Stephen: This is the first person that got me into crypto, Joe Ciccolo. He is the founder of BitAML. I literally went on Google and searched Bitcoin and AML, which is anti-money laundering. And this is the person they were dominating SEO back in 2016 and 17. And this is a great conversation for the Around the Coin podcast.

Because we talk about legislation, we talk about regulation, and we talk about the early, early days of cryptocurrency. Anyone that's in payments crypto, this is the person that you want to listen to, especially as we get into a new administration in the USA. Joe is a person that has built a software that helps with licensing. And all 52 states, I believe I'm Canadian. I believe there's 52 states. This is a great episode. Let me know, reach out and let me or Joe know and subscribe to his newsletter. It is one of the best newsletters for crypto and compliance talk soon.  

Stephen: This is your host Stephen Sargeant around the coin podcast. I'm excited today because one of the first people that I talked to when I got into this industry was Joe Ciccolo. Joe, tell me a little bit about yourself and then we're going to go like how you're mentoring the industry. We're going to talk regulation, especially there in the U.S. and California, and then we're going to go into everything that has to do with crypto compliance and, maybe even dabble in a little bit of a Trump during this episode. Tell me a little bit about yourself.

Joe: Yeah, thanks for having me, Stephen. So Joe Ciccolo, founder and president of BitAMLwe provide regulatory compliance consulting services to the crypto space and have done so for almost a decade now. So we started back in, in the early days of crypto in 2015. So some folks have remarked that I'm a crypto OG, which I think is a compliment, but been around a long time, worked with hundreds of clients, big and small, So AML focused, but also cybersecurity, consumer protection and other areas of risk management.

The second hat that I wear is I'm the executive director and president of the California Blockchain Advocacy Coalition or CBAC. We are a 501c6 trade association representing the interests of crypto and Web3 here in the great state of California. And that takes the form of, of lobbying, legislative initiatives.

But more importantly, advocacy and education and getting our membership and industry represented well in the marketplace. So, two very exciting but sometimes divergent, but sometimes overlapping aspects of the crypto world. And I've loved every minute of it. And as I said, almost a decade in now in the crypto space.

Stephen: Talk to us, because I remember when I first reached out to you, it was probably around 2016, probably maybe early 2017. And you used to laugh about, early days at conferences, kind of being in the background, everyone's talking about disruption, talk to me about some of those early days and did anything surprise you at that time, considering there wasn't much regulation for a lot of these companies to be specifically following other than maybe I think FinCEN had their BSA AML rules in at that time.

Joe: Yeah, so you're right. FinCEN guidance. Hard to believe that was back and I believe it was 2013. So, FinCEN was, was certainly on the cutting edge as they usually are with, with financial services innovations at least here in the States. So, we had initial guidance and, and many folks didn't know if it applied to them or some of them didn't think it applied to them.

And, and it was very difficult to have conversations initially because the folks come into the crypto space. In addition to being very entrepreneurial in, in mindset, we're also avid risk takers. They come from the tech world where you don't generally see a lot of regulation in the tech world.

There's, there's maybe discussions about, IP and, and other areas that are maybe more on the civil side of things in terms of litigation but you very rarely saw any impediments from a regulatory compliance perspective. So you had this sort of initial cohort of folks coming in. That did not either recognize or rather didn't recognize the seriousness of these regulations and having been in the banking space for a decade preceding my time in crypto, I knew all too well that these were very serious regulatory matters in the financial services industry is one of, if not the most regulated industries in the United States and probably the world.

And trying to have that conversation. You're right. Having those initial conversations and trying to keep the tomatoes off my face as I talked to folks on stage about the importance of compliance. It was very difficult in the early days, but I think as Time progressed and conversations were happening, and unfortunately there, there were some enforcement actions and even some investigations involving the criminal court system and certainly regulatory exams taking place.

I think the messages started getting out there that good compliance is indeed good business, as we felt for years. But in the early days, it was very difficult to sell that. And all I add that we dealt with some characters in the early days of crypto that were advocating for some sort of, of, of standing up to these regulations and refusing to comply.

And that somehow we could sort of do the, the Uber approach where we just sort of saturate the market. And by the time they realized who we were, they couldn't regulate us. And that's of course a horrible strategy and one I would never advise in any industry let alone in financial services.

But those voices have since dissipated. And what we see now is a very mature space, not quite as mature as, as we, we could be because we still have some things to work through as an industry, but we've certainly come a long way. And I'm excited to, to work with folks that when I pick up that phone or, or I get on that zoom and I have that conversation I can tell they've already read some materials about A. M. L. B. S. A. O. F. A. C. And they're asking probative questions and they really want to talk about compliance. And they're not looking at it as sort of a situation where they're gonna roll their eyes and say, okay, the compliance guy is gonna tell me how I'm gonna lose all my business. It's quite the opposite.

How can I help you? Stay in business and solidify that business with good compliance and good consumer protection measures.

Stephen: What do you think slowed the, disruption, slowed the libertarian action? Do you think it's like, Hey, we either build a successful business that's regulated and compliant, or we go to libertarian route and pretty much have no access to a legitimate bank account and the even potential of growing a business.

Cause we have to go through some probably less than, what we would call shady payment service providers.

Joe: Yeah, I think it's safe to say we landed somewhere in the middle So you're right the early days the sort of the go go Libertarian spirit was behind a lot of these initial projects and I think it became an object lesson for for those folks who said hey I don't think I look good in orange And maybe maybe I should rethink what I want to do so there is boundary pushing and there always will be in entrepreneurship.

And I think that to a certain extent that should be plotted. And it leads to a lot of great innovations where folks were questioning how we're doing things in the past and why hasn't someone come up with the solution? I'll come up with a solution. I can't think of anything more entrepreneurial or for that matter, anything more American than thinking of the next best idea and bringing it to market, regardless of your, your background circumstance or, or, what, what you have in front of you.

But at the same time, we need some rules of the road. And so we're working through that. And like I said, I think it's a balancing act, and we've we've landed comfortably somewhere in the middle. And my hope is that we can continue to move forward and the areas where we do need less regulation or the areas where we need more regulation, that we have those those conversations and continue to move forward as we have.

Stephen: It's funny listening to you talk now. And, memory, when I got into the industry, I was listening to this exact podcast and, Faisal and Mike and Brian, they were talking about like, guys, this is going to look a lot like payments, everyone thought that it's not going to be regulated.

It will be regulated. It's just a matter of when. So you better start preparing now. I'm curious from like, there's a lot of entrepreneurs and tech people that listen to this podcast. Like, what was that jump like going into entrepreneurship in 2015 when there's barely any regulations? Like, what did that first client look like?

Like, how did you make that jump? Like, people aren't even willing to make the jump now with everything that we've seen, whether it was Bitcoin prices. Emerging regulation. What made you decide to make that jump in 2015?

