EUCI: Negotiating a Better Regulatory Outcome

Greetings! I’m one of the team members at the European Crypto Initiative (EUCI) and here’s more information about our work and the milestones we can achieve with the support of the Octant community.

About EUCI

EUCI is a non-profit advocacy organisation based in Brussels, which acts on behalf of Web3 organisations to negotiate a better regulatory outcome. It’s a mouthful, so what do we do in short? We lobby. We write legal arguments and explain technical terms to the regulators and authorities. Our objective is to prevent bad regulations which could stiff the innovative development of permissionless, decentralised applications leveraging blockchain technology.

Since the formation, we’ve defended the decentralized tech stack on several fronts. Imagine building Octant or holding GLM tokens without wallets or other “crypto-asset service providers” to onboard users. We ensured these weren’t our reality. We educate regulators that DeFi isn’t like TradFi and that decentralization is not only possible but a responsible thing to do. We trained members of the parliament in Metamask use and enlightened EU Commission representatives about DAOs’ utilities.

Do we classify as a public good?
Yes. The provision of regulatory clarity that supports further innovation within the Web3 industry is not to be taken for granted. In fact, it’s often heavily opposed by traditional stakeholders (governments, banks, etc.) who may not be open to decentralised solutions for various misconceptions.

This is why EUCI was created. Establishing strong advocacy and lobbying for the crypto industry and Web3 space was made out of necessity. We must collectively engage in a conversation with the regulators early on when the regulatory frameworks are being drafted. As a team of legal professionals who worked with crypto companies over a few bull runs already, we have the capacity to understand how certain regulations may affect Web3 developments. While we do a lot of work in writing, we continue to organise events and workshops to educate both, policymakers on one side and developers on the other.

What milestones have we achieved?

In the past, we urged the regulators to reconsider their positions and definitions. We’ve fought against harmful regulations, like banning crypto wallets or privacy protocols, equating NFTs to securities, or labelling protocols as bank accounts. Through our public policies, responses and campaigns, EUCI has explained why decentralised governance, tokens, stablecoins and other DeFi intricacies and blockchain innovative tools are detrimental to the preservation of privacy, inclusion and transparency.

We’ve also collaborated with global organizations to curb impractical crypto laws because regulation can make or break an industry, and we won’t let it hinder this ecosystem. While we do much of the work in written form, we often meet with regulators and host regulatory workshops for industry stakeholders. Our workshops and events are usually free of charge and open to anyone. As public discourse is crucial, we’ve also organised several Reg3 conferences and supported Reg3 forks, taking place in other countries.

See some of the highlights and milestones below:

EUCI Public Policies and Responses

Data Act Campaign led by the EUCI

Publication of the Manifesto for Blockchain: Embracing its Potential in the European Union

EUCI Response to the EU Commission’s Call for Evidence on Virtual Worlds

Public Comment on IOSCO’s Consultation Report on Policy Recommendations for DeFi

EUCI’s Response to the ACPR DeFi Discussion Paper, May 2023

EUCI’s Response to the AMF DeFi Discussion Paper, September 2023

EUCI Position Paper on MiCA & Stablecoins, February 2021

EUCI’s Position on MiCA & DeFi, February 2021

Reg3 Events hosted by the EUCI (2023)

Reg3 Lisbon, Portugal - 2022 Report

Milestones we would like to achieve
2024 stands as a pivotal year marked by significant milestones. The narrative for the year and the key objectives will be deeply influenced by the application of the Markets in Crypto-Assets (MiCA) regulation that classifies and defines different tokens, the EU elections, the selection of diverse sets of regulations and position papers, and the emphasis on continuous research and knowledge sharing among the policymakers and industry stakeholders. As Brussels lies at the heart of Europe and presents the centre of European policymaking activities, we especially welcome the decision of EthCC organisers to host the event at the Square in Brussels, Belgium.

