Binance and regulatory scrutiny: changing times for the crypto market

28-09-2021 | Carlo de Meijer | treasuryXL

Long-time regulators were not sure on if at all or how to handle the crypto ecosystem. But that has changed fundamentally with the crypto industry witnessing massive growth and interest from traditional institutions and major investors.


This year has been a year of increased regulatory focus of the booming crypto market. The potential for crypto exchanges to launder money has worried regulators all over the world, with US Treasury Secretary Janet Yellen and ECB President Christine Lagarde among those to voice concerns. As a result regulators and law enforcement agencies worldwide have begun to scrutinise suspect players and started to write regulations to bring those players within the blockchain arena to take control of them.

Recently the world’s largest crypto platform, Binance has come under regulatory fire. Regulators across the world are concerned over the potential for crypto to be used to launder money as well as the risks to consumers from volatile crypto trading. Most recently also DNB, the Dutch Central Bank, joined forces, saying Binance was not compliant with anti-terrorism financial law. It is unclear if this is a coordinated effort by regulators or something closer to a domino effect.

Regulatory scrutiny

Financial regulators across the world have now targeted major cryptocurrency exchange Binance. The platform has come under increased scrutiny from a growing number of regulators worldwide, including regulatory authorities from the UK, US, the Netherlands, Canada, Japan, Malaysia, Thailand, Germany, Cayman Islands, Lithuania, Hong Kong. And this group is growing.

The platform has faced warnings and business curbs from financial watchdogs who are concerned over the use of crypto in money laundering and the high risks of their products to consumers. Binance has also been accused of accepting ‘gigantic tips’ from creators of                  ‘questionable’ cryptocurrencies in exchange of receiving a privileged place on their platform.  Several countries have announced investigations in Binance and its products. While a number of countries have banned the platform from certain activities, quite a few countries have started banning it completely.

Banks are delisting Binance

Not just countries, but also a growing number of banks are cutting ties with the crypto exchange as well. Several banks or payment processors, primarily in Europe and the UK, have subsequently cut off the exchange, potentially freezing its customers’ accounts. Major banks began to ‘delist’ Binance in June and July of 2021, leading the exchange to suspend withdrawals and/or limit withdrawals dramatically on most accounts.

A number of banks, including Barclays, Nationwide, HSBC and Santander pulled Binance’s access or announced reviews of their approach to crypto at large. HSBC banned its UK customers from making any further payments to Binance, while Barclays suspended UK card payments to Binance, citing the FCA warning to customers. Also the European Union’s Single Euro Payments Area appears to have (temporarily) cut off Binance. SEPA payments to Binance were halted.

Regulators and Binance: some approaches

US
The largest of investigations is perhaps be through the US Commodity Futures Trading Commission  (CFTC), with the regulator seeking to determine whether cryptocurrency derivatives were bought and sold by US citizens on the Binance platform.  Binance is also reportedly under investigation by the US Justice Department and Internal Revenue Service (IRS). 

Cayman Islands
The Cayman Islands also challenged the lack of authorization of the exchange. Cayman Islands Monetary Authority (CIMA) said that all the entities associated with Binance are not registered, licensed, or regulated and thus not authorised to operate a crypto exchange from or within the Cayman Islands“.

UK
Last week UK’s Financial Conduct Authority (FCA) stated that it is ‘not capable’ of effectively supervising the world’s largest crypto currency exchange, Binance. They also reiterated the risk its products could pose to customers. The FCA decided to ban the exchange from conducting all regulated activity in the UK for failing to report in line with its ant-money laundering (AML) regulation. The FCA also stated that Binance has refused to answer questions about its wider global business model, and ‘refused or was unable’ to provide (high-risk financial) products offered on Binance, such as their Binance Stock token.

DNB
De Nederlandsche Bank (DNB), the Dutch Central Bank, announced that Binance is providing crypto services in the Netherlands without the required legal registration. As a result the platform was not in compliance with the Dutch anti-money laundering and anti-terrorist financing Act. And thus Binance is illegally offering services for the exchange between virtual and fiduciary currencies as well as illegally offering custodian wallets. This may increase the risk of customers becoming involved in money laundering or terrorist financing.

Japan
Considered to be among the most crypto-forward countries, Japan’s Financial Services Agency (FSA) also warned Binance. It mentioned that the crypto exchange is not registered to accept business from Japanese residents, within the country, ordering to suspend operations.

Hong Kong
Hong Kong’s Securities and Futures Commission (SFC) notified that Binance’s offering of investing in Stock Tokens is not a regulated activity. Binance has not taken any license to offer the services to HK residents.

Malaysia
In June Binance was subject to enforcement actions by the Securities Commission Malaysia for alleged illegal operations. It was ordered specifically to disable Binance.com and mobile applications in the country from June 26 onwards. It was also told to stop media and marketing targeting Malaysian consumers and to restrict access to Binance Telegram group.

Thailand
Thailand’s Securities and Exchange Commission (SEC) notified that it has filed a criminal complaint against Binance. It stated that an investigation has been launched against the exchange for operating its business without a license.

What is Binance?

Binance is the world’s largest cryptocurrency exchange platform by trading volume according to data from CryptoCompare. Notwithstanding the various measures taken it still boasts a daily trading volume of more than $25 billion, which is significantly more than its nearest competitor Coinbase ($3,5 billion). Binance also leads crypto derivatives trading, in large part by allowing people to trade crypto derivatives using high levels of leverage, or borrowed money.
Crypto exchange Binance was established in 2017 by Chinese-Canadian entrepreneur Changpeng Zhao. Binance offers trading in over 500 cryptocurrencies and virtual tokens. Thanks to its own cryptocurrency BNB the Binance platform has a large group of loyal customers. They get a discount when trading/using BNBs.The crypto exchange offers a wide range of services to users across the globe, from cryptocurrency spot and derivatives trading to loans and non-fungible tokens. It also offers services around trading, listing, fundraising and de-listing or withdrawal of cryptocurrencies. Binance’s corporate structure is ‘opaque’ (non-transparent), though its holding company is registered in the Cayman Islands, according to British court documents and Malaysia’s watchdog. This might have contributed to today’s massive regulatory scrutiny.

Measures taken/announced

Binance is undergoing big changes to appease regulators, who are unhappy with some of the exchange’s products and their compliance with local rules. Therefore they have made regulatory compliance its top priority. In the wake of the regulatory pressure from various countries

Binance announced that they will be taking drastic steps to better meet financial regulations, improve user protection and manage risks, including strengthening their compliance and legal teams, banning or scaling back products, demand stricter background checks, change the business model and improve relations with regulators.

Focus on regulatory compliance

Binance is focusing on regulatory compliance as ‘the exchange pivots from a technology start-up into a financial services company’ CEO Zhao explained.

For that they unveiled a series of measures it is going to take to become what it says is a fully compliant and licensed institution in all countries it operates in, as fully licensed competitors continue to appear.

“Compliance is a journey – especially in new sectors like crypto. The industry still has a lot of uncertainty. We also recognize that with the growth comes more complexity and more responsibility”. CEO Zhao

Strengthening compliance and legal teams

Binance is strengthening their compliance and legal teams, by hiring more staff who have relevant regulatory compliance experience as well as very senior people ‘that can bring teams in’.  Binance highlighted that the exchange has increased its international compliance team and advisory board by 500% since 2020.  Binance declared that they are planning to double the size of their compliance team within this year.

Recent appointments

Binance recently announced it was hiring a number of former regulators to its compliance and executive teams. They recently announced the appointment of Richard Teng – former chief executive officer (CEO) of Financial Services Regulatory Authority at Abu Dhabi Global Market (ADGM) – as its new CEO, Singapore.

This announcement comes barely a week after the hire of former US treasury criminal investor, Greg Monahan, as its global money laundering reporting officer (GMLRO) – a move that seeks to clear up Binance’s ongoing money laundering issues. Binance also appointed Samuel Lim, who has over 10 years of experience in compliance in investment banking, as chief compliance officer and Jonathan Farnell, with over 20 years of experience in the UK financial and payments sector, as director of compliance.

Banning or scaling back products

Binance is shifting its commercial focus to other product offerings that will better serve its users for the long term. Binance has scaled back some of its range of crypto products that regulators may oversee. To make sure that all their products are fully compliant, Binance has been limiting their futures, derivatives products in most of Europe,  with users in Germany, Italy and the Netherlands among those first affected. It has also restricted the trading of derivatives in some parts of Asia as well such as by Hong Kong users. Binance also would stop offering crypto margin trading involving the Australian dollar, euro and sterling.  

