Key Takeaways
- A recent enforcement action on a privacy-focused chain highlighted the difficulty of implementing targeted freezes without affecting innocent users.
- Compliance systems that rely on behavioral heuristics can sometimes misidentify legitimate activity as suspicious.
- Questions about the effectiveness of asset freezes are fueling calls for stronger preventive security measures across the industry.
Privacy Chains Face a Compliance Challenge
Stablecoin freezes are bringing a core limitation of some privacy-focused blockchain systems into sharper view. Issuers may be required to isolate illicit funds, yet the underlying infrastructure can make that difficult without also disrupting legitimate users. In an interview with Bitcoin.com News, Jan Philipp Fritsche, founder of Bermuda, framed the issue as part of a broader challenge for privacy-preserving networks rather than a problem confined to one chain.
Recent enforcement actions involving stablecoin issuers responding to court orders have shown how technical design choices can turn targeted restrictions into broader disruptions. In Fritsche’s view, the Zama incident illustrates how commingled funds can complicate enforcement when a network lacks a mechanism for freezing specific assets.
“The Zama incident is the perfect example of this. Circle was required to freeze specific illicit funds on Zama Chain in response to a court order; however, Zama Chain doesn’t provide a mechanism to freeze specific funds — funds on the platform are commingled. Circle was forced to blacklist the entire cUSDC contract on Zama Chain, impacting anyone (including innocent users) who locked funds in the contract,” he said, emphasizing:
“This is a serious problem: the privacy-preserving infrastructure (like Zama Chain and Canton) that institutions are adopting are incapable of handling basic compliance processes without creating a major disruption.”
That problem is compounded when institutions rely on monitoring systems that attempt to identify suspicious conduct before or during enforcement.
The Block-All-or-Block-None Dilemma
At the center of the issue is a blunt compliance choice. If stablecoin issuers cannot distinguish targeted actors from other users within a privacy system, enforcement may shift from precise intervention to broad restriction.
He explained:
“The biggest limitation is that most privacy protocols do not enable stablecoins to selectively freeze adversarial actors; as a result, stablecoins don’t have any choice but to either block all users or none.”
Why Heuristics Remain a Weak Link
Compliance systems often rely on behavioral analysis to identify activity that appears unusual or risky. Those tools may help flag potential threats, but they do not provide certainty and can leave lawful users exposed to mistaken assessments.
“Secondly, the heuristics that platforms use to monitor for illicit activity are, unfortunately, imperfect. They are educated guesses,” Fritsche remarked.
Because these assessments are based on probability, they can turn unusual but legitimate behavior into a compliance concern. That uncertainty becomes especially consequential when a flagged pattern leads to restrictions on access to funds.
Sophisticated Criminals Can Circumvent Freezes
The effectiveness of freezes also remains in question. While asset restrictions can disrupt some activity, Fritsche argued that advanced criminal actors are often capable of adapting around them.
“It should also be noted that freezing is incredibly inefficient. Sophisticated threat actors like North Korean hackers know how to get around it,” he stated.
The concern is not only that legitimate users can be affected, but also that the most sophisticated targets may still evade the controls designed to stop them.
Could Stricter Enforcement Backfire?
Ineffective enforcement can create pressure for more restrictive rules, but additional restrictions do not necessarily produce better results. Fritsche warned that the industry could enter a cycle in which compliance burdens increase while fraud and cybercrime persist.
“Another major danger I see as a consequence of ineffective enforcement is a vicious cycle of stricter rules and worse enforcement, as we already see in traditional finance,” he said. “Stricter and stricter rules that harm legitimate users, sabotage the UX, yet do not prevent actual fraud or crime.”
Such an outcome would leave legitimate participants facing a worse user experience without meaningfully reducing illicit activity.
A Shift Toward Prevention Instead of Freezes
Rather than relying primarily on freezes after suspicious activity has occurred, Fritsche called for stronger emphasis on prevention and application security. That approach would shift the focus from reacting to illicit transfers toward reducing the vulnerabilities that allow attacks to happen.
Despite the expansion of compliance guidelines and enforcement frameworks, global cybercrime continues to rise, with annual damages projected to surpass $10.5 trillion, he noted, adding:
“We need to prevent crime before it happens and build more secure applications, rather than freezing money based on heuristics.”
Read Part 1: Your Stablecoins Could Be Frozen Without Warning, Even If You Did Nothing Wrong
