Another aspect that requires some 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 are putting 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 There was an initial delay funding the law firm’s retainer in September. We were attempting to pay with Bitcoin, but their account with BitPay was not functioning, and it took several weeks to resolve. The project finally funded in October. We have had several meetings with the lawyers clarifying different aspects of Dash. The law firm is now nearly completed with the work to establish the compliance program requirements. We expect final delivery this month and will share this information with the community. It has not been determined yet if the documentation will be put online for anyone to download or do it by request, since it is valuable legal research. We are in the process of checking on this with counsel. We expect this information to be valuable for community members that are looking to start a Dash business. Phase II of the compliance program - which has not yet been approved / funded - would aim to run a pilot program with a limited number of ATM operators in a few pre-selected states. This pilot program would require operators to share data on usage and profitability to determine if a wider-scale program could be self-sustaining or even provide a profit back to the network.