TL;DR
- A fundamental gap exists between philosophical principles and executable code, and simple conceptual frameworks alone cannot secure actual regulatory enforcement.
- Informational EIPs define “what should be done” but suffer from structural limitations in presenting “how to implement”.
- Regulatory authorities require actionable technical means, not recommendations, which must be implemented at the code level.
- The need for an independent Standards Track EIP stems from ensuring legal enforceability, automated execution, and interoperability.
Why a Security Token EIP Must Go Beyond Philosophy
In our previous research, we established the theoretical foundation for regulatory enforceability through the philosophical concept of Selective Decentralization. The insight was that decentralization is not an absolute value, and intentional, limited centralization in areas requiring regulatory compliance can create greater value.
However, what we faced in reality was the harsh gap between philosophical elegance and technical reality, one that only a dedicated security token EIP can bridge. No matter how sophisticated a theory may be, if it cannot be executed, it remains merely academic discourse.
The Tornado Cash sanctions case starkly illustrates this dilemma. Regulatory authorities had clear sanctioning intent, but there were no technical means to actually freeze assets or block transactions at the smart contract level. They were ultimately forced to rely on the indirect method of frontend blocking.
“The most elegant theory is useless if it cannot be executed. What we need is not philosophy but code.”
– Oraclizer Core Team Internal Discussion
The Structural Dilemma of Informational EIPs
Informational EIPs inherently possess the characteristics of “guidelines”. They present conceptual frameworks, define design principles, and recommend best practices. While this is certainly a valuable contribution, it reveals fundamental limitations in the context of regulatory enforceability.
Philosophical Principles
- ✓ Selective Decentralization
- ✓ Regulatory Compliance Theory
- ✓ Asset Control Frameworks
- ✓ Governance Models
Executable Code Required
The Legal Difference Between Recommendation and Enforcement
In regulatory environments, a critical difference exists between “Recommendation” and “Enforcement”. What financial regulatory authorities require is not “it would be good to do this” but rather “this must be done” certainty.
For example, even if an Informational EIP states that “implementing asset freeze functionality is desirable,” this does not mean that the functionality is actually implemented in a form that can be legally recognized in court. Specific interface definitions, authority management systems, and audit trail mechanisms must be standardized at the code level to have legal effect.
The Inherent Powerlessness of Standards Without Code
The principle of “Code is Law” exists in the blockchain ecosystem. No matter how sophisticated the documentation, what actually operates is the code.
The problem with Informational EIPs is the lack of specific guidance on implementation methods. Different development teams can read the same Informational EIP and implement it in completely different ways, which seriously undermines interoperability.
Real-world Case Analysis:
- ERC-1400 Ecosystem: Conceptually aimed for a unified security token standard, but actually fragmented into ERC-1594, ERC-1410, ERC-1643, ERC-1644, etc.
- Lack of Compatibility Between Implementations: Sharing the same philosophy doesn’t mean they can interact at the code level
- Regulatory Authority Confusion: Difficulty in determining which implementation actually meets regulatory requirements
Actual Requirements of Regulatory Authorities
What we discovered through conversations with various regulatory authorities is that what they want is not abstract principles but concrete, actionable technical means.
The Need for Automated Regulatory Enforcement
Regulatory enforcement in traditional financial systems is a manual and time-consuming process. Even when court orders are issued, several intermediate steps must be taken before actual asset freezing, creating risks of assets being moved or hidden during this process.
In blockchain environments, immediacy and irreversibility become even more important. The speed at which assets move in distributed networks is incomparably faster than traditional finance, and once an incorrect transaction is confirmed, it becomes difficult to reverse.
Therefore, what regulatory authorities need is:
- Immediately executable asset freeze mechanisms
- Atomic execution guaranteed cross-chain regulatory measures
- Tamper-proof audit trail records
- Authority-based access control systems
On-Chain Evidence and Audit Trails
One of the most important elements for regulatory authorities is evidence admissibility that can be recognized in court. Existing oracle systems mainly focus on delivering price information or event data, failing to meet the strict audit standards required in regulatory contexts.
Required Audit Functions:
- Timestamps and digital signatures for all state changes
- Records of regulatory authority identity and authorization verification
- Documentation of transaction cancellation or modification rationale and legal basis
- Synchronization proofs for ensuring cross-chain consistency
These requirements must be defined as legally binding standard interfaces, not simple recommendations.
The Necessity of Standards Track
Now it becomes clear why an independent Standards Track EIP is necessary. Transforming philosophical principles into technical reality goes beyond the role of Informational EIPs.
Informational EIP
Characteristics
- Conceptual Framework
- Guidelines & Best Practices
- Design Principles
- Recommendations
What It Provides
“Consider implementing KYC”
“Recommended approach is…”
Standards Track EIP
Characteristics
- Executable Interfaces
- Specific Implementation
- Standardized Functions
- Enforceable Code
What It Provides
function verifyKYC()
function enforceCompliance()
Implementable Interface Definition
The core value of Standards Track EIPs lies in clear and specific interface definitions.
interface IRegulatoryEnforcement {
function emergencyFreeze(address asset, bytes32 orderId) external;
function conditionalSeize(address asset, uint256 amount, bytes calldata evidence) external;
function crossChainRecover(uint256[] memory chainIds, address[] memory assets) external;
}
Through such interface standardization:
- Developers can implement regulatory compliance functions in a consistent manner
- Regulatory authorities can interact with systems in a predictable way
- DeFi protocols can safely integrate regulatory-compliant tokens
Legally Binding Smart Contracts
Standards Track EIPs are not simple technical specifications. They are blueprints for smart contracts that can operate in legal environments.
