Catch Me If .. Then .. Else: Regulatory Enforcement and Compliance

Transcript

hello everyone thank you for coming this early after all those parties so today we're gonna talk about uh regulation and more specifically law enforcement so there has been uh there have been other talks about more what are the rules that are coming like mika and all those new regulations what i wanted to focus on is how law enforcement agencies are actually acting at the moment and what are the strategies um based on prior cases so what has happened over the last years but also have a look of what's potentially coming in terms of new arrangements so first a few words about myself my name is xavier

lavisier i'm a lecturer in paris university which is nearby in a master about finance technology and data i'm also a member of a chair where we do research on blockchain and cryptocurrencies and currently a lot on defy and i've co-founded a few projects ecan is a training company and legalico.io is a list of decisions so it was mostly focused on ico hence the name so if one of you has a better name to adapt to the new state of affairs i'd be happy to hear that and libricoder which is a non-profit about tech education so in prior episodes by reviewing this

talk i realized that there is some sort of narrative in the different talks i've given over the past years and the general idea is that i my vision is that there will be a bridge between what's happening in the cryptocurrency sphere and the rest of the financial system either directly by interacting between existing financial institutions and on the other side what's happening in the crypto sphere or also more directly on the financial needs what are the needs of individuals and and small companies and what might how cryptocurrencies might answer those needs i feel this bridge is not done yet but we are in in this progress

of course there are many challenges and currently we are still in a situation which is in construction there are technical limitations there are the difficulties of interfacing with existing systems there are adapted identity methods that are lacking at the moment so it's difficult to identify a user and that's partially missing when we look at regulation the security the market demand a lot of fraud and of course environmental issues so today we will focus only on law enforcement and how law enforcement is is currently tackling with cryptocurrencies one particular particularity of law enforcement and

which is quite surprising for this ecosystem that's always prospective and building toward the future is that law enforcement only can work with existing laws so as the ecosystem has grown over the past 10 years and laws have been slow to be adopted they had to adapt and use existing laws to tackle what they seemed as a problem in the crypto ecosystem the other part is law enforcement the purpose is not just to apply all the laws for the sake of it is to apply all those for building a future that seems desirable so that guides some of the decisions that have been made in terms of enforcement so what are the objectives of financial

regulations so one first big objective is to guarantee the integrity of the financial system so the personal risk of one particular company but also the systemic risks that could emerge from the world ecosystem and as the ecosystem is growing particularly at the moment stable coins are in in the scope of interest of regulators the more systemic risks are likely to occur really important part and probably the one we will focus the most on is to avoid really dangerous activities so which is money laundering terrorist financing and tax fraud

so i know that in the crypto ecosystem not everybody agrees that there is a strong need for governmental action but i think in general society that's some elements where it's not so controversial it's law that protects generally the functioning of society but that still could be debated there is also a path that's about protecting users so privacy of users and also against fraud so that might be more controversial and also finally to promote an open and fair competition to ensure that the market function properly so which is on one part to allow new entrants to participate in the market to facilitate computation competition and to avoid undue benefits this is

linked to fraud on the other side which is if companies can make money by doing something that's detrimental or not useful for the ecosystem in the end that diverts energy and money from more useful activities so tackling fraud is to protect users but also to protect the market in the end just to give you a scope of the different law agencies that are acting i'm looking at the us in my example i will look at mostly the us and europe as it's the part of the world i'm the most familiar with um you have to have in mind that you have really different types of law enforcement agencies that are tackling cryptocurrencies and so there is not one

big block of law enforcement there are different entities with different objectives the primary one is in the us is the department of justice which includes specific agencies like the fbi dea for drugs but also the general services of the department of justice i think it's quite specific to the us to have a department of justice that's both law enforcement and justice in most europe countries the two activities are separated then you have specific commissions for specific activities so the securities exchange commission that's only regulated regulating the securities

markets and the cftc for the commodity markets so they have been created by a specific law and are focused on on one specific type of activity then finally we have the department of the treasury which has different departments that are relevant for cryptocurrencies the most important probably is the irs so the internal revenue services the tax service and so that's that's one big part of it and then you have the financial crimes enforcement network which tackles more specifically financial crimes um so what enforcement means when we talk about enforcement

