Executive Director @pgpzcash; Founder and CEO @accrediv (inactive); ex @fs_vector; ex @digitalchamber; Cat dad, husband, New Jerseyan
Washington, DC
Joined November 2017
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Divij Pandya retweeted
Hi everyone, here's this week's update.
Originally posted at Weekly Policy Memo: November 2, 2026 | PGPZ Community (pgpz.org/updates/2026-11-02-…).
This week's policy memo covers the U.S. midterm elections; SEC staff providing clarity on ecosystem centralization; HFSC Dems working on a new market structure proposal; an upcoming SEC proposed rule on broker-dealers and recordkeeping undergoing review ahead of public release; and FinCEN and the Federal Reserve withdrawing their 2020 rule that proposed lowering amount threshold required for certain data collection.
Key Takeaways
Democrats have won control of the U.S. House of Representatives and the U.S. Senate, according to election reporting, setting up a divided government when the 120th Congress begins on January 3, 2027.
SEC staff added three crypto-asset FAQs on November 2. For the Commission’s “digital commodity” interpretation, unaffiliated participants in broad-based governance generally are not considered a controlling group merely because they vote, including through a foundation, absent a separate agreement to coordinate.
House Financial Services Democratic staff are developing an unpublished market-structure proposal drawing on Rep. Maxine Waters’ 2025 Crypto Investor and Consumer Bill of Rights amendment and subsequent Senate negotiations.
A key agency tasked with reviewing regulatory proposals received an SEC proposal regarding broker-dealer financial recordkeeping and reporting, among other things. It concerns how registered firms safeguard customer assets, maintain financial resources, and preserve records when handling crypto assets.
FinCEN announced that it and the Federal Reserve are withdrawing their October 2020 proposal on funds-transfer recordkeeping and the Travel Rule. The proposal would have lowered the relevant threshold from $3,000 to $250 for transfers beginning or ending outside the United States, and expressly addressed convertible virtual currencies and digital assets with legal tender status.
Action Item
Please reach out if you have questions about the midterm election results and the impact on the Zcash ecosystem.
November 2026 Midterm Elections Update:
Democrats have won control of the U.S. House of Representatives and the U.S. Senate, according to election reporting, setting up a divided government when the 120th Congress begins on January 3, 2027. President Trump will remain in office.
The 120th Congress is an opportunity to educate new and incumbent lawmakers about Zcash, financial privacy, self-custody, and developer protections, but it will be an uphill battle given the growing backlash towards crypto, particularly “big crypto.” Prominent Democrats have already previewed that the next two years will be marked by investigations into the Trump administration, and that includes crypto companies affiliated with the administration and Trump family.
Read the full article on the Zcash Community Forum (forum.zcashcommunity.com/t/n…) or on X (teapawt.net/pgpzcash/status/211813…).
Why this matters for Zcash:
For the Zcash ecosystem, the most consequential outcome is the forthcoming change in House and Senate committee leadership. Leadership decides which bills move forward and what those bills must contain. Our assessment is that broader crypto legislation, such as market structure legislation, will face tougher negotiations, while scrutiny of financial privacy and illicit finance are likely to increase. Narrower agreements on developer protections and other issues remain possible, but this will be more difficult to achieve, particularly when compared against the CLARITY Act negotiations, which saw the removal of key Blockchain Regulatory Certainty Act (BRCA) provisions. The BRCA clarifies that noncustodial blockchain developers are not money transmitters under the Bank Secrecy Act, and an important part of the legislation that shielded blockchain developers from criminal liability was removed prior to the Senate’s September 15 procedural vote.
Action Item:
Please reach out if you have questions about the midterm election results and the impact on the Zcash ecosystem.
X Post of the Week:
@zcash teapawt.net/Zcash/status/211853433…
SEC Staff Distinguishes Independent Governance From Centralized Control
sec.gov/about/divisions-offi…
The SEC’s Division of Corporation Finance added three crypto-asset FAQs on November 2. For the Commission’s “digital commodity” interpretation, unaffiliated participants in broad-based governance generally are not considered a controlling group merely because they vote, including through a foundation, absent a separate agreement to coordinate. Delegation can still be relevant. Staff identifies unilateral authority over access, voting procedures, consensus participation or transaction reversal as evidence of oversight. It also distinguishes a system’s functionality from decentralization. The clarification offers a more specific framework for assessing control, but remains nonbinding staff guidance, creates no new obligations.