Joe: Yeah, I think in retrospect, on paper, it looks like a pretty silly idea, like, Hey, I'll start a consultancy just on crypto compliance back in 2015. And if you were to look around, there may be a handful of players, I think, we could have we could have had everyone's that was working for a for Coinbase, in the same room behind me right now, right?

That was that that small of an ecosystem. It seemed like a very silly idea. But fast forward, we saw this opportunity and said, Hey, this industry is really going to take off. There's gonna be a lot more players here is gonna be a lot more competition. Innovation has only begun. It was really, really something that we saw working long term.

And I think anytime you take a leap you are taking a chance. So for us, we saw that the technology worked. Right. Bottom line. There were many more naysayers, believe it or not about crypto back then than there are today. We still have a lot today. But I saw through and said, Hey, look, if the technology works, no one has said Bitcoin doesn't work.

They've said why it won't work in banking systems or why it won't work for our society. But the technology works. And I said, it's only a matter of time before people see that this is the car replacing the horse. And it's not going to be something that happens overnight. Certainly not in the, regulatory environment that we see today.

But I knew it was only going to be a matter of time. And you're right, coming from banking and a compliance world us compliance folks, we're not necessarily known as, as entrepreneurial or risk takers, right? That's quite the opposite. We're risk managers. So it's, it's kind of interesting to see folks from the compliance space like myself say, Hey, I want to leave the comfortable job I have with a financial institution that pays really well.

And there's an amazing career track for those that are in anti money laundering or other areas of financial services compliance. It's seemingly the sky's limit, right? If you're able to kind of grow your career and, and propel yourself forward. So, so why, why take off the golden handcuffs?

And I saw the technology. I said, this is where the future is. And I think there's an opportunity to be a part of that. And I see a lot of smart folks going in there. I see a lot of great discussions, a lot of energy. I don't want to miss out. And you're right, a very brave step back in 2015.

But I'm proud to say I took that move and that bold step and it's, it's just been amazing ever since.

Stephen: And it's funny because 10 years later, we still don't have proper regulations. I think by most people's standards in the U S so it's like, it's like your ongoing journey still. Was there a pivotal point in your career where you're like, Oh, I landed this client and it just changed or like a certain regulation happened abroad.

And you're like, Oh. Like that validated what you're doing or, someone else in the industry saying, Hey, you know what? Like, keep going. You're on the right path. So is there anything that you can kind of pull and remember? Like that moment of confidence where you're like, all right, we're all in like head down, let's keep on going.

Or was there any areas where you're like, man, like I could probably just get a job and maybe do this on the side and, not go full time consultant, like walk us through the entrepreneurial journey.

Joe: Yeah, there are definitely periods of time where business was down considerably. And Inevitably, it is a result or at least mostly a result of market conditions. So when the price of crypto is down the phone lines dry up and inquiries dry up and you're sort of left to your own devices like, Hey, business was great, but what am I going to do now?

I haven't had a new client in a month or two. Especially in the early days when things are tenuous and they were for a while, there were periods of time where, I didn't take a salary or I had to really be super conscious of costs. And hey, maybe I wanted a new laptop or, or a new piece of equipment in the office.

And I had to pull pulled off on that. So, as entrepreneurs, we go through those times and it's, but it's important to remember those times and live it. Is if you were always in that time, right? So, very big on on founder bias. I love working with founders. One of the big reasons is because they remember when they had no money and no customers, right?

So it's a bit of a mindset. They're not coming in with their, N. B. A. S. And they're Hey, I've got this great idea. This is what worked in in a hypothetical that I ran back in school. It's like it's a little bit different when you're out there in the trenches and and you've seen and had those experiences.

So if there wasn't one monumental point, I could point to you. Obviously we're going to be sensitive. We can't talk about our specific client names, but there was one project I remember working on where it was, it was a a project size scope and scale that, that we had never done before.

But we were confident we could do it. And at that point in time, I was like, wow, this is, I've really made it like this is an opportunity. And sure enough, after that, referrals and word of mouth and, and continuing to, to be posting as we have on LinkedIn and other social media platforms.

And really getting our message out there. And I'll go back a little bit on on sort of the idle time when business is down. We use that as an opportunity to just share as much as we could about the space. Unfortunately, there are folks that we compete with that just want to hold back information, and we're the opposite.

Like, hey, this is what we've seen. This is what we heard. Here are some bills in California. Here's some legislation to keep an eye on in different jurisdictions. This is what regulators have been talking to us about. This is why, this is some of the conversations we've had with law enforcement and how we can be, good stewards of, of fighting crime and, and, scams and being on that front line and working together cohesively.

So, using that time to the best of, of, of your abilities and, and just continuing to move forward and putting good things out there is really how you not just get new customers, but really show, show and play to your strengths.

Stephen: And to your point, you have one of the best blogs and newsletters that we'll definitely link to. And I think what makes those newsletters great is because you see legislation, and there's a lot of talking heads and headlines, but you don't really know how to synthesize that information. Because, talking heads are like Trump's in, crypto is the best and that's it and that's it.

And you're like, no, let me break it down. These are what these clauses mean. This is what companies actually have to start thinking about. And I think that's what made your blog so popular is really breaking it down. What, what is these acts? What do these bills even mean? And what's the impact? What's the actual impact?

I should say, not this what's going to benefit me in saying like, oh, these are really scary. Come to me for, my compliance services. You actually broke down what the impact would be in the industry. You talked about founders and like, obviously being in the industry for 10 years. What were some of the trends that you've seen then and now?

Like I'm sure a lot of people were in ICOs around 2000 17, 18, 19, and maybe talk about what's the trend you're seeing now? Is it a lot of AI times, blockchain, everything? Is it, the use of meme tokens and tokenization on some speculative assets? Like what are you seeing from founders? What are they coming to you with now?

Joe: Yeah, I think the founders that are coming to us and I appreciate you pointing it out that, we work with a lot of folks early in their journey, one of the first, tangible pieces of compliance that they have to have is a written AML compliance program and is required from day one of operations here in the U.S. And I suspect other Western industrialized nations that regulate crypto. So what does that mean? That means we get to see them at their very early stage and what their business model looks like. And it's not always what it's going to end up looking like, because there's a lot of pivoting, as Stephen with entrepreneurship but the business models we see right now a lot of it is, is maybe more of the quote unquote, traditional exchanges or, or OTC type of business models.

Payments is, is really popular right now, particularly with stable coins for international trade settlement. Payments for contract employees or, or vendors all over the globe. We live in a remote society and I think COVID reinforced remote working. And, and people have really found that to be a great balance with work and life, and that's fantastic.

But that also means we have workforces that aren't coming into an office, but are scattered throughout the country and throughout the world. So, so payment platforms using stable coins as a rail have become very popular of late. On the opposite side, we're, we're seeing a noticeable drop off in Bitcoin ATMs.