For example, regarding asset freeze functionality:
- Authority Verification: Who can issue freeze orders?
- Procedural Compliance: What procedures must be followed for valid orders?
- Time Limits: How long can freezes be maintained?
- Appeal Mechanisms: What are the protest mechanisms against freeze decisions?
All these elements must be clearly defined at the code level to become systems that regulatory authorities can trust.
Benefits of Interoperability and Standardization
Most importantly is ecosystem-wide interoperability. Regulatory compliance is not an individual project issue but directly connected to the trustworthiness of the entire blockchain ecosystem.
Through Standards Track EIPs:
- DeFi protocols can safely accept regulatory-compliant tokens as collateral
- Regulatory authorities can manage all compliant tokens through consistent interfaces
- Developers can utilize proven standards without reinventing the wheel
The Complexity of Technical Implementation
Actually implementing regulatory enforceability is much more complex than establishing philosophical principles. Let’s examine the technical challenges we face.
Hierarchical Authority Management
Simply saying “regulatory authorities can freeze assets” is insufficient. Actual implementation must handle complex authority hierarchies:
- Global vs Regional Regulatory Authorities: What are the priorities when conflicting orders exist?
- Temporal Authority: Regulatory authority valid only during specific time periods
- Conditional Authority: Authority exercisable only when specific conditions are met
- Delegation Systems: Mechanisms for regulatory authorities to delegate authority to other agencies
Ensuring State Consistency
Regulatory measures in cross-chain environments are particularly complex. When the same asset exists on multiple chains, regulatory measures must be applied simultaneously across all chains.
This requires:
- Atomic cross-chain execution mechanisms
- State synchronization verification systems
- Partial execution prevention safeguards
- Rollback mechanism implementation
Balancing Performance and Security
Regulatory enforceability functions must operate immediately in emergency situations while simultaneously preventing abuse. This presents the following technical challenges:
- Immediate Execution vs Verification Time: Balance between fast execution and thorough verification
- Gas Optimization: Economically executable cost structures even in emergency situations
- DoS Attack Prevention: Preventing malicious actors from abusing regulatory systems
- Privacy Protection: Balance between regulatory measure transparency and personal information protection
Technical Implementation Complexity
From Simple Concept to Complex Reality
“Regulators can freeze assets”
Define functions, parameters, return values
Global vs Local, Delegation, Time-based
Synchronized execution, State consistency
- Multi-sig requirements
- Role-based access
- Time-locked permissions
- Cross-chain sync
- Atomic operations
- Rollback mechanisms
- Immutable logging
- Legal evidence
- Compliance reports
- DoS prevention
- Gas optimization
- Privacy protection
Each layer adds exponential complexity. Standards Track EIP provides the blueprint to manage this complexity systematically.
Steps Toward the Future
The reason we are starting Standards Track EIP development is clear. Philosophical principles alone cannot earn the trust of regulatory authorities and cannot provide the reliability and certainty required by actual financial markets.
Going forward, we will complete actionable regulatory enforceability standards through the following steps:
- Core Interface Design: Specific implementation of six granular regulatory actions
- Authority Management System: Development of hierarchical regulatory authority models
- Cross-Chain Execution: Atomic cross-chain regulatory measure mechanisms
- Audit and Monitoring: Tracking systems that meet legal requirements
- Reference Implementation: Providing actual working code and test cases
The important point is that this is not the abandonment of philosophy but the implementation of philosophy. The principles of *Selective Decentralization* remain valid, and we are transforming them into actually working code.
Harmony Between Technical Innovation and Regulatory Compliance
Many people view regulatory compliance as a constraint on technical innovation, but we see it as an opportunity for greater innovation. True innovation is not about completely ignoring existing systems, but about recognizing the value of existing systems while presenting better methods.
Implementing regulatory enforceability at the code level means:
- Traditional financial institutions can adopt blockchain with confidence
- Regulatory authorities can cooperate instead of being hostile to new technology
- Developers can build safer and more trustworthy systems
Conclusion: Philosophy Proven Through Code
The journey from philosophy to reality is an unfinished story. Our starting Standards Track EIP development means not the completion of theory but the beginning of practice.
In upcoming research, we will share the specific design and implementation process of each module. We will honestly share not only successes but also failures, frustrations, and insights gained from the process.
Understanding why regulatory enforceability requires an independent standard is not simply due to technical necessity. This is a necessary process for blockchain technology to become truly mature financial infrastructure.
Our goal is to create a world where philosophy and code harmoniously blend together. There, the ideals of decentralization and the reality of regulation do not oppose each other, but rather complement each other to create greater value.
In our next research, we will begin the process of implementing this vision with actual code. Please join us in witnessing the moment when philosophy becomes reality.
References
[1]. Financial Action Task Force. (2021). Updated Guidance for a Risk-Based Approach for Virtual Assets and Virtual Asset Service Providers. https://www.fatf-gafi.org/publications/fatfrecommendations/documents/guidance-rba-virtual-assets-2021.html
[2]. Ethereum Improvement Proposals (EIPs) https://github.com/ethereum/EIPs
[3]. Informational EIP: Author Handbook https://ethereum-magicians.org/t/informational-eip-author-handbook/11754
[4]. Securities and Exchange Commission. (2024). Framework for Investment Contract Analysis of Digital Assets. https://www.sec.gov/corpfin/framework-investment-contract-analysis-digital-assets
[5]. Bank for International Settlements. (2024). Central Bank Digital Currencies and Regulatory Frameworks. https://www.bis.org/publ/bppdf/bispap125.pdf