any agency or law enforcement department has different ways of interacting with a project and try to correct a trajectory the first level are warnings so one it could be just a simple letter to one a particular actor that he might need to change some activity in order to comply which is a stronger stronger recommendation or even public naming so they could publish on their website that a particular company is not behaving the way it should there are also disciplinary sanctions so by disciplinary sanction in general we mean when there is a regulatory agency that's focused on a specific ecosystem or markets they have a procedure

and it has some rules to apply some some sanctions so it could be a fine it could be a suspension or revocation of a license or it could be even a change in management they could force to change some of the upper management of the company and finally you have criminal charges so they could be triggered by any agency and that will apply to individuals that have behaved in a certain way just i wanted to give you also a sense of the different law enforcement agencies i mentioned before what are the the means they have so it's just one number but just to give you a sense of this

when we talk about law enforcement department so the department of justice in u.s for instance you have 100 000 people working for it uh in france you have even more people than in the for the full us but you know that the us is a federal state so you have a lot of enforcement that happens also at the state level and i'm only looking here at the federal level then you have the tax services and i wanted to mention particularly this number because you have a sense that it's an important workforce within the government to be able to apply tax laws or also around 100 000 people and then you have the means of specific regulatory agencies

and i'm sure that if you're listening to what's happening in regulation in crypto you have heard a lot of the sec and all this regulatory agency but in the end they are the most likely to to do any law enforcement they have really little means and that explains why they have really careful strategies on how they communicate how they choose their cases because they can't go after any project which is not the case of the irs that can go behind a lot of people at the same time so let's look at the past cases what have been the main cases that have been containing cryptocurrencies over the past years

so first the tax services as i mentioned the tax services are the strong arm of the government in france for instance in 2014 the tax administration started to publish instructions on how cryptocurrencies would be would be taxed so the general ide was to consider that it was trading a good and you had to declare it with your revenue and you'll your tax on on this revenue some of this instruction of this instruction have been um cancelled by the supreme administrative court in 2018 notably some disposition that didn't

consider that for instance when you're mining so you're participating to the bitcoin network so you're not really trading you you you didn't just bought bitcoin to resell it you participated in a project and you got money out of it so it's more it's a different kind of revenue that you got so probably not a tax lawyer but probably less taxed than just trading revenues and so they had to take down this instruction since there has been laws there have been laws that have specified how it works in france and now we have a clear clear rules on taxation but so it was the first cases in germany they have the same the same

issues of course with cryptocurrencies and already you can see that tax services have a control by the justice system and they were so in this particular case somebody reported revenues of 100 000 euros in 2017 and the tax administration asked a certain amount to be paid and the person was successful at suspending the decision of the tax administration services on the basis that the rule were not really clear at the moment of calculation and also that there hadn't been final decision in court so they had some

delays to pay those taxes so um yeah then if we look at anti-money on laundering so you remember when i was talking about avoiding illegal activities [Music] something that's notable is that antimony laundering is largely enforced by criminal enforcement agencies so not by specific market agencies but by the more general criminal enforcement advances the first cases that we that's important in the space you have all heard about it it's silk road so silk road was a website where you could buy drugs and there was also

the liberty reserve that was a decentralized currency that started in 2001 and both were tackled on by the department of justice around 2011 2013 they seized the bitcoins from the silkworld project and auctioned them but more importantly they charged the founder of the two projects so the founder of liberty reserve was officially in costa rica but he was still successfully pursued by american administrations and also and the silk road founder was arrested and is now in texas i think anyway he's uh for money laundering computer hiking and

uh conspiracy to trafficking narcotics so serious charges the silk road founder you know is has been sentenced a life sentence on those activities so it's we are talking about 2013 so most of us here didn't had heard about cryptocurrency at that time um the department of justice was already harvesting and charging people on this basis this is in germany there was a website that allowed you to buy a subscription to get movies so before netflix but an illegal website they got money from the subscription and they converted it mostly in in bitcoin and conducted real estate operations in

berlin one of the two founders and they were charged by the by the local administration and uh the the bitcoin wastes and they were charged for money laundering again so money laundering is a good way to to um arrest all all those funders or projects that imply some cryptocurrency at some point a really complete and interesting case in btce btc e have you heard about it no oh by the way i should ask who here has some knowledge about regulation and cryptocurrencies so half of it's good and