“We need to make sure that all of our products are fully compliant … This is why we’ve been limiting our futures, derivatives products in most of Europe and some parts of Asia as well.” CEO Zhao

In July, Binance also stopped offering/selling digital tokens linked to shares like Apple Inc. and Tesla Inc. after regulators raised concerns about the products for appearing to violate local securities regulations. Hong Kong’s markets regulator became the latest regulatory body to warn investors about Binance’s stock tokens. These crypto products will be unavailable for purchase on Binance effective immediately. Customers who own the tokens may sell them over the next 90 days, and Binance will cease to support the products on Oct. 14, the exchange said.

Reduce withdrawal limits

Orders from regulatory authorities in different nations have caused Binance to reduce its non-KYC withdrawal limits. In an official announcement, Binance notified customers that the withdrawal limit for users with basic verification will drop to 0.6 Bitcoin in mid-August. This is in an effort to prevent money laundering and curb broader criminal activities happening through the platform.

Stricter background checks

Pressure from regulators globally also forces Binance to demand stricter background checks on customers to bolster efforts against money laundering, with immediate effect. This should further enhance user protection and combat financial crime. Until now, document-based ID checks at Binance were only required for users seeking higher limits on trading.

Steps taken by crypto exchanges to make identity and background checks remain varied, with some demanding full documentation and others allowing users to sign up for accounts with as little as an email address. Many large platforms also require users to submit ID documents, while others only require personal information for limited access to trades.

From now on, Binance users will have to complete a verification process to access its products and services. Users will now have to upload an ID card, driver’s license or passport to prove their identity. Those who have not done so will only be able to withdraw funds, cancel orders and close positions. The move represents a major shift by Binance.

Changed business model

Binance also plans to make a series of fundamental changes in its corporate structure to ‘get back into the good books’ of the regulators in the various regions to handling increased scrutiny from regulators. The company is going to have to totally overhaul its business model by institutionalising and centralising its digital asset operations. The crypto exchange has until now had decentralized operations, meaning it doesn’t have headquarters of any sort. Instead, they will now add headquarters around the world and work towards being licensed everywhere and become compliant as much as it can in every region where it plans to operate. Each of these headquarters would have regional CEOs as well leading to a centralized authority controlling all these subsidiaries. While this goes against what cryptocurrencies stand for, it is necessary for Binance to stay relevant in many countries.

Improve relations with regulators

Binance CEO Zhao also wanted to improve relations with regulators. Zhao’s focus on regulation is seen as a sign of the changing times in the crypto world. The CEO asserted that new laws are necessary for the crypto ecosystem to support its further development.

The firm is willing to work and communicate with regulators to bring compliance into the crypto ecosystem. For that Binance will expand the team dedicated to working with authorities to ensure services are compliant with local regulations. Binance is also willing to meet regularly with regulators to proactively update them on what the firm is doing. To start, Binance would share some user data with local regulators.

“We aim to work more collaboratively with policy-makers to improve global standards and discourage bad actors,” Binance CEO Changpeng Zhao

Is this enough?

Notwithstanding the various measures announced or taken by Binance there is still a lot of sceptics around Binance real intentions. In the crypto world it is still like the Wild West with many ‘ cowboys’ operating that are averse to rules. Some argue ‘the exchange is playing smart by trying to be compliant, having multiple entities, making influential hires, and more’. Others say ‘It is a nice marketing statement, but from the regulators’ perspective, this is not enough”. For them ‘it is a questionable approach to reportedly evading rather than complying with jurisdictional regulations’.

Still, some lawyers are skeptical over whether Binance move to tighten checks would convince regulators. Regulators would need to know which of Binance’s local entities run the know-your-customer process to audit and check if it complies with local laws. “Since they are doing it on a voluntary basis, regulators do not know whether they have the authority to supervise the identity check, and no one can look whether they are doing it properly.”

It is questionable if Binance is able to face the regulatory actions from so many countries and financial watchdogs at the same time. While Binance says it is intent on cleaning up its compliance image, it will take more than a few give-ins to the regulators to resolve the numerous bans and restrictions that it currently faces.

What may we further expect?

It is tough to say whether it is a coordinated attack on Binance with all the regulatory bodies are coming together against the exchange. Considering it is the biggest crypto exchange in the world and due to its sheer size, it may be expected that many more crypto platforms will come under intensified regulatory scrutiny.

Is this the beginning of a worldwide approach to regulate the whole crypto market? As one of the oldest and largest crypto platforms Binance symbolizes for the whole crypto ecosystem. What is sure,  what happens to Binance may signal how regulators will approach crypto, with enforcement actions against the exchange hinting at what other platforms should expect.

In my mind, this is not a step-change in regulation of the ‘crypto world’. It is part of a growing trend of worldwide and collaborated regulatory intervention in crypto markets. As a consequence regulations are quickly becoming the most important aspect of any company in the cryptocurrency industry. As governments around the world continue to work towards developing regulatory frameworks for crypto, companies are constantly needing to adapt to continue operating.

 

Carlo de Meijer

Economist and researcher

 

 

 

 

Source

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Stablecoins are not that stable: what regulatory approach?

09-08-2021 | Carlo de Meijer | treasuryXL

Stablecoins are one of the newest hot spots on the crypto market. They  have the potential to enhance the efficiency of the provision of financial services including payments, and to promote financial inclusion. They might offer a new way to transact and retain value, starting to redefine modern finance. We all have seen their incredible growth in 2020 and 2021 under the DeFi market influence as I described in my former blog. Stablecoins however bear a number of risks that could harm. They are not that stable as is suggested. And think of the systemic risks when stable coins are being used all over the world. Disruptions in the value of a stablecoin could not only have damaging impact on the broader crypto market, but also on the real financial world, unless regulators step in. Main question is: what kind of regulatory oversight would work best without harming innovation?


What are stable coins?

Stablecoins are a type of cryptocurrencies that are pegged to and/or backed by the underlying real-world assets what can be anything from fiat money, commodities or even another cryptocurrency. Like their name suggests, stablecoins are designed to have value that stays (rather) stable with traditional currencies or the underlying commodities. Many stablecoins are collateralized at a 1:1 ratio with their peg, which can be traded on exchanges across the world.

Stablecoins have been created to overcome the price volatility of crypto currencies such as Bitcoin or Tether, which stems from the fact that there is no robust mechanism to determine their real-world value. Given high levels of distrust in those cryptocurrencies, investors tend to resort to safer options like stablecoins. These may leverage the benefits of cryptocurrencies and blockchain without losing the guarantees of trust and stability that come with using fiat currencies. Currently, there are more than 200 stablecoins. At the time of writing of this blog the total value of stablecoins issued on public blockchain networks has surpassed $110 billion, compared to $28 bn at the start of 2021, which reflects the high institutional and retail demand in unstable times.

Types of stable coins

Based on design, we can split stablecoins into a number of major types: fiat-collateralized, crypto-collateralized, commodity-collateralized, and algorithmic or non-collateralized.

Fiat-collateralized

Fiat-collateralized stablecoins are the simplest and most common type. They are pegged to fiat currencies like the US dollar or the Euro, and usually backed at a 1:1 ratio, by holding a basket of dollar- or euro-denominated assets. This means that for each of such stablecoin in existence, there is a fiat currency in a bank account. Traders can exchange their stable coins and redeem their dollars directly from the exchange at any time. The most popular fiat-collateralised stablecoins are Tether (USDT) (market cap $62 bn) and USD Coin (USDC0 (market cap $ 27,3 bn).

Commodity-collateralized

These are stablecoins that are backed by commodity assets, like precious metals, gold, silver, real estate, or oil. This theoretically indicates to investors that these stablecoins have the potential to appreciate in value in parallel with the increase in value of their underlying assets, thereby providing an increased incentive to hold and use these coins. One example of these stablecoins is PAX Gold (PAXG) (market cap $330 mio), that relies on a gold reserve.

