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DEF’s April Recap
- DeFi Education Fund
- 6 days ago
- 10 min read
Below you’ll find a recap of what the DeFi Education Fund (DEF) has been up to in April 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.
Launching Petition re. Section 1960
On April 28, 2025, DeFi Education Fund launched a petition calling on the Trump administration to end the lawless prosecution of software developers in the U.S., and it now has over 350 signatures from leaders in the digital assets industry (and it includes signatures from trade associations representing an additional 100+ companies in the crypto industry).
The petition explains: “Under a novel and unprecedented theory, the SDNY is attempting to hold software developers criminally liable for how others use their code — even when the developers have no control over those third parties, or user assets. This is not only absurd in principle, but it sets a precedent that potentially chills all crypto development in the United States. Such a framework threatens the very foundation of technological innovation.” The actions from the DOJ contradicted clear 2019 FinCEN guidance: developers of self-custodial, peer-to-peer protocols are NOT money transmitters.
Please consider signing the petition: https://section1960.defieducationfund.org/
Submitting Token Safe Harbor Guiding Principles to SEC Crypto Task Force
On April 18th, 2025, DeFi Education Fund (DEF) submitted ‘Guiding Principles for a Token Safe Harbor Framework’ to the Securities and Exchange Commission’s (SEC) Crypto Task Force. A safe harbor is a legal framework that shields good-faith actors from certain liability or penalties under defined conditions, which provides regulatory clarity and peace of mind to market participants.
DEF submitted five guiding principles for inclusion in the Token Safe Harbor, which are described in detail in our letter: (1) technology-agnostic rules and policies, (2) broad and inclusive eligibility criteria for the Safe Harbor, (3) appropriately calibrated disclosure and compliance considerations, (4) clear and well-defined exit criteria, and (5) appropriate treatment of secondary market activity.
We are collecting feedback on the Guiding Principles from builders in the DeFi ecosystem. You can share thoughts via the form here.
Dropping Lawsuit Against Treasury for IRS “Broker” Rule
On April 16, 2025, DEF and our co-plaintiffs, Blockchain Association and Texas Blockchain Council, were pleased to drop our lawsuit challenging the Treasury Department’s Internal Revenue Service (IRS) DeFi-killing “broker” rule. DEF’s lawsuit was mooted by President Trump’s signature of the DeFi “Broker” Congressional Review Act (CRA) Resolution, which officially disapproved and voided the flawed rulemaking.
DEF’s Executive Director & Chief Legal Officer Amanda Tuminelli on the news: "Today's decision to drop our lawsuit against the Treasury and the IRS marks the successful end point in our advocacy for the DeFi community against regulatory overreach by the prior administration's IRS. Though DeFi technology presents a new set of considerations for policymakers and regulators to understand and navigate, recent actions like the CRA demonstrate the power of collaborative advocacy and public-private partnerships.”
Congress' actions on the CRA represent a bipartisan victory and are a signal of progress for the DeFi industry.
Engaging: April Content and Appearances by DEF
Analysis Further Exploring Treasury’s Tornado Cash Sanctions Removal
On April 15, 2025, DEF released an in-depth analysis on the removal of Tornado Cash smart contracts from the Specially Designated Nationals (SDN) list.
In a blog, we dive into the implications of the delisting, namely: “Treasury has indicated that it does not intend to surrender so easily.” The blog also analyzes the continued designation of Roman Semenov, a Tornado Cash developer, maintained after the delisting of Tornado Cash’s smart contracts; this ultimately raises serious questions about the U.S. government’s evolving stance on software developers and their liability for third parties’ use of decentralized, immutable software. If the protocol itself is no longer sanctioned, what is the continuing basis for pursuing individual developers, especially when they lack control over the code’s ongoing operation?
Click here to read the full blog.
Blog Post on DOJ Memo Calling for End of “Regulation by Prosecution”
On April 8, 2025, DEF published a blog post exploring a new memo from the Deputy Attorney General (DAG) of the United States Department of Justice (DOJ) titled “Ending Regulation by Prosecution” for the digital asset industry. In this memo, the DAG makes clear that the era of regulation by prosecution is over: “The Department of Justice is not a digital assets regulator.”
DEF’s blog explores the potential implications of the memo, noting that the “DAG’s memo is a positive step towards protecting software developers from liability for mere registration violations and from third parties’ misuse of the technology they created, especially when there is no way that a developer can anticipate the myriad of ways a third party will use the tools they created.”
Click here to read the full blog.
April Financial Disclosures
You can find a detailed look into DEF’s February 2025 financials in the breakdown below. If you would like a deeper look at our 2025 financial breakdowns, please click here.