1. Regulatory overview and positioning

Each of these elements contributes to a broader strategy aimed at shaping the Web3 policy landscape in Europe and beyond. Below, we’re naming concrete milestones we wish to achieve in light of the above:

  • European Securities Market Agency (ESMA) has issued two more important consultation papers open to public feedback until 29th April 2024 that are linked to the implications of MiCA regulation. We aim to respond to both, and thus address the topics of (i) reverse solicitation, and (ii) how crypto-assets differ from financial instruments. We deem the first topic extremely relevant for the crypto industry as individuals often establish their entities outside Europe. The EU regulations demand them to register in Europe if they solicit (i.e. offer or market) their products and services within the EU market. We intend to gain clarity with regard to which actions may be perceived as solicitation so we understand the do’s and don’ts when crypto companies outside the EU make their products and services available to EU citizens. The second topic is very similar to the questions often raised in the USA, e.g. “Are my tokens defined as securities?”
  • Noting that provisions of MiCA regulation concerning stablecoin issuers become applicable end of June 2024, we intend to further observe, discuss and negotiate the outcomes for stablecoin issuers within the EU. Namely, it is important to note that non-compliant stablecoin issuers may no longer be listed on exchanges operating their businesses in Europe.
  • Our aim is to further protect and defend the interests of developers, engineers and innovators within the Web3 space. This includes many who develop with Golem and Octant smart contracts. To this end, we intend to continue our legal analysis of regulatory frameworks that impact developers’ responsibilities such as the Product Liability Directive (PLD) and the Data Act. Regarding the PLD it’s important to note that the scope of the PLD has been significantly widened, including both tangible and intangible products (e.g. software), in the definition of ‘product’. This has raised EUCI’s awareness as it comes along with the broader definition of ‘loss’ or ‘corruption of data’ in the definition of ‘damage’. Further, manufacturers are made responsible for software updates (or the lack of them) and cybersecurity vulnerabilities. This is extremely important as it could also entail scoping in developers of certain “software” such as smart contracts – subjecting them to strict liability rules in case they cause harm to consumers (particularly with respect to loss or corruption of data). We will continue to organise public events and produce public written positions explaining the objectives and obligations set by the regulators, while we will discuss the challenges the Web3 community may experience if the regulators do not consider the particularities of the Web3 ecosystem when imposing such rules.
  • Similarly to the above, we will continue our analysis and advocacy regarding the Cyber Resilience Act and Digital Operational Resilience Act (DORA) to ensure crypto-asset service providers and software engineers’ responsibilities are not too burdensome or unreasonable.
  • We will also keep an eye on the Anti-Money Laundering (AML) Regulation and KYC requirements as the Web3 community has been heavily impacted by the request to verify users’ identity on every single step they take. Keeping this in mind, we will continue to advocate and educate the community and policymakers about the privacy preservation tools that have been developed by the Web3 community.
  • Lastly, we will continue to research the intersection between the Product Liability Directive and the Artificial Intelligence (AI) Act as well as the upcoming AI Liability Directive. This work will be important to further discuss the fault-based liability rules that may not only apply to software engineers but also to smart contract developers.

2. Continuous Research and publications

The above political discourse and written positions regarding regulatory proposals will be coupled with the position or research papers we intend to write regarding the perception (and exclusion) of DeFi from regulatory scope, staking and MEV particularities and NFTs. We have formed several working groups and are discussing these topics with individuals, and domain experts, to help us craft better arguments and defend our legal stance.

3. Series of Events during EthCC Brussels

As a result of the organisational work started in late 2023, we will be organising a series of regulatory workshops and events in Brussels during the week of EthCC. The aeries will include a Summer School where we intend to train and educate legal professionals, compliance officers and students on some of the most important Web3 topics. We also intend to organise a regulatory event (Reg3) with Impact+ where we will host meaningful panel discussions between the industry stakeholders and regulators.

4. EU Elections and Manifesto for Blockchain

As per EU elections, it is important to find new allies and approach elected politicians and officials with an agenda and constructive argumentation. We wish to make sure blockchain, crypto and Web3 are seen for what it is and stripped of all the misconceptions and wrongful narratives. Keeping this in mind, we’ve already published a Manifesto for Blockchain with several other EU-focused advocacy groups and intend to organise online webinars and publish papers to help improve the upcoming political agenda and uphold our Web3 core values.

