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MINUTES OF THE MARCH 22, 2023 MEETING OF THE

U.S. COMMODITY FUTURES TRADING COMMISSION’S

TECHNOLOGY ADVISORY COMMITTEE 

The Technology Advisory Committee (“TAC”) convened for a public meeting on 

Wednesday, March 22, 2023 at 12:00 p.m. at the U.S. Commodity Futures Trading 

Commission’s (“CFTC” or “Commission”) Headquarters Conference Center, located at Three 

Lafayette Centre, 1155 21st Street, N.W., Washington, D.C. The meeting consisted of three 

panels. Panel I explored issues in decentralized finance including a survey of the decentralized 

finance landscape; decentralization indicators and issues; the horizon for digital identity, privacy, 

and unhosted wallets; and exploits and continuing vulnerabilities in crypto markets. Panel II 

addressed cyber resilience in financial markets, including the cyber threat landscape. Panel III 

focused on responsible artificial intelligence (“AI”), including a blueprint for an AI bill of rights; 

responsible AI development, deployment, and use; and the emerging threat of AI-enabled cyber

attacks.

TAC Members in Attendance

Carole House, Chair, TAC and Executive in Residence, Terranet Ventures Inc., 

Ari Redbord, Vice Chair, TAC and Head of Legal and Government Affairs, TRM Labs 

Hillary Allen, Professor of Law, Associate Dean for Scholarship, American University, 

Washington College of Law 

Nikos Andrikogiannopoulos, Founder and Chief Executive Officer, Metrika

Dan Awrey, Professor of Law, Cornell Law School 

Christian Catalini, Co-Founder and Chief Strategy Officer, Lightspark 

Todd Conklin, Deputy Assistant Secretary of the Treasury for Office of Cybersecurity and 

Critical Infrastructure Protection, U.S. Department of the Treasury 

Jonah Crane, Partner, Klaros Group 

Sunil Cutinho, Chief Information Officer, CME Group 

Cantrell Dumas, Director, Derivatives Policy, Better Markets, Inc.

Timothy Gallagher, Managing Director, Cyber Risk and Investigations, Kroll 

Michael Greenwald, Global Lead, Digital Assets and Financial Innovation, Amazon Web 

Services

Dan Guido, Co-Founder and Chief Executive Officer, Trail of Bits 

Emin Gun Sirer, Founder and Chief Executive Officer, Ava Labs 

Jill Gunter, Chief Strategy Officer, Espresso Systems 

Stanley Guzik, Chief Technology and Innovation Officer, S&P Global Commodity Insights 

Jenifer Ilkiw, President, ICE Futures U.S.

Kavita Jain, Deputy Associate Director, Innovation Policy, Board of Governors of the Federal 

Reserve System

Ben Milne, Founder and Chief Executive Officer, Brale 

John Palmer, President, Cboe Digital, Cboe Global Markets, Inc. 

Michael Panfil, Senior Director, Lead Counsel, Climate Risk and Clean Power, Environmental 

Defense Fund 

Francesca Rossi, IBM fellow and AI Ethics Global Leader, IBM

Joe Saluzzi, Co-Founder, Partner, and Co-Head of Equity Trading, Themis Trading, LLC 

Michael Shaulov, Co-Founder and Chief Executive Officer, Fireblocks 
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Justin Slaughter, Policy Director, Paradigm 

Todd Smith, Director of Centralized Data Science and Analytics, National Futures Association 

Steve Suppan, Senior Policy Analyst, Institute for Agriculture and Trade Policy

Corey Then, Vice President of Global Policy, Circle 

Nicol Turner Lee, Senior Fellow and Director, Governance Studies, Center for Technology 