USDC & UNI Update: In April, DEF transferred the remaining USDC from our multisig to our Kraken account to fund upcoming business expenses (LINK). Additionally, we are continuing to sell the our UNI tokens in the multisig in accordance with our January 2025 funding update (LINK)
Donations Received | $59,105 |
Lobbyists | $55,000 |
Public Relations | |
Policy Litigation | $80,291 |
Marketing | |
Merchandise | |
Operating Expense | $13,902 |
Payroll and Associated Taxes | $186,020 |
Professional Fees | |
Accounting | $13,385 |
Legal | $6,728 |
Other Consultants | $1,000 |
Transacting Fees | $2,462 |
Insurance | $5,110 |
Tax & Licenses | |
Other Overhead | $26,463 |
April Media
Print/Online
Blockworks: Crypto movement in Trump’s first 100 days: ‘Personnel is policy'
As the last line of a Monday DeFi Education Fund letter to crypto czar David Sacks notes: “The job’s not finished, and the stakes could not be higher.”
That letter was about what it called “unlawful DOJ overreach” in the prosecution against Tornado Cash co-founder Roman Storm.
“No one writing code in good faith should have to fear prosecution for the actions of strangers,” they wrote.
CoinDesk: Tornado Cash Can’t Be Sanctioned Again, Texas Judge Rules
A host of prominent figures in the crypto industry also signed on to a letter from the DeFi Education Fund to White House AI and Crypto Czar David Sacks on Monday, urging U.S. President Donald Trump to intervene in the case to “discontinue the Biden-era Department of Justice’s lawless campaign to criminalize open-source software development” and the prosecution of Storm.
Law360: Feds Urged To Drop Crypto Mixer Charges After DOJ Memo
Crypto advocacy group DeFi Education Fund on Monday addressed a petition to White House AI and Crypto Czar David Sacks arguing the SDNY "has not received the message" from the DOJ memo given it has continued to pursue its prosecution of Storm.
"Under a novel and unprecedented theory, the SDNY is attempting to hold software developers criminally liable for how others use their code — even when the developers have no control over those third parties, or user assets," the petition said. "This is not only absurd in principle, but it sets a precedent that potentially chills all crypto development in the United States."
DL News: Crypto leaders press White House to drop Tornado Cash criminal case
Prosecutors should drop their “lawless” campaign to imprison Tornado Cash co-founder Roman Storm, crypto heavyweights said on Monday in a letter addressed to David Sacks, the White House crypto and AI czar.
Storm’s upcoming criminal trial in the Southern District of New York has become a cause célèbre within crypto.
Led by the DeFi Education Fund, an influential policy group, the letter was signed by executives at venture capital firms Paradigm, Multicoin Capital, and 6th Man Ventures.
Cointelegraph: Crypto group asks Trump to end prosecution of crypto devs, Roman Storm
The crypto lobby group, the DeFi Education Fund, has petitioned the Trump administration to end what it claimed was the “lawless prosecution” of open-source software developers, including Roman Storm, a creator of the crypto mixing service Tornado Cash.
In a letter led by the DeFi Education Fund to White House AI and Crypto Czar David Sacks on Monday, leaders urged the Trump administration to change course and end the Justice Department's "overreach" in prosecuting software developers. Those developers don't have control over third parties and should not be held criminally liable for how their code is used, they said.
Crypto in America: Industry Leaders Launch Petition Urging Trump to Rein in DOJ’s War on Open-Source Crypto Devs
On Monday morning, a group of industry leaders, led by the advocacy group DeFi Education Fund, sent a letter to President Trump’s Crypto and AI Czar, David Sacks, urging the White House to halt the Justice Department’s prosecution of open-source software developers
Blockworks: DeFi Education Fund advocates for safe harbor
As new leadership prepares to take over the US Securities and Exchange Commission, a crypto advocacy group believes now is the time to revive a 2020 proposal, Blockworks has exclusively learned.
The DeFi Education Fund is asking the SEC to establish a “safe harbor” for token issuers, allowing them a limited registration exemption while they develop decentralized networks. It’s an idea Commissioner Hester Peirce first floated five years ago.
CoinDesk: U.S. Crypto Lobbyists Flooding the Zone, But Are There Too Many?
"I think it's a huge benefit that we have so many organizations dedicated to trying to achieve regulatory clarity for digital assets," said Amanda Tuminelli, who stepped up to run the DeFi Education Fund when Whitehouse-Levine left. "I think it's been really needed, especially in the past few years, and when we work together, we actually accomplish great outcomes. For example, the IRS broker rule on DeFi."
Decrypt: From the Crypto Trenches to the Hill: Why Solana Is Making a Big Push in Washington
However, to get that kind of legislation passed, it's important that developers and legislators take the time to understand one another with the help of go-betweens like Whitehouse-Levine, Smith, and other policy experts, DeFi Education Fund Executive Director Amanda Tuminelli—who will be working closely with SPI on DeFi-focused policy initiatives—told Decrypt.
