March 28, 2017 12:00 am

Dash Legal Research – Marco Santori – Cooley LLP available now !

How the Law Applies to DASH
The purpose of the DASH DAO is to promote, protect and standardize DASH. In the course of our mission, we have received inquiries into how some aspects of DASH are treated under United States law. The purpose of this document is to address the most common of these inquiries and explain how we believe the laws apply to DASH. This is not meant as a legal opinion, and you should consult your own attorneys before relying upon it. However, it is meant to state our position on the law, and how the law should be properly interpreted.

What is the Tax Treatment of the Masternode Operators’ DASH?

  • Block Rewards
  • Staked DASH
  • Capital Gains

Can Masternode Operators be Criminally Liable for the Transactions They Relay?

  • Primary Liability
  • Secondary Liability
  • Exchange Liability for Supporting DASH transactions

FIAT – DASH Compliance / ATM Compliance
An aspect that required legal research is what are the compliance requirements to facilitate Dash FIAT exchange. This can be in the form of running ATM kiosks or using other mechanisms to personally offer DASH to FIAT exchange services.
For this purpose we hired Cogent Law who have a lot of experience working in compliance for digital money services. They have put together a compliance program that will be shared with anyone launching a Dash service if they require it. This includes:
A finCEN BSA compliant written Principal MSB/KYC AML Program designed to prevent the Principal MSB from being used to facilitate money laundering and the financing of terrorist activities
A comprehensive risk based assessment by a third party compliance consultant expert

Our lawyer for this project is Adella Toulon-Foerster who has extensive experience in this field including:
Banking Secrecy Act (BSA), Anti-Money Laundering (AML), and Know Your Customer (KYC) regulations
FinCEN requirements and guidance
Written and on-going AML compliance programs
State-by-state money transmitter laws and licensure requirements

We now have full documentation of the program from Cogent Law, the package includes:
BSA AML Compliance training
KYC CDD Policy
AML Program
Risk Assessment
Surveillance and Monitoring Policy
Different Reports to file in different situations

  • extensive Documentation + Guides and Audio Guides

About the author