Innovation, The Brookings Institution 

Adam Zarazinski, Chief Executive Officer, Inca Digital

Jeffrey Zhang, Assessment Professor of Law, University of Michigan Law School 

CFTC Commissioners and Staff in Attendance 

Christy Goldsmith Romero, Commissioner and TAC Sponsor 

Kristin N. Johnson, Commissioner 

Summer K. Mersinger, Commissioner

Caroline D. Pham, Commissioner 

Anthony Biagioli, TAC Designated Federal Officer (“DFO”) 

Joe Cisewski, Chief of Staff and Senior Counsel, Commissioner Christy Goldsmith Romero 

Phil Raimondi, Senior Counsel and Policy Advisor, Commissioner Christy Goldsmith Romero

Invited Speakers in Attendance 

Kevin Stine, Chief of the Applied Cybersecurity Division, NIST Information Technology 

Laboratory, National Institute of Standards and Technology 

Alan E. Mislove, Assistant Director for Data and Democracy, White House Office of Science

Technology and Policy 

I. Opening Remarks

Mr. Biagioli called the meeting to order and welcomed all for attending. He then turned 

to Commissioner Goldsmith Romero, the TAC sponsor, for her welcome and opening remarks. 

 Commissioner Goldsmith Romero welcomed all. She stated that she was excited to hear 

the perspectives of the well-respected technology experts on the committee. She emphasized the 

need for a broad representation of stakeholder perspectives to build a safe financial system that 

harnesses the best of technology while protecting customers and financial stability. She 

introduced the TAC’s chair, Ms. House, and Vice Chair, Mr. Redbord, highlighting their work in 

digital assets. She also thanked her staff and other CFTC staff responsible for organizing the 

meeting. 

Commissioner Goldsmith Romero highlighted the key topics of the panels. First, she 

discussed responsible AI for financial markets and what that means. Responsible AI involves 

using AI technologies to improve the efficiency, accuracy, and transparency of financial systems 

while also ensuring that these technologies are deployed in a way that aligns with the interests of 

all stakeholders. Second, she stated that the TAC would discuss decentralized finance (“DeFi”) 

and its implications for our financial system. Third, she stated that the TAC would discuss how 

to plan and prepare to have cyber resilience. She described cyber resilience as the ability to 

recover quickly from minor cyber incidents and errors. Finally, she stated that the TAC would 
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also discuss various cyber incident responses and the benefits and challenges of cloud 

technology. 

 Commissioner Johnson then gave her opening remarks. She thanked the organizers and 

acknowledged the critical role of the committee. She reflected on the history of the TAC, and 

highlighted how the committee’s focus shifted after 9/11. She emphasized the need for the TAC 

to explore certain topics further, including: digital ledger technology (“DLT”) in common 

business practices, cybersecurity risks and the role of NIST standards, and AI-enabled cyber 

risks and the ethical implications of introducing AI to society. 

Commissioner Mersinger began by thanking the CFTC staff, the organizers of the TAC, 

and the presenters. She specifically acknowledged the hard work of Mr. Biagioli, the DFO for 

the TAC. She emphasized the importance of responsible innovation in the derivatives markets 

and the need to achieve a balance between market integrity, customer protection, and emerging 

technologies. She stated that learning from the public and industry leaders is the key to sound 

policymaking. 

Commissioner Pham began by thanking all the organizers and members of the TAC. 

She focused her remarks on operational resilience in the financial system in light of ongoing 

shocks and disruptions. She stated that the CFTC has direct oversight over systemicallyimportant banks and financial market utilities. She stated the CFTC and its partner the National 

Futures Association (“NFA”) both have rules to help manage the risks associated with 

operational resilience, but compliance failures should be examined and addressed, and the 

Commission should also examine if additional regulations may be necessary.

Mr. Biagioli thanked everyone for their opening remarks and turned to Ms. House and 

Mr. Redbord. 

 Ms. House thanked Chairman Behnam, the Commissioners, and CFTC staff for 

reconstituting the TAC membership. She emphasized the significance of technology in the U.S. 

economy and stated that it is a tool for both legitimate and illicit actors and that it had 

implications for a spectrum of policy issues before the Commission. She stated that she and Mr. 

