-style regional body", "Gulf and North Africa", "mutual evaluation", "transmission mechanism" ], "sources": [ { "label": "MENAFATF", "url": "https://www.menafatf.org/node/1143" }, { "label": "FATF on MENAFATF", "url": "https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-menafatf", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-menafatf.md" }, { "slug": "reg-convention-108", "name": "Convention 108+", "summary": "Convention 108+ (Council of Europe): The only binding international data protection treaty. Region: Global. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Global", "category": "The only binding international data protection treaty", "authority": "Council of Europe", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "The counterweight instrument, and the one that has not arrived. Convention 108+ modernises the only binding international data protection treaty open to states outside Europe, adding minimisation, proportionality, privacy by design, breach notification and a right not to be subject to decisions taken solely by automated processing. Every one of those bears directly on transaction monitoring and blockchain analytics. Article 11 still permits exceptions for national security and criminal investigation subject to necessity and proportionality, which is the hook anti-money-laundering processing hangs on. Four ratifications short of entry into force as of August 2026, eight years after opening. Set that against tax reporting under CARF beginning in 2027 and the asymmetry in this section becomes hard to miss.", "instruments": [ { "label": "CETS No. 223", "note": "amending protocol to the 1981 Convention 108, opened for signature 10 October 2018 and open to non-European states" }, { "label": "What it adds", "note": "data minimisation, proportionality, privacy by design and by default, breach notification, and a right not to be subject to decisions based solely on automated processing" }, { "label": "Not yet in force", "note": "34 ratifications against the 38 needed since 11 October 2023; Moldova ratified on 15 May 2026 as the 34th" } ], "tags": [ "data protection", "binding treaty", "not in force", "automated decisions" ], "sources": [ { "label": "CETS 223 signature chart", "url": "https://www.coe.int/en/web/conventions/full-list?module=signatures-by-treaty&treatynum=223" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-convention-108", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-convention-108.md" }, { "slug": "reg-egmont", "name": "Egmont Group", "summary": "Egmont Group (Network of national Financial Intelligence Units): How financial intelligence crosses borders. Region: Global. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "body", "region": "Global", "category": "How financial intelligence crosses borders", "authority": "Network of national Financial Intelligence Units", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Rarely discussed in privacy debates about crypto, and structurally one of the more significant bodies in this section. The Egmont Group is not a rule-maker and runs no investigations; it operates the closed network over which 182 national financial intelligence units exchange information about people and transactions. What makes it matter is the channel itself. Because the material is intelligence rather than evidence, it crosses borders outside the mutual legal assistance route and the judicial gatekeeping that comes with it. The safeguards that do apply are procedural rather than rights-based: reciprocity, use confined to the purpose for which information was requested, and the supplying unit's prior consent before anything is passed on further.", "instruments": [ { "label": "186 member FIUs", "note": "as of the Baku plenary, July 2026, exchanging over the closed Egmont Secure Web" }, { "label": "Outside ordinary channels", "note": "FIU-to-FIU exchange moves financial intelligence across borders without the mutual legal assistance gatekeeping that applies to evidence, and paragraph 24 bars refusal on bank secrecy grounds" }, { "label": "Principles paragraph 32", "note": "information is to be used only for the purpose for which it was sought or provided, and any use beyond that, including judicial use, requires prior authorisation from the supplying FIU" }, { "label": "Principles paragraph 26", "note": "consent may be refused where disclosure would be clearly disproportionate to the legitimate interests of a natural or legal person" } ], "tags": [ "FIU network", "intelligence sharing", "use limitation", "prior consent" ], "sources": [ { "label": "Principles for information exchange between FIUs", "url": "https://egmontgroup.org/wp-content/uploads/2021/09/Egmont-Group-of-Financial-Intelligence-Units-Principles-for-Information-Exchange-Between-Financial-Intelligence-Units.pdf" }, { "label": "2026 Baku plenary statement", "url": "https://egmontgroup.org/news/2026-egmont-plenary-baku-azerbaijan-co-chairs-statement/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-egmont", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-egmont.md" }, { "slug": "reg-iso", "name": "ISO and IEC standards", "summary": "ISO and IEC standards (ISO/TC 307 · ISO/IEC JTC 1/SC 27): The standards bodies that specify privacy instead of policing it. Region: Global. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Global", "category": "The standards bodies that specify privacy instead of policing it", "authority": "ISO/TC 307 · ISO/IEC JTC 1/SC 27", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "Set this against the financial standard-setters and the contrast is sharp. In February 2026 ISO and IEC published guidelines on privacy preservation based on zero-knowledge proofs, meaning there is now an international standard for deploying the primitive that the anti-money-laundering bodies do not mention at all. FATF's July 2026 report on information sharing identifies data protection law as the main obstacle to cooperation and names no privacy-enhancing technology anywhere. ISO's blockchain committee has treated privacy as an engineering problem since 2020, when its technical report on personally identifiable information in distributed ledgers addressed immutability against erasure directly. None of this binds anyone unless a regulator or contract adopts it, which so far none has.", "instruments": [ { "label": "ISO/IEC 27565:2026, 10 February 2026", "note": "guidelines on privacy preservation based on zero-knowledge proofs, a published international standard for deploying the primitive itself" }, { "label": "ISO/TR 23244:2020", "note": "privacy and personally identifiable information protection considerations for blockchain and DLT, covering immutability against erasure and on-chain versus off-chain placement" }, { "label": "ISO 22739:2024", "note": "second edition of the blockchain vocabulary, superseding the 2020 edition" }, { "label": "ISO/IEC 20889:2018", "note": "privacy-enhancing data de-identification terminology and classification of techniques" } ], "tags": [ "ISO/IEC 27565", "zero-knowledge proofs", "de-identification", "voluntary standards" ], "sources": [ { "label": "ISO/TR 23244", "url": "https://www.iso.org/standard/75061.html" }, { "label": "ISO 22739:2024", "url": "https://www.iso.org/standard/82208.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-iso", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-iso.md" }, { "slug": "reg-nist", "name": "NIST", "summary": "NIST (US National Institute of Standards and Technology): The vocabulary that makes privacy claims testable. Region: Global. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "body", "region": "Global", "category": "The vocabulary that makes privacy claims testable", "authority": "US National Institute of Standards and Technology", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "A national agency rather than a global one, included because its output gets adopted internationally as reference material and because it does something no financial regulator has. NIST turns privacy claims into things a supervisor can check. SP 800-226 gives an evaluation method for differential privacy guarantees and names the implementation hazards that make a formally correct deployment leak anyway, which is exactly the gap between claiming a privacy property and demonstrating one. The multi-party threshold cryptography work under the IR 8214 series covers threshold signatures and the MPC constructions used in custody. Whatever position a regulator eventually takes on privacy-enhancing technology in finance, the measurement vocabulary it will use probably comes from here.", "instruments": [ { "label": "SP 800-226, March 2025", "note": "guidelines for evaluating differential privacy guarantees, setting out evaluation factors and cataloguing common implementation hazards" }, { "label": "Privacy Framework 1.0, CSWP 10, 16 January 2020", "note": "version 1.1 was released as an initial public draft in April 2025 and remained in draft as of August 2026" }, { "label": "Multi-party threshold cryptography, IR 8214 series", "note": "directly relevant to threshold signatures and MPC-based custody" } ], "tags": [ "PETs", "differential privacy", "threshold cryptography", "voluntary standards" ], "sources": [ { "label": "SP 800-226", "url": "https://csrc.nist.gov/pubs/sp/800/226/final" }, { "label": "Threshold cryptography project", "url": "https://csrc.nist.gov/projects/threshold-cryptography" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-nist", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-nist.md" }, { "slug": "reg-eu-data-act", "name": "EU Data Act, Article 36", "summary": "EU Data Act, Article 36 (European Commission): Smart contract requirements · Regulation (EU) 2023/2854. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "body", "region": "Europe", "category": "Smart contract requirements · Regulation (EU) 2023/2854", "authority": "European Commission", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "A useful case of a rule written for one context landing awkwardly on another. Article 36 sets essential requirements for smart contracts used to execute data-sharing agreements, including robustness, access control and, the contested one, safe termination and interruption. Read broadly, a mandatory kill switch cannot coexist with an immutable, non-upgradeable contract. Read as drafted, it addresses enterprise data-sharing rather than permissionless DeFi, and its extension to public-chain contracts was disputed from the start. It has applied since 12 September 2025. The Commission's Digital Omnibus proposal of November 2025 would delete Article 36 outright on legal-certainty grounds, which is a fair signal of how well the drafting landed, but that proposal is still in procedure.", "instruments": [ { "label": "Article 36", "note": "essential requirements for smart contracts used in data-sharing agreements, namely robustness, access control, safe termination and interruption, archiving, continuity" }, { "label": "Applicable since 12 September 2025" }, { "label": "Digital Omnibus (November 2025)", "note": "would delete Article 36 entirely without replacement, on legal-certainty grounds; still in procedure, so treat Article 36 as in force" } ], "tags": [ "Data Act", "safe termination", "kill switch", "status pending" ], "sources": [ { "label": "Regulation (EU) 2023/2854", "url": "https://eur-lex.europa.eu/eli/reg/2023/2854/oj/eng" }, { "label": "Data Act explained", "url": "https://digital-strategy.ec.europa.eu/en/factpages/data-act-explained" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-data-act", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/reg-eu-data-act.md" }, { "slug": "jur-australia", "name": "Australia", "summary": "Australia (AUSTRAC · ASIC · OAIC): Travel rule without a threshold, no coin ban. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Travel rule without a threshold, no coin ban", "authority": "AUSTRAC · ASIC · OAIC", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Australia constrains confidentiality through anti-money-laundering law and not through any coin-specific rule. No Australian instrument prohibits anonymity-enhancing assets; AUSTRAC lists privacy coins, tumblers and mixers among its suspicious activity indicators, and delistings to date have been commercial and bank-driven rather than mandated. The travel rule that starts applying to virtual asset transfers on 1 July 2026 has no minimum value at all, which is stricter than most peers. Transfers to self-hosted wallets are handled as their own category rather than exempted: the sending institution must collect and verify payer information and collect payee and tracing information, with reporting on transfers to unverified self-hosted wallets starting in 2029. Retail CBDC was set aside after Project Acacia, so the retail privacy design question never arose here.", "instruments": [ { "label": "AML/CTF Amendment Act 2024", "note": "commences for existing reporting entities 31 March 2026 and for tranche 2 entities 1 July 2026, widening virtual asset services to exchange, custody, transfer and sale" }, { "label": "Travel rule from 1 July 2026 for virtual assets", "note": "applies to every virtual asset transfer regardless of value; there is no de minimis" }, { "label": "Self-hosted wallets handled separately", "note": "an ordering institution transferring to a self-hosted wallet must collect and verify payer information and collect payee and tracing information; reporting on transfers to unverified self-hosted wallets starts 31 March 2029" }, { "label": "ASIC INFO 225, updated 29 October 2025", "note": "18 worked examples plus a sector-wide no-action position on licensing until 30 June 2026" } ], "tags": [ "no privacy coin ban", "no travel rule threshold", "self-hosted wallets separate", "wholesale CBDC only" ], "sources": [ { "label": "ASIC 25-250MR on digital asset guidance", "url": "https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2025-releases/25-250mr-updated-asic-guidance-supports-digital-asset-innovation-and-boosts-investor-protection/" }, { "label": "Overview of the AML/CTF Amendment Act", "url": "https://www.homeaffairs.gov.au/criminal-justice/Pages/overview-of-the-amlctf-amendment-act.aspx" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-australia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-australia.md" }, { "slug": "jur-thailand", "name": "Thailand", "summary": "Thailand (SEC Thailand · Bank of Thailand · AMLO · PDPC): Closed by whitelist, not by prohibition. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Closed by whitelist, not by prohibition", "authority": "SEC Thailand · Bank of Thailand · AMLO · PDPC", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Thailand is the jurisdiction most often cited as having banned privacy coins, and the claim does not survive reading the instrument. Notification No. Kor Thor. 18/2564 prohibits four categories (meme tokens, fan tokens, NFTs and exchange-issued tokens) and stops there. Anonymity is never mentioned. The exclusion is real but it works through market architecture instead: exchanges may list only what the SEC has approved, the approved list is short, and anonymity-enhancing assets simply never reach it. Combined with the ban on using digital assets for payment since April 2022 and the 2025 extension of the perimeter to offshore operators targeting Thai users, the practical result is closed access rather than illegal holding. The distinction matters, and almost every secondary source erases it.", "instruments": [ { "label": "Notification No. Kor Thor. 18/2564, effective 11 June 2021", "note": "bars exchanges from listing meme tokens, fan tokens, NFTs and exchange-issued tokens; those four categories are the complete scope, and privacy coins are not among them" }, { "label": "Positive listing approval", "note": "exchanges may list only assets the SEC accepts, which has been a short list" }, { "label": "Digital assets barred as a means of payment from 1 April 2022" }, { "label": "Emergency Decree amendments, 13 April 2025", "note": "extended obligations to offshore operators targeting Thai users, with criminal penalties and platform blocking" } ], "tags": [ "whitelist regime", "no named coin ban", "commonly misreported", "payments ban" ], "sources": [ { "label": "Primary text of Notification 18/2564", "url": "https://www.tilleke.com/insights/thailand-announces-prohibited-digital-tokens-and-cryptocurrencies/" }, { "label": "Thailand chapter, Global Legal Insights", "url": "https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/thailand/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-thailand", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-thailand.md" }, { "slug": "jur-india", "name": "India", "summary": "India (FIU-IND · RBI · CBDT · Data Protection Board): No crypto statute, regulated through AML and tax. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "No crypto statute, regulated through AML and tax", "authority": "FIU-IND · RBI · CBDT · Data Protection Board", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "India has no bespoke crypto statute and regulates the sector through anti-money-laundering law and tax instead. Providers became reporting entities under the PMLA in March 2023, and FIU-IND has enforced that perimeter hard against offshore exchanges, issuing show-cause notices to nine of them in December 2023 and following with penalties and URL blocking. We found no Indian instrument restricting privacy coins, so the pressure on confidentiality is indirect: a 1% withholding on transfers creates a transaction-level trail as a matter of tax design, and the 30% flat rate pushes activity onto fully identified venues. The retail e-rupee pilot is the counterweight, its stated design leaving small-value transactions untraced once issued to a wallet, with disclosure expected on larger sums.", "instruments": [ { "label": "Ministry of Finance notification, 7 March 2023", "note": "made virtual digital asset service providers reporting entities under the Prevention of Money Laundering Act 2002, requiring FIU-IND registration, KYC and suspicious transaction reporting" }, { "label": "30% tax and 1% TDS", "note": "sections 115BBH and 194S of the Income Tax Act 1961; the withholding creates a transaction-level trail by design" }, { "label": "Digital Personal Data Protection Rules 2025", "note": "notified 13 November 2025, phasing in through the consent manager framework from 13 November 2026 to full compliance from 13 May 2027" } ], "tags": [ "PMLA reporting entity", "1% TDS", "DPDP Act", "offshore enforcement" ], "sources": [ { "label": "FIU-IND", "url": "https://fiuindia.gov.in/" }, { "label": "India chapter, Global Legal Insights", "url": "https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/india/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-india", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-india.md" }, { "slug": "jur-singapore", "name": "Singapore", "summary": "Singapore (MAS · PDPC): Regulates anonymity by risk assessment, not prohibition. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Regulates anonymity by risk assessment, not prohibition", "authority": "MAS · PDPC", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The one jurisdiction in this section that declined to exclude anonymity-enhancing assets and chose to price the risk instead. MAS set the position in Parliament in October 2022: privacy coins, privacy wallets and mixers attract enhanced obligations rather than prohibition. The notice requires providers to risk-assess such tokens before dealing and to pay special attention to technologies favouring anonymity, and MAS has observed that most licensed firms simply choose not to offer them anyway. That restraint sits alongside a travel rule with no minimum value and a deliberately narrow licensing door. COSMIC is worth noting for what it shows about the underlying logic: Singapore legislated a carve-out from bank secrecy so banks could share data privately with each other, not publicly.", "instruments": [ { "label": "MAS Notice PSN02", "note": "providers must risk-assess privacy tokens before dealing and pay special attention to technologies that favour anonymity, with enhanced transaction monitoring, but no prohibition" }, { "label": "No travel rule threshold", "note": "transfers at or below SGD 1,500 still carry originator and beneficiary names and account numbers; above it the originator's identity must be verified" }, { "label": "DTSP regime, from 30 June 2025", "note": "Part 9 of the Financial Services and Markets Act 2022 commenced with no transition, and MAS said it will generally not licence firms serving only offshore customers" }, { "label": "COSMIC, live 1 April 2024", "note": "a statutory carve-out from banking confidentiality letting six banks share customer red-flag data with each other" } ], "tags": [ "no privacy coin ban", "risk-based", "zero threshold", "Project Guardian" ], "sources": [ { "label": "MAS Notice PSN02", "url": "https://www.mas.gov.sg/regulation/notices/psn02-aml-cft-notice---digital-payment-token-service" }, { "label": "MAS parliamentary reply on privacy coins", "url": "https://www.mas.gov.sg/news/parliamentary-replies/2022/reply-to-parliamentary-question-on-prevalence-and-regulation-of-cryptocurrency-transactions" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-singapore", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-singapore.md" }, { "slug": "jur-hong-kong", "name": "Hong Kong SAR", "summary": "Hong Kong SAR (SFC · HKMA · Privacy Commissioner for Personal Data): Retail exclusion by liquidity gate, not by anonymity rule. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Retail exclusion by liquidity gate, not by anonymity rule", "authority": "SFC · HKMA · Privacy Commissioner for Personal Data", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "A good illustration of exclusion happening without a rule that mentions the thing being excluded. Hong Kong's platform guidelines say nothing about privacy coins, anonymity or mixers anywhere in the text. What they require is that any token offered to retail clients be an eligible large-cap virtual asset, present in at least two acceptable indices from two different providers. Monero and Zcash fail that liquidity test, so they are absent from retail without any policy against confidentiality ever being stated. The wider posture is expansionist on tokenisation and stablecoins, with the first licences granted in April 2026. The June 2025 policy statement setting the digital asset strategy is similarly silent: privacy is not argued against, it is simply never raised.", "instruments": [ { "label": "VATP Guidelines, June 2023, paragraph 7.8", "note": "retail tokens must be eligible large-cap virtual assets, included in at least two acceptable indices from two different providers, one of them IOSCO-compliant" }, { "label": "No anonymity language at all", "note": "the full text of the guidelines contains no mention of privacy coins, anonymity or mixers; paragraph 7.8 Note 3 allows case-by-case appeal to the SFC" }, { "label": "Stablecoins Ordinance (Cap. 656), from 1 August 2025", "note": "first two licences granted 10 April 2026, to Anchorpoint Financial and HSBC" }, { "label": "Policy Statement 2.0, 26 June 2025", "note": "sets the LEAP framework and endorses Project Ensemble; contains no reference to privacy, confidentiality or anonymity anywhere" } ], "tags": [ "large-cap gate", "no explicit ban", "Project Ensemble", "silent on privacy" ], "sources": [ { "label": "SFC virtual asset trading platform operators", "url": "https://www.sfc.hk/en/Rules-and-standards/Virtual-assets/Virtual-asset-trading-platforms-operators" }, { "label": "HKMA stablecoin licences, April 2026", "url": "https://www.hkma.gov.hk/eng/news-and-media/press-releases/2026/04/20260410-4/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-hong-kong", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-hong-kong.md" }, { "slug": "jur-taiwan", "name": "Taiwan", "summary": "Taiwan (Financial Supervisory Commission): The travel rule that has never come into force. Region: Asia-Pacific. Regime still forming: No settled rule on confidentiality yet; the framework is in draft or newly in force.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "The travel rule that has never come into force", "authority": "Financial Supervisory Commission", "stance": "emerging", "stanceLabel": "Regime still forming", "stanceMeaning": "No settled rule on confidentiality yet; the framework is in draft or newly in force.", "description": "Two things commonly reported about Taiwan are wrong. The VASP Act is not pending; it passed its third reading on 30 June 2026, though commencement still has to be designated and licensing runs on a 21-month tail after that. And the travel rule, often described as operative with an NT$30,000 threshold, has never been in force at all. The provision has carried a deferred effective date since 2021, and the regulator confirmed in writing in August 2026 that it has still not been implemented, setting out a phased plan starting with domestic transfers in October 2026. There is no named privacy-coin prohibition. For now Taiwan is the outlier: a registration regime in force, and the transfer-identity machinery still switched off.", "instruments": [ { "label": "VASP Act passed third reading 30 June 2026, promulgated 22 July 2026", "note": "56 articles defining seven service categories and requiring central bank consent plus FSC permission for stablecoin issuance; commencement is delegated to the Executive Yuan and has not been set, after which firms have 12 months to apply and 21 to be licensed" }, { "label": "Travel rule not implemented", "note": "the FSC confirmed in writing on 4 August 2026 that the mechanism has to date not been implemented, five years after the provision was made" }, { "label": "Phased plan announced", "note": "domestic VASP-to-VASP from October 2026, cross-border from end-2027, applying to transfers of any value with NT$30,000 as an enhanced-data trigger" }, { "label": "Mandatory registration from 30 November 2024", "note": "under the Money Laundering Control Act; nine firms had registered as at 22 September 2025" }, { "label": "No functioning data protection authority", "note": "Constitutional Court judgment 111-憲判-13 of 12 August 2022 gave three years to build an independent supervisory mechanism; that deadline lapsed unmet in August 2025" }, { "label": "PDPA Article 1-1 has never commenced", "note": "it designates a Personal Data Protection Commission as competent authority, but the Executive Yuan has not set a commencement date and the body remains a preparatory office" } ], "tags": [ "VASP Act 2026", "travel rule deferred", "no coin blacklist", "commonly misreported" ], "sources": [ { "label": "Financial Supervisory Commission", "url": "https://www.fsc.gov.tw/ch/home.jsp?id=96&parentpath=0,2" }, { "label": "Money Laundering Control Act", "url": "https://law.moj.gov.tw/ENG/LawClass/LawAll.aspx?pcode=G0380131" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-taiwan", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-taiwan.md" }, { "slug": "jur-south-korea", "name": "South Korea", "summary": "South Korea (FSC · FSS · KoFIU · PIPC): Identity-maximalist, and exporting the model. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Identity-maximalist, and exporting the model", "authority": "FSC · FSS · KoFIU · PIPC", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The most identity-maximalist regime covered here, and the only one actively trying to export it. Untraceable assets have been barred from Korean platforms since 2021, layered on top of a real-name bank account requirement that makes the won on-ramp a chokepoint. The August 2026 amendments go further than anything else in this section: the travel rule threshold is abolished outright so it applies to transfers of any size, and transfers to personal wallets are permitted only where the destination is low-risk or the two ends are confirmed to be the same person, with outright prohibition where the counterparty is high-risk. Accommodation exists but sits entirely on the institutional access axis (corporate accounts, tokenised securities) and not on confidentiality.", "instruments": [ { "label": "Dark coin restriction", "note": "the FSC announced in November 2020 that virtual assets whose transaction records are hard to trace could not be handled, with enforcement from March 2021; exchanges had already delisted Monero, Zcash, Dash and Zcoin in September 2019 citing FATF" }, { "label": "Virtual Asset User Protection Act, from 19 July 2024", "note": "deposit custody at banks, asset segregation, mandatory surveillance systems and unfair-trading reporting to the FSS" }, { "label": "Cabinet approval, 11 August 2026", "note": "abolishes the travel rule threshold entirely, so it applies to transfers of all sizes; transfers of KRW 10m or more to overseas providers must be reported to KoFIU" }, { "label": "Unhosted wallet transfers restricted", "note": "permitted only where the destination is low-risk or sender and recipient are confirmed to be the same person, and prohibited outright where the counterparty is high-risk" } ], "tags": [ "dark coin bar", "real-name accounts", "zero threshold", "unhosted wallet limits" ], "sources": [ { "label": "FSC on the August 2026 enforcement decree amendments", "url": "https://www.fsc.go.kr/eng/pr010101/87500" }, { "label": "FSC on the Virtual Asset User Protection Act", "url": "https://www.fsc.go.kr/eng/pr010101/82683" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-korea", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-korea.md" }, { "slug": "jur-japan", "name": "Japan", "summary": "Japan (FSA · JVCEA · Personal Information Protection Commission): Untraceability barred by self-regulation, now moving into ordinance. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Untraceability barred by self-regulation, now moving into ordinance", "authority": "FSA · JVCEA · Personal Information Protection Commission", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Japan shows the pattern in this section at its clearest: the rule is written against untraceability, never against named assets. The industry body's handling rules have barred members since 2018 from dealing in any crypto asset whose transfer records cannot be traced or are markedly difficult to trace, which is why Monero, Zcash and Dash have been absent from Japanese venues for years without any instrument naming them. Legislation enacted in July 2026 moves crypto trading out of payments law and into the securities framework. Worth being precise about what that does to traceability: the statute bars assets failing user-protection standards, but the criteria, including transfer-record management, are delegated to Cabinet Office Ordinance and have not been written yet.", "instruments": [ { "label": "JVCEA handling rules, Article 4(3), from 30 July 2018", "note": "members must not handle a crypto asset whose transfer records cannot be traced or are markedly difficult to trace; the test is traceability, not the asset's name" }, { "label": "Green List, updated 5 August 2026", "note": "30 assets, none of them Monero, Zcash or Dash; note this is a widely-handled list rather than the permitted universe, so absence is evidence and not proof of prohibition" }, { "label": "FIEA migration enacted 15 July 2026", "note": "moves crypto trading out of the Payment Services Act into the Financial Instruments and Exchange Act as a product distinct from securities, creates crypto insider trading, and raises the unregistered-operator penalty to ten years" }, { "label": "Amended FIEA Article 43-7", "note": "bars handling assets failing user-protection standards, with the criteria (including transfer-record management) delegated to Cabinet Office Ordinance rather than set in the statute" } ], "tags": [ "traceability test", "JVCEA Article 4(3)", "FIEA migration", "ordinance-level detail" ], "sources": [ { "label": "JVCEA Green List", "url": "https://jvcea.or.jp/statistics/document/greenlist/" }, { "label": "FSA bill materials, 221st Diet", "url": "https://www.fsa.go.jp/common/diet/221/02/03.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-japan", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-japan.md" }, { "slug": "jur-china", "name": "China", "summary": "China (People's Bank of China · CSRC · NFRA · SAFE): Crypto banned, and a state currency designed for anonymity. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Crypto banned, and a state currency designed for anonymity", "authority": "People's Bank of China · CSRC · NFRA · SAFE", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Two things are true here at once, and most coverage reports only the first. Decentralised crypto is prohibited, and the prohibition was renewed in February 2026 by an eight-agency notice that replaced the 2021 one and extended the perimeter to offshore RMB-pegged stablecoins and domestic tokenisation of real-world assets. Then the same central bank built a retail currency around deliberate anonymity. Its own paper sets the principle as anonymity for small amounts and traceability for large amounts in accordance with the law, and confirms the lowest wallet tier opens on a phone number alone, capped at CNY 2,000, with telecom operators barred from disclosing the identity behind that number even to the central bank. The limits are structural: this anonymity is administered, capped and revocable, not cryptographic.", "instruments": [ { "label": "Notice 银发〔2026〕42号, 6 February 2026", "note": "issued by eight agencies, it repeals and replaces the well-known 2021 notice; virtual currency business remains illegal financial activity, and it newly bars offshore issuance of RMB-pegged stablecoins and domestic real-world-asset tokenisation without approval" }, { "label": "Silent on individuals", "note": "the 2026 notice addresses business activity and says nothing about individual holding, self-custody or wallets" }, { "label": "Managed anonymity", "note": "the e-CNY follows the stated principle of anonymity for small amounts and traceability for large amounts in accordance with the law" }, { "label": "Level-four wallets need only a phone number", "note": "they are opened without identity verification, capped at CNY 2,000 per transaction, and telecom operators may not arbitrarily disclose the identity behind that number to third parties, expressly including the central bank" }, { "label": "The central bank holds no personal data", "note": "it processes only inter-institutional transaction information, while wallet-to-wallet identifier anonymisation keeps users anonymous to counterparties and commercial institutions" } ], "tags": [ "managed anonymity", "e-CNY", "tiered wallets", "2026 notice" ], "sources": [ { "label": "Notice 银发〔2026〕42号", "url": "https://www.pbc.gov.cn/tiaofasi/144941/3581332/2026020619591971323/index.html" }, { "label": "Balancing Privacy and Security, PBoC Digital Currency Institute", "url": "https://www.pbc.gov.cn/en/3935690/3935759/4696666/2022110110364344083.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-china", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-china.md" }, { "slug": "jur-kazakhstan", "name": "Kazakhstan", "summary": "Kazakhstan (National Bank of Kazakhstan · ARDFM · AFSA in the AIFC): Surveillance tooling required of operators, not run by the state. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Surveillance tooling required of operators, not run by the state", "authority": "National Bank of Kazakhstan · ARDFM · AFSA in the AIFC", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Worth correcting a claim that circulates about Kazakhstan: the law does not establish a state system watching digital asset transactions. It requires each licensed operator to run its own analysis and control system, built to the National Bank's specification, which is a mandated chain-analytics obligation rather than centralised surveillance. The teeth are in the identification rule. Operators must hold information sufficient to identify both sender and recipient, and a transfer with incomplete information is suspended and then refused. Unsecured digital assets remain legal but are stripped of status as a means of payment or a financial instrument. A second, separate track exists inside the Astana financial centre under its own regulator, whose terms we could not verify.", "instruments": [ { "label": "Law No. 193-VII of 6 February 2023 on digital assets", "note": "the National Bank licenses and oversees operators of unsecured digital asset exchanges and digital financial asset platforms" }, { "label": "System for the analysis and control of operations", "note": "defined in the law as a platform or service for monitoring digital asset operations, tracking them and detecting suspicious activity; operators must implement one to National Bank specification" }, { "label": "A duty on operators, not a state platform", "note": "the obligation was added by a 2026 amendment and is closer to a mandated chain-analytics requirement than to centralised state surveillance" }, { "label": "Identification blocks the transfer", "note": "operators must collect sender and recipient information sufficient to identify them; transfers with incomplete information are suspended for at least 48 hours and refused if not remedied" }, { "label": "Personal data must stay in country", "note": "Article 12 of the 2013 personal data law requires storage in a database located on Kazakh territory, which constrains offshore custody and analytics" } ], "tags": [ "operator-run analytics", "travel rule", "data localisation", "AIFC second track" ], "sources": [ { "label": "Law No. 193-VII on digital assets", "url": "https://zakon.uchet.kz/rus/docs/Z2300000193" }, { "label": "Law No. 94-V on personal data", "url": "https://zakon.uchet.kz/rus/docs/Z1300000094" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kazakhstan", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kazakhstan.md" }, { "slug": "jur-malaysia", "name": "Malaysia", "summary": "Malaysia (Securities Commission Malaysia): A categorical ban written by definition, not by coin name. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "A categorical ban written by definition, not by coin name", "authority": "Securities Commission Malaysia", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The most explicit categorical ban in the Asia-Pacific set, and notable for how it is drafted. Malaysia does not list forbidden coins. It prohibits exchange operators from permitting a privacy token to be offered for trading, then defines a privacy token by purpose: one intended to enhance user anonymity and transaction confidentiality. That catches the technique wherever it appears, including designs that did not exist when the rule was written, and it applies regardless of whether an asset is otherwise reputable. The same revision liberalised elsewhere, moving listing decisions to the exchange's own board under documented criteria. So Malaysia loosened its grip on what may be listed while tightening it specifically around confidentiality.", "instruments": [ { "label": "Guidelines on Recognized Markets, revised 20 May 2026", "note": "paragraph 15.24 provides that a digital asset exchange operator must not permit a privacy token to be offered for trading on its platforms" }, { "label": "The definition is the mechanism", "note": "guidance defines a privacy token as a digital token intended to enhance user anonymity and transaction confidentiality, so the ban catches technique rather than any named asset" }, { "label": "Restricted, not prohibited", "note": "meme tokens, exchange tokens, nascent utility tokens, initial exchange offering tokens and stablecoins are tradable only under enhanced risk policies" }, { "label": "Listing criteria at paragraph 15.21", "note": "include identifiable rights or utility, at least a year of trading on a FATF-compliant provider, sufficient liquidity, sound ledger security and a security audit" } ], "tags": [ "privacy token ban", "paragraph 15.24", "definition-based", "self-listing" ], "sources": [ { "label": "Guidelines on Recognized Markets", "url": "https://www.sc.com.my/api/documentms/download.ashx?id=9e4d86cb-889d-412d-94ec-a19b8ac5f7d7" }, { "label": "SC media release on the revised guidelines", "url": "https://www.sc.com.my/resources/media/media-release/sc-issues-revised-guidelines-on-recognized-markets-for-digital-asset-exchange" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-malaysia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-malaysia.md" }, { "slug": "jur-philippines", "name": "Philippines", "summary": "Philippines (Bangko Sentral ng Pilipinas · SEC): Every transfer is a cross-border wire, inside a closed chain. Region: Asia-Pacific. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Every transfer is a cross-border wire, inside a closed chain", "authority": "Bangko Sentral ng Pilipinas · SEC", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Read in full, the circular contains no provision on privacy coins, mixers or tumblers, and no express treatment of self-hosted wallets. What makes the Philippines restrictive in practice is structural instead. Every virtual asset transfer is treated as a cross-border wire transfer, so the travel rule applies to flows other regimes would consider domestic, and providers may deal only inside what the circular calls an unbroken chain of regulated entities. That closes the perimeter around self-custody without ever legislating against it. Worth noting the clause that cuts the other way, because it is rare: providers are expressly obliged to keep the identity data they collect confidential and to prevent unauthorised disclosure. The obligation is to know, not to publish.", "instruments": [ { "label": "BSP Circular No. 1108, signed 26 January 2021", "note": "providers and supervised institutions shall consider all virtual asset transfer transactions as cross-border wire transfers" }, { "label": "PHP 50,000 travel rule", "note": "at or above it the originating institution must obtain, hold and transmit originator name, account or wallet, and an address, national ID, customer ID or date and place of birth, plus beneficiary name and wallet" }, { "label": "An unbroken chain of regulated entities", "note": "a provider may engage only with other providers, financial institutions and transfer companies that are duly authorised and licensed, which constrains self-custody indirectly rather than by rule" }, { "label": "A confidentiality duty runs the other way", "note": "providers must uphold the confidentiality, integrity and availability of the required information and prevent unauthorised disclosure" }, { "label": "Thresholds below the travel rule", "note": "customer due diligence from PHP 5,000 in single or linked transactions, enhanced due diligence for pay-outs above PHP 500,000, records kept five years" } ], "tags": [ "cross-border wire treatment", "PHP 50,000", "unbroken chain", "confidentiality duty" ], "sources": [ { "label": "BSP Circular No. 1108", "url": "https://www.bsp.gov.ph/Regulations/Issuances/2021/1108.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-philippines", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-philippines.md" }, { "slug": "jur-bangladesh", "name": "Bangladesh", "summary": "Bangladesh (Bangladesh Bank): Barred through exchange control, not a crypto law. Region: Asia-Pacific. