Counsel Philip Moustakis was appointed head of the Virtual Commodity Association’s enforcement committee.

July 11, 2019

The Virtual Commodity Association Establishes Six Committees to Recommend Standards for Cryptocurrency Exchanges and Custodians

VCA Working Towards SRO Designation to Help Protect America’s Crypto Investors

New York – July 11, 2019 – The Virtual Commodity Association (VCA), a non-profit organization of cryptocurrency exchanges and custodians working to establish a self-regulatory organization (SRO) designation for U.S. cryptocurrency marketplaces, today announced the launch of six
committees, two special advisors, and leadership appointments to help set standards, sound practices, and oversight to self-regulate cryptocurrency marketplaces.

The VCA is currently comprised of cryptocurrency exchanges bitFlyer, Bittrex, Bitstamp and Gemini. The group’s goal of receiving SRO designation will be to formalize its broader mission to help protect America’s cryptocurrency investors.

The VCA has established six committees to address industry challenges identified by the regulatory community: Bank Secrecy Act (BSA)/Anti-Money Laundering (AML) , Custody and Security, Enforcement, Insurance, Market Integrity, and Tax. Each committee will be led by an
expert from its respective industry and establish frameworks for best practices.

“By establishing these committees, the VCA is highlighting key issues facing cryptocurrency exchanges and charting a way forward,” said Maria Filipakis, Interim Executive Director of the VCA. “ I am profoundly grateful to the experts who have come together to lead this initiative.”
The VCA has also appointed Yusuf Hussain, Head of Risk at Gemini Trust Company, LLC, as Board of Directors’ President and Hailey Lennon, Esq., Head of Legal and Regulatory Affairs at bitFlyer USA, Inc. as Board of Directors’ Secretary.

“Several regulatory agencies have called upon our industry to provide better oversight and surveillance of cryptocurrency markets. Today the VCA has stood up six committees — including one dedicated to market integrity — that will address these concerns, while beginning to create a regulatory framework for virtual commodity marketplaces. These committees will adopt best practices and standards commonplace in traditional financial markets,” said Yusuf Hussain, President of the VCA.

Special Advisors — Ellen Zimiles and Alma Angotti (Navigant Consulting, Inc.) and Dana Syracuse (Perkins Coie, LLP) — will work with and advise all committees.

The six committees and leads include:

BSA/AML — led by Michael Carter (Alvarez & Marsal) to apply Bank Secrecy Act BSA/AML and Know Your Customer (KYC) controls, including blockchain analytics, transaction monitoring and investigations.

Custody and Security — co-led by Adam Cohen (Redgrave LLP) and Nicole Becher with a focus on implementing and maintaining current best practices for cryptocurrency custody, which is based heavily on cryptographic principles.

Enforcement — led by Philip Moustakis (Seward & Kissel, LLP) to enforce the regulatory framework established by the VCA, keeping the VCA members accountable. This includes maintaining a system of marketplace conduct rules, implementing policies and procedures, and
responding to and addressing customer concerns and complaints.

Insurance — co-led by Matthew Gaul (Mayer Brown, LLP) and Alexander Sand (Eversheds Sutherland US, LLP) to establish minimum, appropriate insurances and coverages for cryptocurrency exchanges and custodians.

Market Integrity — led by Michael Roe (Exiger), to facilitate cross-market information sharing, consolidated audit trails and cross-market surveillance to detect and deter manipulative and fraudulent activity.

Tax — leader announcement forthcoming, will focus on establishing tax framework and interpreting and establishing tax code law as it relates to cryptocurrency trading.

“The VCA is grateful to the individuals and companies willing to commit their time towards these committees to help advance the goals of the VCA in fostering consumer protection and market integrity for the virtual currency industry,” said Hailey Lennon, Secretary of the VCA.



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