DEF’s March Recap

Below you’ll find a recap of what the DeFi Education Fund (DEF) has been up to in March 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.

Publishing a Coalition Letter to Defend Developer Rights

On March 26, 2025, DEF published a Coalition Letter addressed to members of Congress, co-signed by Paradigm, A16z, Coinbase, and dozens of other crypto-focused companies, kindly requesting Congress’ support in obtaining clarity on the unlawful reinterpretation of Section 1960 by the Department of Justice (DOJ).

In our collective view, the regulation by criminal indictment approach from the DOJ is inconsistent with the law and applies an overly expansive interpretation of the criminal code provision regarding operating an “unlicensed money transmitting business,” particularly as it relates to software developers.

As DEF’s Executive Director, Amanda Tuminelli, told media: “The DeFi Education Fund’s number one policy priority is obtaining Congressional clarity on Section 1960, and we are so incredibly grateful to the broad coalition of crypto industry participants that united to defend the rights of software developers and to push back on the DOJ’s misguided approach of regulation by criminal indictment…On behalf of the crypto industry, we look forward to meeting with Congressional leaders to emphasize why this issue is of the utmost importance to ensuring the successful future of technology and financial innovation in the United States.”

Click here to read the full letter. 

Submitting an Amicus Brief to the U.S. Supreme Court

On March 28, 2025, DEF submitted an amicus brief in support of Jim Harper’s petition for certiorari to the United States Supreme Court in Harper v. Werfel. As a refresher, Harper’s case relates to the IRS’s warrantless acquisition of digital asset transaction records from Coinbase through a “John Doe” summons. This case raises critical questions about whether individuals retain the Fourth Amendment right to privacy in financial data shared with third-party platforms. 

In the amicus brief, DEF argues that the IRS’s warrantless acquisition of digital asset transaction records from Coinbase violates the Fourth Amendment protection against unreasonable searches and seizures. Specifically, our brief focuses on the “third-party doctrine” – a legal principle that says if you voluntarily share information with a third party, you lose your Fourth Amendment protection over that information.

Check out the full brief, as well as a DEF blog post on the matter. 

Continuing Efforts to Overturn IRS “Broker” Rule

On March 26, 2025, the Senate voted to formally pass the “DeFi Broker” CRA, H.J. Res. 25. Another bipartisan supermajority of 70 Senators supported decentralized finance (DeFi) by voting “yea” on the resolution. 

This vote followed a vote in the House of Representatives on March 11, 2025, where they passed H.J. Res. 25, a joint resolution introduced by Representative Mike Carey (R-OH) to disapprove of the DeFi portion of the Internal Revenue Service’s (IRS) “Broker Rule.” The resolution passed the House 292-132, with 76 Democrats voting for the legislation.

The now-defunct rule would have inserted intermediaries where there are none; mandating that front-ends collect and report sensitive information on its users, causing untenable compliance costs, violating user privacy, and fundamentally exceeding Treasury Department’s statutory authority.

DEF applauds the resounding bipartisan support from policymakers who have acted to protect decentralized finance in the United States. Next, President Trump is expected to sign the legislation into law once it is presented to him, as expressed in the Statement of Administration Policy on the legislation.

Announcing DEF Leadership Transition 

On March 13, 2025, DEF announced that Amanda Tuminelli was appointed to an expanded role as DEF’s Executive Director and Chief Legal Officer.

Amanda succeeds Miller Whitehouse-Levine, who stepped down to start the Solana Policy Institute. Miller has joined the Board of DEF, and will continue to be an advocate for DeFi. 

Read more about the transition here. 

Engaging: March Content and Appearances by DEF

Blog Exploring the Delisting of Tornado Cash

On March 21, 2025, the Treasury Department’s Office of Foreign Assets Control (OFAC) officially announced the delisting of Tornado Cash from its Specially Designated Nationals (SDN) and Blocked Persons List following years of litigation on the issue. The Department has announced the delisting of the Tornado Cash front-end website, as well as smart contracts making up the protocol but did not delist developer Roman Semenov.