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Barred through exchange control, not a crypto law", "authority": "Bangladesh Bank", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Bangladesh is a useful reminder that a country does not need a crypto statute to prohibit crypto. The bar here runs through exchange control: because virtual currencies are not currency within the meaning of the 1947 foreign exchange law, dealing in them is not an approved transaction, and the central bank's 2022 circular states plainly that such transactions and any facilitation of them are not permitted. Breach is cognizable under the same 1947 Act. There is no licensing path and no state digital currency offering an alternative, so the practical effect is that residents transact on fully identified bank and mobile money rails. Confidentiality is not restricted here so much as the entire asset class is.", "instruments": [ { "label": "FE Circular No. 24, 15 September 2022", "note": "transactions in, from or to Bangladesh for obtaining virtual assets, and providing any kind of facilitation for such business, are not permitted" }, { "label": "The reasoning is definitional", "note": "virtual currencies are not recognised as currency under section 2(b)(i) of the Foreign Exchange Regulation Act 1947, and are neither approved foreign exchange nor an approved transaction" }, { "label": "Criminally enforceable", "note": "violations contravene section 5(1)(e) of the 1947 Act and are cognizable under section 23(1)" }, { "label": "No substitute channel", "note": "no crypto-specific licensing route exists and we located no central bank digital currency pilot, so activity is pushed onto fully identified banking and mobile financial service rails" } ], "tags": [ "prohibition", "exchange control", "FER Act 1947", "no CBDC found" ], "sources": [ { "label": "FE Circular No. 24", "url": "https://www.bb.org.bd/mediaroom/circulars/fepd/sep152022fepd24e.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bangladesh", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bangladesh.md" }, { "slug": "jur-united-states", "name": "United States", "summary": "United States (Treasury · FinCEN · OFAC · SEC · CFTC · IRS · state regulators): Split by perimeter, not by ideology. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "Split by perimeter, not by ideology", "authority": "Treasury · FinCEN · OFAC · SEC · CFTC · IRS · state regulators", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The US moved in both directions at once between 2024 and 2026, and the dividing line is custody rather than politics. Where an intermediary holds customer assets, identity obligations expanded: broker reporting went live on schedule, the travel rule is unchanged, and stablecoin issuers must now be able to freeze and seize. Where software is non-custodial, the direction reversed: the unhosted wallet proposal was withdrawn, the DeFi broker rule was repealed by Congress and cannot be reissued without new legislation, and a derivatives regulator declined to treat self-custodial wallet software as an intermediary. Executive Order 14178 states protection of self-custody and uncensored transacting as policy. Almost none of this is settled law: the market structure bill has still not passed.", "instruments": [ { "label": "Tightening at the custodial perimeter", "note": "1099-DA broker reporting live with basis from 2026, the Bank Secrecy Act travel rule, GENIUS Act freeze-and-seize capability, NYDFS blockchain analytics, California DFAL five-year identity records" }, { "label": "Loosening around non-custodial software", "note": "the 2020 unhosted wallet rule withdrawn in 2024, the DeFi broker rule repealed in 2025 and barred from reintroduction, the travel rule threshold cut withdrawn, and a CFTC no-action position for self-custodial wallet software in March 2026" }, { "label": "Executive Order 14178, 23 January 2025", "note": "makes it policy to protect lawful use of public blockchains, including developing software, transacting without unlawful censorship, and maintaining self-custody" }, { "label": "Almost nothing legislative has passed", "note": "the CLARITY Act reached a Senate cloture motion in August 2026 without a vote; the Blockchain Regulatory Certainty Act and the anti-CBDC bills remain pending" } ], "tags": [ "perimeter split", "self-custody", "EO 14178", "legislation pending" ], "sources": [ { "label": "Executive Order 14178", "url": "https://www.govinfo.gov/content/pkg/FR-2025-01-31/pdf/2025-02123.pdf" }, { "label": "IRS digital assets", "url": "https://www.irs.gov/filing/digital-assets" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-united-states", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-united-states.md" }, { "slug": "jur-sri-lanka", "name": "Sri Lanka", "summary": "Sri Lanka (Central Bank of Sri Lanka · Financial Intelligence Unit): Unregulated rather than prohibited. Region: Asia-Pacific. Regime still forming: No settled rule on confidentiality yet; the framework is in draft or newly in force.", "kind": "jurisdiction", "region": "Asia-Pacific", "category": "Unregulated rather than prohibited", "authority": "Central Bank of Sri Lanka · Financial Intelligence Unit", "stance": "emerging", "stanceLabel": "Regime still forming", "stanceMeaning": "No settled rule on confidentiality yet; the framework is in draft or newly in force.", "description": "Sri Lanka occupies the position a lot of countries were in five years ago and few still are: crypto is neither licensed nor forbidden. The central bank has said it has authorised nobody to operate schemes involving virtual currencies and approved no token offering, and has warned about the risks, but it has not prohibited holding or trading. That leaves no privacy position to describe, because there is no regime to have one. It also leaves users without the protections a licensing regime brings. Movement toward registration of providers with the financial intelligence unit has been proposed rather than enacted, so the vacuum is the current state rather than a settled policy.", "instruments": [ { "label": "CBSL public notice, 16 April 2018", "note": "virtual currencies are not central bank issued currency, and the central bank has not licensed or authorised any entity to operate schemes involving them, nor authorised any initial coin offering" }, { "label": "A warning, not a ban", "note": "the notice sets out volatility, consumer protection and money laundering risks but stops short of prohibition, which distinguishes Sri Lanka from Bangladesh" }, { "label": "Personal Data Protection Act No. 9 of 2022", "note": "commenced in parts, with Part V from 17 July 2023 and further parts from 1 December 2023" } ], "tags": [ "no licences issued", "warning not ban", "regulatory vacuum", "PDPA 2022" ], "sources": [ { "label": "CBSL public awareness notice on virtual currencies", "url": "https://www.cbsl.gov.lk/en/news/public-awareness-on-virtual-currencies-in-sri-lanka" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-sri-lanka", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-sri-lanka.md" }, { "slug": "jur-united-kingdom", "name": "United Kingdom", "summary": "United Kingdom (FCA · Bank of England · Information Commissioner): Risk-based, with an explicit central bank no-access pledge. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "Risk-based, with an explicit central bank no-access pledge", "authority": "FCA · Bank of England · Information Commissioner", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The UK has built a full regulatory perimeter without reaching for a single prohibition on privacy technology. There is no ban on anonymity-enhancing assets and no bar on transfers to unhosted wallets; firms are expected to document a risk-based approach, and transfers into jurisdictions that have not implemented the travel rule call for enhanced assessment rather than refusal. Two things are worth noting on the other side of the ledger. The FCA runs a permanent digital sandbox offering hundreds of synthetic, anonymised and pseudonymised datasets, cooperating with the data protection regulator. And the digital pound design carries an unusually direct commitment that neither the Bank nor the Government would have access to users' personal data.", "instruments": [ { "label": "FSMA (Cryptoassets) Regulations 2026, made 4 February 2026", "note": "brings dealing, arranging, trading platforms, custody, qualifying stablecoin issuance and staking arrangement into the regulated perimeter" }, { "label": "FCA final rules, 30 June 2026", "note": "the authorisation gateway opens 30 September 2026, applications run to 28 February 2027, and the regime bites 25 October 2027" }, { "label": "Travel rule since 1 September 2023", "note": "under Part 7A of the Money Laundering Regulations 2017; transfers to non-implementing jurisdictions require enhanced assessment rather than automatic refusal" }, { "label": "Digital pound privacy commitment", "note": "neither the Bank nor Government would access users' personal data; payment interface providers do the identity work and anonymise before the core ledger" } ], "tags": [ "risk-based", "no privacy coin ban", "digital sandbox", "digital pound" ], "sources": [ { "label": "FCA new cryptoasset regime", "url": "https://www.fca.org.uk/firms/new-regime-cryptoasset-regulation" }, { "label": "Bank of England digital pound", "url": "https://www.bankofengland.co.uk/the-digital-pound" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-united-kingdom", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-united-kingdom.md" }, { "slug": "jur-switzerland", "name": "Switzerland", "summary": "Switzerland (FINMA · Federal Data Protection and Information Commissioner): Crypto-friendly and strict on anonymity at once. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Europe", "category": "Crypto-friendly and strict on anonymity at once", "authority": "FINMA · Federal Data Protection and Information Commissioner", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "A useful corrective to the assumption that a crypto-friendly jurisdiction is permissive about anonymity. The two are unrelated, and Switzerland proves it. Nothing in Swiss law bans privacy coins, and the regulator treats anonymity as a risk factor rather than a prohibited property. But since 2019 supervised institutions have only been able to move tokens to an external wallet where that wallet belongs to their own identity-verified customer, with ownership demonstrated by technical proof. There is no minimum value and no carve-out for unregulated wallets, which makes it stricter than both the FATF standard and the EU rule that followed. The practical effect is that regulated Swiss venues are closed to anonymous self-custody, by supervisory practice rather than statute.", "instruments": [ { "label": "FINMA Guidance 02/2019, 26 August 2019", "note": "supervised institutions may send or receive tokens to an external wallet only where the wallet belongs to their own identity-verified customer, with ownership proven by technical means" }, { "label": "Stricter than FATF", "note": "no de minimis and no exception for unregulated wallets, which is a higher bar than the global standard or the EU travel rule" }, { "label": "Article 51a AMLO-FINMA", "note": "a CHF 1,000 identification threshold for occasional virtual currency transactions since 1 January 2021, aggregated over 30 days rather than per day" }, { "label": "No privacy coin ban", "note": "FINMA treats blockchain anonymity as an elevated money-laundering risk, not a prohibited feature" } ], "tags": [ "proof of ownership", "Guidance 02/2019", "CHF 1,000", "stricter than FATF" ], "sources": [ { "label": "FINMA Guidance 02/2019", "url": "https://www.finma.ch/en/news/2019/08/20190826-mm-kryptogwg/" }, { "label": "FINMA crypto services overview", "url": "https://www.finma.ch/en/documentation/dossier/dossier-fintech/auf-einen-blick-aufstellung-der-krypto-dienstleistungen/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-switzerland", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-switzerland.md" }, { "slug": "jur-turkey", "name": "Turkey", "summary": "Turkey (Capital Markets Board · MASAK · KVKK): Caps, delays and a compelled purpose description. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Europe", "category": "Caps, delays and a compelled purpose description", "authority": "Capital Markets Board · MASAK · KVKK", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Turkey reaches the same destination as an anonymity ban without ever writing one. No primary instrument prohibiting anonymity-enhancing tokens was found. What exists instead is a stack of operational controls that make routine confidentiality impractical at licensed venues: value caps on transfers, doubled only if the full travel rule dataset is collected, a mandatory waiting period before withdrawal, a declaration requirement for anything touching an unhosted wallet, and a compelled free-text description of what every transfer is for. Each measure is individually defensible as anti-fraud policy. Together they amount to a regime where a licensed Turkish venue cannot process a transfer it does not have a stated reason for.", "instruments": [ { "label": "Law No. 7518, July 2024", "note": "places crypto service provider licensing with the Capital Markets Board, with establishment and capital rules set by communiqués published 13 March 2025" }, { "label": "Travel rule from 25 February 2025", "note": "expanded originator data above TRY 15,000; transfers to or from unhosted wallets require a customer declaration, and transfers with unresolved information gaps are returned or rejected" }, { "label": "Communiqués 28 and 29, June 2025", "note": "stablecoin transfer caps of USD 3,000 daily and USD 50,000 monthly, doubled where full travel rule data is collected, with higher caps for other crypto assets" }, { "label": "Withdrawal delays and purpose text", "note": "a 48-hour delay on withdrawals, 72 hours on the first, plus a minimum 20-character description of every transfer's purpose" } ], "tags": [ "transfer caps", "withdrawal delay", "purpose description", "unhosted declaration" ], "sources": [ { "label": "Capital Markets Board", "url": "https://www.spk.gov.tr/" }, { "label": "MASAK", "url": "https://masak.hmb.gov.tr/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-turkey", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-turkey.md" }, { "slug": "jur-norway", "name": "Norway", "summary": "Norway (Finanstilsynet · Norges Bank · Datatilsynet): MiCA via the EEA, with a privacy-innovation sandbox. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "MiCA via the EEA, with a privacy-innovation sandbox", "authority": "Finanstilsynet · Norges Bank · Datatilsynet", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Norway took the EU rulebook through the EEA route and enforced it promptly, closing its transition window in July 2026 with providers told to wind down. That means the zero-threshold travel rule applies here as it does inside the union. The counterweight is unusual and worth knowing about: the Norwegian data protection authority has run a regulatory sandbox for privacy-enhancing innovation since 2020, and in 2024 ran a joint track with the financial supervisor. Few jurisdictions have both regulators in the same room on this question. Norges Bank concluded that a central bank digital currency is not currently warranted and closed its exploration phase in March 2026, so no retail privacy design question arises.", "instruments": [ { "label": "Lov om kryptoeiendeler, in force 1 July 2025", "note": "gives MiCA effect through the EEA Agreement following Joint Committee Decision No. 41/2025 of 20 February 2025" }, { "label": "Travel rule extended to crypto", "note": "simultaneous amendments to the anti-money-laundering act implemented the EU Transfer of Funds Regulation, with no de minimis" }, { "label": "Transition closed 1 July 2026", "note": "unauthorised providers must stop onboarding and wind down" }, { "label": "Datatilsynet regulatory sandbox", "note": "running since 2020 explicitly for privacy-enhancing innovation, including a joint track with the financial supervisor in 2024" } ], "tags": [ "MiCA via EEA", "no threshold", "privacy sandbox", "no CBDC" ], "sources": [ { "label": "Finanstilsynet on MiCA", "url": "https://www.finanstilsynet.no/tema/kryptoeiendeler-mica/" }, { "label": "Datatilsynet sandbox", "url": "https://www.datatilsynet.no/en/regulations-and-tools/sandbox-for-artificial-intelligence/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-norway", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-norway.md" }, { "slug": "jur-ukraine", "name": "Ukraine", "summary": "Ukraine (NSSMC · National Bank of Ukraine · Ombudsman): The law that passed and never commenced. Region: Europe. Regime still forming: No settled rule on confidentiality yet; the framework is in draft or newly in force.", "kind": "jurisdiction", "region": "Europe", "category": "The law that passed and never commenced", "authority": "NSSMC · National Bank of Ukraine · Ombudsman", "stance": "emerging", "stanceLabel": "Regime still forming", "stanceMeaning": "No settled rule on confidentiality yet; the framework is in draft or newly in force.", "description": "An unusual case: the virtual assets law passed in February 2022 is recorded in the official register as never having entered into force. With no operative licensing regime, there is no in-force restriction on anonymity-enhancing assets and no constraint on unhosted wallets, not as a policy choice, but because the machinery was never switched on. A MiCA-based replacement passed first reading in 2025 and would change that quickly. The detail worth carrying forward is the central bank's e-hryvnia design note, which states plainly that the regulator will not have any personal information. Explicit commitments of that kind from a central bank are rare enough to be worth citing wherever they appear.", "instruments": [ { "label": "Law No. 2074-IX on Virtual Assets, 17 February 2022", "note": "recorded in the official register as not having entered into force; Ukraine therefore has no operative service provider licensing regime" }, { "label": "Draft law 10225-d", "note": "introduced 24 April 2025 and drafted on a MiCA basis, passed first reading" }, { "label": "e-hryvnia design", "note": "the National Bank states that payments are secured by it while the regulator will not have any personal information, alongside offline payments and DLT-based wallet recovery" }, { "label": "Data protection still on the 2010 law", "note": "a GDPR-aligning draft was adopted as a basis in November 2024 and awaits second reading" } ], "tags": [ "not in force", "MiCA alignment", "CBDC no personal data", "unsettled" ], "sources": [ { "label": "Law 2074-IX on the Rada register", "url": "https://zakon.rada.gov.ua/laws/show/2074-20" }, { "label": "NBU e-hryvnia", "url": "https://bank.gov.ua/en/payments/e-hryvnia" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ukraine", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ukraine.md" }, { "slug": "jur-georgia", "name": "Georgia", "summary": "Georgia (National Bank of Georgia · State Audit Office): The one place where privacy oversight went backwards. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Europe", "category": "The one place where privacy oversight went backwards", "authority": "National Bank of Georgia · State Audit Office", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Across every jurisdiction surveyed for this section, institutional privacy oversight was either strengthening or holding steady. Georgia is the exception. Its independent data protection authority was liquidated in March 2026 and the function folded into the State Audit Office, which removes the separation that made the supervisor independent in the first place. On the financial side the picture is restrictive but conventional: providers have registered with the central bank since mid-2023, and using virtual assets for payment is barred by the organic law governing the central bank. Peer-to-peer trading with one's own funds stays outside the regime. We found no instrument addressing anonymity-enhancing assets either way.", "instruments": [ { "label": "Data protection authority abolished 2 March 2026", "note": "the independent Personal Data Protection Service was liquidated and its supervisory, inspection and complaint functions transferred to the State Audit Office" }, { "label": "Virtual asset payments prohibited", "note": "under Article 39¹(2) of the Organic Law on the National Bank, except in cases the central bank defines as necessary to provide virtual asset services" }, { "label": "Provider registration since 1 July 2023", "note": "under Governor's Decree N94/04 of 13 June 2023, imposing fit-and-proper, head office, systems and anti-money-laundering requirements on FATF lines" }, { "label": "Peer-to-peer left alone", "note": "trading with one's own funds does not trigger registration" } ], "tags": [ "DPA abolished", "payments ban", "registration regime", "innovation office" ], "sources": [ { "label": "NBG virtual asset service providers", "url": "https://nbg.gov.ge/en/page/virtual-asset-service-providers-vasps" }, { "label": "Anti-money-laundering law on Matsne", "url": "https://matsne.gov.ge/en/document/view/4690334" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-georgia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-georgia.md" }, { "slug": "jur-russia", "name": "Russia", "summary": "Russia (Bank of Russia · Federal Tax Service · Rosfinmonitoring): Wallet addresses reported to the state by statute. Region: Europe. