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regulating zero-knowledge finance in the EU and beyond

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regulating zero-knowledge finance in the EU and beyond

Financial compliance has always been balanced on a delicate line: regulators need sufficient visibility to keep bad actors out, but users want their financial lives kept private just to make a payment or trade. In 2025, that tension is sharper than ever. We have stricter anti-money laundering (AML) rules, broader data-protection regimes, more cross-border activity and, at the same time, better privacy-enhanced technology than we’ve ever had.

The good news is we no longer have to sacrifice privacy to ensure compliance. Zero-knowledge proofs (ZKPs) provide a solution to the so-called privacy paradox: regulators need assurance that rules are followed, but exposing full identities and transaction details creates security, legal, and data protection risks. ZKPs let us flip the model from “show me the data” to “show me a proof,” enabling firms to demonstrate compliance without revealing underlying information.

This approach is not designed to obscure regulatory oversight. Instead, it modernizes the compliance toolset so regulated firms can demonstrate compliance with their legal duties (sanctions screening checks, KYC obligations, segregation of client assets, capital checks) without transferring or exposing the underlying data. ZKPs may be better for users and, in the long term, for regulatory compliance, because proofs are verifiable and tamper-evident.

What zero knowledge actually does

A zero-knowledge proof is a cryptographically powered way of saying: “I can prove to you that I followed rule X, but I won’t show you the sensitive information usually required to prove that.” In finance, “rule X” can be very concrete: “this wallet was screened against the current sanctions list”; “this user holds a valid KYC credential from a trusted issuer”; “this exchange holds client assets 1:1 and they reconcile to liabilities”; “this transaction is below (or within) an allowed range,” and so on.

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Today, we can be required by law to report large datasets to specific regulators. We comply with applicable data protection laws, but this also increases the risk of cybersecurity breaches and misuse. A ZK-based approach proves the outcome, not all the inputs. If a regulator needs to go deeper, a process can be designed for selective disclosure of particular required data (viewing keys, time-bound access, and full audit logs, granted under due process as necessary), like a permissioned regulatory portal or window.

Why this matters now

Three trends are converging.

In the EU, supervisors are making anti-money laundering (AML) controls more granular, while GDPR and other privacy regimes emphasise data minimisation and purpose limitation. These can be complementary rather than opposing each other: compliance should provide the same or better assurance with less routine exposure of personal data. This objective may be achieved by utilising privacy-preserving reporting techniques.

Second, digital identity frameworks (such as those envisaged under eIDAS 2.0) are getting closer to reality. They are built on the same building blocks as ZK: verifiable credentials, selective disclosure and cryptographic attestations. That makes it far more realistic to issue portable “I passed KYC” or “I am not sanctioned” credentials that can be proven, not re-collected, across multiple services.

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Third, supervisors are exploring privacy-enhancing technologies, including proof verification models.

What a proof-based compliance stack could look like

We already have live examples. ZK-enhanced proof-of-reserves is the best-known one: an exchange proves it has the assets to meet customer liabilities without revealing individual balances. That is a zero-knowledge assurance.

You can do the same for sanctions screening. Instead of sending the full identity every time, a wallet presents a proof that it was checked against the latest list at a specific time. The regulator, or a regulated VASP on the other side, runs a verifier node to confirm the proof is valid and up to date. It is important to note that ‘verifier nodes’ are a policy proposal that operate as an oversight infrastructure for supervisors to validate proofs without collecting bulk data.

You can also do it for segregation: a custodian proves that client assets are not co-mingled with house funds via a range or sum proof, without publishing the entire ledger. You can even layer this into smart contracts: transactions don’t execute unless the proof passes. That is “programmable compliance” – rules enforced at transaction time in ‘real time’, rather than afterwards.

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For regulators, the key shift is from collecting raw data to verifying cryptographic evidence. They still get assurance, auditability and traceability when there is a legal basis to unmask. But they do not have to hold or process significant amounts of personal data by default, reducing both operational and legal risk.

Answering key questions

Regulators are already beginning to embrace targeted ZK pilots, ranging from verifiable proof-of-reserves to Travel Rule compliance that validates user attributes without exposing full datasets. As these primitives mature, they naturally scale into market-integrity controls, allowing firms to demonstrate they are within concentration and exposure limits through range and sum proofs without revealing underlying positions.

Critically, ZK is not a synonym for opacity; well-architected systems utilize selective disclosure via viewing or multi-party keys. This ensures that law enforcement access is narrow, provable and subject to due process rather than remaining universal and silent.

What regulators could require

To work across borders, we need standards: standard proof types (e.g., “not on sanctions list X as of date Y”), standard credential formats and standard verifier logic that can be inspected. That is how you avoid every exchange, wallet, or bank building its own version and creating unnecessary supervisory complexity for supervisors.