Redbord were present to contribute their understanding of technology’s challenges and to help 

propose solutions to those challenges to drive responsible innovation. She stated that the 

meeting would focus on DeFi, cybersecurity, and the responsible use of artificial intelligence.

II. Panel I: Exploring Issues in Decentralized Finance

A. A Survey of the Decentralization of Finance (DeFi) Landscape and Indicators 

and Issues in Decentralization 

 Ms. House introduced Mr. Redbord, who would present a brief survey of the DeFi 

landscape. Mr. Redbord highlighted the potential for DeFi to revolutionize financial services by 

offering peer-to-peer financial services without the need for intermediaries. He discussed the 

qualities of public blockchains that contribute to the promise of DeFi, including transparency, 

traceability, and the permanence of blockchain records. He also emphasized that blockchains 
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offer improved privacy and that their programmability and smart contract execution abilities 

increase financial system access.

 Ms. House then introduced Mr. Andrikogiannopoulos, who presented further on 

decentralization indicators and issues in the context of DeFi. He discussed the historical context 

of DeFi and emphasized that modern technology, cryptography, and consensus have solved the 

coordination problem among untrusted parties. He explained how decentralization brings 

transparency, security, and greater autonomy to users. However, he also acknowledged the 

challenges of decentralization including bootstrapping, technological maturity, governance 

issues, and the interconnection of decentralized networks with traditional finance. He concluded 

by saying that the benefits of decentralization outweigh the costs, and that new tools and 

practices are needed to enable broader adoption of DeFi.

 Mr. Redbord concluded by emphasizing the growth and resilience DeFi has shown and 

noting the potential for regulatory advancements enabled by the transparency and visibility 

offered by blockchain technology. Mr. Redbord then opened the floor to question and comments 

from the TAC membership. Generally, the concerns and discussion raised in this session 

included: the risks associated with DeFi protocols; the distinction between technological 

decentralization and economic decentralization, which is not achieved as easily; the need to 

resolve hardware limitations and the need to explore new technologies such as graphene for more 

efficient processing; the use of DeFi for sanctions evasion; the potential for manipulation; and 

the vision for a truly decentralized future. 

B. Digital Identity, Privacy, Unhosted Wallets: What’s On the Horizon?

Ms. House began the discussion by highlighting NIST’s leading role in establishing

digital identity guidelines in the U.S. and how NIST is essential in finance, consumer services, 

and cryptocurrency. She discussed the need for privacy in certain transactions on public ledgers 

and new privacy-enhancing technologies. She also discussed how the concept of identity is 

complex, with different contexts requiring different types of identities. She explained the 

importance of identity-proofing and enrollment, authentication, and federation, and highlighted 

how exploitation of these aspects requires different solutions. 

Ms. Gunter then discussed the DeFi identity landscape and various identity products, 

including compliance and know your customer (“KYC”) solutions, civil resistance mechanisms, 

standards bodies, and reputation protocols. She discussed the trade-offs of various privacy 

solutions in the Web3 and DeFi space, including private payment protocols, configurable privacy 

solutions, and privacy-oriented DeFi applications. Finally, she discussed the self-custody 

landscape otherwise known as unhosted wallets. She stressed the importance of users being able 

to custody their own assets without relying on third-party custodians or exchanges. 

 

Ms. House concluded by highlighting the importance of examining technology and policy 

to establish standards and clarity in the DeFi space. She emphasized the key features an identity 

system should possess, such as portability, verifiability, equity of access, privacy, and 

recoverability. Ms. House then opened the floor to questions and comments from the TAC 

membership. Generally, the concerns and discussion raised in this session included: concerns 
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about the reliance on centralized on-and off ramps in compliance strategies; the potential shift 

towards decentralized networks; the importance of privacy for mainstream users; the role of 

regulators in encouraging decentralization and competition; the technical challenges in 

implementing privacy preserving systems; addressing unchained identity in the blockchain 

space; lessons learned from using digital assets and digital identity in humanitarian payments; 

the potential for providing access to financial services to individuals who lack traditional 

identification; skepticism about the centralization and credibility of decentralized finance; and 

the importance of control and standardization in identity solutions, including definitions. 