There aren't too many folks interested in, in starting a, a Bitcoin ATM operation, at least not at scale. It's it's an industry that's dominated where the top something like the top 10 in terms of kiosk footprint dominate 70 plus percent of the marketplace. So, that that is an area where it's been concentrated at the top.

And in the early days, we were working with with. New kiosk operators left and right, I think fed into the sort of the libertarian orthodoxy that you were talking about folks that wanted to come into the space. There were much more limited barriers to entry many, I would say most states, at least when we started, most states weren't requiring a state money transmitter license for those that utilized a crypto or sorry, that operated a crypto kiosk because it was doing direct wall to wall transactions, which many states sort of use that as an initial, at least initially.

As a carve out for money transfer licensing as an exemption. Fast forward to today. That's not the case. Most states cover just about every exchanging type of business model up to and including kiosk operation. So, yeah, very much a dramatic shift. I think if we're talking about the folks that are behind it, less of them lean into or, or dominate the conversation with philosophical libertarian debates and talking points.

I'm not saying that we're not working with a bunch of libertarians. I think we are, or at least at heart, but they lead with the business side and they lead with the compliance side. They recognize that if they want to stay in business and they want to do business, they want to do business with great customers.

That means having consumer safeguards. That means protecting folks from scams and doing right by their AML regulatory obligations.

Stephen: Can we double click into the Bitcoin ATM and kiosk situation? Because I remember when I used to first talk to you used to say like, Oh, Bitcoin kiosk is a way that they can essentially be crypto exchanges without having to meet all the crypto exchange requirements. It was kind of almost like a loophole.

Are you saying that kind of loophole has closed now? And like, hey, if you're operating a Bitcoin ATM, you might as well be operating Coinbase because you're going to be met with the same restrictions or, regulatory requirements.

Joe: Yeah, sort of right. So if we do a little bit of a rewind to the earlier days of crypto, listen to me, the early days of crypto back in 2015 16 when we started out folks were setting up crypto etms. Because again, at the state level, at least initially, the states took this sort of risk based approach and said, okay, there's a difference between custodial custodianship and holding on to someone's crypto with the promise that it could be accessed at a later time, later date, later destination or sent on behalf of someone.

There's a distinct difference between that. Yeah. And someone doing a near term or contemporaneous transaction from one asset class to the other, which I agree. There's a huge distinction or risk based approach on. And I think at that time, there weren't a lot of folks in crypto. And so the regulators said, Hey, there's this huge financial system and we have banks and we have check cashers.

We have casinos. We have to, orient our, our time and our scheduling around the risks and all these different areas. And so, as time has gone on, obviously, crypto has gotten more popular. They there's a saturation, at least at one point, a saturation of Bitcoin ATMs. And then I think the regulators sort of said, okay, I think we need to make any sort of exchanging activities.

Money transmission. And Vincent had done that from day one. They said, look, you're doing any sort of exchanging. They didn't make a delineation between the two. So the states caught up. Some of them had to do it through legislation because they maybe had some antiquated verbiage in existing regulatory or legal frameworks.

So, yeah, I think that did your and I'll borrow your terminology, close that sort of loophole. Interesting thing about the kiosk. I mean, it's an opportunity to have a direct transaction. It's done in as little as 30 to 60 seconds. Yes, you're paying a higher fee, but you're paying that fee for convenience.

In an opportunity to enter the space fast forward, the online exchanges and online platforms are trying to make it a little bit easier themselves and maybe using a little bit of a tiered based approach depending upon the level of level you wish to transact at. So, I think those, those 2 sort of variables are coming together and making it difficult to significantly distance yourselves from a competitor.

If you're in the kiosk space, it's at this point, it's about scale.

Stephen: Bitcoin kiosks all get ATMs, they get like a bad reputation, more so than the traditional ATM gets. Like, based on what you're saying, it's like, Hey, we all use ATMs for convenience, but it seems like, Hey, if you're using a Bitcoin ATM, it's because, you're an illicit drug dealer trying to go there at night.

Why is like, what are the legitimate reasons why people are using Bitcoin ATMs? Is it just convenience? And why is it such a negative stigma about using a Bitcoin ATM versus using a traditional cash ATM?

Joe: Sure. Yeah, I think there is a legitimate use case, right? There are folks that work in a cash based economy that want to deal in cash. There's convenience that you spoke of. There's also convenience on another order in that if one were to set up an account with an online exchange, if they want to hold their own crypto, then they have to make a separate transaction.

To a wallet that they then have themselves, right? So and they have to set that up and they're configuring a second step to the process. So it's maybe not as convenient as folks think will enter the Bitcoin ATM, right? You go to the machine. Little is 30 to 60 seconds. If you're going super slow, it could take a minute, right?

Thio transact. You're feeding in cash. You're holding up your, your, your phone with your digital wallet up to the window, which effectively is sort of a scanner and then using a technical term zapped. The bitcoin is then zapped to your wallet through the through the crypto transaction.

So, it's immediate. Unfortunately, the bad guys enjoy the same benefits as the good guys, right? It's a simple, straightforward transaction. The customer presents themselves, goes through the requisite KYC information. They click through the scam warnings. Some click a little too fast or don't read them, but nonetheless they go through that onboarding process and they're able to transact in a super straightforward and quick manner versus an exchange where it takes maybe several days, certainly at least several hours.

To set up the account because you're linking your bank accounts and doing the trial deposits and, going through those different steps that have have take a long time to go through relative to a kiosk again, the exchanges invest a lot of time in the customer experience, which is fantastic, but it's so much quicker at the A.

T. M. And the bad guys knowing this are sending folks to the A. T. M. S. To do those transactions. And you're right, they do get a bad rep. Yeah. When we see a lot of headlines associated with with scams that involved a crypto ATM and pig butchering and and things like that, and it's an inordinate amount of tension.

In my opinion, it and you and I've talked about this and the pig butchering almost always starts at a bank. Yet the bank somehow seemed to not be mentioned when we talk about pig. It somehow seems to be focused on crypto and beyond that hyper focused on Bitcoin ATMs. And I can say with 100 percent confidence.

Not every pig butchering scam results in the use of a Bitcoin ATM. And if it does, it probably involves the use of other things like prepaid cards and certainly involves the use of a bank account because that's where the victim must initially go to withdraw their funds.

Stephen: And it's much easier. Like if you're a pig butchering scammer, it's easier for you to get you to deposit into Coinbase and then getting Coinbase to send funds to a phishing or a fake website, then you having to remove funds, go to a Bitcoin ATM. You're standing there with the person on the phone. Like it just seems like a harder process.

Plus, we just know the volume, like how many, how much money can you transact at a Bitcoin ATM versus like 30, $40, 000 through a bank or a crypto exchange, but let's, let's go back. Let's double click on that point about responsibilities. I just saw your post. I just commented about it. Basically, like, where is the level of standard that we have to hold, the banks to the crypto exchanges.