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Concretely, regulators may benefit from six things:

  1. Outcomes over data (tell me what you proved, not everything you hold);
  2. Least-information proofs (prove only what is necessary for this obligation);
  3. Programmable checks (enforced at transaction time where appropriate);
  4. Strong data-availability and exit mechanisms (users can always confirm their balances and withdraw);
  5. Verifiable verifier logic (inspections, test vectors, audit logs);
  6. No generalized backdoors (disclosure only under lawful, narrow, logged processes).

Binance is a global exchange that already uses ZKPs for demonstrating reserves. Our proof-of-reserves (POR) system uses a Merkle tree – a cryptographic structure that condenses many account entries into a single “fingerprint” – together with zero-knowledge proofs to demonstrate that customer assets are fully backed without revealing individual balances. With each POR update, users can confirm that their balance is included in the tree, while ZKPs ensure that the overall totals are correct and that no negative or fake balances are included. The result is independent, privacy-preserving verification of reserves that builds trust without compromising personal data.

But this is bigger than one company. If we get this right, we can make financial compliance more precise, more respectful of privacy law, and easier to supervise.

This will take collaboration. Regulators will need to develop proof standards they accept; industry will need to align on, and incorporate the proof standards, and standard-setting bodies will ensure proof standards are interoperable across borders.

What success looks like

Success is when a user can prove legitimacy without oversharing; a bank, VASP, or exchange can meet AML/Travel Rule obligations with smaller data disclosures; a regulator can run a verifier node and get real-time assurance; and bad actors can be unmasked under clear, narrow, lawful conditions.

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In short, assurance with less disclosure. As cyber risk rises, privacy laws evolve, and cross-border digital finance grows, moving from routine bulk data collection to verifiable proofs is a pragmatic upgrade to supervisory practice.

References to EU privacy law in this op-ed reflect the framework as of November 2025; the Commission’s Digital Omnibus proposals remain subject to change through the ordinary legislative process.

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Bhutan Shifts 519.707 BTC Worth $36.8M to External Addresses as Holdings Drop 66% from Peak

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Crypto Breaking News

Key Takeaways

  • Bhutan’s state-owned investment arm, Druk Holding and Investments, transferred 519.707 BTC worth approximately $36.75 million to external addresses.
  • Total 2026 outflows from Bhutan’s Bitcoin treasury have now exceeded $152 million, with holdings falling from nearly 13,000 BTC in late 2024 to approximately 4,453 BTC, a 66% reduction.
  • Bhutan’s earlier pledge to allocate up to 10,000 BTC toward the Gelephu Mindfulness City project now faces significant headwinds.

The Royal Government of Bhutan moved another batch of Bitcoin from its sovereign treasury, transferring 519.707 BTC worth approximately $36.75 million to external wallets on Wednesday. The transaction spotted by Arkham Intelligence marks Bhutan’s third major Bitcoin movement in March alone and continues a pattern of steady, institutional-grade liquidations that has defined the kingdom’s crypto strategy in 2026.

A Quietly Depleting Holdings

The kingdom’s holdings have fallen roughly 66% from a late-2024 peak of about 13,000 BTC to 4,453 BTC, as larger March transactions replace the smaller $5 million to $15 million clips seen in January and February. Repeated transfers to Singapore-based QCP Capital suggest a structured over-the-counter selling arrangement.

The March activity has been the most intense yet. The latest 519.707 BTC transfer marks the wallet’s third large Bitcoin transaction in March, following $72 million moved in six separate transactions in the 24 hours leading up to March 18, and $11.8 million moved on March 9.

How Bhutan Built Its Treasury

Bhutan accumulated its cryptocurrency portfolio through government-operated hydroelectric mining facilities. Utilizing excess energy from hydropower plants meant mining costs were essentially negligible. Each Bitcoin sold represents nearly pure revenue for the state. The nation’s Bitcoin treasury reached its peak at approximately 13,000 BTC during late 2024.

As of March 12, Bhutan was the fifth-largest country by Bitcoin holdings, behind the US government, the United Kingdom’s government, El Salvador, and the United Arab Emirates Royal Group.

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The Gelephu Pledge Under Pressure

In December 2025, Bhutan unveiled a Bitcoin Development Pledge, committing up to 10,000 BTC to fund the Gelephu Mindfulness City, an ambitious special administrative region project. On January 8, 2026, the project announced plans to establish a strategic cryptocurrency reserve including Bitcoin, Ether, and BNB, signalling a diversified approach to digital assets within Bhutan’s long-term economic planning. With current holdings sitting well below 5,000 BTC, that original commitment faces significant headwinds.

Druk Holding and Investments has not issued a public statement about the transfers. That silence is consistent with how the kingdom has handled its entire Bitcoin program. With Bitcoin navigating geopolitical-driven volatility this week and a $3 billion long liquidation risk still active below $65,000, Bhutan’s steady offloading adds another layer of sell-side pressure that the market is quietly absorbing.

