Below you’ll find a recap of what the DeFi Education Fund (DEF) has been up to in November 2025. If you have any questions or would like to learn more about a specific activity, please do not hesitate to reach out to contact@defieducationfund.org.

Comment Letter to CFTC

On November 28, 2025, DEF submitted a comment letter to the Commodity Futures Trading Commission (CFTC) in response to its Request for Input on the recommendations for the CFTC in the President’s Working Group on Digital Asset Markets report.

In the letter, we urge the CFTC to continue pursuing a principles-based, technology-neutral approach that protects customers and creates space for DeFi and digital market infrastructure to grow in the United States. 

A major focus of our letter is the need for clear, appropriately tailored guidance for DeFi. Effective regulation must recognize the differences between intermediated and intermediary-less DeFi systems to ensure rules are workable in practice. We also highlight that blockchain-based derivatives can operate within a transparent, compliant framework, but only if regulators provide clarity that supports responsible innovation rather than stifling it.

You can read our comment letter here. 

Response to Treasury Department on GENIUS Act Implementation

On November 4, 2025, DEF and Solana Policy Institute submitted a joint response to the U.S. Treasury Department’s advance notice of proposed rulemaking on the implementation of the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act.

Our response lays out three guiding principles to ensure that the GENIUS Act is implemented in a way that provides clarity, incentivizes U.S. innovation, and protects the technology: 1) regulatory obligations must center on control; 2) GENIUS Act implementation must focus on function over form; and 3) rules must align with existing statutory text and FinCEN guidance. 

Most importantly, we urge the Treasury to preserve the statutory definition of “digital asset service provider” (DASP), which properly captures only centralized intermediaries. We also advocate for a principles-based, technology-neutral framework that can evolve alongside rapidly advancing blockchain infrastructure; recommend protecting stablecoin rewards exactly as directed by the GENIUS Act; and we emphasize the urgent need for workable tax guidance so users aren’t penalized for routine network activity.

You can read our comment letter here.

Letter to the Whitehouse on U.S. Leadership in Crypto

On November 20, 2025, DEF joined the Solana Policy Institute and +65 organizations in writing a letter to the Trump Administration outlining practical next steps to help the United States lead on crypto innovation. 

Importantly, the letter highlighted the importance of developer protections, including recommending that the administration “direct the Department of Treasury Financial Crimes Enforcement Network (FinCEN) to issue updated guidance clarifying that the Bank Secrecy Act does not apply to noncustodial blockchain software, consistent with FinCEN’s 2019 Guidance on Convertible Virtual Currencies.”

You can read the letter at the link. 

Exploring Ways to Combat  Illicit Finance in Crypto 

On November 14, 2025, DEF published a paper, entitled: “Cybersecurity in DeFi: The Case for an SDO-Driven Approach.” 

This paper tackles a timely question—how can we effectively combat illicit finance and protect consumers that engage with open, permissionless blockchain systems & DeFi? The paper digs into the problem and presents a solution: the creation of a standards development organization (SDO) with cybersecurity standards for blockchain and DeFi driven by input from industry experts and government agencies.

You can read the paper here.

Launching DEF’s New Website

On November 4, 2025, DEF proudly unveiled our new brand and redesigned website. We’ve built a cleaner, more intuitive, search-forward experience for those looking to learn more about DeFi policy.

Explore DEF’s updated look here.

November Financial Disclosures

Donations Received	$25,000
Lobbyists	$35,107
Public Relations
Policy Litigation
Marcomm & Fundraising	$5,998
Operating Expense	$324,497

November Content and Appearances by DEF

Blogs/Articles/Papers

• The Persistent Poverty Premium & Possibilities of DeFi by Jennifer Rosental, Chief Communications Officer, DeFi Education Fund
• Crypto for Advisors: What is DeFi? by Jennifer Rosental, Chief Communications Officer, DeFi Education Fund

Select Media 

• Punchbowl: Crypto has some regulatory asks for Trump
  • A letter released Thursday and addressed to Trump lays out several priorities in “tax clarity,” “regulatory clarity” and decentralized finance the group would like to see implemented. It was led by the Solana Policy Institute and joined by groups like the Blockchain Association, Crypto Council for Innovation, Uniswap Foundation, the Digital Chamber, DeFi Education Fund and Paradigm.

• The Defiant: Seven Ethereum Protocol Teams Form Alliance to Engage on Crypto Policy
  • The Alliance will work with groups including the DeFi Education Fund, the Decentralization Research Center, and the European Crypto Initiative to provide technical input and support ongoing policy efforts.

• CoinDesk: State of Crypto: What’s In the New Crypto Market Structure Draft?
  • In a statement, Blockchain Association CEO Summer Mersinger called the release of the draft “another important step,” while DeFi Education Fund Executive Director Amanda Tuminelli said it was “good to see the [Agriculture] Committee make progress on market structure.”

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