“We're all trying to reach out directly to developers and serve as a bridge between DeFi developers and the Hill,” Tuminelli said.
“It's very important that we get clear law on the books while we can, [and] while Congress seems like they're in a place where that could happen," she said, adding that she's seen in recent months an increase in securities regulators and lawmakers holding meetings on issues that impact DeFi developers.
DL News: Indicted Tornado Cash dev just got a boost from an unlikely source — US prosecutors
Amanda Tuminelli, the head of crypto advocacy firm DeFi Education Fund — which has made filings on Storm’s behalf — said she was grateful the department had narrowed its focus.
But she still takes issue with prosecutors’ assertion Tornado Cash is a money transmitting business.
“They never were transferring funds on behalf of someone else,” she told DL News, referring to the Tornado Cash and Samourai Wallet developers.
“Because they never had control over user funds by simply publishing code. That is what I wish the memo said.”
CoinDesk: President Trump Signs Resolution Erasing IRS Crypto Rule Targeting DeFi
"With President Trump’s signature, the rule is officially disapproved and voided, and the United States has passed its first ever crypto legislation — a watershed moment for DeFi," the DeFi Education Fund noted in a Thursday posting to its site.
DL News: Trump signs bill repealing IRS rule targeting DeFi — here’s what it means
“This bipartisan action underscores our nation’s commitment to fostering innovation and ensuring that Americans retain the freedom to choose how they transact,” Amanda Tuminelli, head of crypto advocacy firm DeFi Education Fund, told DL News.
Crypto in America: Trump Makes History Signing First Crypto Bill into Law
“This bipartisan action underscores our nation's commitment to fostering innovation and ensuring that Americans retain the freedom to choose how they transact, said Amanda Tuminelli, CEO of the DeFi Education Fund, an advocacy group focused on decentralized finance. “President Trump’s signature is a critical signal change for the crypto industry: the United States has embraced a sensible, forward-thinking approach to digital assets.”
Decrypt: Trump Becomes First President to Sign Crypto Bill Into Law, Ending Anti-DeFi IRS Rule
“Digital asset regulatory history was made in the U.S. today,” Amanda Tuminelli, Executive Director of crypto lobbying group, the DeFi Education Fund, said in a statement shared with Decrypt.
“President Trump’s signature is a critical signal change for the crypto industry: the U.S. has embraced a sensible, forward-thinking approach to digital assets,” it added
The Block: Trump signs resolution to repeal controversial IRS crypto rule finalized under Biden, lawmaker says
Trump's signature officially puts an end to the IRS' broker rulemaking, said the DeFi Education Fund's Executive Director Amanda Tuminelli in a statement.
"The DeFi Education Fund commends all members of Congress who supported this resolution, recognizing the importance of protecting software developers and promoting the development of decentralized technologies," Tuminelli said. "President Trump’s signature is a critical signal change for the crypto industry: the United States has embraced a sensible, forward-thinking approach to digital assets."
Law.com: Senate Confirms Paul Atkins as SEC Chair
As chair, Atkins has indicated that he will usher in deregulation at the agency and bring regulatory clarity to the crypto industry. His confirmation was hailed by those in the digital asset industry, including one of its leading advocates, the DeFi Education Fund.
"With extensive experience in crypto & financial regulation, and deep commitment to fostering fair and efficient markets, Mr. Atkins is well-equipped to lead the Commission into a new era—one that encourages innovation and ensures robust investor protections," the fund stated on X.
Bloomberg: Justice Department Scales Back Cryptocurrency Enforcement
The letter was issued under the letterhead of the DeFi Education Fund, an advocacy group that lobbies on behalf of the decentralized finance industry.
“We are heartened to see that the DOJ announced it is redirecting resources to prosecuting the bad actors who are actually culpable for misuse of technology rather than the builders of our financial future,” the group’s Executive Director and Chief Legal Officer Amanda Tuminelli said in an emailed statement on Tuesday.
Decrypt: DOJ Will Shutter Crypto Unit, Back Off Services Like Tornado Cash
A copy of the memo was posted to X Tuesday morning by Amanda Tuminelli, CEO of DeFi Education Fund, a crypto lobbying group. A source familiar with the matter confirmed its authenticity. The contents of the document were first reported by Fortune.
Podcasts
In this conversation, Jacob Robinson and Amanda Tuminelli, Executive Director of the DeFi Education Fund, delve into the criminal code provision punishing unlicensed money transmitting businesses, why this is relevant for developers of non-custodial crypto projects, and how a recent memo from the Department of Justice on ending “the regulatory weaponization against digital assets" might not have gone far enough
Blogs/Articles/Papers
For up-to-date information about what’s happening in D.C., and on what the DeFi Education Team is up to, please follow us on X @fund_defi and subscribe to our weekly newsletter “The DeFi Debrief” on Substack.
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