It seems like crypto exchanges are easily thrown under the bus. My defense to that is that, well, the banks have way more information than the crypto exchange ever will, because they're only doing one type of transaction, whereas the bank knows a lot more KYC information, who their spouses are, counterparties, other account activity, right?

You don't see that in the crypto exchange. What's your view? Do you think banks need to be held to a higher standard as they're, they're releasing these funds to, into the crypto ecosystem?

Joe: Yeah, I agree with you. I think we should all be held to the highest standard, regardless of what financial institution products and services we offer or what category we fit in, whether it's a kiosk exchange or a bank. So first things first on that. And I do think the banks have not been held to the highest standards.

In fact, they've in some ways been left out of the conversation and they need to be involved in that. And I agree with you, the banks are in the best possible position that we think about, for our AML friends out there, placement, layering and integration, the three stages of money laundering.

Well, that placement stage is where we, the good guys have the upper hand. You're right. That teller has in front of them, all this information, you kind of mentioned a few pieces of information there, their spouse, their job, their, their transaction history, their transaction patterns. If they're coming into a branch and they're withdrawing 2, 000, we ought to be asking some very probative questions.

Now, there are industries where it would be commonplace to withdraw large amounts of cash, with cash intensive businesses. But if we have someone coming in and withdrawing from their individual account 2, 000, and we look at their transaction history, and there's nothing remotely resembling that. They take out, 20 for each of the grandkids, right, at Christmas time, but all of a sudden there's a 2, 000 withdrawal.

We should be asking some very probative questions that should stick out and does stick out like a sore thumb. And I wonder where the bank's coming to the equation versus, let's say, the Bitcoin ATM, since you brought them up. Someone is going to that Bitcoin ATM and voluntarily engaging in entering into a new asset class for investment.

Right. That's what we know of them. Yes, we have driver's license and information. They've clicked through and said, Hey, I'm not the victim of a scam. They have toll free number on the machine. In many cases, if they have a question about a transaction and they're being guided through that. It very different lenses.

And so again, we are not suggesting that folks in the crypto space should have less of a focus. In fact, I love the high standards that keeps us on our toes that keeps us, questioning how we can be even better with compliance. But I do think the banks need to come to the table and they've been left out of the conversation for far too long as pertains to pig butchering and scams more generally.

Stephen: Yeah, and I think, we've seen Aaron West trying to bring everyone at the table, including the social media apps, that kind of, a lot of the victims. What do you see about victim responsibility? I think one of the articles that you had mentioned, it may have been this, was like, a victim was suing the bank for allowing them to be a victim of pig butchering.

That's like, Hey, you're seeing yourself able to make 10, a hundred times profit. You're taking your chance there. Now you want to hold the bank responsible. I think there's people playing devil's advocate there too. Like, Hey, this person got maybe a little too greedy. And obviously there's, long con, manipulation.

So I get that part of it. But where does the responsibility have to reside with the victim? Especially when we get into crypto, people are using credit cards to buy crypto from their bank, which is why a lot of banks in Canada stopped this, because they were using their credit cards, the price of Bitcoin went down, and then they would charge it back on their credit card, saying, hey, woe is me, that wasn't me.

Where do you think that, do you think that's why the banks are not held to the same standards? Because some of the victim has to hold some of this responsibility on their own.

Joe: it's always difficult and look, there's no excuse for victim blaming. Generally, the folks that are going through this and you're right, Aaron West has done a great job of talking about it from a compassionate standpoint as well, working with victims and hearing this horrible stories. And generally, there's some component behind it.

It's usually not a how can I get rich quick? It's usually someone that's going through some sort of emotional trauma. So. I think we're all in in it for the same reason we all can kind of wrap our heads around that we want to embrace the folks that that that are victims. And, one victim is one too many but individual responsibility again, you sort of talk about the libertarian side of things.

We do hear from folks in the industry that say, well, that those people have selected and they they've attested that they're not a victim of crime. And it's very difficult, right? It's very difficult to straddle that line. Yeah. And at first I was of that mindset of someone says the transaction is fine and they're not a victim, then I don't know that we can ever say that they are.

And I've, I've since sort of backpedaled and reversed on that. I think that there is a fine line and it's going to be unsettled. And you pointed out, you made a great point, Stephen, from an industry perspective. I'd be remiss if I didn't touch upon this. The sort of the chargebacks, the market goes up, everybody's winning.

When the price goes down, we're hearing from our members, from our clients, we get an inordinate amount of folks reaching out to us saying, Oh, somebody stole my card or my son did that or, and I didn't do, I didn't mean to do that transaction. Can you reverse it? Buyers remorse and and that's something that really hurts, the folks that are out there doing the right thing and complying.

They want to resolve a matter involving consumer. But at the same point, you're allowing folks to to back out of something that they they transacted in. So balancing acts all around. I guess that's my my theme for that particular line of question.

Stephen: I love it. Let's you know in three day in two days. Yeah three days January 20th, they're going to announce, the tweet storms are going to be, flying as President Trump comes back in office. He made a lot of promises during the, the Bitcoin conference in Miami as well as other places.

I believe it was either Miami or Nashville. He was going to fire, Gary Gensler. Gary Gensler ended up resigning. Mark Zuckerberg is doing the moonwalk when it comes to free speech and, diversity and inclusion. What do you think Trump? Will do can do like, what do you think he's going to mean to crypto or do you even think he's going to continue the crypto crusade and maybe back off now that he's in office and he's gotten the support of the crypto elite, but we have to even talk about, the crypto and AI czar and David, I can't always forget Friedman, I believe, or Freiburg is a new crypto czar.

What are your thoughts around all this? A lot to take in when he hasn't even stepped into the office already.

Joe: Yeah. Yeah. It's, it's it's very difficult to to look into my crystal ball, particularly talking about the leader of the free world. But I'll do my best even with, with with your questioning here. No, it's interesting. I think you're right. Mr. Trump laid out a lot of different goals and aspirations and things that you would like to do in office to help the crypto space.

And these are very, very lofty goals. Can he deliver on all of them? I don't know. I think my guess is that they'll get through most of them. Some of them are maybe a little bit easier to do and sort of Bitcoin strategic reserve. All you have to do right there is if the U. S. Marshals or or the FBI sees a bunch of crypto, just hold on to it and not sell it.

Right? So that could be a quick win right there. Some of the more lofty goals involve getting the executive cabinets on board. So we have very favorable people. Potential nominees on the SEC and CFTC and other areas of regulatory oversight and financial services that publicly and, and to my knowledge, privately shared very favorable impressions of the crypto space and wanting to, to create a space that is a little bit more sort of straightforward in terms of regulatory oversight. I think the SEC is probably the sort of ground zero. You mentioned Mr. Gensler making a hasty departure before he's ceremonially fired by, by Mr. Trump. By the way, I think that got the most applause at the crypto conference of all the different talking points was firing Mr. Gensler. And for good reason regulatory decision making through enforcement action. It's just not a good way to go, right? If we want to talk about and criticize the, the crypto space for being immature, I would sort of turn the mirror on, on Mr. Gensler and his team and saying, well, you're playing all these guessing games.