Crypto-collateralized

Another type are crypto collateralized stablecoins. These are pegged to other cryptocurrencies as collateral. Because the crypto values themselves are not stable, these stablecoins need to use a set of protocols to ensure that the price of the stablecoin issued remains at $1. They are often collateralized by a diversified reserve of cryptocurrencies that can sustain shocks and yet remain stable. Another mechanism involves over-collateralization, which means for a crypto-backed stablecoin that is pegged 1:2, for each stablecoin, cryptocurrency worth twice the value of stablecoins will be held in reserve. Since everything occurs on the blockchain, these crypto-backed stablecoins are much more transparent, have open source codes, and can be operated in a decentralized manner, unlike their fiat-backed counterparts. However, they are also more complex to understand, and therefore lack popularity. The most popular crypto-backed stablecoin is Dai (market cap $56.8 mio), created by MakerDAO, whose face value is pegged to the US dollar, but is collateralized by Ethereum.

Algorithmic or non-collateralized Stablecoins

A fourth class are so-called algorithmic stablecoins, also known as non-collateralized stablecoins. This is a very different design as it is not backed by any collateral. It operates in the way fiat currencies work, in that it is governed by a sovereign such as a country’s Central Bank. Given the evident difficulties these stablecoins have at maintaining value stability their usefulness is limited.

Algorithmic stablecoins use total supply manipulations to maintain a peg. The basic mechanism is creating a new coin, setting a peg, and then monitoring the price on the exchange. This can be done algorithmically, in a decentralized way, with open source code that is visible and auditable by everyone. This so-called rebasing is a speculative investment asset where the probability of gain and the probability of loss are both greater than zero. A second category of algorithmic stablecoins are coupon-based coins. The difference from rebasing coins is that holders don’t see their number of tokens change unless they do specific actions. The downside, however, is that coupon-based coins seem to be much more unstable. Some of the more known ones include Ampleforth (AMPL), Based, Empty Set Dollar (ESD) and Dynamic Set Dollar (DSD).

How do stablecoins work?

Some central stablecoins, such as Tether, require a custodian to regulate the currency and then reserve a certain amount of collateral. Tether holds the US dollar in a bank account. The amount held must be equal to what they issue to maintain the order of the system. In this way, price fluctuations should be prevented. However, there are other stable decentralized cryptocurrencies, such as the crypto-backed stablecoin Dai that achieve this goal without a central authority figure. They use smart contracts on the Ethereum blockchain to manage the collateral and maintain order. Stablecoins automatically adjust the number of tokens in circulation to keep the price stable. This means that the value of stable coins should (in theory) not fluctuate frequently, as in normal crypto assets.

Why are stablecoins used?

Stablecoins are used in the crypto market for a number of reasons. Crypto currency owners may turn profits into stablecoins in the short term with the intention of investing in other cryptocurrencies when opportunities arise, rather than turning profits into fiat money and transferring them to their bank account.

Stablecoins are also invested in cryptocurrency exchanges or decentralised finance (DEFI) applications to return interest and yield. Investing in crypto currency exchanges in particular offers a safe and attractive alternative to traditional savings methods offered by legacy finance. They empower more people to harness the benefits of the blockchain without the risk of large market fluctuations. In the event of a local fiat currency crashing, people can easily exchange their savings with US dollar backed or Euro-backed or even gold-backed stablecoins, thereby preventing the further depreciation of their savings.

Where are stablecoins used?

With the growing number of stablecoins the use cases keep growing.

Switch between volatile cryptocurrencies and stablecoins

Stablecoins are most popularly used to quickly switch between a volatile cryptocurrency and a stablecoin, while trading, to protect the value of holdings. They provide traders with a ‘safe harbor’, which allows them to reduce their risk to crypto-assets without the need to leave the crypto ecosystem.

Allow the use of smart contracts

Stablecoins allow for the use of smart financial contracts that are enforceable over time. These are self-executing contracts that exist on a blockchain network, and do not require any third party or central authority’s involvement. These automatic transactions are traceable, transparent, and irreversible, making them an ideal tool for salary/loan payments, rent payments, and subscriptions.

Mainstream commerce

Because these stablecoins are seen as relatively less volatile compared to other cryptocurrencies like Bitcoin and Ether, the idea is that stablecoins might be more widely accepted in mainstream commerce. Consumers, businesses and merchants would therefore be more comfortable with using stablecoins as true units of exchange.

Payments

Stablecoins allow payers to get as close to the benefits of cash as possible. Stablecoins are freely transferable just like cash; anyone on the blockchain network can receive and send coins. The coins are structured as bearer instruments, giving the holder the rights to redeem the coins for US dollars at any time. This is especially relevant in the decentralized finance (DeFi) segment, where stablecoins play an important role to enable the ecosystem. Mainstream applications with stablecoins are also picking up in cross-border payments, where they are being used to facilitate cross-border trade and remittances.

Risks of stable coins

While stablecoins have the potential to enhance the efficiency of the provision of financial services, they may also generate risks to financial stability, particularly if they are adopted at a significant scale. Some stablecoins are actually riskier than they may seem. Stablecoins may bear risks in terms of asset contagion, collateral and accountability. We also shouldn’t ignore the risks that stablecoins potentially pose to the financial system in terms of systemic risks thereby undermining sovereign currencies.

Not all stablecoins are stable

Notwithstanding their name and the suggestion that their value is quite stable,  not all stablecoins are really 100 percent price-stable. Their values are dependent on their underlying assets. Stable coins can only be truly stable if they are 100% backed by cash. The reason for that is that the issuers of fiat-collateralized stablecoins need to manage the supply of their coins through issuing and redeeming to ensure the value of their coins maintains roughly 1-to-1 with the fiat currency. This stands true for commodity-backed and crypto-backed stablecoins as well. The promise can only work if the stablecoin issuer properly manages the reserves. Since cryptocurrency prices can fluctuate violently, crypto-backed stablecoins are more susceptible to price instability than other collateralized stablecoins.

Asset contagion risk

The rapid growth of stablecoin issuance could, in time, have implications for the functioning of short-term credit markets. Certain stablecoins are today’s economic equivalent of money-market funds, and in some cases their practices could lead to lower values, creating significant damage in the broader crypto market. There are potential asset contagion risks linked to the liquidation of stablecoin reserve holdings. These risks are primarily associated with collateralised stablecoins, varying based on the size, liquidity and riskiness of their asset holdings, as well as the transparency and governance of the operator.
Fewer risks are posed by coins that are fully backed by safe, highly liquid assets.
One of the most known and most widely traded stablecoin is Tether. Each Tether token is pegged 1-to-1 to the dollar. But the true value of those tokens depends on the market value of its reserves. Tether has disclosed that as of 31 March  it held only 26.2% of its reserves in cash, fiduciary deposits, reverse repo notes and government securities, with a further 49.6% in commercial paper (CP).

Collateral consequences

Also further collateral consequences, particularly because the recent rise in crypto prices, has been fuelled in significant part by debt. It is questionable whether stablecoins could liquidate sufficient investments quickly to satisfy the demand if needed. The consequences of such an inability to meet a sudden wave of withdrawals could be significant in the larger crypto ecosystem.

Lack of accountability

The drawback of fiat-collateralized stablecoins is that they are not transparent or auditable by everyone. They are operated just like non-bank financial intermediaries that provide services similar to traditional commercial banks, but outside normal banking regulation. They therefor may escape accountability. In the case of fiat-backed stablecoins traders need to blindly trust the exchange or operator to trade in these currencies or try to find and examine out its financial disclosers by themselves to ensure that the stablecoins are fully backed by fiat, even if they do not release audit results.

Financial stability and systemic risk

Stablecoins may also generate risks to financial stability. Some of these fiat currency-pegged tokens are not backed by actual fiat currencies, but by a combination of riskier assets. This puts not only stablecoin holders at risk but could potentially threaten financial stability in general, if a run on a stablecoin causes the asset and other cryptocurrency prices to collapse. And there is the systemic risk issue. A widely adopted stablecoin with a potential reach and use across multiple jurisdictions (so-called “global stablecoin” or GSC) like Facebook’s Libra, now called Diem, could become systemically important in and across one or many jurisdictions, including as a means of making payments.

Why is regulation needed?

These issues underline there is a large regulation gap concerning stablecoins that contributes to weak investor protection and fraudulent activities. There is no legal framework for regulating stable coins, so no requirements on how reserves must be invested, nor any requirements for audits or reporting. This lack of regulatory clarity also creates confusion when new products related to stablecoins are brought to market.

The activities associated with “global stablecoins” and the risks they may pose can span across banking, payments and securities/investment regulatory regimes both within jurisdictions and across borders. Especially if stable coins would become a significant part of the payments and finance universe there is urging need for a regulatory framework. Ensuring the appropriate regulatory approach within jurisdictions across sectors and borders will be important.

