[Consensus Check] Grant SFI for Legal and Regulatory Compliance

Previous Proposal
Previous Temperature Check.

Saffron Finance - Legal and Regulatory Compliance Program and Strategy
35 SFI per month from the Treasury, from May – December 2021

Regulatory compliance is critical to the long term success of Saffron Protocol. Compliance failures not only raises risk related to regulation but will inhibit scaling Saffron Protocol and user adoption, particularly if Saffron Protocol is subject to the accreditation and user identification requirements under U.S. laws and regulations.

Saffron Protocol should retain s capital markets executive and corporate lawyer with extensive experience leading early and mid-stage companies through venture financing and initial listings. The individual must be deep in the DeFi industry, and be a strong advocate and value-added advisor to Saffron. The individual must have superb command, knowledge, and advocacy skill with respect to the multiple layers of US financial market regulations.


  1. Legal Strategy and Risk Assessment.
  • Assess the applicability of the U.S. Securities laws, Commodity Trading laws, anti-money laundering regulations under the rules and regulations of Financial Crimes Enforcement Network.
  • Assess whether Saffron Protocol meets to criteria of a “broker” or “dealer” under Sections 3(a)(4) or (5) of the Securities Exchange Act of 1934 (the “Exchange Act”), an “exchange” as defined by Section 3(a)(1) of the Exchange Act, a “trading facility” or “designated contract market” as defined by Section 5 of the Commodity Exchange Act, of a “money services business” under 31 CFR 1010.100(t), the FinCEN implementing regulations of the Bank Secrecy Act, or of an investment adviser under the Investment Advisers Act of 1940.
  • Assess whether SFI is a security under Section 1 of the Securities Act of 1933 and the rules and regulations thereunder; or a “commodity interest” under the Commodity Exchange Act.
  • Review and examine technical documentation and repositories (e.g., Github, Discord) and product documentation prepared by the core developer team of Saffron Finance.
  • Provide legal strategy, written memoranda and guidance of the aforementioned
  1. Product Counsel & Business Development Support (e.g., Exchange Listing, Marketing)
  • Serve as product counsel for product proposal and development, considering the regulatory implications of feature enhancements, including registration and licensure requirements, data handling obligations, user-facing disclosures, and decentralization of control of Saffron Protocol.
  • Prepare materials necessary to support exchange listings, succeed in due diligence. Partnership and other agreements for integrations. Engage with exchanges on listing standards and provided any opinions required for listing.
  • Review all marketing arrangements and marketing collateral related to the protocol and the core developer team.
  • Advise in CDO and tranched digital assets product design, including single and multi-tranche products, tenor rolls, grade rating, and other product structure and market structure considerations.
  1. Core Compliance, Regulatory Engagements and Government Relations.
  • Capital markets executive and corporate lawyer with extensive experience leading early and mid-stage companies through venture financing and initial listings. Deep experience leading new business initiatives for technology companies and financial institutions.
  • Represent Saffron Protocol in regulatory engagement and enquiries from the SEC, CFTC, FinCEN and state regulators.
  • Develop policies and procedures, including for the core developer team regarding, token policy (trading prohibitions), coding controls and development, information security, etc.


  • Former SEC, with CFTC experience, derivatives and structured products experience minimum 10 years of experience. Licensed to practice in NY and other key US jurisdictions.
  • Capital markets executive with deep expertise in the law and also crypto and DeFi advisory practice with 5+ years of FinTech and startup experience.
  • 25%+ FTE utilization

Snapshot Poll


This is our first proposal to make it to final stage, Consensus Check. SFI holders are encouraged to either vote yay or vote nay on the proposal at this point. A successful vote majority will cause the proposal to be implemented upon the poll’s conclusion.


Hi all! Tom from Dragonfly Capital here. Strongly support the proposal. IMO bodes well that the Saffron community is thinking about these issues now and how to keep shipping fast while not running afoul of regulations.


I think this role serves a useful purpose in Saffron and probably other Insurance / Risk Management DeFi platforms as well.

I would propose a few items as an addendum to consider in regards to this and future proposals. I think the requests below do not effect the Consensus Check or Snapshot vote directly, but are more courtesy or procedural requests.

I am voting yes and asking that the Saffron team consider three things:
#1 The candidate(s) considered will be asked to submit a proposal to the Saffron team and Community with a roadmap of deliverables, initiatives, and topics of focus they will prioritize between now and December 2021.

#2 The Saffron Team will provide the community an AMA (voice?) opportunity on Discord for each of the final selection of candidate(s) selected for this role. Possibly scheduled 1 week after the candidates have submitted their proposals/roadmaps. Maybe this request could be pared back to submitting questions, but I feel that a “town hall” type event could help galvanize and engage the core community.

#3 The Saffron team will submit a final hiring proposal specifying their choice of candidate (or choice between 2-3 candidates) and allowing for discussion (here in temperature check/consensus and then in Snapshot) to the Community with the final vote in Snapshot deciding whether or not to hire a specific candidate.

I think my requests don’t effect the proposal as it stands. I think they only further enhance the commitment and cohesiveness between team and community going forward with governance.

Looking forward to Saffron establishing presence and leadership in the vacuum of DeFi regulatory consideration and compliance.

Great job team!

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