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Linda Jeng
@LindaJeng1
Chief Legal & Policy Officer, @Aave Labs | Visiting Scholar, Georgetown Law | Prev. Fed, SEC, OCC, Treasury, Senate, BIS, Crypto Council | opinions = my own
614 Following    1.3K Followers
After our SEC Reg Crypto Assets letter, we've responded to @TheFCA on tokenised gold. Same message both sides of the Atlantic: tokenisation is about collateral mobility, not just trading. £52m of tokenised gold works as collateral on @aave. Regulatory certainty will scale it.
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The real promise of tokenized securities is not just onchain trading, but putting them to work: as collateral, supplied and borrowed. In our Reg Crypto Assets comment letter, we asked the @SECGov to clarify that they can be used on non-custodial lending protocols.
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Great session yesterday with the @SECGov Crypto Task Force on vaults! Deeply grateful for the staff's time and thoughtful questions on vaults at @aave. Looking forward to continuing the conversation!
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We are hiring a Legal Counsel in NYC at @aave. Commercial lawyer, crypto fluent, ready to move fast.
Glad to have joined this one with @AndreCronjeTech, @TuongvyLe12, @NYcryptolawyer, @adcv_, @CharlieStLouis, @RSSH273, and Commissioner @HesterPeirce. The line was never onchain vs. offchain. It's whether someone's making decisions with your money after you deposit it. Thanks @JacobRobinsonJD for inviting me.
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The BRCA's whole purpose is that publishing open-source software is not operating an unlicensed money transmitter. The current draft already keeps criminal liability for anyone who specifically intends to move known-criminal funds. That is the right line. This proposal deletes that intent line and leaves non-controlling developers exposed to federal criminal prosecution for what other people do on open infrastructure. It adds no tool against bad actors. It just criminalizes building.
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We are grateful to Commissioner @HesterPeirce and the @SECGov Crypto Task Force for their continued work and attention to DeFi. Thoughtful engagement like this is exactly what onchain finance needs. @aave has spent years building DeFi infrastructure and working with providers across the ecosystem, and vaults remain important to how users and third-party teams interact with Aave. Increasingly, the market structure of onchain finance is centered on vault structure, since how vaults are designed and standardized is shaping the direction of the industry itself. As Commissioner Peirce notes, vaults "fall along a spectrum from programmatic allocations determined solely by immutable smart contracts, to allocations at the sole discretion of another person or group of persons." Design and discretion are what the analysis turns on. That vault landscape and spectrum was exactly what we presented when we met with the SEC Task Force last month, and we welcome the continued dialogue.
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