Berlin 4.0

The Berlin 4.0 DARTE session took place on June 16th, 2025, at Spielfeld Digital Hub, during Berlin Blockchain Week. Organized with the support of the European Commission, Project Catalyst, 1inch, Blockchain for Good Alliance, and Spielfeld, this roundtable brought together regulators, legal scholars, compliance professionals, and technical experts to examine the intersection of MiCAR and decentralized finance.

The session featured three focused discussions: Peter Großkopf (AllUnity) addressed the legal distinction between DeFi tech providers and regulated crypto-asset services; Alireza Siadat (1inch) examined native DeFi risk management strategies; and Marina Markezic (EUCI) explored the regulatory treatment of user interfaces and front-end decentralization. Glenn Tan (Blockchain for Good Alliance) concluded the session with a keynote on DeFi’s potential impact on the real economy.

The Berlin 4.0 edition continued DARTE’s mission to foster legal clarity in Europe’s evolving digital asset landscape, highlighting both the regulatory blind spots and the innovation potential within DeFi architectures.

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Tech Providers vs. Crypto-Asset Services

This session explored the regulatory ambiguity surrounding the role of DeFi infrastructure providers, such as self-hosted wallets and front-end interfaces, and whether their services fall under MiCAR's definition of crypto-asset services. The session outlined how user experience design, fee structures, and access facilitation could unintentionally classify neutral tools as regulated services. Participants stressed the risk of regulatory overreach if technical providers are held to the same standards as custodial intermediaries, especially in the absence of harmonized EU guidance.

Call to Actions

Clarify the scope of MiCAR for non-custodial interfaces, including wallets and front-ends.
Promote function-based regulatory tests that assess control, discretion, and access to user funds.
Create EU-wide sandbox mechanisms for interface providers to engage with regulators pre-licensing.

DeFi Security and Risk Management

This session, focused on the need for native security and compliance frameworks within DeFi ecosystems. Participants examined how protocols can build effective defenses, such as wallet screening, malicious token detection, and real-time monitoring, without compromising decentralization. Case studies illustrated how voluntary coordination between DeFi projects and regulators has helped mitigate risk, offering a middle path between self-regulation and formal enforcement.

Call to Actions

Encourage the integration of on-chain/off-chain intelligence tools into DeFi platforms.
Support the development of open-source, non-custodial risk mitigation infrastructure.
Foster structured collaboration between DeFi protocols and regulators to shape realistic compliance models.

DeFi Interfaces and Front-End Regulation

This session, examined the increasingly pivotal role of DeFi user interfaces, such as web apps and wallet portals, as potential regulatory touchpoints. While backend smart contracts may be decentralized, front-end gateways are often controlled by identifiable entities, making them susceptible to enforcement. Participants debated decentralization strategies for front-ends and stressed the importance of defining legal boundaries for interface operators within MiCAR.

Call to Action

Recognize the decentralization of interfaces as critical to protocol neutrality and user sovereignty.
Promote adoption of decentralized hosting solutions (e.g., IPFS, Swarm) to ensure resilient access.
Define clear legal thresholds under MiCAR for when front-end operators become regulated entities.