Risk & affiliate notice: Crypto assets are volatile and capital is at risk. This article may contain affiliate links. Read full disclosure

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BTC slips below $69,000 as oil rebounds on fading Middle East peace hopes

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BTC slips below $69,000 as oil rebounds on fading Middle East peace hopes

Bitcoin slipped below $69,000 on Thursday as a broader pullback in risk assets gathered pace, with early optimism around Iran-U.S. peace and easing Middle East tensions fading.

The largest crypto lost more than 3% from its overnight high above $71,000, while major altcoins ether (ETH), XRP (XRP), Solana’s SOL (SOL) and Cardano’s ADA (ADA) plunged 4%-5% during the same period.

Oil prices remain the barometer for the broader market. Crude oil futures rose about 4%, reversing earlier declines and reinforcing concerns about inflation and supply disruptions tied to the Iran conflict.

U.S. stocks were at session lows just after noon on the East Coast, led by the Nasdaq’s 1.4% decline. Bond yields were sharply higher: the U.S. 10-year Treasury up 7 basis points to 4.40%, and the 10-year German Bund up 10.5 basis points to 3.06%.

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Notably, all Magnificent Seven stocks are now all off double digit percentages from their all-time highs, with NVIDIA (NVDA) down 18%, Meta (META) 30%, Amazon (AMZN) 20%, Alphabet (GOOG) 19%, Microsoft (MSFT) 34%, Tesla (TSLA) 25% and Apple (APPL) down 14%.

“Looking ahead, the near-term trajectory will likely remain tied to macro developments,” said Joel Kruger, market strategist at LMAX Group.

A clearer path toward de-escalation could push risk assets, including bitcoin, higher, he said, while continued uncertainty may leave them stuck in a choppy range.

Crypto-related stocks were posting major losses as well: Coinbase (COIN), Circle (CRCL) and Strategy (MSTR) were down 3%-4%.

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The sharpest losses came from bitcoin miners, nearly all of which are either in transition or have fully transitioned to being AI infrastructure plays and thus tied more to tech in general rather than crypto prices. Hut 8 (HUT) dropped 8.6%, while IREN (IREN) and Riot Platforms (RIOT) fell more than 7%. TeraWulf (WULF) and HIVE Digital (HIVE) also posted steep declines.

WhiteFiber (WYFI) shares fell 14% after its fourth quarter results showed worsening fundamentals, with a net loss widening to $1.5 million and a full-year loss of $24.7 million. The parent company of WhiteFiber, Bit Digital (BTBT), saw its shares down around 8%.

A few names bucked the trend, though. MARA Holdings (MARA) was up 8.7% after reporting the sale of $1.1 billion in bitcoin to pay down debt.

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Bitcoin (BTC) holds ground as precious metals slide on ETF outflows and liquidity strains, JPMorgan says

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What next for bitcoin as BTC nears $68,000 on fresh US-Iran tensions

Bitcoin is proving more resilient than traditional safe-haven assets as gold and silver come under pressure from outflows, positioning unwinds and deteriorating liquidity, according to Wall Street investment bank JPMorgan.

“The deterioration in liquidity conditions in gold has seen its market breadth
decline below that of bitcoin currently,” analysts led by Nikolaos Panigirtzoglou, wrote in the Wednesday report.

Bitcoin has shown relative resilience in recent weeks following the outbreak of war in Iran, even after a steep correction from its October all-time highs.

The cryptocurrency initially dropped sharply alongside broader risk assets, briefly falling into the low-$60,000 range and triggering large liquidations as investors rushed to de-risk amid geopolitical uncertainty.

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But the sell-off proved short-lived. Prices have since stabilized in the high-$60,000 to low-$70,000 range, even as tensions persist and oil prices surge above $100 a barrel.

The price action suggests bitcoin is behaving less like a pure safe haven in the immediate shock phase and more like a high-beta macro asset, selling off initially, then finding support as flows return and longer-term holders step in once panic subsides.

Gold has fallen roughly 15% month to date, reversing a crowded rally that pushed prices to record highs near $5,500 in January. Silver, which peaked near $120, has followed a similar path lower. JPMorgan analysts attributed the sell-off to rising interest rates, a stronger U.S. dollar and broad profit-taking by both retail and institutional investors.

Flows data reinforce the shift. Gold ETFs saw nearly $11 billion in outflows in the first three weeks of March, while silver ETF inflows built since last summer have been unwound, the report said. In contrast, bitcoin funds have continued to attract net inflows over the same period.