Impact metrics and results

EUCI Events, Workshops & Podcasts: 61

EUCI Position Papers: 22

EUCI Media Presence: 31

Collab with National Organisations: 21

EUCI Meetings with Policymakers: 28

Regulatory Oversight & Monitoring: 27

Our Team

EUCI founders have been in the Ethereum community since 2014/2015 and have all worked with local blockchain think tanks where they led the conversations between early blockchain adopters and the regulators, authorities and policymakers.

Marina Markezic - EUCI Co-founder and Executive Director

Since 2017 Marina has been working with crypto projects on governance and legal matters with a focus on decentralisation, DeFi, and NFTs. Marina is an expert on key crypto regulatory topics and follows the recent regulatory developments and their influence on the industry. As a speaker at numerous blockchain and regulatory events, Marina is passionate about contributing to the dialogue for innovation-friendly regulation.

Florian Glatz - EUCI Co-founder

Florian Glatz has co-founded and led the German Blockchain Association (Bundesblock) as President for its first four years. He advises political decision-makers at the German and European levels on blockchain regulation. Trained as a lawyer and software developer with many years of experience working full-time in the blockchain space, Florian is aware of the key issues at the intersection of crypto assets and regulation.

Simon Polrot - EUCI Co-founder

Simon Polrot has co-founded and led the French crypto-assets association ADAN as President for its first two years. Lawyer, entrepreneur (VariabL, LGO), nonprofit contributor (Ethereum France, Chaintech, etc.). He has 5 years of expertise in crypto and founded the Ethereum France website in Feb 2016. With ADAN, he is making the crypto-assets industry a reality in France & Europe.

Vyara Savova - Senior Policy Expert

Vyara Savova is a web3 and human rights lawyer based in Sofia, Bulgaria. She is a SOAS, University of London Alumna (LLM in Human Rights, Conflict and Justice), and a PhD candidate focusing on legal automation through the use of smart contracts. Before joining EUCI, Vyara was the Head of Business Development for an NLP-based AI language transcription project and a legal expert and consultant for various technological and crypto projects.

Anja Blaj - Senior Policy Expert

Anja is a lawyer by background, based in Ljubljana, Slovenia. She is the president of Blockchain Think Tank Slovenia and a co-founder of Devleet, a software development firm based in Ljubljana. Anja has previously headed the Advocacy department at the European and Asian Blockchain Hubs and was the Chief Strategy Officer at the Future Law Institute in Bath, UK. She consulted several Web3 companies and was on the organising committee of the DGov Council and ETH Barcelona.

Nicoletta Pavese - Communication Coordinator

Nicoletta is a Communications & Social Media manager with a blend of expertise in technology, environmental issues, and blockchain advocacy. With years of experience spanning across different sectors, she uses content and strategic communication to create awareness and understanding of decentralised applications leveraging blockchain technology and advocate for a progressive EU technological environment.

Tanja Nenadovic - Event Manager

Tanja is currently completing her bachelor’s degree in Biology and aspiring to pursue an MBA, she brings a background in biotech and practical experience from roles at Crypto Exchanges like Bitstamp and pharmaceutical companies such as Novartis. She also holds experience in marketing, social media management, and data analysis from her time at Eyesee Research.

Niksa Maletic - Junior Policy Researcher

Nikša is a 5th year law student at the University of Ljubljana interested in intersections between Law and Technology and Law and economics. Having previously worked in Corporate and Tax Legal Fields he became interested in Blockchain technology and Cryptoasset regulation.

Past funding sources
We have received donations and grants from a number of organizations, such as the Ethereum Foundation, NEAR Foundation, Gitcoin, Optimism, Gnosis, Interchain, MakerDAO, Bain Capital Crypto, Elusiv, Mesari and Ava Labs. In terms of overall funding, we have received around $360k over the span of 4 years, starting in 2020.

In 2022 we received 120,000 USDC worth of a grant from the Gitcoin community.
Our past efforts were also recognised by the Optimism community, which provided us with a Retroactive Optimism Grant in the amount of 21,905.68 OP.

The overall value of voluntary hours provided to the Ethereum community by EUCI senior-level experts and contributors is estimated at 375,000 USDC from 2020.

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