The same day, DEF published a blog post outlining what the delisting actually means while recapping the saga of the Tornado Cash matter. 

 “While the delisting is a positive development for the DeFi industry, more hard work remains to be done to protect software developers’ rights to build.”

Click here to read the full blog. 

Blog Exploring How DAOs are Driving Change

On March 12, 2025, DEF released a blog outlining many of the positive use cases of operating DAOs. The blog explores how many DAOs with the most beneficial impacts on the world are underrepresented in popular discourse about DAOs. The blog post delves into the various impacts these DAOs have on the communities they serve and advance.

Click here to read the full blog. 

Blog on the Impact of the Risley v. Uniswap Ruling

On March 11, 2025, DEF published an analysis of the recent Second Circuit Court of Appeals ruling in Risley v. Universal Labs (Uniswap), where the court held that Uniswap could not be held liable for third-party transactions using the Uniswap protocol’s smart contracts. As we wrote: “The Risley decision is a major win for DeFi because it reinforces the distinction between decentralized platforms for peer-to-peer transactions and the actual creators or sellers of tokens."

Click here to read the full blog. 

Op-Ed on “Broker” CRA

On March 4, 2025, ahead of the Senate’s first vote to pass the CRA to invalidate the IRS’s “broker” rulemaking, DEF’s CEO Miller Whitehouse-Levine published an op-ed outlining the massive issues with the proposed rule.

As Miller wrote: “Broadness is a weakness. Thoughtful rulemaking requires a nuanced understanding to protect Americans while simultaneously enabling technology to flourish.”

Click here to read the full op-ed. 

Chatting About the Administration’s Approach to Crypto at Tokenize.NYC

On March 17, 2025, Amanda Tuminelli spoke on a panel at Tokenize.NYC entitled “How will the US Administration's approach to digital assets evolve in the near future?” The panel also featured DEF Board Members Jake Chervinsky and Rebecca Rettig, and Cathy Yoon, General Counsel at Wormhole Foundation.

In her remarks, Amanda emphasized existential risks posed by Department of Justice actions against DeFi software developers alleging charges related to “unlicensed money transmitting businesses.” The panel also had a comprehensive conversation on DeFi, focusing on software developer liability and compliance obligations. Amanda cautioned that legislation sometimes unknowingly touches on DeFi by hanging disclosure or compliance obligations on software or developers.

Watch a recording of the panel here. 

Speaking on the Regulatory “Sea Change” at DAS

On March 19, 2025, Amanda appeared at Blockwork’s Digital Assets Summit speaking on a panel entitled “Compliance Amidst Crypto's Regulatory Sea Change” alongside former Representative Wiley Nickel (D-NC), Mike Selig from SEC’s Crypto Task Force, Joe Cutler, and Daniel Escobar.

During the panel, Amanda reiterated the need for concrete legislative wins and clear, written rules that will outlive this Administration, especially delineating what software developers can and cannot do. Amanda applauded Commissioner Hester Peirce request for information from the industry and the Token Safe Harbor Proposal, both of which highlight the need for technology neutrality and protections for software developers.

Read a recap of the panel here. 

March 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 will transfer the USDC from our multisig to our Kraken account to fund upcoming business expenses. Additionally, we are continuing to sell the our UNI tokens in the multisig in accordance with our January 2025 funding update.

Donations Received
Lobbyists	$55,018
Public Relations	$580
Policy Litigation	$27,719
Marketing
Merchandise
Operating Expense	$14,733
Payroll and Associated Taxes	$224,461
Professional Fees
Accounting	$13,385
Legal	$5,354
Other Consultants	$1,000
Transacting Fees	$6,557
Insurance	$1,953
Tax & Licenses
Other Overhead	$26,131

February Media

Print/Online

• CoinDesk: The SEC's Crypto Course Reversal

  • Amanda Tuminelli, the chief legal officer at DeFi Education Fund, a decentralized finance-focused lobbying group, said any groups in the crypto sector should be more confident they would not be sued "for a mere registration violation."