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Europe", "category": "Wallet addresses reported to the state by statute", "authority": "Bank of Russia · Federal Tax Service · Rosfinmonitoring", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Russia has the most direct on-chain deanonymisation mandate found anywhere in this section. Miners must report the address identifier itself, mining pool included, to the tax authority, which passes it to the financial intelligence body and the central bank without any suspicion trigger. That is wallet-address disclosure written into statute rather than inferred from analytics. The digital rouble points the same way. Accounts sit not at a bank but on the central bank's own platform, with banks acting as front ends, so the issuer is positioned to see every transaction. The central bank's promise is precise and worth reading closely: the data carries the same bank secrecy as an ordinary account and will not exceed what cashless payments already reveal. That is confidentiality from third parties, not from the state.", "instruments": [ { "label": "Law 259-FZ of 31 July 2020", "note": "on digital financial assets and digital currency; only Russian legal entities entered in the Bank of Russia register may operate the information systems in which such assets are issued" }, { "label": "Article 14.2, the mining register", "note": "miners must report to the tax authority the digital currency received and the address identifier, expressly including the mining pool address" }, { "label": "Onward disclosure by operation of law", "note": "the tax authority then provides that information to the financial intelligence body and to the Bank of Russia, without any further trigger" }, { "label": "Law 223-FZ of 8 August 2024, in force 1 September 2024", "note": "creates the experimental legal regime under which digital currency may be used for settlement in foreign trade contracts" }, { "label": "Digital rouble mass rollout from 1 September 2026", "note": "extending to universal-licence banks and mid-sized merchants in September 2027 and to everyone else in September 2028" } ], "tags": [ "mining register", "wallet address disclosure", "digital rouble", "no anonymity tier" ], "sources": [ { "label": "Bank of Russia on digital financial assets", "url": "https://www.cbr.ru/eng/finm_infrastructure/digital_oper/" }, { "label": "Bank of Russia digital rouble", "url": "https://www.cbr.ru/fintech/dr/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-russia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-russia.md" }, { "slug": "jur-israel", "name": "Israel", "summary": "Israel (ISA · Capital Market Authority · IMPA · Privacy Protection Authority): Light on-chain, heavy on data protection. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Light on-chain, heavy on data protection", "authority": "ISA · Capital Market Authority · IMPA · Privacy Protection Authority", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Israel splits cleanly along the axis this whole section turns on. On chain, the constraint is light: no instrument restricts anonymity-enhancing assets or transfers to self-hosted wallets, and those questions fall under ordinary anti-money-laundering supervision rather than any dedicated rule. Off chain, the regime got considerably heavier a year ago. Amendment 13 to the Protection of Privacy Law came into force in August 2025, requiring privacy protection officers, widening the definition of sensitive data, and giving the regulator administrative orders and fines with real weight behind them. For a firm handling personal data alongside on-chain activity, the binding compliance burden here comes from the data protection side, not the financial one.", "instruments": [ { "label": "No crypto-specific anonymity rule", "note": "no Israeli instrument restricts privacy coins or transfers to self-hosted wallets; both sit under general anti-money-laundering monitoring" }, { "label": "Prohibition on Money Laundering Order (2018)", "note": "financial asset service providers owe customer due diligence, beneficiary and ownership declarations, monitoring and reporting, with source-of-funds enquiry above roughly ILS 100,000 of annual activity" }, { "label": "Amendment 13 to the Protection of Privacy Law, in force 14 August 2025", "note": "mandates privacy protection officers, broadens sensitive data, adds data broker duties, and gives the authority administrative orders, cease-and-desist powers and substantial fines" }, { "label": "Bank of Israel Directive 411 (2022)", "note": "bars banks from blanket refusal of crypto-related transactions" } ], "tags": [ "no AEC ban", "Amendment 13", "CMA licensing", "stablecoin memorandum" ], "sources": [ { "label": "Israel Securities Authority", "url": "https://www.new.isa.gov.il/" }, { "label": "Amendment 13 overview", "url": "https://iapp.org/news/a/israel-marks-a-new-era-in-privacy-law-amendment-13-ushers-in-sweeping-reform" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-israel", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-israel.md" }, { "slug": "jur-uae", "name": "United Arab Emirates", "summary": "United Arab Emirates (VARA · DFSA · ADGM FSRA · CBUAE): The most explicit prohibition anywhere in this section. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "The most explicit prohibition anywhere in this section", "authority": "VARA · DFSA · ADGM FSRA · CBUAE", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "If you want the counterexample to the pattern running through this section, it is here. Almost everywhere else, exclusion happens through listing rules, whitelists or traceability tests that never mention anonymity. Dubai's regulator simply writes it down: issuance of anonymity-enhanced cryptocurrencies, and every activity related to them, is prohibited in the Emirate. The financial free zones go further in a different direction, with the DIFC barring not only privacy tokens but the use of a privacy device (mixers and tumblers) as a category of tool. Four separate regulators operate here with different perimeters, which matters when structuring. Self-custody survives everywhere; the central bank's Digital Dirham is designed so that no personally identifiable information sits on the ledger.", "instruments": [ { "label": "VARA Regulations 2023, Part II Section C", "note": "states that the issuance of anonymity-enhanced cryptocurrencies and all virtual asset activities related to them are prohibited in the Emirate; the clearest named ban found in any jurisdiction here" }, { "label": "DFSA GEN 3A, in force 12 January 2026", "note": "prohibits regulated activity in privacy tokens and bars the use of a privacy device, meaning mixers and tumblers, in or from the DIFC" }, { "label": "ADGM FSRA amendments, 10 June 2025", "note": "enshrine in rules the prohibition on using privacy tokens within ADGM, and the FSRA refuses simplified customer due diligence for virtual assets citing pseudonymity" }, { "label": "VARA travel rule above AED 3,500", "note": "unhosted wallets are not banned; providers must document how they handle non-obliged entities and anonymity-enhanced transactions" } ], "tags": [ "explicit ban", "privacy devices", "four regulators", "Digital Dirham" ], "sources": [ { "label": "VARA rulebook, prohibited virtual assets", "url": "https://rulebooks.vara.ae/rulebook/c-prohibited-virtual-assets" }, { "label": "VARA rulebook, FATF travel rule", "url": "https://rulebooks.vara.ae/rulebook/g-fatf-travel-rule" }, { "label": "CBUAE Digital Dirham policy paper", "url": "https://www.centralbank.ae/media/lczb23l4/cbdc-short-report_july.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-uae", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-uae.md" }, { "slug": "jur-kenya", "name": "Kenya", "summary": "Kenya (Capital Markets Authority · Central Bank of Kenya · Data Protection Commissioner): The ban written into primary legislation, not a rulebook. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "The ban written into primary legislation, not a rulebook", "authority": "Capital Markets Authority · Central Bank of Kenya · Data Protection Commissioner", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Most prohibitions in this section live in rulebooks that a regulator can amend without going back to a legislature. Kenya's does not. The 2025 Act puts the restriction in primary law: a service provider may not undertake mixer or tumbler services, or anonymity-enhancing services, with the latter defined broadly enough to reach any transaction whose effect or intention is to conceal information. Breach is a criminal offence. That drafting choice matters more than its content, because it sets a much higher bar for reversal than the Gulf rulebooks that reach a similar result. Note also what the definition catches: it turns on effect, not on the name of an asset, so it is technique-neutral by design.", "instruments": [ { "label": "Virtual Asset Service Providers Act, No. 20 of 2025", "note": "assented 15 October 2025, gazetted 21 October and commenced 4 November 2025, amending the Capital Markets Act, the Central Bank of Kenya Act and the anti-money-laundering statute" }, { "label": "Section 21(1)(a)", "note": "a provider shall not undertake mixer or tumbler services or anonymity-enhancing services, the latter defined as transactions with the effect or intention of concealing information" }, { "label": "Criminal, not administrative", "note": "breach is an offence under section 40(3), which makes this materially harder to reverse than a regulator-made rule" }, { "label": "Split supervision under section 5", "note": "custody, payments and stablecoin issuance to the central bank; exchanges, brokerage, tokenisation and offerings to the markets authority" } ], "tags": [ "statutory ban", "mixers", "anonymity-enhancing services", "criminal penalty" ], "sources": [ { "label": "VASP Act No. 20 of 2025", "url": "https://new.kenyalaw.org/akn/ke/act/2025/20" }, { "label": "VASP Regulations 2026, Legal Notice 134", "url": "https://new.kenyalaw.org/akn/ke/act/ln/2026/134" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kenya", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kenya.md" }, { "slug": "jur-ghana", "name": "Ghana", "summary": "Ghana (Bank of Ghana · SEC · Financial Intelligence Centre): The regulator that put self-custody in writing. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "The regulator that put self-custody in writing", "authority": "Bank of Ghana · SEC · Financial Intelligence Centre", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Worth citing well beyond Ghana, because a central bank stated plainly in writing what most regimes leave to inference. Its FAQ says that neither the regulatory authorities nor the government will control private wallets or individual transactions, and that the law regulates service providers rather than personal ownership of digital assets. That is the custodial-perimeter principle running through this entire section, expressed by a regulator rather than argued by an industry. Ghana moved from prohibition to licensing inside a year, splitting supervision between the central bank and the securities regulator by activity. The cedi remains sole legal tender, and pricing or paying wages in virtual assets is not permitted.", "instruments": [ { "label": "Virtual Asset Service Providers Bill passed December 2025", "note": "confirmed by Bank of Ghana press release on 22 December 2025, establishing licensing with either the central bank or the securities regulator depending on activity" }, { "label": "Bank of Ghana FAQ, February 2026, Q8", "note": "neither the regulatory authorities nor the government will control private wallets or individual transactions, and the law focuses on regulating service providers rather than personal ownership of digital assets" }, { "label": "The cedi remains sole legal tender", "note": "invoicing, pricing or paying wages in virtual assets is not permitted" }, { "label": "Virtual Assets Regulatory Office", "note": "mandatory provider registration, with a public notice on unauthorised virtual asset and stablecoin advertising issued in February 2026" } ], "tags": [ "self-custody protected", "service providers only", "rare explicit statement", "VARO" ], "sources": [ { "label": "Bank of Ghana press release on the VASP Bill", "url": "https://www.bog.gov.gh/wp-content/uploads/2025/12/PRESS-RELEASE-PASSAGE-OF-THE-VIRTUAL-ASSET-SERVICE-PROVIDERS-BILL221225-1.pdf" }, { "label": "Bank of Ghana VASP Act FAQ", "url": "https://www.bog.gov.gh/virtual-assets/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ghana", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ghana.md" }, { "slug": "jur-south-africa", "name": "South Africa", "summary": "South Africa (FSCA · Financial Intelligence Centre · Information Regulator): A travel rule that starts at any value above zero. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "A travel rule that starts at any value above zero", "authority": "FSCA · Financial Intelligence Centre · Information Regulator", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The most precisely drafted travel rule in this section, and the one that leaves least room. Where other regimes debate where to set a minimum, South Africa defined a qualifying transfer as any crypto asset transfer above zero, then used its R5,000 line to reduce how much data is required rather than whether the rule applies at all. Providers must refuse to execute where they cannot comply. Self-custody is treated the way most of the world treats it (a risk category requiring documented policy, not a prohibition), and 2026 guidance singles out peer-to-peer and wallet-to-wallet transfers as higher risk. The tightening arrived alongside the country's exit from the FATF grey list in October 2025, which is the usual pattern.", "instruments": [ { "label": "Directive 9 of 2024, in operation 30 April 2025", "note": "defines a qualifying transfer as one involving a crypto asset which is any value above zero, so full originator identification travels with every single transfer" }, { "label": "Below R5,000", "note": "a reduced dataset applies and need not be verified absent money-laundering suspicion; the threshold reduces the data, it does not switch the rule off" }, { "label": "Paragraph 4.8", "note": "bars execution of a transfer where the rule cannot be met" }, { "label": "Section 8 and PCC 61 of 2026", "note": "unhosted wallets require documented risk-based policies rather than prohibition, with peer-to-peer and unhosted-to-unhosted transfers flagged as heightened risk" } ], "tags": [ "zero threshold", "Directive 9", "unhosted risk-based", "POPIA" ], "sources": [ { "label": "Directive 9 on the travel rule", "url": "https://www.fic.gov.za/wp-content/uploads/2024/11/Directive-9-Travel-rule-relating-to-crypto-asset-transfers.pdf" }, { "label": "PCC 61 of 2026", "url": "https://www.fic.gov.za/wp-content/uploads/2026/03/2026.3-PCC-_Travel-Rule-for-CASPS.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-africa", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-africa.md" }, { "slug": "jur-bahrain", "name": "Bahrain", "summary": "Bahrain (Central Bank of Bahrain · Personal Data Protection Authority): A listing test written against effects, not asset names. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "A listing test written against effects, not asset names", "authority": "Central Bank of Bahrain · Personal Data Protection Authority", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Bahrain never names a coin, and its rule is broader for it. Licensees may not list assets that facilitate, or may facilitate, obfuscation or concealment of a client or counterparty's identity, and the phrase may facilitate does a great deal of work, since it reaches capability rather than demonstrated use. The second limb is arguably more consequential: a licensee may only list assets it actually has the monitoring capability to supervise, which makes listing contingent on the state of analytics tooling rather than on any judgement about the asset. Together they are a cleaner statement of the real mechanism than most explicit bans, because they explain what regulators are actually protecting: their own ability to see.", "instruments": [ { "label": "CBB Rulebook Volume 6, CRA-4.3.12", "note": "licensees must not list crypto-assets that facilitate or may facilitate the obfuscation or concealment of the identity of a client or counterparty, or assets designed to or substantially used to circumvent laws and regulations" }, { "label": "Monitoring capability as a condition", "note": "the same rule requires licensees to list only assets for which they have the necessary anti-money-laundering monitoring capabilities in place" }, { "label": "Self-certified listing", "note": "against a board-approved policy filed with the central bank, with per-asset risk assessment including on-chain analysis capability" }, { "label": "Separate stablecoin module", "note": "the SIO module governs approved stablecoin issuance and offering" } ], "tags": [ "obfuscation test", "may facilitate", "monitoring capability", "self-certified listing" ], "sources": [ { "label": "CBB Rulebook, listing crypto-assets", "url": "https://cbben.thomsonreuters.com/rulebook/cra-43-listing-crypto-assets" }, { "label": "CBB Volume 6 crypto-asset module", "url": "https://www.cbb.gov.bh/wp-content/uploads/2024/01/Vol-6_CRA_2024.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bahrain", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bahrain.md" }, { "slug": "jur-qatar", "name": "Qatar", "summary": "Qatar (QFC Regulatory Authority · Qatar Central Bank): Exclusion by perimeter rather than prohibition. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Exclusion by perimeter rather than prohibition", "authority": "QFC Regulatory Authority · Qatar Central Bank", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Qatar reaches exclusion without ever writing a prohibition on anonymity, because its perimeter is drawn as a positive list. Only permitted tokens may be issued or traded: assets anchored to a verified real-world asset or legal right, passing a defined validation and tokenisation process. Cryptocurrencies and stablecoins are outside that definition entirely, so anonymity-enhancing assets never come up for consideration. What Qatar is building instead is a tokenisation regime with real property rights attached, recognised in its own courts, supported by an incubator. It is worth reading as a statement of what a regulator wants from a ledger: verified claims on identified things, not bearer instruments.", "instruments": [ { "label": "QFC Digital Assets Framework 2024, effective 1 September 2024", "note": "the Digital Asset Regulations 2024 and Investment Token Rules 2024 regulate only permitted tokens, meaning those anchored to verified real-world assets or legal rights" }, { "label": "Cryptocurrencies excluded by design", "note": "the framework expressly excludes cryptocurrencies, stablecoins and central bank digital currencies as currency substitutes" }, { "label": "Virtual asset services banned in the QFC since 26 December 2019", "note": "by regulatory alert, and not reversed by the 2024 framework" }, { "label": "Digital Assets Lab", "note": "a tokenisation incubator, with property rights in tokens recognised in QFC courts" } ], "tags": [ "permitted tokens", "crypto excluded", "tokenisation", "property rights" ], "sources": [ { "label": "QFC laws and regulations", "url": "https://www.qfc.qa/en/laws-and-regulations" }, { "label": "QFC Digital Assets Lab", "url": "https://www.qfc.qa/en/digital-assets-lab" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-qatar", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-qatar.md" }, { "slug": "jur-nigeria", "name": "Nigeria", "summary": "Nigeria (SEC · Central Bank of Nigeria · Data Protection Commission): Securities-first, with banking access restored. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Securities-first, with banking access restored", "authority": "SEC · Central Bank of Nigeria · Data Protection Commission", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Nigeria took the securities route rather than building a bespoke crypto statute, bringing digital assets under the securities regulator through the 2025 Act while the 2022 rules continue to carry the operational detail. The more consequential shift for anyone actually operating there was the central bank reversing its 2021 banking restriction in December 2023, which restored the account access that had pushed activity into informal channels. On confidentiality specifically, the file is empty in both directions: we found no instrument restricting anonymity-enhancing assets, mixers or self-hosted wallets, and equally nothing protecting them. Read that as an unwritten question rather than as permission.", "instruments": [ { "label": "Investments and Securities Act 2025", "note": "repeals the 2007 Act and formally recognises digital assets as securities under securities regulator oversight" }, { "label": "SEC Rules on Issuance, Offering Platforms and Custody of Digital Assets, 11 May 2022", "note": "still the operative conduct rules, with Part D covering virtual asset service providers, supplemented by the Accelerated Regulatory Incubation Programme" }, { "label": "Central bank reversal, December 2023", "note": "guidelines permitting banks to operate accounts for virtual asset service providers, reversing the February 2021 restriction" }, { "label": "No published position on confidentiality", "note": "we found no Nigerian instrument addressing privacy coins, mixers or unhosted wallets" } ], "tags": [ "digital assets as securities", "banking access restored", "no AEC rule", "NDPA 2023" ], "sources": [ { "label": "Nigeria SEC rules and regulations", "url": "https://sec.gov.ng/our-mandate/regulation/rules-and-regulations/" }, { "label": "Nigeria Data Protection Commission", "url": "https://ndpc.gov.ng/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-nigeria", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-nigeria.md" }, { "slug": "jur-seychelles", "name": "Seychelles", "summary": "Seychelles (Financial Services Authority): No anonymity rule, but the offshore route is closing. