a16z and DeFi Education Fund propose DEX safe harbor as SEC advances Project Crypto

a16z and the DeFi Education Fund have proposed a safe harbor exempting qualifying DEXs and DEX apps from SEC exchange registration, arguing automated, non-custodial systems don't pose risks exchange rules target. To qualify, DEXs must be non-custodial, automated, permissionless, and credibly neutral; DEX apps face four parallel criteria. A separate a16z submission suggests an ATS-style registration framework for centralized crypto trading platforms to trade tokenized securities. The authors say prior SEC positions, including a Wells notice, threatened to chill DeFi innovation and that the Innovation Exemption covers only intermediated venues.

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• DEX
• Crypto
• a16z
• SEC