You're making people guess whether something is a security and if they're wrong you're taking them to court and you're making them pay fines rather than to come up with a framework and say, Hey, look, we had this Howie Howie case, so many years ago, the Howie test and the Supreme court case involving it.

Orange groves in the early 1900s. I think we've, we've kind of evolved from that, let's set some regulatory buckets in terms of, of what digitized and digital investments, digital assets look like. I think that model is probably something we'll see maybe not in.

Stephen: you the XRP winning that case in, in the court and then eventually Bitcoin spot ETFs winning in court against, do you think it's kind of like the SEC is going to have to just rearrange their whole decision making when it comes to crypto and decentralized digital assets?

Joe: Yeah, from my understanding, the SEC is a sort of a big battleship. It's gonna be very difficult to turn that around. I think we can nudge it a little bit through through favorable leadership. But yeah, I don't know. It's gonna be a little bit. It's gonna take a little time for that to evolve. But I do think that within the next, certainly within the next first two years before the midterms, We'll probably see as many initiatives of Mr. Trump's move forward as possible. And I think, I think we have a great opportunity. The SEC mentioned the ripple settlement or ripple goings on with with the SEC and other matters. I'll say this. I think the SEC completely underestimated the crypto space is willingness to fight back. Historically, the SEC would come in and banks and other financial institutions would, yeah, they would negotiate or talk through it.

But at the end of the day, they knew they were settling and they would just sort of. Figure out what's the best path. Give me give me my ticket. I'll pay my fine and I'll move on with my day. And the crypto space said, no, we're not setting bad precedent. This is ridiculous. And fought back.

And I think Mr Gensler especially underestimated the willingness of the crypto space to only fight back, but to continue to fight back. How long has the rebel case been going on?

Stephen: It's be at least four or five years and probably you're in probably seven figures when it comes to lawyers fees unless they're doing a pro bono for the benefit of the entire space, but you're racking up some serious money fighting these cases.

Joe: Yeah, no, absolutely. And we've seen it not just with the SEC, but but other, organizing or other regulatory agencies where members of the crypto community will fight back and they're willing to take a loss financially in order to ensure to the best of their abilities. Bad precedent is not set.

And I think that, if if I were sort of helping run the https: otter. ai Why don't we set up a framework? Why don't we work with industry and put something in place so that it's fair? And, and not just so the industry can thrive, but it's fair for consumers, right? I don't know that anyone ever woke up under Mr Gensler's tenure and said, well, I feel so much safer with the SEC it comes to investments.

No one thinks about that. No one's going through these voluminous 10 K documents and all this other paperwork. I think the SEC has a chance to be more modernized and I don't think they should go away. I think that there's some folks in the crypto space maybe would disagree with that, but I think there's a way to work from within and sort of reimagine and recraft this, this regulatory agency to be something that is, is there for consumers, because by the way, that's their mandate to protect consumers but also provides a clear, distinct, transparent path for members of industry that wants to bring forward great products and great services that, that delight clients.

Stephen: I think they also underestimate the collaboration of the industry, right? You go after a couple of fintechs. Everyone's like, Hey, that's my competitor. Go right ahead and knock him out of the race where I think crypto has been more collaborative. Like, Oh no, we're all going to fight back. Even though you're only going after one, we're all going to fight back.

And I don't know. I'm not that well versed in SEC

Joe: you're spot on. I'll

Stephen: I have to say that like, you don't normally see the entire industry rallying behind what would be deemed as their competitor

Joe: I'll validate your point. I mean, there's a lot of folks in the crypto space that aren't fans of ripple, but you know, the moment they get sued by the SEC and are fighting back and winning the crypto space is there cheering the background, same with, with Coinbase, it seems like the, the, maybe there's a little jealousy or something there, but the crypto space is not too, too keen on Coinbase.

But once they start fighting back against the SEC, they become Sort of the toast of the town in the crypto space. So, there is some, there is some cohesion there and there's some, some working together and some collaboration, as you mentioned in the crypto space. And it's, it's good to have mutual, mutual admiration.

Yes, we're competing with, with folks all around us, but that doesn't mean we can't come together and say, Hey, I think there could be something better. And I just want to add, this isn't about the crypto space getting special treatment or. Or a tax break or or something to benefit them. It's about clarity and consistency and fair treatment. The crypto industry just wants a fair shake, a lowercase on the F of fair shake, a lowercase fair shake in the industry.

Stephen: I'm curious, you talk about regulation now and, adopting, a lot of people are talking about federal regulation. Should there be a federal regulator in charge of crypto? I've seen in EU, MICA is like, seems like it's butting up and confusing. There's a lot of confusion around the European Banking Association and Micah and what the rules apply and, grandfathering clauses.

Is there anywhere, maybe Dubai that, or even ADGM in Abu Dhabi, is there anywhere you think that the U S. Could borrow or use that as a starting framework as they're both building their own regulation. Have you seen anything abroad that you found meets, the regulatory requirements, but also allows for innovation.

I've also seen in the UK, the FCA and their sandboxes with a lot of the industry players around the travel rule. Anything that you're seeing abroad or, hey, like, can we, like, can we borrow some things from the traditional landscape of regulation that could be used as a framework to, build crypto and digital assets on top of,

Joe: Yeah, I mean, there's something of some, there's something somewhere is a nothing of nowhere, right? So I don't know that we want to necessarily borrow, although we could, cherry pick or uses inspiration things in other jurisdictions. I think as it pertains to the U. S. I don't. Want to see a crypto regulator if we had a crypto regulator right now It would be FinCEN as they regulate the vast majority of crypto related exchanging activities In the US marketplace, and I think that they put in put in a good position to do that I think when Jen Calvary came out with the guidance and sort of set things down and said hey look you're a money transmitter We're going to treat you the same way we treat every other money transmitters, nothing special and nothing more over the top.

And the industry is like, okay, yeah, we can, we can maybe work with that. And so, time has gone on. There've been regulatory exam cycles and, and things have moved forward, but I think we're in a pretty good position there already federally. I think the issue is at the state level. So each of the states, with the exception of Montana regulates money transmitters and they all have different ways of doing that.

Right. There's different reporting requirements, different applications different whether it's a quarterly report or annual renewal or miscellaneous reports they vary from state to state. There is a good degree of parody, right? There's only so many ways to artfully ask for your business name or your E I N number.

But you know, when you get down into the actual requirements there are noticeable and distinct differences in how they're presented and how they're completed to the degree that now cost several hundreds of thousands of dollars to get a license in each of the states. And the smallest part of that is the actual application fee, right?

