DeFi Education Fund: Championing Innovation and Clarity in Decentralized Finance

The DeFi Education Fund (DEF) is a nonpartisan and global nonprofit organization dedicated to educating policymakers about the benefits of decentralized finance (DeFi) and achieving regulatory clarity for the DeFi ecosystem. Through research, advocacy, and grant distribution, DEF strives to foster an environment where DeFi can flourish. DEF mobilizes DeFi by elevating the voices of people building it and creating coalitions to stand strong together.

The Genesis of the DeFi Education Fund

The DeFi Education Fund was created to further DEF’s mission of educating lawmakers about DeFi, protecting software developers, and promoting sound DeFi policy. This new chapter wouldn’t be possible without the continued generosity of the DeFi community.

Leadership

The DeFi Education Foundation’s Board of Directors are DeFi legal and regulatory experts, and will help us support the advancement of DeFi. The foundation is led by:

Amanda Tuminelli, Executive Director & Chief Legal Officer, DeFi Education Fund. Prior to joining DEF, Amanda was a lawyer at Kobre & Kim, where she defended clients against criminal and regulatory investigations, government enforcement actions, and large scale litigation, particularly in the crypto and blockchain space. She previously served as a law clerk for the Honorable Ann M.
Greg Xethalis, General Counsel of Multicoin Capital.
Michael Mosier, Co-founder of Arktouros PLLC.

The Imperative for Regulatory Clarity

The policy and regulatory environment that will affect DeFi is developing quickly. DEF recognizes that DeFi has immense potential for human prosperity, but that can only be realized with buy in from governments and appropriate policy.

Protecting Software Developers and Non-Custodial Service Providers

One of the DEF's primary concerns is ensuring that market structure legislation includes robust, nationwide protections for software developers and non-custodial service providers. The advocacy group has gathered over 100 signatories asking the Senate to provide robust, nationwide protections for software developers and non-custodial service providers in market structure legislation. According to DEF, market structure legislation must treat blockchain technology as neutral infrastructure and include comprehensive protections for the developers building it and the non-custodial service providers enabling users to access it.

The organization believes that without such protections, any market structure bill would be detrimental to the industry. DEF policy lead Gavin Zavatone stated on X that they have united the largest and most broad coalition in American crypto history behind one clear message: protect the software developers building our self-custodial, p2p financial future.

The CLARITY Act and the Responsible Financial Innovation Act

The House passed the Digital Asset Market Clarity Act of 2025, or CLARITY Act, which defines how digital asset service providers should be regulated in the United States. The CLARITY Act includes an exception for developers of non-custodial services to not be defined as money transmitters. As the CLARITY Act reads: "a non-controlling blockchain developer or provider of a blockchain service shall not be treated as a money transmitter or as engaged in 'money transmitting' or, following the date of enactment of this Act, be otherwise subject to any new registration requirement that is substantially similar to the requirement that currently applies to money transmitters, solely on the basis of creating or publishing software to facilitate the creation of, or provision of maintenance services to, a blockchain or blockchain service; providing hardware or software to facilitate a customer’s own custody or safekeeping of the customer’s digital assets; or providing infrastructure support to maintain a blockchain service."

The Senate Banking Committee has since introduced a competing discussion draft of the Responsible Financial Innovation Act of 2025 (RIFA), which similarly includes a section on the protection for non-custodial developers, referred to as the Blockchain Regulatory Certainty Act (BRCA). As the BRCA states, developers of non-custodial services "shall not be treated as a money transmitter; or engaged in money transmitting; and on or after the date of enactment of this Act, shall not be otherwise subject to any registration requirement that is substantially similar to the requirement that applies to money transmitters, as in effect on the day before the date of enactment of this Act, solely on the basis of creating or publishing software to facilitate the creation of, or providing maintenance services to, a distributed ledger or a service associated with a distributed ledger; providing hardware or software to facilitate a customer’s own custody or safekeeping of the customer’s digital assets; or providing infrastructure support to maintain a distributed ledger service."

However, DEF emphasizes that the exclusion of non-custodial developers from existing money transmission laws does not prevent Congress from enacting new legislation that could apply to them, as outlined in the White House Digital Assets Report.

The Decline of Open-Source Development

Citing a report by Electric Capital, DEF highlights that the number of open-source developers in the US has declined from 25% in 2021 to just 18% in 2025. DEF's letter states that it is critical that legislation recognizes and preserves the historical protections afforded to open-source software development, and ensures that software developers and non-custodial service providers who create, support, and enable access to decentralized networks are not forced into unworkable regulatory categories designed for the traditional, intermediated financial world.