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "No anonymity rule, but the offshore route is closing", "authority": "Financial Services Authority", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Seychelles matters here because of how many crypto entities are domiciled in it rather than because of anything it says about confidentiality, and it says nothing. No located instrument restricts anonymity-enhancing assets. What changed is the plumbing around that silence. The 2024 Act arrived with an unusually complete set of regulations, and the regulator paired them with substance requirements and guidance on what counts as operating in or from Seychelles. That combination closes the structure anonymity-tolerant venues have historically relied on: registering in a jurisdiction with no privacy rules while serving users everywhere else. The absence of a prohibition is becoming less useful than it looks.", "instruments": [ { "label": "Virtual Asset Service Providers Act 2024", "note": "supported by licensing, advertising, cyber security, client asset safekeeping, capital, and ICO and NFT registration regulations all made in 2024" }, { "label": "Substance requirements", "note": "an FSA guidance note on substance, plus guidance interpreting what it means to operate in or from Seychelles; this is the nexus test that closes the registered-here, operating-elsewhere structure" }, { "label": "Only companies may apply", "note": "domestic companies and international business companies, never individuals" }, { "label": "Circular No. 14 of 2025", "note": "governs transitional applications, with active enforcement against unlicensed offshore platforms continuing through 2026" } ], "tags": [ "offshore domicile", "substance requirements", "nexus test", "no AEC rule" ], "sources": [ { "label": "FSA VASP legal framework", "url": "https://fsaseychelles.sc/vasp/legal-framework" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-seychelles", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-seychelles.md" }, { "slug": "jur-oman", "name": "Oman", "summary": "Oman (Financial Services Authority · Central Bank of Oman): The only rule found that names privacy wallets. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "The only rule found that names privacy wallets", "authority": "Financial Services Authority · Central Bank of Oman", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Most rules in this section reach assets, and a few reach tools. Oman's drafting reaches further than any other we found. The registration decision already bars virtual assets that conceal the identity of the originator or the nature of the transaction, which is broad on its own. The consultation framework then extends the intent to tumblers, mixers and, unusually, privacy-enhanced wallets, and targets concealment of the holder and beneficial owner rather than only the counterparties to a transfer. That last move matters: a rule aimed at who owns an asset catches designs that a transfer-focused rule would miss. We could not confirm whether the wider framework has been finalised, so treat the registration decision as the operative instrument.", "instruments": [ { "label": "FSA Decision No. E/35/2023", "note": "providers must register and meet enhanced anti-money-laundering requirements, and the decision includes the prohibition of virtual assets that conceal the identity of the originator or the nature of the transaction" }, { "label": "The draft framework goes further", "note": "the Virtual Assets Regulatory Framework consultation, opened 30 July 2023, states an intention to strictly prohibit the issuance of privacy coins, defined as assets allowing reduced transparency and increased obfuscation of financial flows" }, { "label": "It reaches tools and holders, not just transfers", "note": "the consultation would outlaw tumblers, mixers, privacy-enhanced wallets and other technologies that obscure the identity of the sender, recipient, holder or beneficial owner" }, { "label": "Status of the fuller framework unconfirmed", "note": "the registration duty is in force; whether the wider framework has been finalised we could not verify" } ], "tags": [ "privacy wallets named", "beneficial owner concealment", "E/35/2023", "framework pending" ], "sources": [ { "label": "Overview of crypto in Oman", "url": "https://www.addleshawgoddard.com/en/insights/insights-briefings/2025/financial-services/overview-of-crypto-in-oman/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-oman", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-oman.md" }, { "slug": "jur-rwanda", "name": "Rwanda", "summary": "Rwanda (Capital Market Authority · National Bank of Rwanda): Anonymity defined out of the regime rather than banned. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Anonymity defined out of the regime rather than banned", "authority": "Capital Market Authority · National Bank of Rwanda", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Rwanda uses a technique worth understanding because it is different from a ban. Rather than prohibiting anonymity-enhanced assets, the law writes them out of the definition of a virtual asset altogether, alongside NFTs, algorithmic stablecoins and central bank digital currencies. The effect is that no licensed provider can deal in them, because they are not the thing the licence covers. Whether dealing in them is otherwise lawful is left unanswered, which is a meaningfully different position from prohibition. More surprising is the treatment of mixers: operating one without authorisation is an offence, and the drafting implies such services could in principle be authorised. Very few regimes anywhere treat mixing as licensable rather than forbidden.", "instruments": [ { "label": "Law nº 023/2026 of 25 May 2026, gazetted 28 May 2026", "note": "Rwanda's first law regulating virtual asset business, with the Capital Market Authority as lead regulatory authority" }, { "label": "Anonymity-enhanced assets are excluded from the definition", "note": "the definition of virtual asset expressly excludes them, alongside central bank digital currencies, NFTs, algorithm-based stablecoins and closed-loop systems, so they sit outside the licensed perimeter entirely" }, { "label": "Mixers are licensable, not banned", "note": "operating mixer or tumbler services, mining facilities or crypto ATMs without authorisation is an offence, which implies such services can in principle be authorised" }, { "label": "Travel rule mandatory", "note": "originator and beneficiary information requirements apply to virtual asset transfers, with suspicious transaction reporting regardless of amount" }, { "label": "Implementing regulations not yet issued", "note": "licence categories remain undefined and transition arrangements for existing operators are unspecified" } ], "tags": [ "scope exclusion", "mixers licensable", "Law 023/2026", "regulations pending" ], "sources": [ { "label": "Rwanda gazettes first virtual asset law", "url": "https://www.ensafrica.com/news/detail/11972/rwanda-gazettes-first-law-regulating-virtual-" }, { "label": "Analysis of Law nº 023/2026", "url": "https://www.mondaq.com/financial-services/1801206/rwanda-gazettes-first-law-regulating-virtual-asset-business" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-rwanda", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-rwanda.md" }, { "slug": "jur-mauritius", "name": "Mauritius", "summary": "Mauritius (Financial Services Commission): A mature licensing regime that never mentions anonymity. Region: Middle East & Africa. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "A mature licensing regime that never mentions anonymity", "authority": "Financial Services Commission", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Mauritius matters here out of proportion to its size, because a great many crypto entities are domiciled in it. Its regime is mature rather than minimal: a licensing act in force since 2022, five distinct licence classes with capital requirements, and seven detailed rules covering everything from custody to cybersecurity. What it does not contain, anywhere we could find across the act, the rules and independent reviews of both, is any restriction on anonymity-enhancing assets, mixers or self-hosted wallets. That silence is the finding. It is not a considered permission and should not be read as one, but it does make Mauritius the most accommodating jurisdiction in the region on confidentiality, purely by not having addressed it.", "instruments": [ { "label": "VAITOS Act 2021, in force 7 February 2022", "note": "five licence classes covering broker-dealer, wallet services, custodian, advisory and marketplace, each with its own capital floor" }, { "label": "Seven FSC Rules from 1 July 2022", "note": "covering capital, client disclosure, custody of client assets, cybersecurity, advertising, risk management and statutory returns" }, { "label": "No located restriction on anonymity-enhancing assets", "note": "across the Act, all seven rules and independent reviews of them, we found no mention of privacy coins, mixers or self-hosted wallets" }, { "label": "Anti-money-laundering under FIAMLA", "note": "customer due diligence, ongoing transaction monitoring, a seven-year record retention minimum and mandatory compliance and reporting officers" } ], "tags": [ "VAITOS 2021", "no privacy coin rule", "domiciliation hub", "silence not permission" ], "sources": [ { "label": "Mauritius virtual assets regulation", "url": "https://charltonsquantum.com/mauritius-virtual-assets-regulation/" }, { "label": "Appleby on the FSC Rules under VAITOS", "url": "https://www.applebyglobal.com/publications/mau-fsc-rules-issued-under-the-virtual-asset-and-initial-token-offerings-services-act-2021-vaitos/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-mauritius", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-mauritius.md" }, { "slug": "jur-kuwait", "name": "Kuwait", "summary": "Kuwait (Capital Markets Authority · Central Bank of Kuwait): A ban whose stated reason is anonymity itself. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "A ban whose stated reason is anonymity itself", "authority": "Capital Markets Authority · Central Bank of Kuwait", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Kuwait is worth including precisely because its regulators said the quiet part out loud. The prohibition covers payment use, investment recognition, provider licensing and mining, and the stated reason is not volatility or consumer protection but anonymity: the central bank's warning is that the anonymous nature of crypto transactions creates room for illegal use. That makes it one of the few places where confidentiality is the explicit basis for excluding an entire asset class rather than a secondary concern. The consequence for this section is a useful caution. Kuwait has no travel rule and no privacy-coin rule, but that silence reflects the absence of any licensable activity, not tolerance.", "instruments": [ { "label": "CMA Circular No. 10 of 2023", "note": "prohibits use of virtual assets as a payment tool, their recognition as investment instruments or as decentralised currency, the licensing of providers operating as commercial entities, and all mining in the country" }, { "label": "The rationale is explicit", "note": "the central bank warns that the anonymous nature of crypto transactions creates significant room for illegal uses and money laundering" }, { "label": "No licensable activity means no rules to attach", "note": "there is no travel rule, no anonymity-asset carve-out and no self-hosted wallet rule, because the licence door is closed by the same instrument" }, { "label": "Existing regulated instruments are carved out", "note": "securities and instruments already supervised by the central bank and the markets authority fall outside the prohibition" } ], "tags": [ "absolute prohibition", "anonymity as rationale", "no licences", "mining banned" ], "sources": [ { "label": "CMA ban on virtual assets", "url": "https://www.bakertilly.com.kw/en/capital-markets-authority-ban-virtual-assets/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kuwait", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-kuwait.md" }, { "slug": "jur-egypt", "name": "Egypt", "summary": "Egypt (Central Bank of Egypt · Personal Data Protection Center): Crypto barred, so data protection is the live constraint. Region: Middle East & Africa. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Crypto barred, so data protection is the live constraint", "authority": "Central Bank of Egypt · Personal Data Protection Center", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Egypt inverts the usual shape of an entry in this section. There is no crypto privacy regime to describe because there is no lawful crypto activity: the banking law requires central bank approval to issue, trade or promote cryptocurrencies, and no approval has ever been granted. What is live instead is data protection. The 2020 personal data law sat without executive regulations for years and finally received them in 2025, turning it into a working supervisory regime with licensing requirements attached, including for cross-border transfers of personal data. For any firm handling Egyptian personal data, that transfer licence is the real compliance surface, and the grace period closes at the end of October 2026.", "instruments": [ { "label": "Banking Law No. 194 of 2020", "note": "prohibits issuing, trading or promoting cryptocurrencies without central bank approval, and the central bank has confirmed no licence has ever been issued, making it a prohibition in practice" }, { "label": "Personal Data Protection Law No. 151 of 2020", "note": "its executive regulations were finally issued by ministerial decree in 2025, converting a statement of principles into a supervisory regime" }, { "label": "Licensing for data, not for crypto", "note": "the regulations introduce specific licences including for cross-border personal data transfers, which is the binding constraint for any crypto-adjacent business operating there" }, { "label": "Grace period ends 31 October 2026", "note": "giving roughly a year from issuance for organisations to comply" } ], "tags": [ "de facto ban", "PDPL 151/2020", "cross-border licence", "deadline 2026" ], "sources": [ { "label": "Egypt data protection update", "url": "https://www.bakermckenzie.com/en/insight/publications/2026/01/egypt-important-data-protection-update" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-egypt", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-egypt.md" }, { "slug": "jur-morocco", "name": "Morocco", "summary": "Morocco (Bank Al-Maghrib · AMMC · Office des Changes): Liberalising in direction, with a ten-year retention sting. Region: Middle East & Africa. Regime still forming: No settled rule on confidentiality yet; the framework is in draft or newly in force.", "kind": "jurisdiction", "region": "Middle East & Africa", "category": "Liberalising in direction, with a ten-year retention sting", "authority": "Bank Al-Maghrib · AMMC · Office des Changes", "stance": "emerging", "stanceLabel": "Regime still forming", "stanceMeaning": "No settled rule on confidentiality yet; the framework is in draft or newly in force.", "description": "Morocco is moving from prohibition toward a framework, and the direction is genuinely liberalising after years in which crypto activity sat outside the exchange control rules. The detail worth attention is not the licensing but the retention. The draft would require providers to keep transaction data for ten years, which is longer than most regimes in this section and creates a large standing pool of transaction-level records regardless of any suspicion. Issuance of fiat-indexed tokens would be reserved to approved banks. Decentralised finance is left out of scope entirely. As of mid-2026 the central bank reported progress but no firm date for submission to parliament, so none of this is law yet.", "instruments": [ { "label": "Draft Bill 42.25", "note": "prepared jointly by the finance ministry, the central bank and the markets authority and published in November 2025, aligned with FATF Recommendation 15" }, { "label": "Ten-year transaction data retention", "note": "the draft would oblige crypto service providers to retain transaction data for a decade, the most privacy-consequential provision located in the text" }, { "label": "Stablecoin issuance reserved to banks", "note": "only credit institutions approved by the central bank could issue tokens indexed to fiat currencies" }, { "label": "DeFi left outside", "note": "the draft does not regulate decentralised finance, with on-ramps and off-ramps to be monitored separately" } ], "tags": [ "Bill 42.25", "draft not adopted", "ten-year retention", "bank-only stablecoins" ], "sources": [ { "label": "Analysis of Bill 42.25", "url": "https://www.lexisma.info/?p=12230" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-morocco", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-morocco.md" }, { "slug": "jur-france", "name": "France", "summary": "France (AMF · ACPR · CNIL): Hardest against anonymity, most literate about privacy tech. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "Hardest against anonymity, most literate about privacy tech", "authority": "AMF · ACPR · CNIL", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "France pulls harder in both directions than any other member state. On one side it legislated against transactional anonymity earlier and more explicitly than the EU baseline required: providers may not hold anonymous accounts, identification is required before any occasional transaction with no minimum value, and anonymous electronic money cannot be used to buy digital assets. On the other, its data protection regulator produced the most technically literate guidance any European authority has published on building compliant chains. The 2018 analysis ranks cryptographic techniques in order of preference and states that a perfectly hiding commitment, once its witness is destroyed, ceases to be personal data at all. That is a regulator describing how to do this properly rather than warning people off.", "instruments": [ { "label": "Ordonnance 2020-1544 of 9 December 2020", "note": "its Article 4 prohibits digital asset service providers from holding anonymous accounts, placing them among the entities barred from doing so under the monetary and financial code" }, { "label": "Décret 2021-387 of 2 April 2021", "note": "imposes identification before any occasional transaction, removing the de minimis threshold entirely, and provides that anonymous electronic money may not be used to buy digital assets" }, { "label": "CNIL blockchain analysis, September 2018", "note": "sets a ranked preference for recording personal data, favouring a cryptographic commitment, then a keyed hash, then at minimum ciphertext, with plain hashing or clear text only exceptionally" }, { "label": "A national regulator on anonymisation", "note": "the CNIL states that where a commitment is perfectly hiding, deleting the witness and the committed value anonymises it such that it loses its character as personal data" }, { "label": "CNIL on the digital euro, 13 May 2026", "note": "firmly supports the offline mode guaranteeing anonymity, argues for an online threshold below which intermediaries should not trace transactions, and prefers dynamic identifiers over static ones" } ], "tags": [ "anonymous account ban", "no de minimis", "CNIL doctrine", "commitments over hashing" ], "sources": [ { "label": "Décret 2021-387 on combating anonymity of virtual assets", "url": "https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000043328577" }, { "label": "CNIL analysis of blockchain", "url": "https://www.cnil.fr/sites/default/files/2025-08/la_blockchain_chaine_blocs.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-france", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-france.md" }, { "slug": "jur-germany", "name": "Germany", "summary": "Germany (BaFin · Bundesbank · BfDI and the Länder authorities): A national custody licence, and secrecy for tokenised securities. