Core Principles – Global DCA

Core Principles

The Global Digital Asset & Cryptocurrency Association (Global DCA) is issuing the following Core Principles for the purpose of setting minimum standards and best practices for the conduct of centralized digital assets businesses that handle customer (or user) digital assets and funds.

This effort was initiated in response to the bankruptcies of several prominent businesses that caused substantial harm to a significant number of customers and investors. The collapses were due, at least in part, to failures to implement certain fundamental business conduct and governance, risk management, and customer protection processes and procedures, as well as failures to implement adequate disclosures regarding the handling of customer funds and assets and the core use and operation of specifically issued tokens, the presence of which could have avoided these catastrophic events or at the very least mitigated their impact.

These Core Principles are not intended for use by fully decentralized businesses. Rather, they are focused on digital asset businesses that serve as intermediaries or fiduciaries of customer assets and property, which may enable access to DeFi systems and products/services as well as more centrally-enabled financial services activities. The terms “intermediaries” or “fiduciaries” for these purposes do not include software developers, miners/validators, personal wallet software, bridging technologies without a single controller, or any other decentralized network, application or platform.

The Core Principles are not intended to replace any applicable regulation. Specific applicable regulation would take precedence over the relevant Core Principle.

The Global DCA would like to take a moment to thank the very hard work undertaken by the Core Principles Steering Committee which convened to develop the following Core Principles document:

  • J. Christopher Giancarlo, Senior Counsel and Co-head of the Digital Works Practice, Willkie Farr & Gallagher / Former Chairman of the U.S. Commodity Futures Trading Commission (CFTC)
  • Maggie Sklar, Partner, Davis Wright Tremaine / Former Senior Policy Advisor and the Director of International Engagement, Financial Markets Group, at the Federal Reserve Bank of Chicago / Former Senior Counsel at the Commodity Futures Trading Commission / Chairwoman of the Global DCA Public Policy & Regulatory Committee
  • Renata Szkoda, Chief Financial Officer, INX / Chairwoman Global DCA
  • Dawn Stump, Former Commissioner, U.S. Commodity Futures Trading Commission (CFTC)
  • Jamila Piracci, Founder, Roos Innovations / Former program lead overseeing the National Futures Association (NFA) regulatory program for swap dealers under the Dodd-Frank Act (2011 to 2019) / Former Attorney, Federal Reserve Bank of New York
  • Amit Sharma, Founder & CEO, FinClusive / Former Head of New Products and Chief of Staff to Global Markets, Mitsubishi UFJ Securities / Former Chief of Staff to the Deputy Secretary & Senior Advisor, Office of Terrorism & Financial Intelligence, U.S. Treasury
  • Kristy Littman, Partner and Co-head of the Digital Works Practice, Willkie Farr & Gallagher / Former Chief of Crypto Assets and Cyber Unit, U.S. Securities and Exchange Commission (SEC)
  • Patrick Daugherty, Partner, Foley & Lardner / Adjunct Professor of Crypto Assets and Web3, Cornell Law School
  • Suzanne Morsfield, Global Head of Accounting Policy, LUKKA / Chairwoman of the Global DCA Accounting & Taxation Working Group
  • Georgia Quinn, General Counsel, Anchorage Digital
  • Jason Allegrante, Chief Legal & Compliance Officer, Fireblocks
  • Daniel Davis, Financial Markets and Regulation Partner, Katten / Former General Counsel, U.S. Commodity Futures Trading Commission (CFTC)
  • Jeff Horowitz, Chief Compliance Officer, BitGo
  • Lee Schneider, General Counsel, Ava Labs
  • Matthew Lisle, Chairman Standards Committee, Global DCA
  • Adam Schneider, Global DCA Advisory Board; Investor / Director for FinTech, RegTech, and Crypto Startups; Former Partner Oliver Wyman; Former Partner Deloitte Consulting; Member, Bretton Woods Committee
  • Gabriella Kusz, CEO, Global DCA / Emerging Leader, Chicago Council on Global Affairs / Former Principal of Strategic Initiatives at the International Federation of Accountants
  • Antonio Flores, Manager of Operations, Evertas / Project Manager – Policy Fellow, Global DCA

Please read below for the full Preface and text of the Core Principles.

OR Click HERE for the PDF Version of the CPs.