DEF believes that without these explicit safeguards, the bill risks stifling innovation, undermining open-source development, and driving blockchain infrastructure development out of the United States.

DeFi's Challenges in the Legal Landscape

DeFi has also been challenged in the courts following a jury's decision last week to find Tornado Cash creator Roman Storm guilty of conspiracy to operate an unlicensed money transmitting business. DEF had taken the position that software developers of "noncustodial peer-to-peer protocols" do not have control or have custody of users' assets, so they cannot be money transmitting businesses.

Research and Advocacy Initiatives

The DEF actively engages in research and advocacy to promote informed policymaking.

Ipsos Research and American Sentiment

A new national study for DEF, conducted with Ipsos and supplemented by in-depth interviews in the Bronx and Queens, provides insights into how Americans, especially underbanked communities, view the financial system and emerging technologies, like DeFi.

In alignment with other probability-based sample surveys, Ipsos x DEF research shows that almost 1 in 5 Americans (18%) have owned or used crypto at some point in their lifetime. Amanda Tuminelli, DEF’s Executive Director, stated that particularly against a backdrop of diminishing trust in traditional finance institutions, their new data reveals that Americans want to have total unilateral control of their money and to be able to transact directly with their peers, without middlemen or third parties. She also noted that the DEF team was excited to partner with Ipsos to provide research-based insights into Americans’ views on the current state of financial services and the possibilities that crypto and decentralized finance innovations can help unlock.

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Key findings from the Ipsos research include:

Trust in traditional finance is low across the board, and the data revealed significant variations and areas of skepticism across the financial landscape. Fees are a particular point of friction.
Consumers want to take back control of their finances.
Americans are increasingly concerned about their financial security.
Many Americans are curious about DeFi, even though it’s early.

Senate Banking Committee Response

On August 1, 2025, DEF submitted their response to the Senate Banking Committee’s Digital Asset Market Structure Request for Information and recently published discussion draft of the Responsible Financial Innovation Act of 2025.

Coalition Letter to Congress

On August 27, 2025 a coalition of 100+ signatories joined DEF in sending a letter to Congress calling for protections for software developers in market structure. DEF sees this critical issue unites crypto and tech builders, investors, and advocates.

Amicus Brief in Michael Lewellen v. Pamela Bondi

On July 7, 2025, DEF alongside industry partners, filed an amicus brief in Michael Lewellen v. Pamela Bondi in support of Lewellen’s opposition to the DOJ’s motion to dismiss.

Additional Activities

DEF's CCO Jennifer Rosenthal joined Remy Blaire on FINTECH.TV to discuss their recent Ipsos research and American's feelings on financial services.

Organizational Structure

Jennifer Rosenthal is the Chief Communications Officer. Prior to joining DEF, Jennifer was the head of Corporate Communications at Grayscale Investments, where she led external media relations and corporate affairs, notably as the firm navigated a high-profile, victorious legal battle against the SEC to obtain approval for spot Bitcoin ETFs to begin trading in the United States. Jennifer started her career in education, and she holds a B.A. in English Education from the University of Delaware and a M.S.
Max serves as the DEF’s Director of Development and Operations and is responsible for the development and execution of all aspects of DEF’s development strategy. Max also is responsible for the operations of DEF. Prior to joining the Fund, Max spent five years as an in-house communications consultant, serving clients in both the nonprofit and for-profit sectors. Max has experience working with some of the nation’s biggest names in finance and fintech, advising clients on a plethora of issues including, pending legislation, DOJ investigations and mergers and acquisitions. Max holds a B.A.
Laz serves as the DEF’s Research Director and is responsible for policy research and advocacy. House campaigns. Laz was first introduced to DeFi in Spring 2020 while conducting foreign policy research for his internship at a Washington-based think tank. Laz holds a B.A. Law and Government, as well as minors in both Legal Studies and Criminology from Colorado State University. Laz is currently obtaining a B.S.
Gavin works as a policy analyst with DEF, contributing to DEF's policy research and advocacy efforts. Prior to joining DEF, Gavin interned in a variety of public policy roles. Gavin holds a B.A.

Supporting the DeFi Education Fund

DEF relies on the generosity of the DeFi community to power its work. In-kind crypto donations to DeFi Education Foundation can be a more tax-efficient way to support DEF’s mission. DeFi Education Foundation also still lists DEF’s wallet addresses for many popular chains.

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