The, what you're paying for are the accountants, the lawyers the other subject matter experts, compliance and otherwise that are helping you prepare that application. For for go time when it's presented to the regulator and then, slowly releasing your your geo fence from around those states.

You're not able to do business with and that gets into an issue of states rights. And there's been some talk of potential preemption at the federal level, but I don't know how that's going to look because you have states that have These frameworks in place and they already have requirements written into law.

They have specific expectations around what the cost is in order to be able to operate in their jurisdiction. So that, that's going to be difficult. I don't know that there's a simple solution at the state level. We've tried different things of, of aligning, sort of common requirements among some of the states and those that have particular parity.

And what generally happens is that model framework, the state will take the model framework and go, Oh, this looks great. But. I'm going to change a few things. Well, you're done adopted the model framework. You've just basically used it as a suggestion sheet. And so we're, we're getting closer, but there's no unified application.

There's new unified structure country or from different states of state across the country. So. Some states tax each remittance, some states have a one time application fee. Some states require audit financials. Others don't, right? There's, there's different, requirements and, and it makes that process very difficult, especially for an entrepreneur coming out.

If you want to start an exchange in the U S yeah, you register with Vincent, get an AML program, start to, to build and invest as you would grow any other business. But now you have to effectively geo fence out every single state and slowly. The. Incrementally apply for those states and the barrier to entry financially is is significantly steeper than it was back in the day.

Now I could see someone looking at the, if someone were to go back and and look at a time machine on Coinbase as an example, those guys stole their licenses. And what I mean by that, it was just so cheap back then. Right. You had these requirements and you brought in a legal team and you brought everything forward.

Fast forward to today, the requirements have gotten more and more layers to those and wait times. And now there's more competition, folks waiting in line with you. So it's, it's it's an interesting process. And we kind of went from federal to state, but I think in some ways they feed into each other and be interesting to see what happens on the state side.

And

Stephen: and this is why a lot of, foreign exchanges or international exchanges just exclude U. S. customers altogether because it's too nuanced. You have a technology company that actually helps people get licensed in different states just because of how nuanced it is. And hey, entrepreneurial America, take advantage of that with expensive lawyers and consultants that could basically be doing the same thing that your technology is doing for a lot cheaper.

We're going to get into California legislation, which is your bread and butter, but talk to me about the entire state landscape. Like, which of the states, if you're an entrepreneur, do you feel is a little bit more advantageous for you? Which of the states that people are staying away from? I know the BitLicense.

Has become more lenient, but I still think they've only licensed 12 to 14 exchanges. I could be wrong on that one. But it still seems like a pretty onerous task to get a license there in New York.

Joe: Yeah, no, New York is is the vast majority of folks. We speak to to have no interest in New York. They're, they're not even asking what does a bit license look like? Or has anything gotten better? It's just a, it's a non starter. We, we met here in California with Chair Grayson of the Banking Committee and sort of, I presented it was in public comment.

I said I did some back of the envelope math while I was in the galley. And it turns out that New York issues, sort of 4. 25 bit licenses a year. or something on that order. And clearly it's not for a lack of interest or lack of trying. This is in the context of California getting their own licensing regime.

So you're right. Folks have just sort of looked at the U. S. International folks have looked at the U. S. And said, Hey, it's not really worth my time. Folks in the U. S. Have looked at New York and said, Hey, it's not worth my time. So the remaining states, obviously it comes down to unique facts and circumstances of everybody's business.

Generally speaking, we're speaking in generalities. Red states are tending to be more favorable than blue states. And now that's kind of gone sort of double down where we see some of the blue states putting more onerous, consumer protection regulations in place. Some of which I feel are warranted and are probably good news on the order for the industry as a whole.

Stephen: Be like Connecticut? Would that be an example? I saw Connecticut just released a lot of consumer protection when it came to crypto, Bitcoin, ATM kiosks. I'm not sure if it's a blue state or not, but

Joe: yeah, no, it certainly is. It certainly is a blue state. I think they were one of, if not the first to have a crypto ATM specific bill. Actually beating us out here in California by a matter of months in terms of their legislation passing first, they've since gone back and, and fixed a little, some elements of the bill, which are a little too onerous and, and didn't ultimately protect consumers.

But the, the, the point is made right, that they're, they're leading the way and, and now they have a, a, a bill that addresses pig butchering, which is super cool. And, and that'll be fun to watch. But yeah, the generally the blue states are are leading the way with the focus and the theme being on consumer protection, the red states tend to look a little bit more crypto from a perspective of mining.

And maybe that's, texas kind of, stealing the show in terms of being the largest red state looking at mining or looking at tax incentives and other perks to create their own sort of crypto hub. Both have their, their pluses and minuses in terms of, of what they bring to the marketplace or what they mean for the marketplace.

But what I'm focused on now, and you mentioned, Mr. Trump's inauguration coming up in mere days what is going to be the reaction from the blue States? We've got a lot of those questions, obviously being California, probably the bluest of blue States and certainly the largest state by far.

In fact, we're the fifth largest economy in the world. If California were to be its own country. So folks are kind of looking at us and right now. I'm pleased to report our legislature is not looking at crypto necessarily as something to be adversarial towards. They kind of see it now as sort of a right leaning issue, but they're not necessarily inclined to, to sort of be compative overly combative just for the sake of doing so, which I think is good discipline.

And I hope that I hope that I'm right in that initial assessment. It's only been a couple of couple of weeks here for our legislature in California, but obviously we have some more pressing issues to deal with. Right now, with the wildfires and the budget situation. But yeah, beyond that, I'm hopeful that the states are continue to look at crypto from the perspective of, hey, how can we promote innovation?

But how can we balance that with protecting consumers? And once again, I go back to my my statement that it's a balancing act, right? We have to land somewhere comfortably in the middle.

Stephen: And my heart goes out to anyone that's, been affected, lost their house family members that have lost their house. I know we had some guests on the podcast that I reached out to, and similar, maybe three, four hours away, but their parents live in those areas, and it's just completely Sad to not even have enough time to remove some of the articles that you've, worked your whole life to build up.

So we're definitely saddened by what's happening and I think, maybe on the more satire side, I think a lot of people would hope that California became its own country outside of the United States with some of their actions. But let's dive deep. You're, you're front lining lobbying.

What seems to be the pain points? What's the biggest pushback that you're getting? What are the areas? Is it just consumer protection? Is it maybe ignorance and, not enough education around like, Hey, this is what can happen with digital assets. No, it's not completely anonymous, like what's the pain points that you're, you're running into with your association as I'm assuming you're lobbying for more crypto and more, guide guardrails to be put in place so that companies can actually build in the space versus kind of just watching what's happening and seeing who's getting penalized and who's not, who's getting enforcement actions and who's not

Joe: Sure. Yeah. California prides itself from a legislative standpoint on being on the cutting edge for consumer protection. And you know that that cuts both ways, right? So here in California, we have the Department of Financial Protection and Innovation, which regulates, among other things, crypto and other aspects of not just financial services, but other areas of the marketplace.