so who here knows about btce okay so btc was one of the largest cryptocurrency exchange it was notable because you could use it with really low carbohy so for a lot of cases where you had ransomware hacks and bitcoins you could use btce to withdraw the money so it was mentioned that it might have been used for the 2015-2016 democratic national convention act so his founder was subject of a lawsuit in the u.s and in russia in russia he was charged for 10 000 fines so it looks a bit more symbolic as as as the charge compared to what it

was um subject to in in the u.s he was arrested in greece in 2017 and then he was extradited to france and he has been judged and in last december he has been charged for anti-for money laundering for five years of jail um i don't know what's the state of the exploration procedure to the u.s but it was acquitted of every ransomware charges so it's a bit similar to with more recent cases where the exchange is also suspected to be part of the scheme that allowed the russell attack to be led because the money would go through this exchange but

there was not enough element there were not enough proof to charge him with that so he avoided those charges um and at the same time the new zealand police ceased a lot of the bitcoins and funds that were in the btc-e exchange so that's also to tackle the general idea that bitcoin can be seized but in most projects once you reach a certain scale you it's rare that an individual holds all the keys and law enforcement find some ways um there are some cryptocurrency enforcement cases that challenges a bit of fundamental rights and uh that i think are interesting um one interesting case was in uh grid

butane where a company had been subject to a ransomware and so they had paid 100 bitcoin to to a particular company they realized that some of the bitcoins were in control of an address linked to a big phoenix so they wanted to get the identity of the people that were the final owner of those of these bitcoins and the high court of justice of england and wales agreed that it was a property and then they could apply the rules of um having an injunction that forced bitfenix to reveal the identity of those bitcoins so that was the first decision another one that

i find more interesting even is a really light approach to law enforcement so in 2017 you remember there was a lot of icos and especially in estonia which is a country that's quite digitally advanced there were a lot of icos operating from estonia and so the the agency for regulating the market so the equivalent of the ercc in estonia published on its website warnings to say you these companies are selling tokens but they don't hold any license to operate as a financial intermediary and so they shouldn't conduct this kind of

activities but it wasn't any remember when i mentioned all the means it wasn't any decision it was on the sanction it was on the fine it wasn't anything but just a naming of this company and saying they should they have no license on this so from the point of view of the agency they were just warning the users that they didn't have any license however the reinforcement agency lost in court in 2021 so at the beginning of this year the supreme court ruled that they couldn't issue this warning because in doing so they were detrimental to those companies and as they were not doing anything specifically legal there was no reason for the law enforcement agency to to say that they had no license that was um detrimental to the activity of the

businesses so that shows again that uh even if law enforcement are often uh feared by a crypto project they have limited actions in terms of what they can do concerning a particular project and the supreme court said that they could act on if there was a specific law that they were breaching and that would justify an alert another case i wanted to mention which is not directly linked to cryptocurrency but as facebook is looking in the space i think it's relevant it's on personal data and it's a fine by the federal trade commission of five billions to facebook two years ago on the basis that they

didn't comply with a prior order so again you remember the different means of interaction they had issue in order to facebook to say that they had to comply to certain rules on how they would they were dealing with personal data they didn't comply and so a few years later they put the five billion fine and also a supervisory committee for the next years that should of oversight facebook for for a long time so they definitely got in a um yeah more cornered situation there is this is probably not fully conscientious that libra idm was announced around this same period to me there is definitely a shift in facebook on how they perceive their

business model and how they can go forward with their current activities and this is probably a big part of it something that's really important in law enforcement is first international cooperation so as i mentioned in the prior cases you have seen that often there are different law agent law enforcement agencies from different countries that are involved in the same case and also engagement with the private sectors and especially as it's a new sector law enforcement agencies need to interact to educate themselves to to try to identify what's the worst behavior in the ecosystem and and so on one example of this international aspect

is a telegram settlement so telegram you remember issued an ico in 2018 but it was a foreign entity from for the u.s they didn't engage at all with u.s entities and so they were one of the big cases to be attacked by the sec for conducting an illegal um cell of security the acc didn't pursue all the projects but this one was a particular example of an actor that that didn't interact with them and didn't try to to comply at first and so they had to give back all the assets that were collected during the ico plus paying a penalty that looks