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "A national custody licence, and secrecy for tokenised securities", "authority": "BaFin · Bundesbank · BfDI and the Länder authorities", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Germany's divergence runs in two directions and neither is about coins. It built a national licence for crypto custody before the EU had one, and that licence survives alongside the European regime without carrying a passport. But it drew the line at self-custody in unusually clear terms: holding your own assets is not the licensed activity, because you are not doing it for anyone else. Less discussed, and more interesting for this section, is the confidentiality rule for tokenised securities. A holder's identity and address may be disclosed from the register only on a special legitimate interest, weighed against their data protection interests. That is confidentiality by default in a securities register, with no equivalent in EU law. Germany's data protection authorities, notably, have published nothing at all on blockchain.", "instruments": [ { "label": "Crypto custody as a licensed business", "note": "introduced into the banking act in December 2019, covering the custody, administration and safeguarding of crypto-assets or of the private keys used to hold them for others" }, { "label": "Self-custody is expressly outside it", "note": "BaFin guidance states that holding one's own crypto-assets does not constitute the licensed business, because the element of doing so for others is missing" }, { "label": "Register secrecy for electronic securities", "note": "section 10 of the electronic securities act lets third parties see a registered security only on a legitimate interest, and disclosure of a holder's identity and address requires a special legitimate interest weighed against their data protection interests" }, { "label": "The national travel rule lapsed", "note": "the crypto transfer regulation of May 2023 required name and address of an unhosted counterparty with no value threshold, and expired on 30 December 2024" }, { "label": "No national blockchain guidance", "note": "the German data protection conference's index of orientation papers runs from 2014 to 2026 and contains nothing on blockchain, distributed ledgers or crypto-assets" } ], "tags": [ "custody licence", "self-custody exempt", "register secrecy", "DPAs silent" ], "sources": [ { "label": "BaFin guidance on crypto custody", "url": "https://www.bafin.de/SharedDocs/Veroeffentlichungen/DE/Merkblatt/mb_200302_kryptoverwahrgeschaeft.html" }, { "label": "Electronic Securities Act, section 10", "url": "https://www.gesetze-im-internet.de/ewpg/__10.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-germany", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-germany.md" }, { "slug": "jur-liechtenstein", "name": "Liechtenstein", "summary": "Liechtenstein (Finanzmarktaufsicht): Identification unbundled into its own licensed role. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "Identification unbundled into its own licensed role", "authority": "Finanzmarktaufsicht", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Liechtenstein made a structural choice worth understanding: rather than requiring every participant to identify counterparties, it turned identification into its own licensed role. An identity service provider is defined as the party who identifies whoever is entitled to dispose of a token and records them in a register, and the corresponding duty is to assign identifiers correctly to the lawful holder and keep customer data securely. That scopes the surveillance function to a nameable actor instead of spreading it everywhere. Technology neutrality is written into the statute's purpose rather than asserted in marketing. Nothing in the text we read restricts anonymity-enhancing assets. Note that the financially regulated activities have since been carved out to the EU regime, leaving this act covering the civil-law and non-EU residue.", "instruments": [ { "label": "Token and TT Service Provider Act (TVTG)", "note": "the law of 3 October 2019 on tokens and trustworthy technology service providers, published in the national gazette on 2 December 2019" }, { "label": "Technology neutrality is a statutory purpose", "note": "Article 1 states the aim of creating optimal, innovation-friendly and technology-neutral conditions for services on trustworthy technology systems" }, { "label": "Identity as a separate licensed function", "note": "Article 2(1)(t) defines an identity service provider as a person who identifies the party entitled to dispose of a token and records them in a register, rather than spreading that duty across every actor" }, { "label": "The corresponding duty", "note": "Article 17 requires such providers to ensure correct assignment of identifiers to the lawful holder and secure retention of customer data" }, { "label": "A guardrail on onward transfer", "note": "Article 42 permits transmission of personal data to third-country authorities only where the conditions of Chapter V of the GDPR are met" }, { "label": "The EU anti-money-laundering regulation is not incorporated", "note": "it remains under examination for the EEA by Liechtenstein, Iceland and Norway, so the EU prohibition on anonymous crypto accounts does not currently bind them" } ], "tags": [ "TVTG", "technology neutral", "identity as a service", "GDPR Chapter V" ], "sources": [ { "label": "TVTG consolidated text", "url": "https://www.gesetze.li/konso/2019301000" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-liechtenstein", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-liechtenstein.md" }, { "slug": "jur-iceland", "name": "Iceland", "summary": "Iceland (Seðlabanki Íslands · EFTA Surveillance Authority · Persónuvernd): MiCA a year late, the travel rule not yet switched on. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "MiCA a year late, the travel rule not yet switched on", "authority": "Seðlabanki Íslands · EFTA Surveillance Authority · Persónuvernd", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Iceland is worth a card mainly for what it reveals about the EEA route into EU financial law. It adopted the European crypto framework a full year behind the union, shifting the internal dates forward so the transitional architecture still worked. More consequentially, the two instruments that matter most for confidentiality have arrived at different speeds. The travel rule was incorporated into the EEA agreement in June 2025 but the government's own database still records implementation as not begun, so the obligation exists in principle without national machinery. The EU anti-money-laundering regulation, which carries the 2027 prohibition on anonymous accounts, has not been incorporated at all. For now the binding rule here is the narrower trading-platform test.", "instruments": [ { "label": "Act No. 101/2025 on markets in crypto-assets, 24 December 2025", "note": "Article 16 brings it into force on 1 January 2026, a year behind the EU" }, { "label": "Dates shifted to preserve the transition", "note": "MiCA references to 30 December 2024 read as 1 January 2026, and references to 30 July 2024 read as 1 February 2026" }, { "label": "Article 3 names the authorities", "note": "the Central Bank of Iceland is the competent authority, with the financial supervisory function inside it and the EFTA Surveillance Authority exercising the powers MiCA gives ESMA" }, { "label": "The travel rule is incorporated but not implemented", "note": "the EU transfer of funds regulation entered into force through the EEA on 24 June 2025, yet the government's own EEA database records implementation as not begun, with a national regulation still required" }, { "label": "The EU anti-money-laundering regulation is not incorporated", "note": "it remains under examination by Iceland, Liechtenstein and Norway, so the EU prohibition on anonymous crypto accounts does not currently reach them" } ], "tags": [ "MiCA late adopter", "travel rule gap", "AMLR not incorporated", "two-pillar supervision" ], "sources": [ { "label": "Act No. 101/2025", "url": "https://www.althingi.is/lagas/nuna/2025101.html" }, { "label": "Icelandic EEA database entry for MiCA", "url": "https://gagnagrunnur.ees.is/32023r1114" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-iceland", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-iceland.md" }, { "slug": "jur-netherlands", "name": "Netherlands", "summary": "Netherlands (AFM · De Nederlandsche Bank · Autoriteit Persoonsgegevens): The wallet verification demand that was abandoned. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "The wallet verification demand that was abandoned", "authority": "AFM · De Nederlandsche Bank · Autoriteit Persoonsgegevens", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The Netherlands ran the most aggressive self-hosted wallet identification demand in Europe and then gave it up, which makes it the most instructive European case in this section. Providers had to verify the address on every transfer to or from an external wallet, in practice by asking customers to photograph their wallet or sign a message. Worth being precise, because the headlines were not: the court did not annul the requirement. It gave the regulator six weeks to justify it properly. The regulator then accepted the challenge was well founded, revoked the requirement and stopped collecting screenshots. A supervisor reversing itself on proportionality grounds is rare enough to be worth citing wherever the unhosted wallet question comes up.", "instruments": [ { "label": "The central bank's address verification requirement", "note": "providers had to verify the wallet address on every transaction to or from an external wallet, in practice by collecting a customer screenshot or a signature over the receiving address" }, { "label": "Challenged as disproportionate", "note": "the exchange argued the requirement had no technical merit and violated customer privacy, putting its complaints to the court in March 2021" }, { "label": "The court did not strike it down", "note": "the judge gave the central bank six weeks to review and re-justify its address verification policy rather than annulling it" }, { "label": "The regulator then withdrew it", "note": "the central bank accepted the challenge was right, revoked the requirement and stopped asking for wallet screenshots" } ], "tags": [ "wallet verification withdrawn", "proportionality", "self-hosted wallets", "regulator reversal" ], "sources": [ { "label": "Dutch court ruling on Bitonic wallet verification", "url": "https://www.coindesk.com/markets/2021/05/20/dutch-court-rules-bitonic-no-longer-requires-crypto-wallet-verification" }, { "label": "Bitonic on the additional verification measures", "url": "https://bitonic.nl/en/news/213/additional-verification-measures-due-to-registration-application" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-netherlands", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-netherlands.md" }, { "slug": "jur-poland", "name": "Poland", "summary": "Poland (KNF · GIIF): The one EU state with no functioning licensing regime. Region: Europe. Regime still forming: No settled rule on confidentiality yet; the framework is in draft or newly in force.", "kind": "jurisdiction", "region": "Europe", "category": "The one EU state with no functioning licensing regime", "authority": "KNF · GIIF", "stance": "emerging", "stanceLabel": "Regime still forming", "stanceMeaning": "No settled rule on confidentiality yet; the framework is in draft or newly in force.", "description": "Poland is the exception that shows how the EU framework behaves when a member state cannot implement it. Three presidential vetoes have blocked the national act, so no authority has been designated to licence providers. Meanwhile the European deadline passed regardless: since July 2026, serving the Polish market without authorisation breaches Union law, and the only lawful route in is cross-border activity by firms licensed elsewhere. Around two thousand registered operators are caught between the two. The substance of the dispute is directly relevant here, because the objections concerned how long a regulator may freeze accounts and block domains without a court, which is the supervisory-power question underneath most privacy arguments.", "instruments": [ { "label": "Three presidential vetoes", "note": "the crypto market bill was vetoed on 1 December 2025, again on 12 February 2026, and a third time in June 2026 after the Sejm passed a revised version on 15 May 2026" }, { "label": "No competent authority designated", "note": "the vetoed bill would have empowered the financial supervision authority to supervise the market, licence operators and impose penalties; without it, the regulator cannot grant authorisations" }, { "label": "The perimeter closed anyway on 1 July 2026", "note": "providing crypto-asset services without authorisation from that date breaches Union law, leaving cross-border service by firms licensed in other member states as the only lawful route" }, { "label": "Roughly 2,000 registered firms in limbo", "note": "with no domestic licensing path, operators have been seeking authorisation in other member states and passporting back" } ], "tags": [ "no national act", "presidential veto", "no competent authority", "passporting in" ], "sources": [ { "label": "Why Poland is the only EU country where firms cannot get a licence", "url": "https://www.coindesk.com/policy/2026/07/01/why-poland-is-the-only-eu-country-where-crypto-firms-can-t-get-a-mica-license" }, { "label": "Third veto and the deadline", "url": "https://www.cryptotimes.io/2026/06/12/poland-president-vetoes-crypto-bill-for-third-time-triggers-mica-deadline-crisis/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-poland", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-poland.md" }, { "slug": "jur-ireland", "name": "Ireland", "summary": "Ireland (Central Bank of Ireland · Data Protection Commission): A central bank piloting zero-knowledge KYC. Region: Europe. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "jurisdiction", "region": "Europe", "category": "A central bank piloting zero-knowledge KYC", "authority": "Central Bank of Ireland · Data Protection Commission", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "Ireland adds nothing of its own to the EU rules on crypto confidentiality, and that is worth saying plainly rather than inventing local colour. What makes it worth a card is the opposite move. Its central bank ran its first innovation sandbox specifically on financial crime, and one of the seven projects put zero-knowledge proofs to work inside the compliance process itself: verifying a customer's name and address in real time against authoritative national datasets without revealing or transferring the underlying data. That is a supervisor hosting a live pilot of exactly the technique this section argues is compatible with regulation, inside the very programme aimed at money laundering. Very few of the accommodating signals elsewhere in this section are that concrete.", "instruments": [ { "label": "Innovation Sandbox Programme on combatting financial crime", "note": "launched by the central bank in December 2024 as a six-month programme, with a first cohort of seven ventures" }, { "label": "A live zero-knowledge KYC pilot", "note": "Sedicii and Permanent TSB built real-time name and address verification using zero-knowledge proofs, with a utility acting as the address data authority" }, { "label": "What it demonstrated", "note": "customer details were validated against authoritative national datasets without revealing or transferring the underlying personal data, removing the need for paper utility bills" }, { "label": "No national divergence on confidentiality", "note": "we found no Irish restriction on anonymity-enhancing assets and no national rule on self-hosted wallets; on those questions Ireland applies the EU baseline" } ], "tags": [ "zero-knowledge KYC", "regulatory sandbox", "EU baseline", "no privacy coin rule" ], "sources": [ { "label": "Innovation Sandbox Programme", "url": "https://www.centralbank.ie/regulation/innovation-hub/innovation-sandbox-programme" }, { "label": "Sandbox programme on combatting financial crime", "url": "https://www.centralbank.ie/regulation/innovation-hub/innovation-sandbox-programme/financial-crime" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ireland", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-ireland.md" }, { "slug": "jur-spain", "name": "Spain", "summary": "Spain (CNMV · Banco de España · AEPD): First in the EU to regulate how crypto is advertised. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "First in the EU to regulate how crypto is advertised", "authority": "CNMV · Banco de España · AEPD", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Spain's national contribution sits on the marketing side rather than the confidentiality side, and it got there first. Its advertising circular, in force since February 2022, was the earliest crypto advertising regulation published in any EU member state: it compels a specific risk warning and requires campaigns aimed at more than a hundred thousand people to be notified to the regulator ten business days in advance. That is a rule about how crypto is sold, not how privately it can be held. On the questions this section is actually about, Spain adds nothing to the European baseline, and we found no Spanish instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets.", "instruments": [ { "label": "CNMV Circular 1/2022 of 10 January 2022", "note": "published 17 January and in force 17 February 2022, the first crypto advertising regulation published in an EU country" }, { "label": "A compulsory warning", "note": "advertising must state explicitly that investment in crypto-assets is unregulated, may not be suitable for retail investors, and can result in the loss of the entire amount invested" }, { "label": "Prior notification for mass campaigns", "note": "campaigns directed at more than 100,000 people must be notified to the regulator at least ten business days before they run" }, { "label": "No divergence on confidentiality", "note": "the national additions concern how crypto is marketed rather than how confidentially it is held; we found no Spanish restriction on anonymity-enhancing assets" } ], "tags": [ "advertising rules", "100,000 threshold", "prior notification", "no privacy coin rule" ], "sources": [ { "label": "Circular 1/2022, BOE-A-2022-666", "url": "https://www.boe.es/diario_boe/txt.php?id=BOE-A-2022-666" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-spain", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-spain.md" }, { "slug": "jur-italy", "name": "Italy", "summary": "Italy (CONSOB · Banca d'Italia · Garante per la protezione dei dati personali): Customer-level reporting to a public registrar. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "Customer-level reporting to a public registrar", "authority": "CONSOB · Banca d'Italia · Garante per la protezione dei dati personali", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Italy's national addition was a reporting channel rather than a prohibition, and it went further than the European baseline in an unusual direction. Providers registered in the special section had to transmit, every quarter, identification data for each customer together with summary data on that customer's overall activity in Italy. That is customer-level reporting to a registrar, on a fixed cycle, with no suspicion trigger and no transaction threshold. Nothing comparable exists in the EU rules the framework sat on top of. On the questions this section is otherwise about, Italy is quiet: we found no restriction on anonymity-enhancing assets and no national rule on self-hosted wallets.", "instruments": [ { "label": "Ministry of Finance decree of 13 January 2022", "note": "published in the Official Gazette on 17 February 2022, setting how and when virtual currency and digital wallet service providers must report their Italian activity" }, { "label": "A special section of the agents and brokers register", "note": "operational from 18 May 2022, with registration required to operate or intend to operate in Italy" }, { "label": "Quarterly transmission of customer-level data", "note": "providers report identification data for each customer plus summary data on that customer's overall activity, by the fifteenth day of the month following each quarter" }, { "label": "No asset-level restriction found", "note": "we located no Italian instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets" } ], "tags": [ "quarterly reporting", "customer-level data", "OAM register", "no privacy coin rule" ], "sources": [ { "label": "Decree of 13 January 2022 on reporting to the register", "url": "https://annunziataconso.eu/pills/decreto-ministeriale-13-gennaio-2022-sulle-modalita-e-tempistiche-di-comunicazione-di-operativita-alloam-da-parte-dei-prestatori-di-servizi-relativi-allutilizzo-di-valuta-virtuale-e/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-italy", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-italy.md" }, { "slug": "jur-canada", "name": "Canada", "summary": "Canada (FINTRAC · Canadian Securities Administrators · Privacy Commissioner): Delistings without a rule that names the assets. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "Delistings without a rule that names the assets", "authority": "FINTRAC · Canadian Securities Administrators · Privacy Commissioner", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Canada is the clearest case in this section of an outcome that looks like a ban and is not one. Anonymity-enhancing assets have largely disappeared from Canadian platforms, and yet across the securities administrators and the financial intelligence unit we found no instrument that names them or prohibits them as a class. The mechanism appears to be the combination of know-your-product duties on platforms and a travel rule that makes an untraceable transfer above CAD 1,000 impossible to comply with. One large exchange's own delisting notice attributes the decision to recent compliance requirements in Canada without citing a single rule. Read that carefully: it is a compliance judgement by a private firm, not a prohibition, and the distinction matters when people cite Canada as precedent.", "instruments": [ { "label": "Transfer records from CAD 1,000", "note": "a virtual currency transfer record is required when transferring at the request of a person or entity at that value, with a separate large transaction record at CAD 10,000 in a single transaction" }, { "label": "What must travel", "note": "name, address and account or reference number for both the party requesting the transfer and the beneficiary, with reasonable measures required where information is missing" }, { "label": "No instrument names privacy assets", "note": "we found no securities regulator or FINTRAC instrument naming privacy coins or anonymity-enhanced assets, or prohibiting them as a class" }, { "label": "The mechanism appears commercial", "note": "one major exchange's own Canadian delisting notice attributes the decision to recent compliance requirements in Canada, naming no regulator and no regulation" }, { "label": "Federal privacy reform stalled", "note": "PIPEDA remains the federal private-sector law; Quebec's Law 25 is the more demanding regime in practice" } ], "tags": [ "travel rule CAD 1,000", "no named ban", "know your product", "Quebec Law 25" ], "sources": [ { "label": "FINTRAC travel rule guidance", "url": "https://fintrac-canafe.canada.ca/guidance-directives/transaction-operation/travel-acheminement/1-eng" }, { "label": "FINTRAC record keeping for money services businesses", "url": "https://fintrac-canafe.canada.ca/guidance-directives/recordkeeping-document/record/msb-eng" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-canada", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-canada.md" }, { "slug": "jur-portugal", "name": "Portugal", "summary": "Portugal (CMVM · Banco de Portugal · CNPD): A data regulator stopping biometrics bought with tokens. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "A data regulator stopping biometrics bought with tokens", "authority": "CMVM · Banco de Portugal · CNPD", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Portugal's distinctive contribution came from its data protection authority rather than its financial regulators, and it addresses a question the financial rules do not reach. When an identity system offered crypto tokens in exchange for iris scans, the authority suspended collection of biometric data across Portuguese territory as an urgent measure, citing collection from minors without parental authorisation, inadequate information, and no way to delete data or withdraw consent. The detail that matters here is the absence of any age check while people joined specifically to receive tokens. It is a regulator treating payment for biometric data as the problem, which is the mirror image of most debates in this section, where the worry is that transactions reveal too much rather than that identity is being bought.", "instruments": [ { "label": "CNPD suspension of Worldcoin, 26 March 2024", "note": "suspended collection of iris, eye and face biometric data in Portuguese territory to safeguard the fundamental right to personal data protection, especially for minors" }, { "label": "An urgent provisional measure", "note": "imposed for 90 days to allow the authority to conclude its investigation and issue a final decision, and maintained on review in July 2024" }, { "label": "What prompted it", "note": "numerous complaints reporting collection from minors without parental authorisation, deficient information to data subjects, and inability to delete data or withdraw consent" }, { "label": "The crypto link is the point", "note": "the authority noted there was no age verification mechanism despite a significant influx of people, including minors, joining to receive tokens" } ], "tags": [ "biometrics for tokens", "CNPD suspension", "minors", "data protection first" ], "sources": [ { "label": "CNPD suspends biometric data collection", "url": "https://www.cnpd.pt/comunicacao-publica/noticias/cnpd-suspende-recolha-de-dados-biometricos/" }, { "label": "CNPD press release, 26 March 2024", "url": "https://www.cnpd.pt/media/bzwb5k5j/comunicado-de-imprensa_cnpd-suspende-recolha-de-ddos-da-worldcoin_26-mar%C3%A7o-2024.pdf" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-portugal", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-portugal.md" }, { "slug": "jur-brazil", "name": "Brazil", "summary": "Brazil (Banco Central do Brasil · CVM · ANPD): A named anonymity rule, and a CBDC that could not solve privacy. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Americas", "category": "A named anonymity rule, and a CBDC that could not solve privacy", "authority": "Banco Central do Brasil · CVM · ANPD", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Brazil holds the two halves of this section's argument in one place. Its listing rule is among the most explicit anywhere, requiring providers to bar assets designed to favour money laundering by facilitating anonymity, while the same framework expressly contemplates a client choosing self-custody and asks only that the provider explain the risks. Then there is Drex. The central bank spent a pilot phase testing zero-knowledge designs precisely to build confidentiality into a state currency, and reported that the approaches which delivered privacy also cost it the visibility and control it judged necessary for its legal obligations. That is the trilemma stated by a central bank from its own experiment rather than argued in the abstract, and it is the most honest public account of the problem we found.", "instruments": [ { "label": "Resolutions BCB 519, 520 and 521 of 10 November 2025", "note": "create the virtual asset service provider framework, covering authorisation, operation, and virtual asset services in the foreign exchange market" }, { "label": "Resolution 520, Article 64", "note": "listing policies must prohibit offering virtual assets with characteristics that favour fraud or crime, expressly including assets designed to favour money laundering and terrorist financing by facilitating anonymity" }, { "label": "Self-custody expressly permitted", "note": "Article 57 contemplates a client choosing self-custody, with the provider's duty being to explain the necessary security measures rather than to refuse" }, { "label": "Travel rule with wallet identification", "note": "Article 44 requires originator and beneficiary information including identification of the transaction's virtual asset wallet" }, { "label": "Drex could not reconcile privacy with oversight", "note": "the central bank tested zero-knowledge approaches including Anonymous Zether and Rayls, and found that stronger anonymisation cost it the visibility and control it considered necessary" } ], "tags": [ "Article 64", "anonymity prohibited", "self-custody permitted", "Drex trilemma" ], "sources": [ { "label": "Resolution BCB 520/2025", "url": "https://www.legisweb.com.br/legislacao/?id=486181" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-brazil", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-brazil.md" }, { "slug": "jur-mexico", "name": "Mexico", "summary": "Mexico (Banco de México · CNBV · UIF): Anonymity named as the reason to exclude the asset class. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Americas", "category": "Anonymity named as the reason to exclude the asset class", "authority": "Banco de México · CNBV · UIF", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Mexico states the reasoning that most regulators leave implicit. Its central bank says plainly that offering virtual asset services to the public through financial institutions is not advisable, and lists the anonymity those assets provide in transactions among the reasons. That is anonymity named as the ground for keeping an entire asset class outside the regulated banking perimeter, rather than as a factor to be managed within it. Note what it is not: no named asset is prohibited, and exchange houses may continue to serve clients who bear the risk themselves. The other development worth flagging sits on the data protection side, where the independent regulator was abolished and its private-sector functions moved into a government ministry.", "instruments": [ { "label": "The central bank's stated position", "note": "it considers that providing virtual asset services to the general public through financial institutions is not advisable, identifying the anonymity such assets provide in transactions as a core reason" }, { "label": "Internal use only, with permission", "note": "financial institutions may use distributed ledgers or virtual assets for internal operations with prior central bank authorisation, provided the risks do not reach end consumers" }, { "label": "Fintech Law authorisation", "note": "institutions may operate only with virtual assets previously authorised by the central bank, which is a whitelist in substance" }, { "label": "The data protection regulator was abolished", "note": "a constitutional reform ended the independent transparency and data protection institute, moving private-sector data protection competence into an executive ministry" } ], "tags": [ "anonymity as rationale", "bank perimeter exclusion", "whitelist", "regulator independence lost" ], "sources": [ { "label": "Banco de México regulatory actions on virtual assets", "url": "https://www.banxico.org.mx/sistemas-de-pago/6--acciones-regulatorias-po.html" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-mexico", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-mexico.md" }, { "slug": "jur-argentina", "name": "Argentina", "summary": "Argentina (CNV · Unidad de Información Financiera · AAIP): Self-custody providers written out of the regime. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "Self-custody providers written out of the regime", "authority": "CNV · Unidad de Información Financiera · AAIP", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Argentina drew its perimeter in the place this section keeps arguing is the right one. Providers of self-custody wallets are exempt from the registration regime by the resolution's opening article, which is the most explicit carve-out for non-custodial software we found anywhere in the Americas. What the rules do restrict is the service rather than the asset: registered providers must not offer mechanisms designed to hinder identification of where a transaction came from and where it went. No coin is named. Read together, the two provisions describe a coherent position: the regulator claims authority over intermediaries that obscure flows, and disclaims it over software that merely lets people hold their own keys.", "instruments": [ { "label": "CNV General Resolution 1058/2025", "note": "published in the Official Bulletin on 14 March 2025 and in force 45 days later, creating the registry and conduct rules for virtual asset service providers" }, { "label": "Article 1 exempts self-custody providers", "note": "those providing services exclusively as suppliers of self-custody wallets are outside the registration regime altogether" }, { "label": "Article 24 bars obfuscation mechanisms", "note": "providers must abstain from offering mechanisms designed to hinder identification of the origin and destination of transactions, which reaches mixing services at the service level rather than any named asset" }, { "label": "Client asset segregation", "note": "Article 16 requires proprietary and client assets to be separated across operational accounts and on-chain wallets and recorded clearly and individually" } ], "tags": [ "self-custody exempt", "anti-obfuscation", "service level not asset level", "RG 1058/2025" ], "sources": [ { "label": "CNV General Resolution 1058/2025", "url": "https://www.boletinoficial.gob.ar/detalleAviso/primera/322539/20250314" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-argentina", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-argentina.md" }, { "slug": "jur-bahamas", "name": "Bahamas", "summary": "Bahamas (Securities Commission of The Bahamas · Central Bank): Issuance of privacy tokens barred, trading not. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Americas", "category": "Issuance of privacy tokens barred, trading not", "authority": "Securities Commission of The Bahamas · Central Bank", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "The Bahamas holds the sharpest contradiction in this section, and both halves are deliberate. Its 2024 act bars issuers from offering privacy tokens for sale in or from the jurisdiction, and makes the provision of anonymity-enhancing services a regulated activity. The nuance almost always dropped in reporting is that the bar is on issuance: trading and exchange of such tokens is not prohibited, so long as the business can meet its obligations while doing it. Meanwhile the country's own central bank digital currency ships a tier that requires no identification at all below modest limits. A state that will not let you issue a private token will let you hold its own money without giving your name.", "instruments": [ { "label": "Digital Assets and Registered Exchanges Act 2024", "note": "passed 29 July 2024, building on the 2020 act, and reported to provide that no issuer may offer privacy tokens for sale in or from within The Bahamas" }, { "label": "The distinction that gets lost", "note": "the prohibition is on issuance; exchange or trading of privacy tokens is not prohibited provided the business can do so consistently with its regulatory obligations" }, { "label": "Anonymity-enhancing services are now regulated", "note": "providing them is treated as a regulated activity rather than an unregulated one" }, { "label": "Sand Dollar ships a no-identification tier", "note": "the lowest central bank digital currency tier carries a 500 dollar holding limit and 1,500 dollar monthly transaction limit with no identification requirement and no link to a bank account" } ], "tags": [ "issuance ban", "trading permitted", "Sand Dollar", "tiered CBDC" ], "sources": [ { "label": "Fintech laws and regulations, Bahamas", "url": "https://iclg.com/practice-areas/fintech-laws-and-regulations/bahamas" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bahamas", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bahamas.md" }, { "slug": "jur-bermuda", "name": "Bermuda", "summary": "Bermuda (Bermuda Monetary Authority · Privacy Commissioner): A travel rule with no minimum, reaching self-hosted wallets. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "kind": "jurisdiction", "region": "Americas", "category": "A travel rule with no minimum, reaching self-hosted wallets", "authority": "Bermuda Monetary Authority · Privacy Commissioner", "stance": "restrictive", "stanceLabel": "Attribution required", "stanceMeaning": "A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.", "description": "Bermuda restricts no asset by name and still runs the most comprehensive transaction surveillance requirement found in the Americas. There is no minimum value: every virtual asset transfer carries originator and beneficiary information. More unusually, the obligation expressly reaches transfers to self-hosted wallets, where most regimes either carve out an exemption or say nothing at all. Set against that, the regulator has published no position whatsoever on anonymity-enhancing assets, mixers or tumblers, treating everything under the single heading of digital assets. It is a clean illustration of the pattern running through this section: the binding constraint on confidentiality is the transfer rule, not a list of forbidden coins.", "instruments": [ { "label": "Digital Asset Business Act 2018", "note": "the licensing framework, with proceeds of crime regulations and 2021 sector-specific guidance carrying the transfer obligations" }, { "label": "No de minimis at all", "note": "the obligation to transmit transaction information applies to all virtual asset transfers regardless of amount, the strictest threshold located anywhere in this section" }, { "label": "Self-hosted wallets are expressly in scope", "note": "providers must obtain and record originator and beneficiary information for transfers to self-hosted wallets, which most regimes either exempt or leave unaddressed" }, { "label": "No position on anonymity-enhancing assets", "note": "the regulator's own digital assets pages contain no mention of privacy coins, mixers or tumblers, and treat all coins and tokens under the single term digital assets" } ], "tags": [ "zero threshold", "self-hosted in scope", "no AEC position", "DABA 2018" ], "sources": [ { "label": "BMA digital asset supervision and regulation", "url": "https://www.bma.bm/digital-assets-supervision-regulation" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bermuda", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-bermuda.md" }, { "slug": "jur-cayman-islands", "name": "Cayman Islands", "summary": "Cayman Islands (Cayman Islands Monetary Authority · Ombudsman): A mature regime that never addresses confidentiality. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "A mature regime that never addresses confidentiality", "authority": "Cayman Islands Monetary Authority · Ombudsman", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Cayman matters because so many funds and token issuers are structured through it, and the finding is a set of absences rather than rules. The licensing framework is mature and the travel rule has applied since 2022, with a second licensing phase for trading platforms and custodians since April 2025. But across the regulator's own provider guidance and its dedicated travel rule page, there is no position on anonymity-enhancing assets, nothing on transfers to self-hosted wallets, and no stated monetary threshold for the transfer obligation. For a jurisdiction of this importance to the industry, that silence is itself the useful information: the questions this section is about have not been answered here.", "instruments": [ { "label": "Virtual Asset (Service Providers) Act, 2024 Revision", "note": "with the 2024 amendment act and 2025 amendment regulations forming the current framework" }, { "label": "Travel rule since 1 July 2022", "note": "implemented by Part XA of the anti-money-laundering amendment regulations, covering transfers between a provider and another obliged entity and between a provider and a non-obliged entity" }, { "label": "Licensing phase two from 1 April 2025", "note": "brought virtual asset trading platforms and custodians into licensing, adding prudential requirements, client disclosure and segregation of client assets" }, { "label": "Silent on the questions this section asks", "note": "neither the provider guidance nor the travel rule page addresses anonymity-enhancing assets or self-hosted wallets, and no monetary threshold is stated on either" } ], "tags": [ "Part XA", "phase two licensing", "no threshold stated", "no anonymity position" ], "sources": [ { "label": "CIMA virtual asset service provider FAQ", "url": "https://www.cima.ky/vasp-faq" }, { "label": "CIMA travel rule requirements", "url": "https://www.cima.ky/travel-rule-requirements-for-vasp" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-cayman-islands", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-cayman-islands.md" }, { "slug": "jur-british-virgin-islands", "name": "British Virgin Islands", "summary": "British Virgin Islands (BVI Financial Services Commission · Information Commissioner): Structural confidentiality kept, transactional confidentiality not. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "Structural confidentiality kept, transactional confidentiality not", "authority": "BVI Financial Services Commission · Information Commissioner", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "The British Virgin Islands is a useful illustration that confidentiality is not one thing. At the level of corporate structure it deliberately preserves it: beneficial ownership information is filed with the regulator but not publicly disclosed, which is a policy choice other jurisdictions have abandoned under pressure. At the level of transactions it does the opposite, applying a travel rule from a thousand dollars and extending automatic exchange of information to crypto businesses. We located no position either way on anonymity-enhancing assets. So the entity behind a structure can stay out of public view while its transfers are reported, which is close to the inverse of how a public blockchain behaves.", "instruments": [ { "label": "Virtual Assets Service Providers Act, 2022, in force 1 February 2023", "note": "with the anti-money-laundering regulations of 2020 as amended in 2024 and the associated code of practice" }, { "label": "Travel rule from USD 1,000", "note": "providers must transmit sender and recipient data, retain transfer records and apply enhanced due diligence for high-risk jurisdictions" }, { "label": "Beneficial ownership filed but not public", "note": "ownership data goes to the regulator without public disclosure, which is a deliberate entity-level confidentiality choice paired with regulator-level transparency" }, { "label": "Automatic exchange of information extended to crypto from 2025", "note": "a direct counterweight to that structural confidentiality" } ], "tags": [ "travel rule USD 1,000", "non-public ownership register", "AEOI from 2025", "no anonymity position" ], "sources": [ { "label": "BVI crypto-asset regulation", "url": "https://www.walkersglobal.com/en/Insights/2025/08/British-Virgin-Islands-Crypto-asset-regulation" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-british-virgin-islands", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-british-virgin-islands.md" }, { "slug": "jur-estonia", "name": "Estonia", "summary": "Estonia (Finantsinspektsioon): The licence cull that reshaped the European market. