DeFi Education Fund along with 9 major organizations proposed 4 core principles to differentiate DeFi developers from centralized intermediaries in the RFIA 2025 bill.
DeFi Education Fund (DEF), a lobbying group funded by Uniswap Foundation, has sent an important comment letter to the U.S. Senate Banking Committee. The content calls for caution from the legislative body when bringing decentralized finance (DeFi) into the scope of regulation in the draft Responsible Financial Innovation Act 2025 (RFIA).
This response document is co-signed by nine leading organizations in the cryptocurrency sector, including a16z Crypto, Paradigm, Jump Crypto, Multicoin Capital, Solana Policy Institute, and organizations related to Uniswap. The involvement of these major names reflects the high level of industry interest in shaping the legal framework for DeFi.
The RFIA 2025 draft is an updated version of the cryptocurrency market act that was first considered in June 2022. The Senate Banking Committee stated that the goal is to effectively build on the foundation laid by the CLARITY Act, aiming to promote innovation in the U.S. without risking financial stability or harming consumers.
Four core principles for DeFi regulation
DEF has emphasized four core principles that should guide the legislative process. The first principle is to clearly distinguish between DeFi developers and centralized intermediaries, to avoid applying the same regulatory framework to two fundamentally different types of activities. Second, a clear definition needs to be established for the mandatory intermediaries that must register with the government.
The third principle proposes specific criteria to evaluate the degree of decentralization of a protocol, creating transparency in determining legal obligations. Ultimately, DEF calls for ensuring technological neutrality principles throughout the legal framework, avoiding discrimination based on specific technological platforms.
In relation to the Tornado Cash case, DEF suggests that Congress needs to update the guidelines from the U.S. Financial Crimes Enforcement Network (FinCEN). These guidelines are playing a crucial role in the trial of developer Roman Storm, who is accused by the Department of Justice of violating federal law by releasing source code used by hacker groups like the Lazarus Group.
"The issuance of regulations should reflect that pure technologies, being non-custodial and uncontrollable software, should not be regulated as a financial institution or financial intermediary," DEF emphasized. The ruling against Roman Storm is expected to be announced as early as next week, potentially creating an important precedent for the industry.
DEF also calls on the Senate to adopt federal regulations that take precedence over state laws to protect the DeFi development community. The organization warns that without prioritization of federal law, traditional financial institutions may exploit the fragmentation of state-level legal frameworks to fund legal actions against DeFi developers, not to protect consumers but to eliminate competition.