small compared to the ico amount but yeah so probably the most important slide is for me this one in the the point i want to strongly make is to understand that there is an opportunity cost for any uh enforce law enforcement agency and as a particular project you have to consider that where you are situated and how if you are triggering uh likely uh um some activities especially if you're what you're doing is maybe not perfectly not illegal but not perfectly clearly legal at the same time you have to be careful of what might trigger a law enforcement

action so on the on the right side you have what are the limitations of the law enforcement agencies so they have limited financial means they don't have limited budgets they don't have limited practical capabilities like seizing bitcoins it's not always easy to seize crypto assets they don't have an unlimited expertise and they don't have all the legal authority that's what we have seen in prior examples so what they would choose on is on the criteria on the left is evidence so if they have strong evidence that there is a case they will be more likely to enforce and so there are many cases that are never led

just because there is no strong evidence of the case even if it's likely that it was an illegal activity the proportionality of the risks that's incurred by the ecosystem by individuals by the illegal activity the impact of their law enforcement action the likeliness of success in court most crypto projects at the moment have a lot of money and they would challenge in court any decision by a law enforcement agency and they want to just make a state most of the time they want to make a statement and clarify the rules so if they get a ruling that's defavable in the end of the process they are there they are missing a bit their objectives so they will choose cases that are more

likely to succeed later in court and effectiveness toward the objective that what i was mentioning at the at the beginning law enforcement agencies are focused to shape the ecosystem in a way that seems suitable for them and so the the objective is not to apply every law some laws are not fully enforced the objective is to apply the laws that exist in order to shape the ecosystem in a certain way one last case to summarize a bit of this and probably the most breathtaking of the last month is a colonial ransomware attack so you probably all heard about it so colonial is a company in the south of the us

that has pipelines that provide gasoline to a lot of different activities on may 7 they were subject to ransomware attacks so i think they were received a message saying that they had a lot of data on them and they had to pay a certain amount of bitcoin to specific address so colonial shutdown partic part of its activity to avoid any any malfunction by being worried that the data would be used in a nefarious way that disturbed a lot of the activity in the south of the u.s they paid the ransom so 75 bitcoins to

specific address and over the next days we have seen the the funds move over different addresses until on june 7th the fbi was able to apply for warrant and and seize some of those bitcoins so what's interesting of course is that on the bitcoin blockchain and it seems that the attackers didn't realize the importance of this case we go back to the trade-off i was mentioning before this was disturbing a lot of the u.s activities so there was no way that law enforcement agency would not act and so if they had realized that they would

probably have put more mitigation technique in place but you can follow the funds from the payments so there is a specific address that receive the payments just after you see that there is a split in two 10 bitcoin on one side and 63 on the other one which is likely that one part is for the person that provides the software and the infrastructure that's identified as dark side from what i understood and the other one is probably for the people that actually led the attack and then the 65 that 63 that left moved along several address until they were on the specific address that the fbi claimed to have control on and was able to seize

so there is this warrant so which is pretty interesting because it details what their methods how they analyze the blockchain to identify how move the phones they only see 63 bitcoins even if the address had more on it because they consider that only 63 bitcoins were from the ransomware attack the rest they can't know where it comes from it's also probably from illegal activities but as they can't specifically identify it they don't seize it so they only took the 63 bitcoin that's a more detailed scheme of what happened so you see that there is a coinbase transaction first that's received by the colonial company the colonial company pays the ransomware the ransom company

then there is a split between the two addresses as i mentioned and then you see the phones moving to a collecting address that received a lot of different fonts from different acts and this is where engine 7 the last one is when the fbi sees on their own address the phones which have not moved since and the rest has been moved so i don't know if it's by the fbi or probably by the hacker itself realizing that they could still move some of the phones um so there is still an open question and i have no elements on this of how they actually acquired control over those keys so there are several hypotheses we can make

insider information one of the responsible of the attack realized that they were probably subject to strong criminal charges and prefer to redeem some of the bitcoin and avoid some some of the some of the of the of the legal threats uh it could be that they got control of the server that would hold the keys so that could be uh possible or that the keys were hauled by an intermediary that similarly redeemed the funds to the fbi so there is specifically no no no explanation in the warrant on this and in no communication of the api i think they want to keep

a bit secret this element but we can have an idea of what are the hypothesis so i don't know how much time i have but i will just give you a few elements on where we could go in the future um and then open for a few questions if we have a few minutes left so on the future you you realize that we are in a world of d5 daos and trying to move in a more decentralized approach of our projects so a lot of the discussion is how this decentralization avoids some of the legal threats