"I don't think that we've won. I won't think that we have won until there are clear final rules on the books that make it clear, that are durable wins that make it clear that the industry is going to be able to innovate and exist for years in the future," she said in an interview.

• CoinDesk: President Warming Up His Pen to Sign Resolution to Kill IRS Crypto Rule If Passed

  • "In a bipartisan, super majority vote, the Senate voted to move forward to discuss and debate the CRA resolution," noted Jennifer Rosenthal, a spokesperson for the DeFi Education Fund. "This is a tremendous step forward, and now we move to the debate before the full Senate vote."

• DL News: Crypto scores win after US Senate votes to repeal DeFi tax rule

  • “Today marks the first of many historic milestones in the regulation of digital assets in the United States in this next chapter — as we move towards the enactment of the first standalone crypto legislation,” a spokesperson for crypto lobbyist DeFi Education Fund told DL News in a statement.

“The DeFi Education Fund applauds the bipartisan supermajority of Senators who recognised the need to push back against regulatory overreach to protect Americans' freedom to choose how they transact and American innovation.”

• Decrypt: US Senate Votes to Overturn Controversial Crypto Tax Reporting Rule

  • "Today marks the first of many historic milestones in the regulation of digital assets in the United States in this next chapter—as we move towards the enactment of the first standalone crypto legislation," a spokesperson for the DeFi Education Fund, another D.C.-based crypto lobbying group told Decrypt.

"The DeFi Education Fund applauds the bipartisan supermajority of Senators who recognized the need to push back against regulatory overreach to protect Americans’ freedom to choose how they transact and American innovation."

• CoinDesk: Effort to Kill IRS Crypto Rule Clears U.S. Senate Hurdle

  • The DeFi Education Fund called the Senate development the "first of many historic milestones in the regulation of digital assets in the United States."

• The Block: DeFi Education Fund names Amanda Tuminelli as new executive director as crypto legislation gains tractions in Washington

  • Leadership is shifting at the DeFi Education Fund in appointing its Chief Legal Officer Amanda Tuminelli to become the executive director as crypto priorities gain momentum in Washington.

On Thursday, the DeFi-focused advocacy group said that Tuminelli will succeed CEO Miller Whitehouse-Levine, who is stepping down from the group to pursue another opportunity. 

• CoinDesk: Crypto's DeFi Education Fund Swaps Directors as Miller Whitehouse-Levine Moves On

  • One of the leading U.S. advocates for decentralized finance (DeFi), Miller Whitehouse-Levine, is departing his job as executive director of the DeFi Education Fund, where he'll be replaced by the group's chief legal officer, Amanda Tuminelli.

Whitehouse-Levine, a fixture in U.S. crypto circles, will remain on the organization's board, according to a Thursday announcement, and a person familiar with his plans said he'll be taking a not-yet-announced role that keeps him in the industry lobbying space.

• POLITICO: Crypto’s day of reckoning in the Senate

  • A shake-up at DeFi Education Fund — The DeFi Education Fund, an advocacy group focused on the decentralized finance ecosystem, has a new leader: Amanda Tuminelli, Declan Harty reports.

• Unchained: Most Federal Agencies Have Changed Their Tune on Crypto. Not the DOJ.

  • The ruling in the 2023 Risley v. Uniswap case, in which Uniswap and some of its investors were accused of facilitating the trades of “scam tokens” on its decentralized exchange, could also be helpful in Storm’s case. In its decision, the court said that Uniswap developers were not liable for how third parties used the software. “This is an important principle for developers of all software, including DeFi technology and infrastructure: software is a neutral tool, and it is very important for developers to have clarity on their legal liabilities,” explained Amanda Tuminelli, Executive Director and Chief Legal Officer of the DeFi Education Fund in an email to Unchained. “This same principle is at issue in the case against Roman Storm, and it will certainly be at issue for the jury at his trial next month.”