Regulatory scrutiny of stablecoins

A range of regulatory bodies, from the G7, the Federal Stability Board (FSB) to the BIS, have started publishing guidelines. They mostly highlighted risks and challenges, including issues such as financial stability, consumer and investor protection, anti-money laundering, combating financing of terrorism, data protection, market integrity and monetary sovereignty, as well as issues of competition, monetary policy, cybersecurity, operational resilience and regulatory uncertainties.

G7 Summit

At the recently held 2021 G7 Summit in Cornwall (UK) delegations concluded that common standards would be maintained through international cooperation, as well as, standards from the Financial Standards Board. They concluded that no global stablecoin project should begin operation until it adequately addresses relevant legal, regulatory, and oversight requirements through appropriate design and by adhering to applicable standards.

Basel Committee on Banking Supervision

Also released recently was a consultation paper from the Basel Committee on Banking Supervision on prudential treatment of stablecoin exposures. While the paper notes that bank exposure is currently limited the continued growth and innovation in crypto assets and related services, coupled with the heightened interest of some banks, could increase global financial stability concerns and risks to the banking system in the absence of a specified prudential treatment.

BIS

The BIS’ Basel Committee ‘posited’ in a recent announcement that the crypto classes would be divided between offerings such as stablecoins and tokenized assets that would be eligible for treatment under the Basel Framework, which provides standards for banking supervision. The proposed roadmap hints at more regulation such as stablecoins being governed by stricter capital reserve policies.

FSB recommendations

The Financial Stability Board (FSB) has agreed on 10 high-level recommendations to address the regulatory, supervisory and oversight challenges raised by “global stablecoin” arrangements. They thereby respond  o a call by the G20 to examine regulatory issues raised by “global stablecoin” arrangements and to advise on multilateral responses as appropriate, taking into account the perspective of emerging market and developing economies.

According to the FSB, the emergence of global stable coins (GSCs) may challenge the comprehensiveness and effectiveness of existing regulatory and supervisory oversight. They therefor proposed some principles for regulating stablecoins, including restrictions on reserves, limits on risk and transparency requirements. That should promote coordinated and effective regulation, supervision and oversight of GSC arrangements These arrangements should address the financial stability risks posed by GSCs, both at the domestic and international level. The recommendations call for regulation, supervision and oversight that is proportionate to the risks. They thereby  support responsible innovation and provide sufficient flexibility for jurisdictions.

The final recommendations., including the feedback from the public consultation, will be published in October 2021, while the completion of international standard-setting work is planned by December this year.

Regulatory approaches

Notwithstanding the active work of the various international regulatory and oversight bodies it is still far from sure what regulatory approach would be chosen. There still remains uncertainty as to how they will regulate, either by proposing a bespoke regime for stable coins, banning it outright or assimilating the asset class into their existing regulatory frameworks. There is a number of regulatory approaches starting to shape how stablecoins might be governed and to more narrowly define their use. Most advanced are the EU where the EU Commission came up with their MICA proposal, though the timetable and details of planned changes remain unclear or subject to change. But now also in countries like the US and the UK regulatory activities are accelerating.

EU Market in Crypto-Asset Regulation (MICA)

Europe is currently assessing the large number of comments received during the consultation period on its proposed Market in Crypto-Assets regulation (MICA) that was issued last year September. MICA especially focuses on rules that regulate stablecoins, particularly those that have the potential to become widely accepted and systemic and crypto asset providers such as exchanges. Aim is to provide a comprehensive and transparent regulatory framework and establish a uniform set of rules that should provide investor protection, transparency and governance standard, while allowing the digital asset ecosystem to flourish.

The regulation thereby separates stablecoins into categories such as e-money tokens (stablecoins whose value is pegged to a single fiat currency) and significant asset referenced tokens’, which purport to maintain a stable value by referring to the worth of fiat currencies. These significant asset-referenced tokens are subject to strict regulatory standards of transparency, operation, and governance. Unlike other cryptocurrencies, stablecoins need to be authorised by regulatory institutions to be traded within the EU. The authorisation requirement applies also to stablecoins already in circulation. Except for existing credit institutions, everyone else that wishes to engage in stablecoin activities will also have to gain prior permission from their national supervisory authority.

MICA regulation makes it a legal obligation for stable coin projects to issue a white paper and submit it to their national financial supervisory authority. That supervisory body has the power to prohibit the issuer from releasing their planned stable coins. Most importantly, the regulation prohibits the issuance of interest to e-money tokens. With the interest ban, the EU legislator is arguably aiming to disincentivise the investment of crypto profits in stablecoins, and consequently to protect the interests of the European banking sector.

UK Bank of England

Though the UK is well behind with its regulatory activities around stablecoins compared to the EU, regulators in the UK are now also speeding up their steps to regulate stablecoins. Earlier this year the UK HM Treasury issued a general consultation and a call for evidence on crypto assets and stablecoins generally. The UK’s proposals however are narrower than the UK MICA proposals, reflecting an intention to take a ‘staged and proportionate approach’. In particular, the UK proposes to regulate only ‘stable tokens used as a means of payment’ initially.

The Bank of England Discussion Paper that was recently launched kicked of a conversation regarding digital money, stating that stablecoins, typically backed by fiat or another asset, but issued by a private firm, need to be regulated in the same way as payments currently handled by banks if they become widespread and can impact financial stabilities.

US Biden government

With the new Biden government also in the US activities surrounding regulating stablecoins are speeding up, and there is a growing optimism that 2021 will ‘bear witness to material progression’ from US regulators and law makers to better understand this technology and clarify the regulatory framework.

Stable Act

In December last 2020, just before the end of the US Congress tenure, a draft of the Stablecoin and Bank Licensing Enforcement Act (Stable Act) was introduced. The law would approve the use of stablecoins and cryptocurrencies as legitimate alternatives to other real-time payment systems. This Act however proposed significant increases in the regulatory oversight of stablecoins. It would limit who can issue the stablecoins, requiring that stablecoins be issued by a bank and would impose certain standards. It is however questionable if this Act in this form will really be approved by the US Congress.

US Fed

The US Fed is now also taking note of the rising usage of stablecoins. They announced it will issue a report later this year to begin a ‘major public consultation’ on crypto regulation, especially stablecoins, laying out the risks and benefits associated with stablecoins as well as a potential digital dollar.
Federal Reserve Chairman Jerome Powell said that the US is at a ‘critical point’ for regulation of these digital currencies, advocating for the application of new rules on stablecoins that are similar to those applied to bank deposits and money-market mutual funds, where the US has a pretty strong regulatory framework. The issuance of a stablecoin should be conditioned on following risk-limiting practices designed to ensure that the tokens are in fact worth that price. There should be liquidity requirements as well.

The President’s Working Group for Financial Markets

The President’s Working Group for Financial Markets, the nation’s top financial regulators in the US, last week met to discuss stablecoins and how to react. This is marking the first publicly-announced meeting of this group of regulators since Joe Biden took office earlier this year. Topics of discussion included the rapid growth of stablecoins, potential uses of stablecoins as a means of payment and potential risks to end users, the financial system and national security. This conversation is clearly only just starting. The meeting promised that the group, would publish recommendations for stablecoin regulation within the next few months. From this discussion it is not yet clear what sort of regulatory framework we might see, and which one would make the most sense for stablecoins.

The regulatory way forward

Stablecoins present peculiar challenges to regulators that ask for narrow cooperation between regulators and the stablecoin industry and global regulatory cooperation.

Stablecoins do not stand for a uniform category but represent a variety of crypto instruments that can vary significantly in legal, technical, functional and economic terms. In order to be effective in limiting risks and not disturbing innovations the stablecoin industry must work together with the regulators to come up with a framework that helps put them at ease while protecting this nascent industry from overregulation.

Another major regulatory challenge relating to global stablecoins is international coordination of regulatory efforts across diverse economies, jurisdictions, legal systems, and different levels of economic development and needs. There is not (yet) a uniform regulatory approach of regulators worldwide relating to stablecoins. Calls for the harmonization of legal and regulatory frameworks include areas such as governing data use and sharing, competition policy, consumer protection, digital identity and other important policy issues.

This all should contribute to more stability of stablecoins.

