Divij Pandya

Cheers to a decade of research, resilience, and a community committed to financial privacy. We’re honored to help carry that work forward. Here’s to the next decade of building and defending privacy. 🛡️🥂

Happy Friday! Here's this week's weekly policy memo. Pretty light week. Hi everyone, here’s this week’s update. Originally posted at pgpz.org/updates/2026-10-19-… This week’s policy memo covers PGPZ’s response to the SEC’s Regulation Crypto Assets. Key Takeaways PGPZ submitted SEC comments on October 20 addressing asset classification, financial privacy and continued development. Our recommendations would permit meaningful verification while limiting unnecessary disclosure of financial histories and sensitive keys. Action Items Help us increase outreach and engagement by reposting/sharing our SEC comment letter. The @ZcashFoundation announced on October 20 that its Board has appointed @alchemyDC David Campbell Executive Director, succeeding Alex Bornstein. Alex, who joined as COO in 2021 and became Executive Director in March 2025, will remain in a transition role through the end of January 2027. In his community post, he emphasized cooperation across the ecosystem and said he plans to work more closely with the Financial Privacy Foundation after taking time off. David brings security and operating experience, including four years as COO of Electric Coin Company and two years consulting with the Foundation. His stated priorities include keeping Zebra and Foundation infrastructure secure and reliable, and making privacy easier for ordinary people to use. The planned overlap provides continuity while he takes on the role. We thank Alex for his service to the Foundation and the wider ecosystem, and welcome David to his new role. X Post of the Week: xitter.gq/pgpzcash/status/211290… PGPZ Submits Comments on SEC Regulation Crypto Assets We submitted comments on the SEC’s proposed Regulation Crypto Assets. The proposal would create fundraising exemptions for certain investment contracts involving crypto assets and a conditional safe harbor under which an asset could be deemed no longer subject to an investment contract. Our response addresses questions focusing on the distinction between an asset and an investment contract, financial privacy and continued development. We ask the SEC to preserve the distinction between an asset and an investment contract involving it and expressly accommodate encrypted transactions and zero-knowledge proofs in its definitions. For issuers using the proposed exemptions, disclosure rules should permit accounting records, cryptographic proofs, and selective disclosure that substantiate material claims without exposing unrelated financial activity. The letter seeks consistent protections for unnecessary wallet identifiers and transaction histories, and clarification that verification does not require disclosure of viewing keys or spending keys, disabling shielded transfers, or routing funds through transparent addresses. We also ask the SEC to incorporate its continued-development explanation into Rule 400. Once the relevant conditions are met, maintaining, securing, improving or funding a functional network should not, by itself, prevent safe-harbor reliance. Unfinished essential promises and new promises would still matter. Filing should not imply an admission that an investment contract existed, that the asset was a security, or that the filer was its issuer; declining to file should create no adverse inference. These are recommendations for the final rule, and their adoption and timing remain uncertain. Why it matters for Zcash: The objective is to let eligible ecosystem businesses raise capital and provide investors with material information while preserving financial privacy. Our recommendations focus on reducing unnecessary exposure of balances, commercial relationships, and personal associations without concealing material holdings or conflicts. The letter also distinguishes transaction validity from evidence about use of investor funds (i.e., a cryptographic proof does not automatically establish every financial claim). Conventional records may still be needed, and requiring viewing key access should not be the default. Clarifying the treatment of continued development would give contributors greater certainty while preserving responsibility for actual promises to investors. Action Item: Help us increase outreach and engagement by reposting/sharing our SEC comment letter. Relevant Post: xitter.gq/pgpzcash/status/211290…

