Imagine the following scenario: Sometime in 2021, financial regulators declare that all stablecoin owners must be verified. What would happen to the cryptocurrency ecosystem?
Right now, a large chunk of stablecoin usage is pseudonymous. That is, you or I can hold $20,000 worth of tether or USD coin stablecoins in an unhosted wallet (i.e., not on an exchange) without having to provide our identities to either Tether or Circle, the managers of these stablecoin platforms. We can send this $20,000 along to other users, who can transfer the coins on, who in turn can transfer them on, and no one along this chain needs to unveil themselves.
The only point at which stablecoin users have to submit to a Tether or Circle know-your-customer (KYC) process is to redeem stablecoins directly for traditional bank dollars. Or vice versa, to deposit dollars with Tether or Circle and get freshly minted stablecoins.
In a world where traditional non-blockchain based financial institutions like PayPal, Chase, and Zelle link all payments to names and addresses, stablecoin networks have become a rare moat of digital payments privacy. This has led to some fairly exotic uses for stablecoins.
In Moscow, Chinese gray market clothes vendors trade cash for tether to repatriate profits, writes CoinDesk’s Anna Baydakova. Ukrainian companies that import from Turkey use tether to skirt foreign exchange controls, and a multi-million Ponzi scheme relied on Paxos standard (PAX) for payments. Meanwhile, in the world of decentralized finance (DeFi), unidentifiable computer programs are conducting billions of dollars in unregulated financial transactions using USD coin and other stablecoins.
But will regulators allow this privacy moat to continue to exist? What if, at this very moment, officials working for the Financial Crimes Enforcement Network (FinCEN), the U.S. Treasury’s money laundering watchdog, are plotting how to rein in stablecoin pseudonymity?
See also: What Are Stablecoins?
Let me speculate about how a potential unveiling might look.
FinCEN could rule that henceforth, if anyone wants to access tether, USD coin, or any other official stablecoin (TrueUSD, Paxos standard, Gemini dollar, Binance USD, HUSD) they will need to apply for a verified stablecoin account. That would mean providing photo ID, proof of address and other information to Tether, Circle or other issuers.
For many existing stablecoin owners, this won’t be a big deal. Professional arbitrageurs who use stablecoins to move value from one centralized exchange to another are probably already KYC’d. And retail clients who keep their stablecoins on an exchange like Binance wouldn’t see any changes because the exchange already verifies their identities anyways.
But given that every transfer would need to have names and addresses associated with it, an unveiling would certainly weigh on gray market uses such as the Chinese traders in Moscow.
The issuers themselves would be inconvenienced, too. Building infrastructure to collect and verify the identity of all users, and not just the few who redeem or deposit, is expensive. To recoup their costs, issuers like Tether and Circle may consider introducing fees. All of this could render stablecoins less accessible for people who only want to use them for casual remittances.
It is in the world of DeFi that the fallout of a stablecoin unveiling could be felt the most. Real people who own stablecoins can be easily identified. But in DeFi, stablecoins are often deposited into accounts controlled by bits of autonomous code, or smart contracts, which don’t have any underlying owner. It’s not evident how a stablecoin issuer can conduct KYC on a smart contract.
Maker, one of the most popular decentralized tools, contains $350 million USD coins in various user-created vaults. This hoard of stablecoins serves as collateral backing for dai, Maker’s decentralized stablecoin. Another $130 million USD coin is held in a Maker’s peg stability module smart contract. If all stablecoin owners must be identified, it’s not apparent who or what entity would have to undergo a KYC check for this $130 million.
Compound, another popular DeFi tool, currently holds $1.6 billion USD coin and $350 million tether. Lenders can deposit their stablecoins into Compound smart contracts and collect interest from borrowers who draw from the contracts.
Liquidity pools, smart contracts underpinning decentralized exchanges like Uniswap and Curve, also hold large amounts of stablecoins. Curve liquidity pools currently contain $1.25 billion worth USD coin and $450 million worth of tether.
See also: JP Koning – What Tether Means When It Says It’s ‘Regulated’
Under the strictest scenario, stablecoin issuers could be required to cut off any entity that can’t provide a verified name or address. Which means Curve, Maker, and Compound smart contracts would all be prevented from receiving stablecoins.
Given the ecosystem’s reliance on stablecoins, this would come close to breaking it. Compound, Curve and Uniswap might try to adapt by substituting FinCEN compliant stablecoins like USD coin with decentralized ones, say like Maker’s dai stablecoin. Because decentralized stablecoins don’t rely on traditional banks, they are less beholden to FinCEN dictat.
But remember, Maker relies on USD coin collateral to imbue dai with stability. If Maker, like Compound and Curve, can no longer hold USD coin, then dai itself would become less stable. And so the usability of Compound and other protocols relying on dai would suffer.
If we imagine a more dovish scenario, FinCEN might allow for a smart contract exemption. As long as stablecoins are held in a smart contract rather than an externally controlled account, then FinCEN would allow the stablecoin issuer to provide financial services to the smart contract. Much of DeFi could continue on as before.
This option provides a pretty big loophole for bad actors, though. The whole reason for requiring platforms to verify accounts is to prevent them moving illicit funds. If stablecoins held in smart contracts are exempt from KYC obligations, then enterprising individuals will move stablecoins to the smart contract layer and thus stimie FinCEN controls.
A middle-of-the-road scenario is that FinCEN exempts smart contracts from stablecoin KYC, but only if the smart contract itself verifies the identities of all addresses that interact with the contract. So Curve, in this case, would have to set up a customer due diligence program if it wanted to qualify to use stablecoins. Maker would have to vet all vault owners.
Under this scenario, we could imagine DeFi splitting into two. Purely decentralized protocols would avoid stablecoins altogether to avoid subjecting their users to KYC. Not-so-decentralized finance would start to verify users to maintain access to stablecoins.
There are many other potential scenarios. As you can see, this is a complex problem. If FinCEN is indeed exploring the question of stablecoin pseudonymity, I wouldn’t want to be the official tasked with trying to design an appropriate response. Too strict and DeFi may no longer function. Too light and DeFi will continue to pose a money laundering threat.
But the clock is ticking. The combination of tether, USD coin, Paxos standard, Binance USD, TrueUSD, dai, and HUSD now regularly surpasses bitcoin in terms of on-chain volume. In January 2021, these stablecoins processed $308 billion in transactions compared to bitcoin’s $297 billion. With stablecoins getting bigger by the day, regulators probably can’t ignore the issue of pseudonymity forever.