 

Carlo de Meijer

Economist and researcher

 

 

 

 

Source

Banks, Fintechs and the Changing Landscape

2-8-2021 | treasuryXL | Pieter de Kiewit

My regular blog readers know I like to take the layman perspective on what amazes me in (Corporate) Treasury. I have my personal archive with relevant news we use to discuss every second week in team meetings. What currently amazes me most are the completely unpredictable developments in what used to be the banking market. Just some recent news:

  • Wise, formerly known as Transferwise does a direct listing in London and is valued at $11 billion. They will invest in further facilitating cross border payments thus offering a bank service substitute; read more
  • The competition of Wise, Revolut receives further investments and is valued at GBP 21 billion. They will establish full banking services building direct competition; read more
  • Mollie, a miniature Adyen, explicitly states that they will beat banks at their game; read more
  • One can also see banks creating their own new brands and services. ABN started Aymz, entering the niche market where RNHB and others are financing real estate in not too big tickets: read more
  • And Niels van Daatselaar, CEO of TreasurUp writes about banks and fintechs working together: read more
  • My final example is Ebury being taken over by Santander: the old world takes over the new contender: read more

A few years ago, the Traditional banks had the upper hand and would buy all parties that threatened them. By now, many Fintechs have a much higher valuation than banks. The extreme liquidity in the markets and willingness to invest leads to a situation that predicting what will be next is hard. I think that future winners find a right balance between applying newest technology, understanding potential clients, choose a clear strategy and move forward at highest speed. Many markets are winner takes all, making the game extra exciting.

I have not found a journalist or researcher who was able to solve this market equation and predict which of the various “eat or being eaten” scenarios will occur. The constant flow of new market entrants will continue. My expectations are that Apple, Microsoft, Google or Amazon entering this market with very substantial investments might be the next game changer. But why would I know?

What do you think will happen?

 

 

Pieter de Kiewit

Owner at Treasurer Search

 

 

 

DeFi and Regulation | the European Approach

| 07-07-2021 | Carlo de Meijer | treasuryXL

In an earlier blog about the newest trends in 2021 in the blockchain world I mentioned the spectacular growth in decentralised finance or DeFi. Decentralized finance, an unbundling of traditional finance, is challenging the centralized financial system by disempowering middlemen and facilitate peer-to-peer transactions and let users retain control over their money. Being almost completely unregulated, DeFi promises a dynamic, disintermediating revolution in finance, steadily taking over the traditional financial world. In this blog I will touch some of the high-level implications of DeFi for existing financial regulations, as well as the challenges regulators are confronted with. I will especially focus on Europe’s approach MICA.

What is DeFi?

But first of all what is decentralised finance or DeFi? Decentralized Finance refers to platforms that allow consumers to perform financial type transactions with each. The goal is thereby improving the availability of and efficiency in financial services through disintermediation. DeFi uses blockchain, cryptocurrencies (mainly stablecoins) and smart contracts to manage financial transactions such as lending, borrowing and trading outside the control of traditional financial institutions like banks, brokerage firms, and centralised exchanges. Users thereby interact with the open software protocols through unhosted wallets—which are digital wallets that are managed by users themselves rather than by a service provider.

How does DeFi work

Decentralized finance uses blockchain platforms to disintermediate centralized models and enable the provisioning and settlement of financial services anywhere by using crypto currencies, rather than going through traditional financial intermediaries. By eliminating intermediaries, DeFi users are able to maintain full control over their money through personal wallets (DeFi smart contract tokens) and trading services, as well as directly interact with them via DeFi dApps.

Smart contracts

DeFi makes use of smart contracts that provide the fundaments for the functioning of DeFi apps, because they encode the terms and activities necessary for the functioning of these apps. Smart contracts are computer programs run on a blockchain that controls digital assets, and automate agreement terms between buyers and sellers or lenders and borrowers. They are used to execute a transaction between two or more parties, thereby reducing friction and costs.

Software protocols

DeFi software protocols on blockchains are standards and rules written to govern specific tasks or activities. They are interoperable, meaning they can be used by multiple entities at the same time to build a service or an app, enabling  buyers, sellers, lenders, and borrowers to interact peer to peer. DeFi protocols achieve their investment purposes through self-executing smart contracts that allow users to invest crypto assets in a pool from which other users can borrow. The most common protocols for current DeFi projects are built on Ethereum.

Decentralised applications (dApps)

Decentralised applications (dApps) abstract underlying protocols into simple consumer-focused services.  DeFi can be used for the full range of financial services including crypto asset trading, lending and borrowing, savings, payments, derivatives trading, insuring risk etc.

Governance tokens

Some DeFi protocols allocate so called “governance tokens” to reward users for engaging with the system and for conducting or supporting different types of transactions. Participants typically earn tokens by interacting with and providing services to a protocol, for example by providing liquidity in a decentralized exchange or collateral on a lending platform.

These governance tokens generally give users a right to returns from the project and allow users to vote on changes proposed to the protocols. Because of these associated rights, governance tokens have value and are tradeable. This structure gives a wide range of holders the ability to contribute to a project’s governance and evolution by voting on proposals to change the protocol and, therefore, its incentives and operations.

DeFi platforms

DeFi does not just build financial services natively as software, but it recreates the entire ecosystem of finance on novel technical foundations, so-called DeFi platforms. These  platforms are consumer-facing financial interfaces that require blockchain technology and  crypto stakers (the transaction processors) to operate. The blockchains thereby act like digital highways allowing DeFi transactions to move. Several decentralized platforms exist including decentralized exchanges (DEX), lending and borrowing, trading (complex) derivatives, insurance, asset management etc.

Decentralised exchanges

Decentralized exchanges (DEXs) are marketplaces that allow the trading of digital assets without any centralized controller. They replace the market-making and custody features of exchanges with a powerful algorithm that dynamically adjusts prices and executes trades based on available liquidity. Automated market makers (AMMs) have become a popular means of providing liquidity. They match buyers and sellers of digital assets or let them “swap” one cryptocurrency or tokens for another (exchange trading). Rewards on this platform results from providing liquidity in token pools. Well known examples are Uniswap and Justswap.

DeFi lending platforms

And there are decentralized lending platforms, that allow holders of cryptocurrencies to lend anonymously vast sums of funds instantly to people who want to borrow, provided that they can provide enough collateral to deposit in a smart contract and settle the loan within an agreed timeframe. Lenders earn interest on the loaned amount (credit intermediation). Some DeFi protocols offer crypto loans against fiat collateral and vice versa. Apart from loans, DeFi users can borrow a token to participate in blockchain activities such as governance. Leading examples are Compound, Makerdao, and Aave.

DeFi derivatives platforms

DeFi derivatives platforms establish markets for synthetic assets, in which users can establish derivative positions in cryptocurrencies while posting collateral to support those positions (derivatives trading). They automatically track the value of commodities, stocks, indices, or any combination of financial instruments. Most known example is Synthetix.

Other DeFi platforms

Other DeFi platforms offer insurance, asset management, and other higher-order financial services, to maximize portfolio returns, as well as collateralising crypto assets for proof of stake or liquidity provision.

Non-Custodial Lending Platforms

Cryptocurrencies have further extended into the world of DeFi through the recent creation of non-custodial lending platforms. These are decentralized markets where users participate as depositors or borrowers. The concept of these lending platforms are designed to mitigate any potential losses or defaults through controlling collateral on the blockchain. Retail lenders are able to quickly liquidate unhealthy loans on these lending platforms through the underlying technology of the platform itself. DeFi pools also have the potential of opening up liquidity in cross-jurisdictional markets that have previously not been able to transact. DeFi users are (theoretically) able to extend credit and liquidity through cryptocurrencies to users across the globe, including markets in developing countries that traditionally do not see influxes of western funds.

New DeFi services

Thanks to DeFi, users can now obtain financial services such as margin trading,  yield farming, liquidity mining, and crypto staking  on a distributed ledger. Especially staking platforms and yield farming protocols have surged in popularity. Yield farming is a tool to help provide network liquidity. It is “the act of hunting for rewards” by interacting with DeFi protocols, by temporarily putting depositing assets as collateral in a liquidity pool, that could be used by others including investors and start-ups, in exchange for financial rewards.  Liquidity mining is a specific form of yield farming, in which digital asset owners provide liquidity to DEXs (Decentralized Exchanges) in return for rewards. Since DEXs historically suffered from low liquidity, this is an important development for the ecosystem as well as a major source of revenue for some digital asset investors. While liquidity miners and yield farmers add funds to liquidity pools, stakers either hold funds in a wallet or delegate their coins to a validator node. This involves locking assets in a wallet in order to gain governance rights and token rewards in proof of stake (PoS) blockchain’s native asset.