Why it matters for Zcash:
For the ecosystem, the practical inquiry is who can exercise authority over a network or application. Community voting, grant administration, and the existence of a foundation should be assessed through their actual powers and relationships. Moreover, a token-voting label alone cannot establish independence. This is relevant to evaluating governance proposals; it is not an SEC classification of ZEC or approval of a particular arrangement.
Action Item:
No action item at this time.
Relevant Post:
@propelforward teapawt.net/propelforward/status/2…
Election Results Change the Congressional Market-Structure Debate
cryptoinamerica.com/p/house-…
Crypto In America reports that House Financial Services Democratic staff are developing an unpublished market-structure proposal drawing on Rep. Maxine Waters’ 2025 Crypto Investor and Consumer Bill of Rights amendment and subsequent Senate negotiations. Discussions reportedly envisage a larger SEC role and a more limited CFTC role than the CLARITY Act, alongside consumer protection and ethics provisions. Treatment of decentralized finance remains disputed. Note that a Democratic majority would strengthen agenda-setting power, but enactment would still require negotiations with Republicans and the administration.
Why it matters for Zcash:
This is an opportunity to discuss how Zcash can promote effective consumer protection (e.g., via data minimization), lawful financial privacy, and clear distinctions between custodial intermediaries and people who publish or maintain noncustodial software.
Action Item:
No action item at this time.
Relevant Post:
@eleanorterrett teapawt.net/EleanorTerrett/status/…
SEC Crypto Broker-Dealer Proposal Enters White House Review
thedefiant.io/converge/regul…
A key agency tasked with reviewing regulatory proposals before they are published received the SEC’s proposed “Amendments to Broker-Dealer Financial Responsibility and Recordkeeping and Reporting Rules Regarding Crypto Assets.” White House review is an important procedural step toward a possible public proposal. The regulatory agenda identifies potential amendments to net-capital and customer-protection rules, together with broker-dealer recordkeeping rules. These subjects concern how registered firms safeguard customer assets, maintain financial resources and preserve records when handling crypto assets.
Why it matters for Zcash:
For registered intermediaries considering ZEC-related services, clearer capital, custody, and recordkeeping treatment could affect the feasibility and cost of offering those services. The effects will depend on the proposal’s scope and the legal treatment of the assets and activities involved. Additionally, the recordkeeping component warrants attention to data security and financial privacy.
Action Item:
No action item at this time.
Relevant Post:
@laurashin teapawt.net/laurashin/status/21186…
FinCEN and Federal Reserve Withdraw the 2020 Travel Rule Proposal
fincen.gov/news/news-release…
FinCEN announced that it and the Federal Reserve are withdrawing their October 2020 proposal on funds-transfer recordkeeping and the Travel Rule. The proposal would have lowered the relevant threshold from $3,000 to $250 for transfers beginning or ending outside the United States, and expressly addressed convertible virtual currencies and digital assets with legal tender status. The withdrawal notice is scheduled for Federal Register publication on November 9, when it becomes effective.
The agencies cite the age of the proposal, changes in digital asset markets and emerging legal frameworks, and the value of fresh public input before adopting similar amendments. They will not finalize this NPRM, and any renewed proposal would require another opportunity for comment. The notice records concerns about compliance costs, remittances and retention of personally identifiable information. Existing recordkeeping and Travel Rule obligations remain in place. The action removes a pending expansion of information collection rather than creating a general exemption for crypto transactions.
Why it matters for Zcash:
Avoiding a lower threshold limits an additional source of identity data collection and transmission by covered institutions. That is relevant to Zcash users who interact with regulated services, because unnecessary copies of sensitive information can increase exposure to breaches and misuse.
Action Item:
No action item at this time.
Relevant Post:
@ADLXBT teapawt.net/ADLXBT/status/21187309…
Hacks and breaches have been on the rise, but I'll admit I didn't have this one on my bingo card. We really need to rethink data minimization and how we protect financial privacy.
This is huge not only because of the individuals and companies that work with Chainalysis but also because they partner with the U.S. government, among others.
I guess this explains why I can't respond to @MindsFiction's vitriolic attacks against members of the Zcash community. Was it because I challenged the assertions, called out misinformation, and tried to have a civil discussion?
I thought this was the town square though? What happened?
1) everything you’ve been saying to try to smear Paul and ZCG is categorically false.
2) these types of personal attacks say more about you than anyone else.
3) ZECsy’s work is lawful. Things you disagree with aren’t illegal and there’s no legal exposure with what they’re doing (not legal advice).