And that was actually created by current current Governor Gavin Newsom in response to the first Trump administration sort of, winding down, effectively winding down operations at the CFPB. It was still operational, but it had sort of a, nominal budget and really didn't bring any enforcement action.

So that was sort of the equal and opposite response. So just to give you an order of magnitude about, the focus on consumers out here. So that's. That's one thing that consumer protection the other is, and you alluded to the sort of ignorance. You think of California, we think of, Oh, it must be run by a bunch of surfers and high tech people.

When in reality our the average age of our legislator actually got older this past cycle. And it turns out it's mostly, career politicians and, and folks that staffers or were somewhere else in government or lawyers. And that's what you get in response. You get it. Lawyers, legal paperwork right?

Regulatory frameworks. You don't necessarily get sort of, tech forward. We do have some folks from Silicon Valley and other areas that think in a tech forward manner or open minded or have some degree of inclination to be pro crypto. It's very difficult right now as a Democrat to be pro pro crypto, or at least be public about that.

Bravo to Ro Khanna, Richie Torres and some of the other Democrats nationwide that have remained steadfast in their support. Commitment to seeing a vibrant crypto space, but we understand that they're, they're sort of handcuffed in a way by the current political dynamic that's out there.

But yeah, California comes down to consumer protection being a main focus and priding ourselves on that. And the other is that education hurdle. And I will add in the background you have some squeaky wheel constituencies in the AARP. Is front and center on this. They are going around shopping model legislation in any state that will give them an audience.

Here's what we want to do for Bitcoin ATMs. We want to restrict the transaction amount. We want to, we want to restrict different activities. We want certain paths for refunds. We want certain disclosures and, there are things in there that we actually agree with an industry. And in some cases we actually exceed some of the things that they're

Stephen: just who are the AARP? What's their and what's their mandate? It was just maybe so for people that are outside the industry. Okay. We're outside of California,

Joe: Yeah, so American Association of Retired Persons, right? So the A. R. P. Is a very powerful constituency. They represent as a consumer protection and organization. They represent our seniors. And many years ago, they actually lowered the entry age to 50. Even though we're living longer, they lower the age to 50.

So they

Stephen: need more member membership.

Joe: Yeah, they represent a huge swath of folks out there in the marketplace, and they provide things like, discounts for seniors, and they advocate for Medicare and Social Security, and, and they have different, different clubs, different associations, different webinars for, for seniors, and they do some amazing things as an organization.

They're fantastic. They have a wonderful reputation as advocating for, for our seniors, which I think is fantastic. Unfortunately, they're not. I think they've got a little heavy handed in wanting to prescribe specific legislation for, in this case, Bitcoin ATMs. And what I'll remind folks, if you're not necessarily sympathetic to Bitcoin ATMs or, or you think that there's a better mousetrap out there, I understand, but if we're allowing this to go forward, we might have more prescriptive regulation around a business model that you do care about down the line.

So it's important to kind of push back on this. I think we're all, we all agree that we don't want a senior or anyone to, to fall victim to a scam. But I think it's important that we look at this from the perspective of not just innovation, the world that you and I are in Stephen compliance, we can't have anti AML regulations in place.

And what I mean by that are controls that are, are in there or sorry, requirements that are in there. That get around or, or even in some cases tip the hand of the controls that are in place to, to thwart AML or cut off valuable channels of communication and and ways of connecting with law enforcement.

Stephen: Do you think that's one of the challenges that we see in crypto, even in traditional banking and lobbying is that everyone has a specific agenda that's, obviously pandering to their constituents, their members, the reasons why they even exist in the first place. Whereas we're not all sitting down at the table and seeing what we can do to compromise in certain areas.

Everyone's just kind of pushing their agenda forward and trying to be the loudest and throw the most money behind it. And it just feels like we're kind of going around in this wheel of what everyone's agenda is. And we're not really reaching a consensus of how we can move the industry forward. And

Joe: on that order. I think, first of all, I don't begrudge any organization for, for standing up to standing up for its members and supporting its members. CBAC, California Blockchain Advocacy Coalition, we represent industry, we are a member based organization, we're going to advocate for our members.

And I applaud the AARP, though we disagree on some things for advocating for their members. And I would have it no other way. I think the problem we run into in the crypto space is it seems to me on the one hand, we have not just a powerful constituency. And again, I'll use the AARP as an example. But we have individual consumers, someone that is relatable to a member of the legislature, to an elected official versus an industry.

So when you have industry, it is a lot different in terms of optics than people and consumers, right? So they're, there's, to my knowledge, not a, a focused group of consumer advocates in the crypto space advocating for the everyday investor, the everyday person who is interested in crypto. It just becomes an industry Versus person, and it's very easy for folks that have a particular opinion to kind of use that to their advantage when they're advocating for a particular position.

So, in the crypto space, we have a lot of crypto enthusiasts, and they'll be happy to tell you that on Twitter or X. But to be a little bit more organized, a little bit more focused and say, look, we're advocating as consumers were interested in the space. We're not coming to you as an organization, as a company, as a as a as an exchanger or something like that, but simply advocating from the consumer perspective is something that we need to see more of in our industry and is a good compliment to the folks that we represent who are the builders, the innovators, those that have platforms that allow consumers to, to safely and, and effectively transacting crypto.

Stephen: When I'm watching, I don't know if these are committee house meetings or Senate meetings or Congress meetings when they're like, Putting Zuckerberg under fire and these, what seemed to be very, very attacking questions. I'm sure when you're, I've seen you in similar spots, maybe to a lesser degree, more, maybe more localized than national.

Where, like, what do you say when they're bringing up FTX and Celsius and, rug pulls? And, what are you saying, ICOs? What are you saying kind of like to talk them back away from just focusing on some of the, the biggest. Catastrophes that we've seen in crypto

Joe: Yeah, it's,

Stephen: they bringing it?

Maybe I should ask you, are they bringing those up? And then how do you deal with them when they do,

Joe: I think less and less. I mean, certainly when we go back to the original bill here in California, Assembly Bill 39, which created the, licensing framework for crypto exchanges. That bill was being drafted as FTX was collapsing as the Terra Luna debacle was going down. By the way, that's why there's a separate chapter for stable coins in large part because the Terra Luna debacle was happening.

So things don't happen in a vacuum. They happen in response to what's going out there. So there's some historical context for you in California. So how do we get away from that? I don't think we can. We do have some legacy issues as a as an industry. I think the important thing is to, to not shy away from that, but to rather offer context for it.

Right? So if you look at FTX, it was a fraud from day one, it has less to do about crypto and more to do about a fraud. It might as well be Enron, but instead of energy and electricity, it was crypto. Right. We didn't just say, Hey, the, we should get rid of the energy industry. No one should have electricity anymore.