DeFi market

Decentralized finance has been one of the fastest-growing crypto sectors since 2019. Interest in crypto and decentralized finance (DeFi) rose sharply during the Covid-pandemic and investment has accelerated. Though decentralised finance is still in the beginning stages of its evolution, the total value locked into DeFi of various types (collateral pools, DeFi smart contracts/protocols) in leading platforms such as Maker, Compound, Uniswap and Aave has grown from less than US$1 billion in 2019 to over US$90 billion early June 2021.

This rise was fuelled in part by investors looking for increased transparency and control of their funds regarding its open network as an attractive alternative to traditional banking. Another reason for the firm growth was the maturation of stablecoins, i.e. cryptocurrencies designed to track the value of stable assets, such as the US dollar. And there was the emergence of incentive structures, such asyield farming and governance tokensthrough which participants can earn returns for providing liquidity to DeFi services.

DeFi and benefits

Using DeFi applications has a number of interesting advantages beyond the traditional financial services, in terms of easier access to financial products and liquidity, improved market efficiency, enhanced financial privacy, lower fees and faster innovation.

Easier access

The protocols are easily accessible, making it possible for everyone to experience banking-like services. DeFi applications not only make financial services accessible but also affordable. Besides moving between protocols is relatively frictionless because users have full control of their assets/funds.

Peer-to-peer trade

Since dApps power the ecosystem without intermediaries thereby using self-executing codes that envisage the outcome and resolution of activities on these platforms, it allows for a flexible, direct person-to-person trade with high levels of transparency and zero requirements for joining.

Availability

There are also (theoretical) benefits for international financial transactions. The distributed nature of DeFi platforms and protocols makes them available across the world. The idea is that with a cheaper alternative, remittance charges and commission fees will drop, and currency conversion will have to get cheaper to be more competitive.

Improved market efficiency

Individuals can also borrow of these platforms instantaneously by using crypto assets as collateral. This automation may increase the speed of financial transactions, decrease costs, and—given enough time—broaden the availability of these services.

Lower costs

Such decentralised and non-custodial platforms have low start-up and entry costs as market entrants often remain unregulated and have minimal operating and regulatory costs. The absence or lack of central intermediaries makes it hard for regulators to forbid DeFi services.

Innovation

It may also lead to new types of services, triggering further innovations.  If a community of users is displeased with the service provided by a protocol, that community can vote to change the services supported by it or can fork the existing open source code base and develop a new protocol to meet the community’s needs better.

DeFi and risks

DeFi is an emerging phenomenon that comes with various risks, such as user errors. Who takes responsibility for any mistakes done during a transaction as blockchain is nearly impossible to alter?

And there is the smart contract vulnerability. The engine that runs DeFi applications is embedded in the code bundled together to make a smart contract. When this code has a flaw, it exposes the entire project leading to loss of funds.

Software systems may also malfunction due to a wide variety of factors. For example, what if an incorrect input causes a system to crash? Or, if a compiler which is responsible for composing and running codes makes a mistake. Who is liable for these changes?

While many DeFi tokens have already delivered lucrative returns, they come with considerable risk and price volatility that exceeds that of established digital assets like Bitcoin and Ethereum. Their lower liquidity means that they are more prone to large price swings.

And the anonymity of participants in DeFi transactions, makes it vulnerable for cyberattacks, hacks, scams, false, misleading, or greatly exaggerated recommendations. This may lead to funds theft or loss, without any regulated recourse.

No consumer protections

DeFi has flourished in the absence of rules and regulations. DeFi users however do not receive the protection benefits of transacting with regulated intermediaries. In centralized finance banks are required by law to hold a certain amount of their capital as reserves, to maintain stability and cash you out of your account any time you need. In DeFi they do not receive risk disclosures. Protocols are not subject to risk management requirements, such as capital and liquidity requirements, that protect against loss of consumer funds and systemic risks. So DeFi users may have little recourse should a transaction go foul. There is no help desk or relationship manager to contact if a transaction goes wrong.

Present regulation

DeFi is currently subject to existing regulation laws. The regulatory frameworks that apply to cryptocurrency projects however do not regulate the specifics of DEFI. Their approach is still based on the presence and regulation of centralized intermediaries, and would not work for decentralised DeFi digital asset classes. DeFi transactions conducted between individual users through unhosted wallets would not be subject to existing regulatory requirements, including KYCand AML reviews.Because DeFi protocols support anonymized transactions, there is no meaningful way for market participants to determine what requirements apply to their DeFi transactions.

Regulators are puzzling

Regulators world-wide are gathering speed to step in. They however are puzzling how to deal with DeFi and how to fill the gaps. Considering the fragmented and diverse nature of the DEFI market the task for regulators seems impressive. Who and what is there to regulate? From a regulatory standpoint, DeFi poses several serious and multifaceted risks and challenges, that will become more serious as the market further grows. DeFi does not fit within the historic practical and regulatory model used for financial transactions.

No intermediaries

Present regulation assumes the presence of intermediaries, and it applies regulation to intermediaries as a way to regulate financial markets and related activities comprehensively. But why apply rules designed for centralized finance to decentralised non-custodial, open  information DeFi systems?

Decentralised networks

Blockchain networks are decentralized and global, so participation in DeFi activities presently does not require interaction with the regulated financial system or other national legal regimes, such as taxation and national identity systems. How to look at these centralised networks from a regulatory standpoint?

Governance tokens

As with any new market, classification will be challenging. Governance tokens issued by DeFi projects may not constitute ‘investment contracts’ under securities laws. The absence of intermediaries and a wide dispersal of governance tokens may further weigh against governance tokens being subject to existing securities regulation. How are they going to be classified will determine under what regulatory regime governance tokens will fall.

Codes

Even when a corporate entity develops the software for a DeFi service, the service itself is just software code executing on a blockchain and accessible to all through the internet. This makes regulatory enforcement challenging. Using just the traditional financial services view to regulate the codes is not enough. They not only relate to just blockchain virtual assets, but also around automation and smart contracts more generally. These are very much linked and regulators need to look at those things together.

Source of information

It is also difficult to imagine a practical situation where a user of a DeFi platform is able to provide the source of information about an exchanged private or non-private crypto coin beyond one or two transactions. So what regulatory rules should apply?

WEF Policy Toolkit: regulatory clarity and balanced approach

Policy-makers and regulators are urgently looking for frameworks to address these issues responsibly. The World Economic Forum recently published a policy toolkit for decentralized finance, in a bid to assist governments around the world to appropriately address this phenomenon and help shape regulation of digital asset marketplaces between different countries. Regulators worldwide contributed to the policy document including representatives from lawmakers involved in creating the new European Markets in Crypto Assets (MiCA) rules. The toolkit provides a foundational basis for understanding and examining the critical factors concerning DeFi regulations that should drive policy-making decisions. Authors thereby call for technologically neutral approaches that can balance objectives of regulatory regimes and innovation and market development with policies that are fair, efficient and enforceable.

New regulatory approach: basic principles

As DeFi projects eliminate the need for financial intermediaries, regulators may need to fundamentally rethink their approach. They will need to step away from traditional thinking and take an approach that should have a number of basic principles.

Regulatory clarity

Regulation is key to, at least, set minimum standards to market participants in the DeFi industry, to protect capital and clearly define the regulatory treatment of all crypto-assets that are not covered by existing financial services regulation. Regulators will need to further clarify these guidelines for reporting entities a.s.a.p. to solidify international adoption.

No overregulation

In order not to frustrate full adoption in the DeFi world, government agencies will need to be more flexible in their approach. One should prevent too strict regulation as that could severely disincentivize people to enter the DeFi market. The approach should be based on disintermediation whereby regulatory bodies should look beyond the centralized intermediaries approach.

Balanced approach

To promote the development of the various DeFi markets, it is necessary to put in place a safe and proportionate regulatory framework to support innovation and fair competition. Regulators should thereby maintain an adequate balance between safeguarding positive blockchain-based financial innovation in terms of greater efficiency and broader inclusiveness in finance on one hand and limit the potential of these financial applications being misused for money laundering and terrorism financing.

Level playing field

Given the increasing interwovenness of traditional financial institutions and the crypto market that have to compete against a growing number of non-regulated decentralized and non-custodial DeFi platforms, traditional business may be adversely affected if they fail to compete on an equal basis against them. So regulators should follow a level playing field approach, based on functional and operational equivalency.