4) stop with the vitriole and have a real discussion without resorting to personal attacks and inflammatory posts. (Unless you’re willing to admit you’re incapable of doing so.). It reflects poorly on the ecosystem.
5) nobody speaks for the ecosystem. That includes you.
6) go touch some grass, dude.
🙌🏽🙌🏽🙌🏽 engaging people and meeting them where they are is so undervalued as an effective way to onboard people, especially being able to answer questions and provide feedback instantly.
Much appreciation for the educational and marketing work @rollergirlVi and the rest of the ZECsy team is doing.
Importantly, their train-the-trainer model is super important for getting others onboarded, particularly marginalized groups and the debanked.
Come discuss using @Zcash in concert with other cryptocurrencies to FULLY escape the bondage of surveilled and abusive fiat banking regimes and monopolistic payment processing legalized crime rings.
Maybe that was harsh. We can also just talk about getting no-coiners onboard. :)
Divij Pandya retweeted
A decade ago, in 2016, I went full time in Washington working on crypto policy. Since then, I’ve helped build two national crypto trade associations and worked with quite literally hundreds upon hundreds of companies across seven Congresses, from the 114th to the incoming 120th.
That spans the presidencies of Obama, Trump 1, Biden, and Trump 2, and the SEC chairmanships of Mary Jo White, Jay Clayton, Gary Gensler, and Paul Atkins.
I’ve worked with Republicans and Democrats through all of it. Last night’s results don’t change the need to keep doing that.
Bad actors, and the groups that enable them, will be held accountable. Good actors should have clear rules and room to build.
The show goes on.
Divij Pandya retweeted
You protect your passwords. Why expose your money?
Zcash brings privacy to digital money, because your financial life shouldn’t be an open book.
Privacy isn’t a privilege. It’s security.
$ZEC
A barista lost her life savings in a spear phishing attack. They preyed on her kindness and willingness to help others. This kind of scam unfortunately has no recourse. The EFTA does nothing for her here.
And then Zcash entered the chat.
I’m so proud to advocate for shielded transactions that will help Sarah protect her assets from prying eyes, self-custody that will help Sarah keep her funds safe, and, use of Zcash for payments, which means credit card processing fees won’t eat away at these tips.
There are some phenomenal upgrades that will make Zcash even stronger and more competitive coming to wallets soon that could not be possible without developers obsessing over how to improve the technology.
Beyond grateful for what this technology enables and that I have the privilege of educating policymakers and regulators about it.
update @zooko: sarah has now received 20.37 $ZEC (~$25K) in shielded donations
19 deliveries straight to her shielded zcash wallet in under 10 hours, every one with a memo saying it came from solana:4LT4uDp694w7soJerjRjSEVr2884J33EjLNG1WGzcash on sapling.cash. another 0.76 $ZEC is on its way right now
every delivery, with its zcash and solana receipts: sapling.cash/payout?coin=4LT…
this is what zcash-native means
Divij Pandya retweeted
Feeling a bit blindsided...
@zodl_co gave out ZEC gift cards at the Cypherpunk Policy Dinner and t-shirts at Zcon, @ZcashFoundation had awesome t-shirts and tumblers and @zcashbrazil had an amazing swag bag at Zcon, and @zReadyMouse (ZECsy) has ZipZap + stickers and tote bags.
Enough is enough.
Mark my words, PGPZ is going to dominate the swag arms race in 2027.
Great work experience, learning from a great team, AND getting paid for it? Stop setting the bar so high, guys...sheesh.
Hyperliquid Policy Center is hiring Legal Interns for Summer 2027.
If you’re a rising 2L or 3L, join our team in DC to work on the legal and policy questions shaping how Americans access onchain markets.
Apply here: linkedin.com/jobs/view/44821…
I've loved reading about @zooko tipping his local barista with $ZEC. People accepting it and expanding adoption should be celebrated. Hope she gets one hell of a welcome. But also, so happy to see she's not losing a portion of her tips to credit card processing fees.