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "The licence cull that reshaped the European market", "authority": "Finantsinspektsioon", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Estonia mattered to this market out of proportion to its size, because for a few years it issued more crypto authorisations than anywhere else in Europe. The 2022 amendments ended that: capital requirements, real local presence, a compliance officer and fit and proper testing of owners took the register from over fourteen hundred licences to roughly a hundred. Worth being precise about what that was and was not. It was a gate on who may operate, not a rule about what operators may offer. We found no Estonian instrument touching anonymity-enhancing assets or self-hosted wallets, so on confidentiality the European baseline governs here as it does elsewhere.", "instruments": [ { "label": "From over 1,400 licences to roughly 100", "note": "amendments to the money laundering prevention act in force from March 2022 cut the register by around 93%, with most authorisations either surrendered or revoked" }, { "label": "What the amendments required", "note": "minimum capital of EUR 250,000, genuine physical presence and operations in Estonia, a dedicated anti-money-laundering officer, and fit and proper testing of managers and beneficial owners" }, { "label": "An entity-side gate, not a transaction rule", "note": "the cull changed who may hold a licence rather than what licensed firms may do, and we located no Estonian rule on anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "VASP cull", "substance requirements", "entity-side gate", "no confidentiality rule" ], "sources": [ { "label": "Estonian crypto regulation overview", "url": "https://cryptolicenses.net/regulation/estonia/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-estonia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-estonia.md" }, { "slug": "jur-lithuania", "name": "Lithuania", "summary": "Lithuania (Bank of Lithuania): Capital requirements used as a filter. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "Capital requirements used as a filter", "authority": "Bank of Lithuania", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Lithuania took the same route as Estonia and reached a similar destination by a different instrument. Rather than testing substance and ownership, it raised the capital floor to EUR 125,000 and struck off everyone who had not met it by the end of 2022. Firms lost the right to operate from the first day of 2023. Like Estonia's, this was a filter on who may hold a licence rather than a rule about confidentiality, and we located nothing in Lithuanian law addressing anonymity-enhancing assets or self-hosted wallets. Supervision now sits with the central bank, which is a slightly unusual choice among member states.", "instruments": [ { "label": "EUR 125,000 minimum capital", "note": "introduced by a law in force from November 2022, a large step up from the previous position" }, { "label": "Non-compliant firms struck off", "note": "operators that had not met the new requirements by 31 December 2022 were removed from the register of exchange and wallet operators and lost the right to provide services from 1 January 2023" }, { "label": "Supervision moved to the central bank", "note": "the Bank of Lithuania is the competent authority for crypto-asset service providers under the European regime" }, { "label": "No located rule on confidentiality", "note": "we found no Lithuanian instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets" } ], "tags": [ "capital threshold", "register cleanup", "central bank supervisor", "no confidentiality rule" ], "sources": [ { "label": "Lithuania crypto regulation overview", "url": "https://www.globallegalinsights.com/practice-areas/blockchain-cryptocurrency-laws-and-regulations/lithuania/" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-lithuania", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-lithuania.md" }, { "slug": "jur-wyoming", "name": "Wyoming", "summary": "Wyoming (Wyoming Division of Banking · Secretary of State): Property law written for self-custody. Region: Americas. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "jurisdiction", "region": "Americas", "category": "Property law written for self-custody", "authority": "Wyoming Division of Banking · Secretary of State", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "Wyoming is the clearest example in the United States of a legislature building around self-custody rather than treating it as a gap. Classifying digital assets as property under the commercial code sounds technical and is not: it gives a holder a defined legal interest in an asset they control directly, rather than leaving the question to be answered by whoever holds it for them. Declining to require a money transmitter licence for standalone virtual currency keeps non-custodial activity outside the perimeter that elsewhere drags identity collection along with it. The state has since issued its own stable token, which makes it both regulator and issuer.", "instruments": [ { "label": "Digital assets as property under the commercial code", "note": "Wyoming was the first state to classify digital assets as intangible property under Article 9 of the Uniform Commercial Code, giving holders a defined legal interest rather than an undefined one" }, { "label": "No money transmitter licence for standalone virtual currency", "note": "which keeps non-custodial activity outside the licensing perimeter that would otherwise pull identity collection with it" }, { "label": "A state-issued stable token", "note": "the Frontier Stable Token launched in August 2025, reported as the first stablecoin issued by a US state, with reserve backing above par" } ], "tags": [ "property rights", "no money transmitter licence", "self-custody friendly", "state stablecoin" ], "sources": [ { "label": "Wyoming digital assets law overview", "url": "https://www.lexology.com/library/detail.aspx?g=72a5d03a-98c2-45d5-8bdd-ff98ac7b9730" }, { "label": "State-level developments tracker", "url": "https://www.paulhastings.com/insights/crypto-policy-tracker/state-level-developments-the-regulatory-landscape-for-digital-assets" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-wyoming", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-wyoming.md" }, { "slug": "jur-california", "name": "California", "summary": "California (Department of Financial Protection and Innovation): A licensing regime that arrived in July 2026. Region: Americas. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Americas", "category": "A licensing regime that arrived in July 2026", "authority": "Department of Financial Protection and Innovation", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "California is the counterweight to Wyoming within the same country, and the contrast is instructive because neither state legislates about anonymity at all. California built a licensing regime for digital asset businesses that took effect at the start of July 2026, and the confidentiality consequences follow from the licence rather than from any rule naming an asset: a licensed business keeps records and identifies customers. That is the pattern this whole section keeps finding. Where a state or country reaches for a licence, identity obligations arrive with it; where it does not, the question is usually left unanswered rather than decided in either direction.", "instruments": [ { "label": "Digital Financial Assets Law, effective 1 July 2026", "note": "creates a licensing regime specifically for digital asset businesses including exchanges, roughly six weeks old at the time of writing" }, { "label": "What it constrains", "note": "licensing brings record-keeping and customer identification duties with it, so the constraint on confidentiality arrives through the licence rather than through any rule about assets" }, { "label": "No located rule on anonymity", "note": "we found no Californian provision restricting anonymity-enhancing assets or transfers to self-hosted wallets" } ], "tags": [ "DFAL", "July 2026", "licensing perimeter", "no anonymity rule" ], "sources": [ { "label": "State-level developments tracker", "url": "https://www.paulhastings.com/insights/crypto-policy-tracker/state-level-developments-the-regulatory-landscape-for-digital-assets" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-california", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-california.md" }, { "slug": "jur-texas", "name": "Texas", "summary": "Texas (Texas Department of Banking · State Securities Board): No licence for non-stablecoin crypto. Region: Americas. Builds with privacy tech: The regime itself mandates, pilots or funds privacy-preserving technology.", "kind": "jurisdiction", "region": "Americas", "category": "No licence for non-stablecoin crypto", "authority": "Texas Department of Banking · State Securities Board", "stance": "accommodating", "stanceLabel": "Builds with privacy tech", "stanceMeaning": "The regime itself mandates, pilots or funds privacy-preserving technology.", "description": "Texas belongs in this section for what it does not do. Non-stablecoin cryptocurrency does not require a money transmitter licence there, which leaves a large share of activity outside the perimeter that elsewhere carries customer identification and record-keeping duties with it. Legislative energy has gone into stablecoins instead, including proposals for a commodity-backed state token. As with the other American states covered here, nothing in Texan law addresses anonymity-enhancing assets or self-hosted wallets. The federal layer still applies in full, so the practical position is a light state regime sitting under the Bank Secrecy Act rather than an absence of rules.", "instruments": [ { "label": "No money transmitter licence for non-stablecoin cryptocurrency", "note": "which keeps a large share of activity outside the licensing perimeter and the identity duties that come with it" }, { "label": "Stablecoins treated differently", "note": "legislative attention has focused on stablecoins, including a proposal for a commodity-backed state token" }, { "label": "No located rule on anonymity", "note": "we found no Texan provision restricting anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "no money transmitter licence", "stablecoin focus", "permissive perimeter", "no anonymity rule" ], "sources": [ { "label": "State-level developments tracker", "url": "https://www.paulhastings.com/insights/crypto-policy-tracker/state-level-developments-the-regulatory-landscape-for-digital-assets" } ], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-texas", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-texas.md" }, { "slug": "jur-belgium", "name": "Belgium", "summary": "Belgium (FSMA · National Bank of Belgium): EU baseline, with no national layer on confidentiality. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, with no national layer on confidentiality", "authority": "FSMA · National Bank of Belgium", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Belgium adds no national layer on confidentiality, and that is worth stating plainly rather than manufacturing local colour. The authority to deal with is the FSMA, working alongside the National Bank on prudential questions, and the rules that actually bite are the European ones covered elsewhere in this section: identity attached to every transfer regardless of size, and from July 2027 a bar on regulated firms keeping accounts that anonymise the holder. Nothing Belgian restricts anonymity-enhancing assets or self-hosted wallets. For anyone mapping obligations, that means the Belgian answer is the European answer.", "instruments": [ { "label": "FSMA is the competent authority", "note": "for authorising and supervising crypto-asset service providers under the European regime, alongside the National Bank on prudential matters" }, { "label": "The binding rules are European", "note": "the travel rule applies to every transfer with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located", "note": "we found no Belgian instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets" } ], "tags": [ "EU baseline", "FSMA", "no national divergence", "dual supervision" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-belgium", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-belgium.md" }, { "slug": "jur-austria", "name": "Austria", "summary": "Austria (Finanzmarktaufsicht): EU baseline, with an early transition close. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, with an early transition close", "authority": "Finanzmarktaufsicht", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Austria's only real distinguishing feature in this area is timing. It was among the member states that chose a short grandfathering window, closing the door on national-regime operators near the end of 2025 rather than running to the outer limit the following July. On the substance of confidentiality it adds nothing: the FMA authorises and supervises, and the operative rules are the European ones. We located no Austrian provision on anonymity-enhancing assets or transfers to self-hosted wallets. Firms that missed the earlier deadline had to be authorised or stop, which made Austria one of the tighter places to be caught mid-transition.", "instruments": [ { "label": "The FMA is the competent authority", "note": "for authorisation and supervision of crypto-asset service providers" }, { "label": "A short grandfathering window", "note": "Austria was among the member states that closed their transition near the end of 2025 rather than running to the July 2026 outer limit" }, { "label": "The binding rules are European", "note": "identity travels with every transfer with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located", "note": "we found no Austrian instrument restricting anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "EU baseline", "FMA", "early transition", "no national divergence" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-austria", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-austria.md" }, { "slug": "jur-luxembourg", "name": "Luxembourg", "summary": "Luxembourg (Commission de Surveillance du Secteur Financier): EU baseline, seen through a fund domicile. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, seen through a fund domicile", "authority": "Commission de Surveillance du Secteur Financier", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Luxembourg carries weight here because of what is domiciled in it rather than because of any national rule on confidentiality. It is one of Europe's main fund jurisdictions, so the questions that arise are institutional: what a regulated fund may hold, through which custodian, and what diligence the manager must do on the assets themselves. Those duties tend to bite on provenance and on who controls the keys rather than on whether amounts are public. On the narrower question this section asks, we located no Luxembourg instrument restricting anonymity-enhancing assets or self-hosted wallets, so the European baseline governs.", "instruments": [ { "label": "The CSSF is the competent authority", "note": "for authorising and supervising crypto-asset service providers" }, { "label": "Why it matters disproportionately", "note": "Luxembourg is one of Europe's principal fund domiciles, so the practical questions here are about what regulated funds may hold and through whom, rather than about retail transfers" }, { "label": "The binding rules are European", "note": "the travel rule applies with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located", "note": "we found no Luxembourg instrument restricting anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "EU baseline", "CSSF", "fund domicile", "no national divergence" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-luxembourg", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-luxembourg.md" }, { "slug": "jur-sweden", "name": "Sweden", "summary": "Sweden (Finansinspektionen): EU baseline, with a hawkish supervisory tone. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, with a hawkish supervisory tone", "authority": "Finansinspektionen", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Sweden has a reputation for hostility to crypto that is worth separating into its parts. Its supervisors have been openly sceptical about crypto as an investment and about its energy use, and that scepticism is real. But it is a view about an asset class, not a rule about confidentiality, and the two get conflated constantly. We located no Swedish instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets. What applies is the European framework, supervised by Finansinspektionen. Anyone reading Swedish policy statements as a privacy position is reading across a gap that the instruments themselves do not close.", "instruments": [ { "label": "Finansinspektionen is the competent authority", "note": "for authorising and supervising crypto-asset service providers" }, { "label": "Tone is not the same as rule", "note": "Swedish supervisors have been publicly sceptical of crypto as an asset class, but scepticism about an asset class is not a restriction on confidentiality technology" }, { "label": "The binding rules are European", "note": "identity travels with every transfer with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located", "note": "we found no Swedish instrument restricting anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "EU baseline", "Finansinspektionen", "supervisory tone", "no national divergence" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-sweden", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-sweden.md" }, { "slug": "jur-denmark", "name": "Denmark", "summary": "Denmark (Finanstilsynet · Skattestyrelsen): EU baseline, with tax as the historic pressure point. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, with tax as the historic pressure point", "authority": "Finanstilsynet · Skattestyrelsen", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Denmark is a useful reminder that the financial supervisor is not always the body that matters most for privacy. Its crypto framework is the European one, administered by Finanstilsynet, with no national rule on anonymity-enhancing assets or self-hosted wallets that we could locate. The pressure historically came from the tax side, where the administration has obtained transaction and identity data covering the customer bases of domestic exchanges in bulk rather than case by case. That is a different mechanism from anything in the financial rulebook, and it is the one worth checking in any jurisdiction: what the revenue authority can compel often exceeds what the market supervisor asks for.", "instruments": [ { "label": "Finanstilsynet is the competent authority", "note": "for authorising and supervising crypto-asset service providers" }, { "label": "The tax authority has been the more assertive actor", "note": "Danish tax administration has previously obtained bulk transaction and identity data covering the user bases of domestic exchanges, rather than proceeding customer by customer" }, { "label": "The binding rules are European", "note": "the travel rule applies with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located on confidentiality", "note": "we found no Danish instrument restricting anonymity-enhancing assets or self-hosted wallets" } ], "tags": [ "EU baseline", "tax authority", "bulk disclosure", "no national divergence" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-denmark", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-denmark.md" }, { "slug": "jur-czechia", "name": "Czechia", "summary": "Czechia (Česká národní banka): EU baseline, supervised by the central bank. Region: Europe. Confidential with disclosure: Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "kind": "jurisdiction", "region": "Europe", "category": "EU baseline, supervised by the central bank", "authority": "Česká národní banka", "stance": "conditional", "stanceLabel": "Confidential with disclosure", "stanceMeaning": "Confidentiality is workable so long as the regulated firm can identify the parties and disclose on demand. Encrypted amounts are not the thing being restricted.", "description": "Czechia is one of the member states that put crypto supervision inside the central bank rather than with a separate markets authority, which matters more for how firms experience the process than for what the rules say. On confidentiality it adds nothing to the European position: we located no Czech instrument restricting anonymity-enhancing assets or self-hosted wallets. The operative constraints are the ones described in the European entries in this section, and the practical question for anyone operating here is the authorisation process at the central bank rather than any distinctively Czech rule about how private a transaction may be.", "instruments": [ { "label": "The Czech National Bank is the competent authority", "note": "an arrangement shared with only a few member states, where the central bank rather than a separate markets regulator authorises crypto-asset service providers" }, { "label": "The binding rules are European", "note": "identity travels with every transfer with no minimum value, and from 10 July 2027 regulated firms may not keep accounts that anonymise the holder" }, { "label": "No national divergence located", "note": "we found no Czech instrument restricting anonymity-enhancing assets or transfers to self-hosted wallets" } ], "tags": [ "EU baseline", "central bank supervisor", "no national divergence" ], "sources": [], "url": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-czechia", "markdown": "https://www.sodalabs.xyz/privacy-hub/regulation/jur-czechia.md" } ] }