European DeFi regulation: MICA

Last year September the European Commission adopted the Markets in Crypto-Assets Regulation (MiCA) proposal. Aim  is to improve harmonisation and legitimisation of how tokens are being regulated generally and the supervision of issuers and firms that qualify as crypto-asset service providers (CASPs). MICA would set clear rules of the crypto assets throughout the European Economic Area (EEA) establishing a common framework and avoiding inconsistencies. MICA thereby follows a technology, asset class and jurisdiction agnostic neutral approach.

MiCA aims to provide greater legal certainty, supporting innovation, ensuring appropriate levels of consumer and investor protection, promoting market integrity and financial stability and thus transform Europe’s current fragmented crypto-asset legislative and regulatory framework into a uniform approach. MiCA will apply to persons engaged in the issuance of crypto-assets and to crypto-asset providers in the EU-27. MiCA itself may be implemented as early as between mid-2021 and early 2022 and aims to be fully operational by 2024.

Main proposals

This new MICA regime clarifies which tokens will qualify as a “financial instrument” and thus fall under the existing financial services regulatory regime, as amended, and which tokens will qualify as “crypto-assets” and thus fall under MiCA’s specific regime for crypto-asset services (CAS).

Assessment of whether a digital asset will be a crypto-asset and subject to MiCA or a token that is a financial instrument subject to the existing financial services regime, will look at the substance over form and thus depends on the content of an instrument and not the technology behind it.

With MiCA, the European Commission intends to include stablecoins within the scope of the tailored MiCA regime on crypto-assets (to the extent not already regulated) and to modify the e-money regime to include a new type of e-money: “ ‘electronic money token’ or ‘e-money token’ means a type of crypto-assets whose main purpose is to be used as a means of exchange and that purports to maintain a stable value by being denominated in (units of) a fiat currency”

Other stablecoins are likely in scope as ‘asset-referenced tokens’, defined as: “a type of crypto-assets whose main purpose is to be used as a means of exchange and that purports to maintain a stable value by referring to the value of several fiat currencies, one or several commodities or one or several crypto-assets, or a combination of such assets.”

For stablecoins that do not fall within the above definition, the issuers must still publish a white paper, notify the regulator and may not refer to their coins as being ‘stable’. Stablecoin (being a type of ‘asset-referenced token’) issuers not already regulated as credit institutions or e-money institutions will need to be authorised and to publish a white paper approved by their home state regulator.

Issuers of ‘significant e-money tokens’ and ‘significant asset-referenced tokens’ will be directly regulated by the European Banking Authority (EBA) and will have additional obligations in respect of capital, interoperability and liquidity management.

ECB and MICA

In February this year the ECB published an Opinion on the current proposed form of MICA regulation. Their proposals generally aim to grant greater powers to the ECB, set prudential requirements for certain stable coin issuers and generally improve anti-money laundering and financial crime prevention measures.

The ECB is generally in favour of MICA’s aims and its contribution to harmonization of crypto asset regulation. The ECB however suggests several adjustments and clarifications, specifically calls for improvements, including greater scope of which tokens and what activity will fall under and be regulated by MICA and by which regulatory authority under MICA and what activity will be subject to the MIFIR/MIFID II framework. The ECB has called for changes to provide a clearer definition of what constitutes a crypto-asset and thus falls into MICA. This to help support the provision of crypto-asset services on a cross-border basis and to establish a truly harmonized set of rules for crypto-assets.

The ECB has suggested a distinction between crypto-assets that would be classified and thus treated as MIFID II financial instruments and those that would fall under the scope of MICA’s regulatory regime. Specifically the ECB has requested a number of changes concerning the supervision of stable coins i.e. what MICA defines as asset-referenced tokens (ARTs). The ECB asks for additional safeguards under MICA, including prudential and liquidity requirements for such issuers. And there is the issue of what financial stability and prudential supervisory aspects will require greater regulatory and supervisory oversight by the ECB, and how this will interact with oversight from other European authorities.

The way forward: regulatory sandboxes and safe harbors

Implementing full-fledged regulations right now however would be unwise. Regulators should get well-required time to gain experience in this new technology, interact productively with the DeFi industry, and provide informal regulatory guidance to them. In the meantime regulators can learn from techniques that are proving effective for the existing cryptocurrency market via so-called regulatory sandboxes. These could create a safe space for regulators and innovative services to work through the various issues. In addition, regulators should start with clarifying relatively easy cases first to provide guidance to the industry. This can give them enough time to solve the harder issues later, while ensuring market participants remain confident in the broad contours of the regulatory environment.

Because DeFi encompasses a broad range of applications and protocols, many of which may lie outside securities law, US SEC Commissioner Pierce suggested implementing a so-called ‘safe harbor’ policy with respect to DeFi and cryptocurrency projects. Disclosure requirements or safe harbors can encourage market participants to provide regulators with information that helps them better understand market dynamics and develop best practices. Without this safe harbor policy in place, it is currently impossible for someone to develop a truly decentralized system without potentially being in breach of securities law throughout the development process.

 

 

Carlo de Meijer

Economist and researcher

 

 

 

 

Source

Is Digital Cash now King? Enigma tells……

23-06-2021 | treasuryXL | Enigma Consulting |

Get inspired by the extensive and catchy interview with Robert-Jan Wekking about Enigma Consulting. Robert-Jan takes you into the warm corporate culture, mission, expertise, innovation and their continues investment in knowledge with great examples.

Enigma Consulting is a revolutionary knowledge hub in the field of Payments, Digitisation, Risk & Compliance and Treasury. They are a connecting factor in the financial sector thanks to our consultants’ engagement with their clients, both banks and companies and solution providers.

AN INTRODUCTION TO

Robert-Jan has more than 25 years of experience in payment transactions and he advises corporate clients in the areas of treasury, risk management and bank connectivity.He understands the solutions in the market, both from the B2B and B2C perspective.

Robert-Jan switches easily between executive and operational level within companies and the banking sector, as he easily combines his strategic vision with substantive process and product knowledge. He has a wide network with contacts at all (international) banks, which can speed up the implementation of corporates connectivity with their banks.

We asked him 11 questions. Let’s go!

 

INTERVIEW

1. Tell us more about Enigma Consulting and its mission

Enigma Consulting has in-depth knowledge of all ecosystems that are relevant in payments, transaction value chains and financial markets. Transactional connectivity and digitization increase the prosperity and well-being of consumers, companies and the public sector and thus serve a social interest. Our mission is to contribute to the development of efficient digital transaction traffic and to ensure that this is done in an innovative, sustainable, honest and effective manner with controlled business operations. Combined with a correct attitude and behaviour, this contributes to the translation of legislation and regulations into ethical business operations and a better market position. We follow developments closely, research, analyse and make connections. Our consultants reflect, structure and help organisations to achieve their goals.

2. What is the core topic Enigma Consulting aims to address and how does it differentiate it from the other players in the market?

Digitalization is all about the exchange of data, whether these are payments, information, identities, contracts, signatures or any other regular consumer or business transactions. The complexity of exchanging transactions is constantly increasing; regulations, fraud and data protection are just three of the factors impacting this complexity.  On the other hand, innovative technology is continuously providing easier interaction between data, leading to better and integrated business propositions and making client journeys faster, more friction less and safer.  This is exactly in this domain where Enigma operates.  We leverage our in-depth knowledge of payments and transactions to advise and implement.

We distinguish ourselves from other players by looking at the end-to-end value chain, not only from the viewpoint of efficiency but also with a perspective on regulations and compliance. We understand the guiding laws and regulations and can translate them into practical advice to make sure that our clients remain compliant. We recognize that laws and regulations applying to financial institutions are becoming stricter and that attention is now also shifting towards corporates.

Our legal consultants are specialised in transaction and data related legislation, and we have strong connection with for example DNB and AFM in relation to our guidance of our clients.

Our consultancy practice focuses on the  financial-,  corporate- and retail sectors, hence we understand the complexities affecting those areas. With our knowledge of the ecosystems and  vendor solutions we play the matchmaking role between individual client wishes and the solutions available in the market.

This combination of end-to-end view, legislation and compliancy, working in different sectors, and the matchmaker role gives us a unique position. The fact that we not only advise but also take responsibility for  implementations during the past 20 years, makes us a trusted and recognized partner for our clients.

3. Why choose customers for Enigma Consulting?

Our knowledge of payments and other transaction processes is often the starting point for customers to reach out to us. Our capability to advise and implement solutions from an end-to-end perspective is the basis for our interaction with our customers.  Additionally, customers also appreciate the fact that we are able to advise at a strategic level, but at the same time are pragmatic enough to look for feasible and not theoretical answers.