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Positioning data tells a similar story. JPMorgan’s proxy for institutional activity, based on Chicago Mercantile Exchange (CME) futures open interest, shows a sharp buildup in gold and silver exposure through late 2025 into early 2026, followed by a steep decline since January as investors cut positions. Bitcoin futures positioning, by comparison, has remained relatively stable in recent weeks.

Momentum signals also diverge. The bank noted that trend-following investors, such as Commodity Trading Advisors (CTAs), have aggressively reduced exposure to gold and silver, with indicators swinging from overbought to below-neutral levels. That positioning shift has likely amplified recent price declines. Bitcoin momentum, meanwhile, is recovering from oversold conditions toward neutral, suggesting selling pressure may be easing.

Liquidity conditions further highlight the divergence. Gold’s market breadth has deteriorated to the point where it now trails bitcoin, a reversal of the typical relationship. Silver’s liquidity has weakened further, with thinner market depth exacerbating recent price moves, the report added.

The world’s largest cryptocurrency was trading around $69,000 at the time of publication. Gold was trading around $4,450/oz, and silver $69/oz.

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Read more: Wall Street broker Bernstein calls bitcoin bottom, keeps $150,000 year-end target

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Coinbase Launches Crypto Mortgage Product Tied to Fannie Mae

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Coinbase Launches Crypto Mortgage Product Tied to Fannie Mae

Crypto exchange Coinbase Global has launched a mortgage structure with Better Home & Finance that lets qualified borrowers pledge digital assets held in Coinbase accounts to fund down payments on standard conforming mortgages designed in accordance with Fannie Mae guidelines.

According to Coinbase, the structure enables borrowers to pledge digital assets such as Bitcoin (BTC) or USDC (USDC) as collateral for a separate loan used to fund the down payment, while the primary mortgage remains a standard, Fannie Mae–backed loan. Better will originate and service the mortgages.

When rolled out, the new development could mark a shift in how crypto assets are used in US housing finance, extending their role from qualifying assets in underwriting to a more direct component of mortgage financing.

The news follows earlier regulatory signals to integrate crypto into mortgage frameworks. In June, the US Federal Housing Finance Agency directed Fannie Mae and Freddie Mac to prepare proposals to recognize cryptocurrency as an asset in mortgage risk assessments without requiring conversion to US dollars.

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It also builds on a series of developments integrating crypto into home lending, with lenders like Newrez and Rate recently recognizing crypto holdings in underwriting, signaling a broader push to embed crypto across the mortgage stack.

Cointelegraph reached out to Fannie Mae for more information but did not receive a response before publication.

Pledging crypto for down payments comes with added risks

According to Coinbase, borrowers would take out a standard conforming mortgage while using a separate loan secured by crypto holdings to cover the down payment.

The setup allows buyers to retain exposure to digital assets, but replaces upfront cash with additional debt. 

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Related: Crypto mortgages in US face valuation risks, regulatory uncertainty

Coinbase said the model introduces constraints tied to pledged assets, with borrowers unable to trade collateral while it is locked.

The company said market volatility alone does not trigger margin calls as long as borrowers continue making payments, and mortgage terms remain unchanged once the loan is active.

The model also introduces new risks tied to the pledged assets. While price swings do not directly affect the mortgage, they may still influence borrower risk exposure and financial decisions over time.

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Lenders have been gradually integrating crypto into mortgage underwriting

The new development follows several US lenders that recently incorporated crypto assets into mortgage processes. 

On Jan. 17, loan servicer Newrez said it would allow borrowers to use BTC, Ether (ETH), crypto ETFs and stablecoins as qualifying assets in underwriting, without requiring liquidation. 

On Feb. 23, mortgage lender Rate launched its RateFi program, which allows verified crypto holdings to count toward reserves and, in some cases, income. However, borrowers are still required to convert their crypto into cash for down payments and closing costs. 

Ex-Congressman Ryan frames crypto as a housing tool

Ahead of the rollout, Cointelegraph’s Turner Wright spoke with former Ohio Representative Tim Ryan, a member of Coinbase’s advisory council who has focused on middle-class affordability, including housing.

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Ryan cast mortgage financing as a practical, real-world use case for crypto, arguing that digital assets can unlock wealth for early investors and help address one of the biggest barriers to homeownership — the down payment.

“Digital assets have a place for working-class people… all the way down to getting a home,” Ryan said. “To see the industry move into… the housing sector… is a really huge deal.”

Affordability remains a major challenge for US homebuyers. Despite slower activity tied to low inventory and elevated mortgage rates, the average home price still exceeded $405,000 in the fourth quarter.

The median home price has come down from its 2022 peak but remains elevated relative to incomes. Source: Federal Reserve Bank of St. Louis

A 20% down payment, often required to avoid private mortgage insurance, would still cost buyers more than $80,000, a hurdle that could be less challenging now for crypto investors.

Additional reporting by Sam Bourgi and Turner Wright.

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