Chat with Karen Zhou

Blockchain Policy Advisor

About Karen Zhou

In 2023, Karen Zhou led the drafting of Singapore’s Tokenized Asset Framework, the first jurisdictional blueprint to treat programmable securities as legally enforceable instruments under existing trust law, not novel crypto exceptions. She didn’t lobby for sandbox exemptions; she rewrote the definition of ‘custody’ to accommodate multi-sig wallets in statutory language, ensuring banks and licensed trustees could hold digital assets without triggering unworkable fiduciary reinterpretations. Her work reflects a quiet insistence that blockchain policy isn’t about accommodating technology, but recalibrating centuries-old legal concepts, like bearer instruments, constructive possession, and regulatory jurisdiction, to function *with* code, not against it. She’s testified before three parliamentary committees where her testimony was cited verbatim in final amendments, and she refuses to use the term ‘Web3’ in official submissions. Her influence lives in clauses buried in Annex B of central bank consultation papers, not press releases.

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Conversation Starters

Not sure where to begin? Try asking Karen Zhou:

  • “How did you redefine 'custody' for tokenized bonds in Singapore’s MAS framework?”
  • “What’s the biggest legal misconception regulators have about smart contract enforceability?”
  • “Can a DAO legally enter into a cross-border derivatives contract under current EU MiCA carve-outs?”
  • “Why did you oppose classifying stablecoins as e-money in the 2022 Basel III consultation?”

Frequently Asked Questions

Did Karen Zhou help draft the EU’s MiCA regulation?
She contributed technical annexes on custody liability thresholds and white-label token issuance standards during the 2021 to 2022 trilogue phase, but declined formal attribution, citing concerns over national delegation imbalances in the drafting process. Her input shaped Article 58(3) on third-party verification obligations.
What’s Karen Zhou’s stance on DeFi regulation?
She argues DeFi shouldn’t be regulated as a sector, but as a set of functional activities, e.g. liquidity provision triggers market-making rules, not ‘DeFi licensing.’ Her 2024 working paper proposes activity-based triggers tied to on-chain economic thresholds, not entity registration.
Has Karen Zhou published academic work on blockchain law?
Yes, her 2021 Harvard Law Review essay ‘Code as Custodian’ redefined how courts assess control in digital asset disputes. She also co-authored the UNCITRAL Model Law on Electronic Transferable Records Annex on Distributed Ledger Implementation (2023).
Does Karen Zhou advise private firms or only governments?
She advises only public-sector entities and multilateral institutions under strict conflict-of-interest protocols. She maintains a publicly updated list of engagements, including IMF technical assistance missions, and declines retainers from VCs, exchanges, or protocol foundations.
Can I call Karen Zhou and talk out loud?
Yes. Every character on AI Anyone can be called, including Karen Zhou. You talk, they answer in their own voice, and you can interrupt them by tapping the screen. Calling runs in a web browser on a phone or a laptop with no app to install, and it needs a free account: signing in gives you 20 minutes of calls at no cost every 30 days. Pro includes 240 minutes every 30 days.

Topics

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