We didn't, we didn't, thankfully we didn't go that far off the edge. We said, Hey, here are some bad people doing some bad things. And by the way, the vast majority of people, to my knowledge that worked at at Enron and, and FTX were just people that were doing something for a living that they were, didn't do anything wrong criminally.

They thought they were supporting an amazing organization that was doing great things and was on the cutting edge. So it's important to add context to these things and, and we didn't shy away from regulation in California. We said, no, we want a license. We just want to make sure that that license is straightforward.

And allows for people to, to bring their ideas to the table, have a conversation with regulators, figure out where they fit in. What are the license requirements? Essentially, what are the rules and how do I play? In the licensing bill in California, yeah. Far from perfect, but I think it was, it was much better certainly much better than the original version, but I think it was, it was a lot, a lot more in there to, to be happy about than, than maybe folks are willing to give, give credit for.

Stephen: what are you looking for? As this will be released in 2020, early 2025, probably February. We think it's the year of stable coins. We seen, some, huge investment into wallet infrastructure, like phantom. We've also seen stable coin investment with the merger and acquisition stripe had with bridge.

We saw BVNK raise a huge round stable coin and we see mergers and acquisitions with companies like Chainalysis. But we're also seeing, NFTs coming out with their own tokens and real world asset tokenization being a huge thing. Where do you think we are in 2025? What do you think is gonna when we look back on December 31st, where do we think, like, where will the conversation be, do you think?

Joe: Yeah, I think if we're talking legislatively, I think stable coins and you've probably seen we've been posting a lot about stable coins lately and I mentioned here in California with the first state. And the federal government hasn't either, but the first state to take up legislatively, at least oversight of stable coin issuers.

And again, there's some historical context with this being drafted as Terra Luna is Falling apart. And, and so we had the, in some ways, the benefit of that timing. Now the other states are looking to say, Hey, this stable coin market, we can't ignore it. It's, it's so big, it's really taken off.

There are a bunch of different stable coins out there. People are using these in real world situations to settle trade internationally. It's a competitive threat to traditional financial institutions that are out there. And so it's such a big elephant in the room. And then on top of that, we have the public spectacle.

Of the Doquan trial going on, it's scheduled for for 2026. But of course, there's going to be different court motions and things happening between now and then one would suspect, right, that are going to play out publicly. So that sort of cauldron bubbling over, in my opinion, is going to lead to several states saying, hey, If the federal government doesn't want to take this up or if my state is blue and I disagree with Mr.

Trump and the way he leads on crypto, we're going to, we're not going to wait by the phone, we're going to go out and we're going to put together a bill that deals with stable coins. Hey, has anyone done one? Oh, we have here in California here. Why don't we take a look at what we have? So I think that states are going to start looking into that this year and we're starting to get into the, the, the meat of the, the legislative session here.

So if it's not introduced this year, I suspect many of the states will start next year. Bitcoin ATM legislation. We've already seen several states putting out proposed bills this year, Massachusetts, Virginia, Washington State, or just a few of the many states that are even North Dakota, believe it or not, are putting out proposed bills, at least at this point that would regulate specifically to crypto ATMs and borrow in whole or in part some of the framework established by AARP, but also some of the framework that we as an industry Have been very proactive about look, we we don't like scams either We want to have some guardrails as well.

And we do have customer support Folks that that are engaging. We do have scam warnings. We do have disclosures. We have receipts digital or printed We're able to to meet you you know somewhere in the middle. We we do have reasonable fee structures so there I think there are are ways we can work together on that.

But yeah, I'd say bitcoin atms stable coins will probably be the two big ones, and then I think we'll see a lot of states start to ratchet up the consumer protection aspect of it. What's interesting to see with, with a bull market is everybody's winning, right? But what happens when we have a big downturn?

Are we going to start to see a big uptick in consumer complaints? Are we going to start to

Stephen: yes, people don't blame themselves when they lose money.

Joe: Right, right, right, right. Yeah. And I think, the thing to watch out for and I'll speak to my fellow compliance analysts out there when there's a bull market. So framework a little bit. So we see elder abuse and scams.

Statistically, that tends to be kind of flatlined. Yeah, there's some some bumps here and there from some major crime groups or things like that coming and going. But for the most part, it's fairly flatlined. Investment scams take off in a bull market. Because people are afraid of missing out, they see the price of bitcoin going up, they read a one off story about, some guy that put in 10 and now he's on a yacht and he has hundreds of millions of dollars and, these sort of obscure, half truth or no truth stories that that people start to cut corners, right?

And that's when they fall for scams. And so, the scam artists are probably going to focus a little bit more on, I would think on investment related Types of scams, wanting to, to get at the, the the greedy nature of folks, and folks that don't want to be left behind. Whereas I feel, and I hate to say it this way, but the elder abuse scams are timeless and that they just sort of continue over time.

But, we shouldn't we shouldn't back away from, from confronting either, but just offering some perspective and in terms of how market dynamics impact.

Stephen: I love it, Joe. You took us through 10 years of crypto compliance legislation, even touched a little bit on Trump. This was a fascinating conversation. Maybe we can do it the same time next year and kind of, go back, maybe stitch in some of our conversation from today and go back and see where we were right, where we were wrong and go through whole predictions episode next year. Always a great mentor in this space. OG crypto, I think when you look back at starting a, starting your own firm in 2015, focus strictly on crypto compliance. Your SEO was crazy back then because I put Bitcoin AML and you were the only company that showed up and that's how I got in touch with you.

I think you're, I think you've run into a lot more competition, not just. Crypto companies trying to get licenses. You've run into a lot more competition yourself over the last 10 years as well.

Joe: Yeah, no, thank you, Stephen. It's been an amazing ride. We continue to pay it forward by sharing and putting as much information as we can out there for folks. And you're kind enough to talk about our our newsletter and our web presence and and sharing stories. And I wish we had more time and more hours in the day to share everything that we could possibly think of under the sun that's out there.

But when we have have those moments of wanting to share and things that we have that we feel ought to be shared We'll put those out there. But in the meantime, we're working hard for our clients and our members and making sure we can get as many folks up to speed and where they need to be in compliance.

You mentioned competitors. We recognize there are competitors out there and, and part of me wants to say, I wish there were no competitors, but there's a rational compliance brain in me that says, I'm glad because that means that there are folks helping out, whether it's with us or another company, making sure you get compliant and stay compliant.

And that's going to be key for us going forward.

Stephen: Right. I always think what chain analysis is CEO at the time, Michael Groninger, you say that every company will become a blockchain company. And if that's true, you're not going to be able to handle the compliance for all of them anyway. So the more competitors in this space means it's growing. Joe Ciccolo, thank you so much for joining us today.

Joe: Thank you, Stephen. My pleasure.