my opinion is that there are still a lot of elements that needs to be analyzed precisely and it's not just because the project is decentralized that it will avoid a lot of the legal complications there are the legal liability of funders and as we've seen before most of the time at the moment the gun enforcement goes after founders and lots of projects so you still have the disability the question of governance and dispute resolution in operation so when something goes wrong how problems are resolved financial law applicable to token activities so i think that's the part where most of the focus is and one part that's probably the most clear is anti-money laundering

rules are not going to be avoided for any crypto activities and that's the most likely minimal requirement we can expect from any crypto project taxation again this is a strong arm of the government and they will not lose revenues and the question of partnerships and and contracts and so on um so we don't see the emojis it's cuter with emojis but it's just i looked at d5 projects and tried to identify where they were headquarters where the the the founders were so the headquarters of course is of one specific companies most project claimed to be an ecosystem with no one central company but in most

projects you have one project one company that's definitely leading most of the research research and marketing operation of the project the only one that has its emoji is sushi swap you know that is probably slightly less identified than others even if that's debatable but still so if i project have funders have headquarters they have users also so a lot of the users of d5 project have looked at the frequentation of their websites is in u.s in china and some in australia which are countries that have a good and efficient law enforcement

um well i will just jump to maybe the the general idea i want to give is that what's open at the moment is what are the different new ways we're going to enforce rules on on crypto projects one way to do that is to have permission open models that's what i call so it's keeping some of the decentralization and openness that we have in the current exo system while having some elements of permissioning to make sure that people that interact abide by certain rules the most obvious one system is to have a white listing so it's pretty

easy to do technically to have a white listing procedure before engaging with specific projects we could have automated process with a legal backup or recognition that's the subject of the eos so one a dio is a formidable way to organize some activities but i think that that's the discussion that's going forward is how this is intertwined with having some legal backup if something goes wrong the already example of of this done really interestingly for instance refuge that has this legal backing behind some decentralized activity and then you have all this field of

technically enforced processes so law enforcement agencies regulators love this id but i think technically it's probably difficult to do is having in the code some elements that ensure that the phones can't move without respecting some rules for instance so we could use their own large proof to ensure that some private transactions don't go above a certain threshold otherwise it's reported or we could imagine a lot of this kind of rules or also use hardware and class and and have this kind of enforcement this is interesting of course but this is way forward in terms of how likely it is to go thank you for listening [Music]

thank you they are welcome morning thank you for your presentation uh what do you think about the mica regulations coming out in the fall mika yeah yeah so mega is the the big um regulation that's coming in europe there is a talk uh tomorrow i think with simone that that should be interesting about

what should be the strategy of d5 project about this and there was one yesterday by victor also that might be interesting on regulation the so the general idea of mikael is to yeah create a lot of categories and define for each categories what would be the rules have a strong enforcement on stable coins because it was designed probably at the time of libra so they were scared about stable coins and i think that's probably the most detrimental aspect that it's really tampering with the ability of creating stablecoins in europe but at the moment it's being discussed and the european commission is pretty good at

taking into account feedback so i don't know at which stage we are exactly at the moment but i know that there is a lot of arrangement that we can expect between the initial text and what's going to be adopted in the end and most of the laws are written for third person right so somebody who's held responsible for an action yeah right and the d5 is smart contract who's going to be held responsible for this kind of that's a good point and that's why i'm and that's the title of this slide i'm i'm saying that we move from an entity base to embedded rules definitely i think the the future is to look a bit less at the individual responsibility of a company and or an individual but to try to have a system that's well

designed and guarantees some of the property we want to have the problem is if you at the moment if you are not an entity that's registered and is legally liable that's what happened in the prior cases i mentioned it's individuals that are liable and so i think it's the worst case scenario is that as a founder you are personally responsible and you go to jail if something goes wrong in your project most of the financial system at the moment so a lot of illegal activity happens a lot of things go wrong and the funders don't go to jail because they are protected by by the legal framework which is also maybe disputable but um i see the future going to

more toward the infrastructure and and trying to have a system and i think that's a fantastic part of crypto to offer the possibility of having a system that offers some guarantees but that's the current state of affairs um yeah thank you for this presentation i would like to follow up on on that um question of i think taos are sufficiently well protected themselves in a way the individuals are not what do you think are the best ways for those to protect their contributors what can they do today how the house should protect the contributors uh yeah the best way is to think about what's the legal uh filter so

