Benjamin Lawsky

Created and implemented regulatory frameworks for trust companies and crypto service providers in New York that later served as the legal foundation for Paxos Trust Company's regulated activities. Concrete actions included issuing guidance on limited‑purpose trust charters, enforcement expectations for custody of customer assets, and AML/KYC supervisory standards. Those documented regulatory steps were applied in approvals and oversight procedures used when Paxos structured token issuance under a trust model. Provided the supervisory template for how a regulated trust must manage custody arrangements, third‑party audits and reporting obligations. By formalising expectations for reserves reporting, custodian segregation and internal controls, the framework directly influenced how tokenised asset issuers structured redeemability and reserve attestations for products like PAXG. Engaged publicly and through formal guidance documents with market participants to clarify the permissible scope of trust activities, leaving a legacy of precedent that Paxos and other firms invoked when designing compliant issuance and custody flows. The regulatory decisions made in this period materially reduced legal uncertainty around custody‑backed token issuance and shaped the operational compliance conditions under which PAXG was marketed and operated.