Divij Pandya retweeted
about this time one year ago, i officially joined @Zcash as global ambassador.
i thought i'd spend most of my time creating content, educating people about privacy and organizing a few events. i had no idea how much this journey would change me.
before Zcash, i'd spent years trading, managing communities, writing and working with different crypto projects. but looking back now, i realize i'd been playing small, because over the past year, i've done things i never imagined myself doing.
from speaking about crypto on a big stage for the first time at Women in DeFi, an event with over 1,500 attendees, to bringing an idea like Proof of Privacy to life and watching it grow into something much bigger than i'd anticipated, it's been a year of pushing myself beyond what i thought i could do.
i've organized contributor workshops, led IRL onboarding initiatives, hosted community conversations and created opportunities for more people to get involved in Zcash. but what makes me happiest is seeing people who came into the ecosystem through these initiatives go on to become contributors and advocates themselves.
looking back, i realize there was so much more to me than i'd given myself credit for, and i owe a lot of that growth to the autonomy, trust and support i've received in this ecosystem.
having the freedom to identify problems, explore ideas and actually build solutions brought out a side of me i hadn't fully explored.
this year has also changed how i think about community building. it's so much more than getting people to join a community or download a wallet. it's about understanding what matters to them, giving them reasons to participate and creating opportunities for them to grow.
i'm incredibly grateful to everyone who's supported, collaborated with and believed in me throughout this journey. most especially the incredible people at @ZecHub, @zksquirrel , @theKroyX , @dismad8, @vitozkp, it’s been a blessing knowing and working with you.
there's still so much i want to learn, so many people to reach and so much more i want to build, especially through deeper technical learning and more collaborations.
one year later, i'm proud of what we've accomplished, but even more grateful for the person this journey has helped me become.
here's to another year of building, learning and advancing privacy together. 🥂
Divij Pandya retweeted
Hi everyone, here’s last week’s update.
Originally posted at pgpz.org/updates/2026-10-26-…
This week’s policy memo covers FATF’s targeted reviews of member countries for crypto compliance and the IRS including crypto in planned changes to voluntary tax disclosure.
Key Takeaways
- FATF adopted targeted reviews to accelerate countries’ implementation of crypto AML standards. Results are due in June and October 2027.
- The IRS is reportedly preparing lower penalties and faster voluntary-disclosure procedures. The final terms remain unresolved.
Action Item
- Invite friends and colleagues to join the PGPZ Community and Coalition.
October Monthly Update
The Cypherpunk Policy Dinner was a great success, and we were fortunate to have former SEC Commissioner Hester Peirce join us. Thank you to everyone who participated and helped make it happen.
At the DC Privacy Summit, we also had productive conversations with attendees from other organizations about potential collaboration to advance financial privacy.
Zcon7, this year’s Zcash-focused conference, provided another valuable opportunity to build on this work and connect with advocates across the ecosystem.
Why this matters for Zcash:
These relationships create opportunities to connect policy advocacy with the experiences of people building and using privacy technology. They can support better-informed education and future collaboration on financial privacy across the ecosystem.
Action Item:
Help us spread awareness by inviting friends and colleagues to join the Community and Coalition.
X Post of the Week:
teapawt.net/Zcash/status/211551016…
FATF Launches Targeted Reviews of Crypto Compliance in Major Jurisdictions (cointelegraph.com/news/fatf-…)
The Financial Action Task Force announced it will undertake targeted reviews focused primarily on jurisdictions with materially important virtual asset service provider (VASP) activity, taking their existing assessment status into account. The reviews will supplement regular mutual evaluations, with accelerated follow-up and reporting intended to address implementation gaps. Initial results are scheduled for June 2027, followed by further results in October 2027. The announcement did not identify the jurisdictions to be reviewed or specify their number.
The process has been adopted. Its practical effect will depend on national authorities’ responses, including licensing, supervision and enforcement of existing standards. FATF’s July assessment found continuing enforcement gaps even where Travel Rule legislation had been enacted. The new timetable increases pressure to demonstrate effective implementation, but it does not itself create a new domestic reporting duty or an asset-specific prohibition.
Why it matters for Zcash:
The primary impact could arise through exchanges, custodians, and other service providers that support ZEC. Stronger supervisory expectations may change their compliance costs, customer-information practices and willingness to support privacy-preserving activity. Those effects will vary by jurisdiction and by the functions a business performs.
Action Item:
No action item at this time.
Relevant Post:
teapawt.net/FATFNews/status/211622…
IRS Plans Changes to Voluntary Tax Disclosure Including Digital Assets (cointelegraph.com/news/irs-p…)
IRS Criminal Investigation Chief Jarod Koopman said the agency aims to introduce revised voluntary-disclosure procedures before December. The reported plans include substantially lower penalties, a 120-day resolution target after required submissions are complete, and consideration of greater payment flexibility. Digital assets would use the general process rather than a separate crypto program. Specific penalty amounts were not announced.