safety net i would say so if something goes wrong in the dros if there are really a nefarious activity that happened through this deo how individuals are shielded from what happened in the deo i don't think that the pseudonymity approach is really safe and and definitely so i'm i'm looking a lot at all the initiatives that have been done so you probably aware of it um of having different ideas on how we can either recognize an existing dio as a legal entity just having some rules that would automatically recognize it having contract contracts so it's also a way to get recognized as a dio and saying okay

besides the code aspects there is some contract that's explained will happen and that still can be recognized by a judge or having a formal registered company which is also the approach that some states and countries [Music] approach so yeah that's that's the lawyer part of me is to all i think that thing will go wrong and it's better to have some safety net just to comment on a question uh the comment is from your initial slide of of the us regulatory agencies there there was no listing there's no line for for u.s states but it

appears that u.s states have some muscles to flex here as well sure um as evidenced by blockfy's investigation yesterday by new jersey of all things um i didn't even know new jersey had a securities regulator my question is is more to do with with the eu and comments coming out of uh various politicians about privacy um and is the idea about anonymous uh crypto accounts which we all kind of have right and um how likely do you think it is that on our we're going to have to disclose all of our uh crypto accounts or crypto

addresses as as part of some kind of official like is privacy going to die that's an excellent question and something i'm really interested in how we can manage some balance so we have already a lot of decisions that shows that when law enforcement wants to have access to all the information about you all the accounts um in in europe in the u.s you have decisions that mitigate this you know there was a decision about coinbase i think a few years ago where the tax services wanted to have all the accounts that coinbase had because they realized that there was a discrepancy between the amounts that were declared by by

americans and the amounts that they could see in the market and the activity of coinbase but the the the court decided that they would only have to reveal some big accounts but not every account of every user on con base so then there is a question of all the unholstered wallets on anonymity tokens and and all these so and also this is a big question currently in cbdc projects so the project of central bank digital currency uh how design how they will be designed and how private they will be and how private can be access acceptable my view is that um currently we have

already cash and we have already some part of the economy that are fully private and i think it's it's probably a good thing that that some of the financial activities fully private even if that means that some illegal activity will happen and then the question is where we put the lines to avoid too much detrimental financial activity and so i don't have the answer of what's going to happen in the next years there's definitely a big area of focus but i've met regulators and and and politicians and starting to have a thinking in this balance like a few years ago it was clear that every privacy should be tackled so now they have realized that cryptocurrency are actually mostly not

so private and even on cbdc projects there are some discussion on like how transparent it should be for every actors and yeah i don't have the answer what's going to be the final decision but but the idea is already there that maybe some food privacy is useful for for for some cases yeah i was just wondering about uh your thoughts on the announcement of the european commission yesterday about the travel rule implementing the travel rule for crypto companies in europe and uh whether you think that it could mean that at some point in the future using self-hosted wallets for individuals would become practically

impossible so we would invest in crypto assets maybe we would be free to do that but then we would we could only send them from one crypto compliant a crypto service provider to the other that's an excellent point so yes yesterday the european commission announced for a piece of legislation about anti-money laundering and with a lot of new rules well i think it's going to happen and it's already what you can see with the bce cases i mentioned before is that authorities have a good idea of what's the scope of the i would say transparent part of the ecosystem and the opaque part of the ecosystem and when

they tackle one big crypto exchange like these they know that they are kind of shutting a door to a fully opaque part of the ecosystem and then most of the transaction have an entry point that they can control and i think that's the objective so with the european commission rules what's gonna happen is that most of the users will buy on an exchange then use maybe unhosted wallet but that still sends some information uh when you're doing the transaction to the counterparty so you have some some some yeah transparency from the compliance point of view but still i think that it would be possible that in parallel you keep some fully private transaction if people

have uh mine on their side and then they use a downloaded open source hosted wallet i don't think that at the moment there is a thinking on how to fully eradicate that but they want that most common users will be tracked and followed and yeah so i think that's the stage we are at and definitely the proposition is in this direction so we are not going to shut down all cryptocurrencies but everything that's happening in with some legal entry point is going to be clear from from the beginning to the end yeah so it's time thank you very much for listening

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