C. Exploits & Continuing Vulnerabilities in Crypto Markets

Ms. House then introduced Mr. Guido, who discussed the unique challenges faced by the 

blockchain industry. He emphasized the need for better security expertise and the lack of 

trustworthy information. He stated that traditional standards and practices are insufficient to 

keep up with the rapidly changing blockchain technology. The public nature of blockchain 

transactions and hacks creates a need for highly accurate safety measures. In fact, it requires risk 

elimination rather than mitigation as each hack directly impacts a blockchain firm’s finances and 

operations. He believes more research, innovation, and precise algorithms are needed to secure 

blockchain systems effectively. He also presented twelve critical security controls that can help 

assess the safety of blockchain protocols. 

 Next, Mr. Shaulov discussed three real-world hacks that occurred in the past 18 months. 

In these examples, hackers were able to: convince an IT engineer to download a malicious PDF 

file, which allowed them to access private keys and withdraw $650 million in cryptocurrency; 

target a decentralized application and insert code that tricked users into approving transactions 

for the hackers to steal $120 million in assets; and exploit a logical bug in a protocol to trigger a 

liquidation that allowed the hackers to steal $200 million. He emphasized the need to improve 

key management, transaction security, and smart contract security in the industry. 

Following Mr. Shaulov’s presentation, Ms. House moved to further consider the issues 

discussed with a motion to create a Digital Asset and Blockchain Technology Subcommittee. 

She asked for a motion, which was seconded, to establish the subcommittee. TAC members then 

briefly discussed their support for the committee and commented on the panel discussion. 

Generally, the concerns and discussions raised included: the fact that most of the hacks were 

cybersecurity-related and did not have to do with vulnerabilities on the blockchain; DeFi cannot 

be applied to different financial products with a one-size-fits-all approach; the need to examine 

front-running in the context of a DeFi environment; and an emphasis on investor protection and 

economic competitiveness.

Ms. House then called for vote on the motion and the motion to establish the 

subcommittee was unanimously adopted.

[Break] 
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III. Panel II: Ensuring Cyber Resilience in Financial Markets

A. The Cyber Threat Landscape for Financial Markets: Lessons earned from 

ION Markets, Cloud Use in Financial Services, and Beyond

Ms. House introduced the first speaker, Mr. Conklin, who highlighted the U.S. Treasury 

Department’s efforts to support cyber resilience through the Treasury Cloud Study and Report, 

which highlighted gaps and recommended follow-on items to improve the financial sector’s 

cloud adoption, including rebuilding the cyber incident communications and response playbook, 

coordinating with the private sector, and providing declassified cybersecurity information to the 

financial sector. He stated that the Treasury Department plans to establish a Cloud Services 

Steering Group to develop common definitions and terms, explore oversight of cloud service 

providers, improve contract prices, and establish NIST-centric frameworks for cloud adoption 

strategies.

B. Pillars of a Cyber Resilience Framework for Financial Markets

Ms. House then introduced Mr. Stine, who highlighted the strong relationship between 

NIST and the financial sector, and NIST’s mission to promote innovation and competitiveness 

through standards and measurements science. He emphasized the importance of risk 

management and enterprise risk management. He also discussed the NIST Cybersecurity 

Framework, a standards-based tool developed to help organizations understand, communicate, 

manage, and reduce cybersecurity risks. NIST plans to update this framework. 

Ms. House then opened the floor to questions and comments from the TAC membership. 