• DL News: US removes Tornado Cash from sanctions list as token jumps 60%

  • An analysis from crypto advocacy firm DeFi Education Fund noted that the Treasury department has implied it still considers Tornado Cash a sanctionable entity, as some aspects of the protocol as controlled by its developers.

“Continuing to assert that a decentralized software protocol is an entity and that developers of said protocol are themselves liable for enabling illicit activity for writing its code and making it publicly available is a flawed conclusion,” DeFi Education Fund wrote in its analysis. 

• Capitol Account: Talking Fintech in the Trump Era

  • Stepping back: The DeFi Education Fund, which has been a strong supporter of removing the sanctions, said in a blog post that the decision “minds the technological nuances of decentralized software protocols and front-end websites” and also “reaffirms something that DEF has been advocating for: immutable decentralized software cannot and should not be designated under sanctions authorities.” 

• Crypto in America: Resolution to Overturn IRS DeFi Broker Rule Could Become Law By Week's End

  • The letter, led by the DeFi Education Fund—an advocacy group focused on decentralized finance—was also signed by major industry players, including exchanges Coinbase and Kraken, crypto venture capital firms A16z, Multicoin Capital, and Paradigm, as well as self-custody companies Exodus and Ledger.

• Blockwork’s Forward Guidance: March 27, 2025

  • The DeFi Education Fund has published a letter from various industry advocates calling on Congress to correct what it calls “the DOJ’s dangerous misinterpretation of money transmission laws.”

• Cointelegraph: Crypto urges Congress to change DOJ rule used against Tornado Cash devs

  • The letter — led by the DeFi Education Fund and signed by the likes of Kraken and Coinbase — added that the Justice Department’s interpretation “creates confusion and ambiguity” and “threatens the viability of U.S.-based software development in the digital asset industry.”

• CoinDesk: U.S. House Stablecoin Bill Goes Live in Flurry of Crypto Activity on Capitol Hill

  •  In a statement, DeFi Education Fund Executive Director and Chief Legal Officer Amanda Tuminelli said the group "commends the bipartisan supermajority of Congressional leaders who voted in favor of the “DeFi Broker” CRA resolution, recognizing the severe and far-reaching consequences of the IRS’ misguided rulemaking."

• The Block: Senate votes to repeal controversial IRS rule, Trump expected to sign

  •  Calling the repeal a "crucial step towards protecting U.S. innovation and ensuring that developers can continue to build cutting-edge technologies without the burden of unclear, overreaching regulations," Amanda Tuminelli, the fund's executive director, hailed the Senate's vote in a statement on Wednesday. "The DeFi Education Fund commends the bipartisan supermajority of Congressional leaders who voted in favor of the 'DeFi Broker' CRA resolution, recognizing the severe and far-reaching consequences of the IRS’ misguided rulemaking."

• Law360: Justices Ask US To Respond To IRS Crypto Doc Seizure Case

  • In its amicus, DeFi disagreed with the First Circuit's conclusion that the kinds of records seized by the IRS in Harper's case — including his taxpayer identification number, address and account statements — were similar to the bank records in Miller.

Broadcast

• FinTech TV: Market Movers: Opening Bell

  • Interview with Amanda Tuminelli. 

Blogs/Articles/Papers

• DAOs at Work: How Blockchain-Powered Organizations Are Driving Change

• Risley v. Uniswap Ruling: A Massive Win for DeFi

• Treasury Department Officially Delists Sanctions on Tornado Cash

For up-to-date information about what’s happening in D.C. and what the DeFi Education Team is up to, please follow us on Twitter @fund_defi and subscribe to our weekly newsletter on Substack.