Defend PoW: Submission to ESMA
The Open Dialogue Foundation (ODF) welcomes the opportunity to participate in this consultation of the European Securities and Markets Authority (ESMA) concerning “Technical Standards specifying certain requirements of Markets in Crypto Assets Regulation (MiCA)”. We believe our comments will help to shape the upcoming regulation of the use of crypto-assets in line with fundamental rights, as well as the new AML/CFT Regulation of the EU, declarations of the Parliamentary Assembly of the Organization of the Security and Co-Operation in Europe, Parliamentary Assembly of the Council of Europe (PACE) members [1],[2],[3] regarding combating financial exclusion, supporting civil society and humanitarian efforts which have already been adopted. All of them have taken into account the positive role that PoW mechanisms (i.e., Bitcoin and stablecoins) can play in supporting socially useful goals. In August and December 2023, we submitted our comments under the Financial Action Task Force (FATF) Recommendations [4],[5] consultation process regarding the use of PoW crypto-assets and non-governmental organisations as well. We expect the legislative and regulatory bodies – at the international, European and national levels, in particular the FATF and the Organisation for Economic Co-operation and Development (OECD) – to take the above aspects into further consideration. ODF is a human rights and rule of law watchdog coordinating the efforts of the Building True Change coalition (BTC Coalition) composed of human rights defenders, political activists, Bitcoin entrepreneurs, and industry experts. The BTC Coalition aims to: (1) combat the abuse of Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) within the wider range of transnational repression mechanisms; (2) promote financial inclusion in non-democratic and developing countries; (3) promote Bitcoin and stablecoins as tools to support human rights efforts and provide humanitarian aid worldwide; and (4) educate on the role of Bitcoin mining as an instrument to facilitate the adoption of renewable energy sources.
This Submission has been prepared by Lyudmyla Kozlovska and Bota Jardemalie. The Testimonials included within it are attributed to the individuals as described therein.