Generally, the concerns and discussion raised in this session included: improving incident 

response and early warning in non-cloud systems; measuring cybersecurity capabilities and 

providing more context around the impact of risks; the need for better risk management and 

modelling; and the importance of repeated testing to improve defenses against cyber attacks.

Ms. House moved to further consider the issues discussed with a motion to reestablish the 

Subcommittee on Cybersecurity. She asked for a motion, which was seconded, to reestablish the 

subcommittee. Ms. House then called for vote on the motion and the motion to reestablish the 

subcommittees was unanimously adopted. 

IV. Panel III: Responsible Artificial Intelligence (AI)

A. Blueprint for an AI Bill of Rights: Making Automated Systems Work for the 

American People

Ms. House introduced Mr. Mislove, who discussed the Blueprint for an AI Bill of Rights. 

The blueprint aims to ensure the responsible development and deployment of AI systems that 

protect the rights of the American public and uphold democratic values. The Blueprint focuses 

on five core protections for AI systems: (1) protect from unsafe or ineffective systems; (2) 

prevent discrimination by algorithms; (3) protect against abusive data practices; (4) provide 

notice and an explanation of when automated systems are being used; and (5) preserve the ability 
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to opt-out of automated systems and access human assistance. The Blueprint includes a 

technical companion that provides example and concrete steps for integrating the protections into 

the design process of AI systems. Mr. Mislove discussed the applications of the Blueprint, the 

importance of ensuring safe and effective systems, and the need for these systems to work well 

with real-world data.

B. Responsible AI Development, Deployment, and Use

Ms. House introduced Ms. Rossi, who presented on AI ethics. She began by highlighting 

the history and development of AI. She stated that since AI is used in various online activities 

and high-stakes decision-making applications, ethics is crucial. Ethical considerations include: 

data privacy, fairness, inclusivity, explainability, transparency, accountability, social impact, 

human agency, and environmental impact. She suggested a multidisciplinary and collaborative 

approach to address ethics issues. She stated that issues that arise in AI development should be 

addressed quickly and described three phases of AI development: (1) the awareness phase; (2) 

the principles phase; and (3) the current practice phase. Finally, she highlighted IBM’s approach 

in structuring its AI ethics activities around five pillars: explainability, fairness, robustness, 

transparency, and privacy. 

C. The Emerging Threat of AI-Enabled Cyber Attacks

Ms. House introduced Mr. Gallagher, who discussed threats to the nation’s financial 

infrastructure as a result of AI-enabled cyber attacks. He stated that partnerships between law 

enforcement, regulatory agencies, and private companies can mitigate these threats. He then 

discussed different types of threats, including malware and phishing attacks. He further 

expressed concerns about how AI cyber attacks are a threat to financial markets and the 

importance of public confidence. He also stated that AI can help further malign activity in 

certain instances, such as in pump-and-dump schemes, where AI can help recruit investors, 

create synthetic profiles, and generate fake news to manipulates stock prices. 

Ms. House then opened the floor to questions and comments from the TAC membership. 

Generally, the concerns and discussion raised in this session included: how a private firm can 

protect itself and individuals if it is coerced by an organization to manipulate markets using their 

AI technology; the use of AI in risk management; and the challenges of evaluating generative AI 

systems that lack specific use cases or specifications and the need to anticipate and mitigate 

potential risks and unintended consequences. 

Ms. House moved to further consider the issues discussed with a motion to establish a 

Subcommittee on Emerging and Evolving Technologies. She asked for a motion, which was 

seconded, to establish the subcommittee. Ms. House then called for vote on the motion and the 

motion to establish the subcommittees was unanimously adopted. 

V. Closing Remarks 

In closing, Ms. House thanked the presenters and Commissioners for the excellent 

discussion. Commissioner Goldsmith Romero also thanked all for their expertise. 
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Mr. Biagioli adjourned the meeting at 4:55 p.m. 

___________________________________ ___________________ 

Carole House

Chair, TAC

 Date 

20JUN2023