a16z crypto published Banks Don’t Need Closed Blockchains (written by Rebecca Rettig of Jito Labs). The legal reading is solid. The BSA and OFAC ask for control proportionate to identified risk, not zero risk, and no rule says a bank must own or screen the infrastructure its messages travel over. I have no argument with any of that.

HOWEVER, the conclusion does not follow. Banks are not sitting in permissioned networks because a statute traps them there. They are sitting there because that is where their trust model, their commercial agreements, investments, and their competitive advantage already live. I made this case in The Realities of On Chain Finance: Why Closed Ledgers Will Lead the Way and the last 18 months have only confirmed it.