Happy Friday! Here's this week's PGPZ Weekly Policy Memo for the Week of October 12, 2026. Posted here first: community.pgpz.org/updates/2… Not a PGPZ member? Sign up and join the PGPZ Community: community.pgpz.org KEY TAKEAWAYS • BIS research supports designing privacy into digital payments, while identifying remaining security and implementation limits. • The House Financial Services Committee leadership contest kicks off as the 119th Congress enters its final weeks. • President’s Council of Advisors on Digital Assets Executive Director Patrick Witt’s departure creates uncertainty about who will shape the next phase of crypto policy. ACTION ITEMS No action items at this time. THIS WEEK IN WASHINGTON On October 14, PGPZ and @ProjectGlitch_ convened the inaugural Cypherpunk Policy Dinner in Washington, bringing privacy advocates together with the people building private financial tools. @zodl_co Chief Policy and Regulatory Officer and PGPZ Chairman @PaulBrigner opened with a call to defend privacy and the freedom to build and use those tools. The program featured remarks by former @SECgov Hester Peirce; SEC Counsel to the Chairman and Senior Advisor for the Crypto Task Force Landon Zinda (@landon); and ZODL CEO Josh Swihart (@jswihart), followed by a fireside conversation between Landon and Josh moderated by @DCGco Chief Policy Officer and PGPZ Board Member @Julie_Stitzel. The third annual DC Privacy Summit followed on October 15. Its program addressed financial privacy, digital identity, AI, and cryptography, including how to limit unnecessary data exposure as digital systems become more capable. Together, the events provided a forum for connecting the technical design of privacy tools with the policy choices that govern their use. X POST OF THE WEEK xitter.gq/pgpzcash/status/211079… BIS RESEARCH DEMONSTRATES PRIVACY BY DESIGN IN DIGITAL CASH The Bank for International Settlements published its second-phase Project Aurum report, examining a digital cash prototype that combines zero-knowledge proofs and other privacy-preserving technologies with regulated bank onboarding and defined compliance functions. The project tests whether payment validity can be verified while limiting disclosure of identity and transaction information. BIS presents it as an experimental design, with further work needed before production deployment. Note that it does not announce a CBDC launch or impose regulatory requirements. The Bank found that separating data among participants can reduce the consequences of a compromise, but a breach at a customer’s bank can still expose that bank’s customer information. The technical protections also depend on assumptions about the components being compromised. Why it matters for Zcash: The research gives Zcash stakeholders a concrete institutional reference for explaining that verification need not require routine disclosure of everyone’s payment history. It supports discussion of zero-knowledge proofs, selective disclosure, and the cybersecurity value of data minimization. Action item: No action item at this time. Read the report: bis.org/publications/project… Relevant post: xitter.gq/BIS_org/status/2110308… DEMOCRATS FACE A CONTEST FOR FINANCIAL SERVICES COMMITTEE LEADERSHIP Rep. Sean Casten’s (D-IL) effort to replace Rep. Maxine Waters (D-CA) as the top Democrat on the House Financial Services Committee is developing into a contested succession debate. Reporting on the race describes a dispute over seniority, experience and generational change. Semafor reported that Democratic leadership was taking a hands-off approach and that Rep. Bill Foster (D-IL) was also considering a bid. The outcome remains unsettled; committee leadership would be determined through the Democratic caucus process after the elections. The result could affect the committee’s legislative agenda, oversight, and negotiating priorities in the next Congress. If Democrats win the House, their selected leader could chair the panel; otherwise, the position would remain the leading Democratic voice on the committee. This is a prospective leadership contest and does not itself change current law or demonstrate new agreement on digital asset legislation. Why it matters for Zcash: Rep. Casten has been a prominent critic of illicit finance risks in digital assets. His record includes the 2024 Blockchain Integrity Act proposal restricting financial institutions’ dealings with funds routed through mixers and the 2025 CODE Act proposal for developing AML, sanctions, and identity controls for DeFi. Note that both Rep. Waters and Casten have jointly challenged SEC crypto-enforcement rollbacks, so a personnel change would not necessarily represent a broad reversal of the committee Democrats’ approach. Action item: No action item at this time. Read more: politico.com/newsletters/mor… Relevant post: xitter.gq/BrendanPedersen/status… WHITE HOUSE CRYPTO POLICY VACANCY ADDS COORDINATION UNCERTAINTY Patrick Witt confirmed his departure as Executive Director of the White House President’s Council of Advisors on Digital Assets, without leaving a publicly named successor for the administration’s dedicated digital assets policy office. A White House official told the publication that digital assets and the CLARITY Act remain presidential priorities. Existing SEC, CFTC, and Treasury work continues under those agencies’ respective authorities. The immediate implication is uncertainty about responsibility for interagency coordination and congressional negotiations. A vacancy may complicate efforts to broker remaining compromises during the post-election legislative period, although it does not establish that the administration has abandoned market structure legislation. Passage still depends on congressional agreement, and agency initiatives continue to face their own statutory and procedural limits. Why it matters for Zcash: Continuity of technical and policy engagement matters as personnel change. Financial privacy, data minimization, and protections for noncustodial developers may receive limited attention if discussion concentrates on exchange access, capital formation, and stablecoins. The vacancy creates no immediate change to ZEC’s legal treatment or to the obligations of users and developers. Its practical significance will depend on whether a successor is appointed, the authority assigned to that role, and the priorities of any renewed legislative negotiations. Action item: No action item at this time. Read more: coindesk.com/news-analysis/2… Relevant post: xitter.gq/DCGco/status/211073328…

“You shouldn’t have to give up your privacy to participate in the digital economy.” Last night, government and cypherpunks came together in DC for the first Cypherpunk Policy Dinner. Paul Brigner @paulbrigner opened the evening with a call to stand with the people building privacy tools and defend everyone’s freedom to use them. Watch his opening remarks below.