These are reported implementation plans, not finalized relief. The IRS’s published guidance continues to distinguish willful noncompliance, which may involve criminal exposure, from inadvertent errors for which other correction routes may be appropriate. It also states that voluntary disclosure does not automatically guarantee immunity from prosecution. The significance of the planned changes will depend on published eligibility, penalty and procedural terms.
Why it matters for Zcash:
Zcash users with historical tax-reporting problems could benefit from a more predictable process for resolving them.
Action Item:
No action item at this time.
Relevant Post:
teapawt.net/accounting/status/2115…
The IRS just told a room full of tax pros it wants to make confessing your tax sins cheaper. Crypto included.
Here's what was said, and what it doesn't fix.
At the UCLA tax controversy conference, IRS Criminal Investigation Chief Jarod Koopman said a revised voluntary disclosure program is coming before December.
The goals: resolve cases within 120 days of a complete submission, substantially lower penalties, and the option to pay through installment plans or an offer in compromise.
That's real progress. Today the process can drag on for a year or more.
But read the fine print.
The IRS voluntary disclosure program is built for willful noncompliance. People whose conduct could expose them to criminal prosecution.
Most crypto investors I talk to aren't that.
A typical case: someone traded on three exchanges in 2021, used a couple of DeFi apps, lost track of transfers, and filed with whatever their software spit out.
That's a mess. It's not a crime.
There's also no separate track for digital assets, and no penalty numbers yet.
So the honest-mistake crowd is still stuck choosing between:
• Amending and hoping
• Doing nothing and waiting for a letter
• Walking into a program designed for people facing criminal exposure
That gap is exactly why I helped write Section 502 of the Digital Asset Tax Certainty Act, and why I've met with 60+ congressional offices and the Ways and Means Committee.
It creates a path for people who made unintentional crypto reporting errors to come forward and fix them. It cleared Ways and Means in September.
Faster IRS disclosure is good news. It's just the right tool for a different problem.
If your past crypto returns have gaps, step one is the same either way: rebuild your transaction history and know your number before the IRS does.
What a week.
So much appreciation and gratitude for the @ZcashFoundation and what they’ve built. This was my first #ZCon, and it’s been the best conference I’ve ever attended. Sure, it was 100% focused on #Zcash, which is naturally a reason for me to love it, but it was also intimate with strong small-group discussions. Great speakers, great conversations, great vibes.
But a lot of this week was overshadowed by subversive activity happening on X, with people saying deeply ugly things, revealing their overt and covert bigotry, and attacking and ganging up on individuals who are laser-focused on helping Zcash succeed, something everyone benefits from. Debating governance is one thing. Attacking and calling into question people’s hard work and their missions is something else. It’s embarrassing and reflects poorly on the Community that’s worked so hard to get Zcash to where it is.
Candidly, I’m physically and emotionally exhausted. It’s hard watching good, decent people—friends, new and old—get attacked in a virtual “town square.” In a real town square, if someone’s harassing you and in your face, you can walk away, get assistance from public safety officials and others, or (I don’t endorse violence) physically fight them off. How do you do that on a social media platform where the people attacking you are cowards hiding behind screens and blocking someone is your only real option? How do you discuss things meaningfully when you’re limited to 280 characters in a response? How do you even know if the responses you’re receiving are from real people?
It’s great that there’s consensus building around how to move forward with Zcash governance. Was it necessary to burn so many bridges and leave so many scars in the process?
If anything, Zcon showed me how strong and resilient this Community is, how beautifully diverse it is, and it exponentially strengthened my own sense of purpose and mission-driven advocacy. Many people’s lives and safety legitimately depend on Zcash succeeding. And that’s why we need to keep fighting. Just maybe not with each other.
Vamos.
Expanded with some additional thoughts: forum.zcashcommunity.com/t/r…
“the back channeling, bullying, and intimidation tactics are unacceptable and not going to be tolerated anymore.”
Lol, that’s rich.
No. Everything that needs to be discussed about ZCG can be, and should be, discussed in the town square.
Zcash and its community deserve this. Frankly, the stories I've heard about the bad behavior behind the scenes are disappointing to say the least. We don't need to go into the details, but the back channeling, bullying, and intimidation tactics are unacceptable and not going to be tolerated anymore.
The best preventative measures going forward are sunlight and transparency, which is to say having all conversations out in the open.