Infrastructure Intermediaries and Facilitators in the Crypto Ecosystem: New Targets of Regulatory Pressure and Boundaries of Liability
This report analyzes the expansion of legal liability to technical intermediaries within the crypto industry, including validators, protocol developers, and node providers. The research focuses on the concept of “facilitators,” which international regulators increasingly use to assign guilt to participants who provide only the technical functionality of networks. The author details the risks of criminalizing software code, the problem of “protocol neutrality,” and the consequences of forcing infrastructure players to perform financial control functions. Special emphasis is placed on the threat to decentralization and technological sovereignty in an environment where the technical layer of the blockchain becomes a tool for global enforcement and transaction censorship.
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