Happy Friday! Here's this week's weekly policy memo, originally posted at community.pgpz.org/updates/2…. Key Takeaways: · The CFTC opened an early-stage consultation on regulations for retail crypto markets, but agency action leaves important statutory questions unresolved. · FinCEN withdrew its mixing and unhosted wallet proposals. The withdrawals recognize legitimate privacy interests; the Tornado Cash prosecution continues. · Fairshake PAC named 32 House incumbents for support. Action Item: · Comments on the CFTC ANPRM are due 60 days after publication in the Federal Register. Please reach out if you have any feedback. X Post of the Week: from @ZakuraZcash: xitter.gq/ZakuraZcash/status/210… CFTC Opens Retail Crypto Consultation as Congress Weighs the Limits of Agency Action The Commodity Futures Trading Commission (CFTC) issued an advance notice of proposed rulemaking (ANPRM) seeking input on Regulation Crypto Asset Transactions (Reg CTX) and Regulation Crypto Asset Markets (Reg CAM). The framework would use the Commodity Exchange Act’s existing authority over retail commodity transactions offered on a leveraged, margined or financed basis to implement the regulation. It would clarify covered transactions and develop a tailored category of designated contract market registration for digital asset trading. The initiative advances Chairman Michael Selig’s effort to establish a federal route for covered trading under existing law. It also illustrates the limits identified by House Financial Services Committee Chairman French Hill, who recently argued that SEC and CFTC action cannot provide the durability of the CLARITY Act. The CFTC cannot use this process to require registration of every spot digital assets platform. Accordingly, this provides incremental clarification, but it does not resolve comprehensive spot-market jurisdiction or establish a congressional agreement on market structure. Why it matters for Zcash: For exchanges and intermediaries supporting ZEC, the eventual framework could affect market access, custody and transaction delivery. The consultation is also an opportunity to explain how customers obtain control of shielded assets and how regulated intermediaries can verify relevant information without requiring universal public transaction histories. These are policy questions for future rules as opposed to requirements impacting Zcash users today. Action Item: Comments are due 60 days after publication in the Federal Register. Please reach out if you have any feedback. Relevant Post: from @crypto_council: xitter.gq/crypto_council/status/… FinCEN Withdraws Crypto Reporting Proposals While Tornado Cash Litigation Continues The Financial Crimes Enforcement Network (FinCEN) announced withdrawal of two proposed reporting regimes: its 2023 proposal concerning international convertible virtual currency mixing and its 2020 proposal concerning certain transactions with unhosted or otherwise covered wallets. The notice withdraws both the proposed special measure and the underlying finding that the identified class of transactions was of primary money-laundering concern. FinCEN acknowledged that its broad approach could burden financial institutions and discourage legitimate activity, including lawful uses of financial privacy. Note that while these proposals have been withdrawn, they still enable Treasury to consider future measures under its existing authority. Separately, federal prosecutors are continuing to litigate the Tornado Cash case. In an October 5 filing, they cited the appellate decision in the separate Bitcoin Fog case, United States v. Sterlingov, to support their venue arguments concerning Roman Storm. Why it matters for Zcash: The withdrawal is particularly relevant to Zcash because the abandoned definition of mixing reached a broad set of transaction techniques, rather than only a named service. FinCEN’s recognition of legitimate privacy interests provides useful support for shielded transactions, self-custody and data minimization. However, it does not establish a general exemption for privacy software or resolve developer liability, such as the Tornado Cash case. Action Item: No suggested action item at this time. Relevant Post: from @coincenter: xitter.gq/coincenter/status/2107… Fairshake Names 32 House Incumbents for Election Spending Fairshake PAC announced support for 32 House incumbents, 13 Democrats and 19 Republicans, and plans for substantial independent spending. CoinDesk reports $1 million commitments for each of six lawmakers: Republicans French Hill (R-AR), Bill Huizenga (R-MI), and Bryan Steil (R-WI), and Democrats Steven Horsford (D-NV), Derek Tran (D-CA), and Janelle Bynum (D-OR). The roster includes lawmakers positioned to influence financial-services, tax and agricultural-market legislation. The effort could affect the next Congress’s composition, but election spending does not secure passage of pending legislation or resolve the Senate’s current disagreements. Its policy significance will depend on election results, committee assignments and lawmakers’ substantive positions. Why it matters for Zcash: Support for digital asset legislation does not necessarily establish support for shielded transactions or developer protections, however it creates an environment where lawmakers may be more receptive to learning about these issue areas within broader crypto-related policymaking. Action Item: No suggested action item at this time. Relevant Post: from @PatrickSvitek: xitter.gq/PatrickSvitek/status/2…

Across the United States, policymakers are reconsidering how large data centers should interact with the electric grid. Recent policy developments in Texas exemplify that broader trend. But not all large loads operate the same way. A one-size-fits-all approach that treats flexible proof-of-work mining like an always-on enterprise data center risks penalizing facilities that can rapidly reduce consumption when the Texas grid is under strain. Read our statement on why @PUCTX should adopt a performance-based framework for large loads: community.pgpz.org/resources…