Blockchain Regulation Matrix
The Blockchain Regulation Matrix (BRM) establishes a framework outlining the concerns of regulating the blockchain from both the government and the consumer perspective, and in doing so, provides a pragmatic and clear approach to Web3 regulation. The BRM outlines regulation aspects of the blockchain by viewing it as a blockchain stack in many layers starting with the electricity physically supporting the blockchain at the base layer, all the way to the process of offloading crypto to fiat currency. With centralization and decentralization on either side of the matrix, the primary objective of the BRM is to understand where and how regulation of the blockchain should be developed specific to each layer.
Beginning with the electricty supporting the blockchain, as you hover over the images of each row, you'll see the specifics for that topic within that layer. The left side refers to projects that are centralized, while the right side refers to projects that are decentralized. For example, if there was an organization or business that wanted to provide electricity to miners in their area, that would be a centralized project. However, if there was a solar farm operating as a DAO that wanted to provide electricity to miners, that could be a decentralized project.
There are two illustrations of the Blockchain Regulation Matrix below, a short-form immediately below and a long-form afterwards.
Hover over the icons to preview each topic, and click any icon to pin its details — the address bar then links straight to that cell, ready to share.
The Developerdecentralized
This row applies to developers who are coding any aspect of their project relating to the blockchain.
ContestedDeveloper liability for published code is being litigated case by case (Pertsev, Storm).
Government Concerns
- Liability for publishing immutable code that others later misuse
- Pseudonymous teams shipping financial infrastructure with no accountable person
- Unmaintained critical libraries underpinning billions in value
Consumer Risks
- Anonymous developers can abandon or rug projects without consequence
- Critical dependencies maintained by unpaid volunteers with no succession
- No signal separates a careful pseudonymous team from a throwaway one
Cons to over-regulation
- Prosecuting code publication as money transmission chills open-source development broadly
- Criminalizing privacy-tool authorship outlaws a class of speech, not a class of crime
Cons to lack of regulation
- No recourse exists against anonymous developers whose code was designed to exploit
Does blockchain technology currently exist to fulfill these obligations, and if so, what is it?
- On-chain reputation and attestation systems giving pseudonymous teams verifiable histories
- Reproducible builds proving deployed bytecode matches published source
- Timelocked, multisig-governed deployments limiting any single developer's power
Current regulatory landscape
- rulingPertsev conviction (Netherlands) — EU — NL, 2024. A Tornado Cash developer held criminally liable for laundering through the protocol — the maximal developer-liability position.
- rulingUS v. Storm partial verdict — US, 2025. Conviction on one count, hung jury on others — US developer liability for published code remains unsettled.
- proposedCLARITY Act developer protections — US, 2025. Would codify that non-custodial software development is not money transmission.
Notable incidents
- Tornado Cash developer prosecutions (2023–25) — Pertsev convicted in the Netherlands (2024); Storm's US trial (2025) produced a partial verdict — the live test of whether publishing code is itself a crime.
- SushiSwap 'Chef Nomi' dev-key sale (2020) — An anonymous founder sold the dev fund overnight (later returned) — the anonymous-developer accountability problem in one weekend.