We have strong relationships with a number of our clients, some even stretching back over more than 20 years. This is something we foster, not only by delivering more than what is expected, but also by working closely together. For instance, our Treasury Barometer is an example where we cooperate with the Rabobank, whilst at the same time we are participating in a number of their projects.

At the end, it all comes together with trust, in the quality of delivery, in our people and in the overall relation. This is how we ensure that we will be shortlisted again the next time.

4. What has been the biggest challenge for Enigma Consulting regarding customer projects so far?

The most challenging projects are when we are asked to take end-to-end responsibility for delivering a complete project. Quite often, this means that we have a team onboard and the client is looking at us as lead consultant to get the job done. A good example is the setup of a complete bank payments infrastructure. Apart from the fact that these assignments are exciting and demanding, it is always challenging to make it happen in an environment with its own complexities.

For our individual consultants, stepping into a new assignment always has its own challenges.

Customers ask for us for different reasons, and our consultants have to quickly adapt to start advising the client. This means not only understanding the clients’ business, but primarily building trust relations with the client and their stakeholders. Hence for every consultant the adaptability towards the new environment is always an important challenge.

For myself personally, I am proud to have led a number of strategic programs, like SEPA, Instant Payments and iDIN.  Besides building completely new products, the key challenge is always to work and build bridges between internal and external parties (Banks, DNB, governmental bodies) with sometimes opposing objectives. Working with all these parties and ultimately developing a new product is what makes me happy and proud of my role as consultant.

5. Can you tell us in what sector you see the most innovative developments regarding payments and how does Enigma Consulting react to these?

One of the most exciting aspects of payments is the continuous innovation in the field. However, it is never a revolution but more an evolution. An example are the digital currencies. I believe that in the long run, these might become as important as, or even replace, the current way of paying. But it will take many years to get there. Where it started with the cryptos and Facebook’s Libra, the central banks are now seriously embracing it.

Additionally, the technical transitions to APIs and SaaS, Open Banking and Instant are ingredients for completely new business innovation. Through API and SaaS, corporates can select best in class software modules and integrate them, rather than select single platforms that will still sub-optimise their process. The introduction of Instant Payments in Europe will ultimately change the way the treasurer needs to forecast and manage their accounts.

In the B2C or C2C world, the client journey will continuously improve, seamlessly and friction less, with data integration as a key element.

Through our assignments, we are constantly in the middle of this innovation. For example, we are the leading consultancy firm in the Netherlands for supporting FinTechs, cryptos and payment software companies with their PSD2 application. Our role in digital identity and Mobility as a Service provides us with insights in yet other areas of innovation.

In order to keep all our consultants informed, we have a weekly meeting with our consultants to discuss the latest trends.

We also leverage this knowledge to assist our clients with their questions around innovation. For this purpose, we have initiated the Enigma Innovation Lab, an accelerator environment to answer client specific questions around innovation, vision building or technical solutions by injecting are our own knowledge combined with our ecosystem of solution providers and subject matter specialists, all facilitated by various methodologies like Design Thinking.

6. Do you experience differences in the world of payments before COVID19 and the time we live in now? What are the differences?

The differences are not that when you look at the regular payment products themselves. But we do see COVID as a steppingstone for digitalization. E-commerce and e-commerce payments have shown significant growth and people are spending increasing amounts of time online. The volumes of payments facilitated by Payment Service Providers are going through the roof.

Also “Cash is King” is the phrase that everybody uses, but this should now be “Digital Cash is King”. Volume of physical cash is dropping significantly, being taken over by contactless payments.

I believe these are just indicators for a bigger change, which is the acceptance of the consumer to step into a full mobile journey.

Customers are now more familiar with working with a cashless wallet and seem also to be willing to adapt faster to other contactless, digital processes. Examples are registration, ordering food and payments in restaurants (for example via QR). But also using mobile apps to order your groceries. Clearly, this has already been taking place for many years, but I believe that COVID has accelerated this transformation through necessity.  People are therefore more willing to change their attitude. What is interesting is whether this transformation will continue, or whether people will step backwards to the old normal or step forward to a new normal.

For the retail sector and corporates, before COVID they already had to understand how to become more relevant in the mobile cashless digital world.  COVID is demanding corporates to speed up this thought process.

7. How does the future of payments look like in your perspective? And how will it change the world?

Digital currencies will be an important element in our future, adopted stepwise, and will be overlooked by market systems and regulators. There will be a continuous drive for integrating payments in the client journey, seamless, frictionless and supporting the Internet of Things. Hence payments will be a key enabler of future growth towards the digital world. Digitization is also very attractive for fraudsters, money laundering etc, as your counterpart is not always visible anymore. The need for trustworthy digital identities will be an important building block for this roadmap.

At the same time, the pressure of fraud, regulations and compliance will shift from banks to other parties (corporates) in the end-to-end value chain. Where banks are currently the gatekeeper, corporates will have to integrate this responsibility in their own business processes.

Hence the roadmap to digital, whether it is digital payments, or any other data transaction, will demand continuous change from all parties in the value chain. This will be a stepwise change, but fast enough to need to keep an eye on it.

8. What has been the biggest success for Enigma Consulting?

The biggest success for Enigma is that we have made a transformation from payments “only” to understanding the full transaction, risk and data value chain. For example, we have made a transition from bank payments to treasury payments and risk processes, but also from payments to compliance, and to integrated transactions and data models.

During this period, we have also changed our internal organisation.  We have been running a number of Young Professional Programs. These next generation talents bring us a more diverse view of the world, which makes our proposition to the market stronger and our internal culture more diverse. As a result, we believe that we have the foundation for supporting our clients, now and in the future, with a passion for payments and transactions.

9. How does Enigma Consulting keep on innovating and stay one step ahead of its competitors?

Our ambition is to be recognised as a though leader in the domain of payment and transactions. Investing in knowledge is the basis for our current and future advisory services.

This means that we continuously invest in gaining and sharing knowledge with our consultants and clients. We have organised this in a number of ways.

We have introduced the so-called Theme Lifecycle within Enigma. When we expect a theme becomes relevant for our business, now or the future, we start a workgroup to progress this theme from idea through different stages. It starts with writing a one pager based on study and analysis, called the exploring stage. We validate the readiness for every next stage (exploring, campaigning, harvesting) so that we invest time in those subjects that also become relevant for the market. All our consultants participate in one or more themes, which helps keep them engaged with innovation and market developments.

Every week we organise meetings to discuss news and articles. On turn, every consultant is responsible to select a number of articles to be discussed during this half hour meeting.

For our clients, we have regular Breakfast and Brains meetings to share our insights and to have open discussions on a specific subject. The success is that clients that even might compete in a certain sector, are always willing to learn and share from our and other clients’ experiences.

Finally, we also participate in and cooperate with FinTechs. We support them by leveraging our network of solutions, whilst their innovative ideas are a good source for future improvements, leading to a broader ecosystem that benefits our clients.

10. We are heading to the end of 2020, can you give us an outlook on the scheduled developments for the upcoming year?

The best outlook would be that we leave COVID-19 behind us, however I think that COVID will strongly influence the developments and investments in 2021. There are a number of scheduled developments which will impact corporate clients. Corporates will have to put their capacity in the IBOR Migration.  Also, the transition to XML messages will impact the operating architecture and bank connectivity of corporates.  In parallel, the transition to instant payments including batches will have to be put on the calendar of the finance function.

And in parallel, it is recommended to continue to look at the potential of open banking and further integration of payments data in the corporate business processes. An example is how payment data can improve the risk profiles of insurance companies.

In summary, enough subjects to keep an eye on. Sitting still and waiting is not an option.

11. A great initiative is that Enigma Consulting supports charity projects, what kind of charity projects does Enigma Consulting support, why and how?

The why should never be a discussion, the real discussion is what you can do. One of our activities is the ZEPA challenge.  Our consultants do like sports, and a lot of them love to cycle. When the transition to SEPA was going on, some of our consultants took the initiative for this challenge: cycling from Zeist to Paris in 24 hours. We have done this now 3 times, and a number of our clients’ employees have also participated.  This year’s event was cancelled, but we are already “ready” for the next challenge. There is not a fixed charity goal, the last charity was support for the education of young refugees.

Apart from the above, we have a warm partnership with “Goede Doelen” charity organisations in Netherlands and facilitate a free payments helpdesk for them.

It is of crucial importance to us to participate in an open and honest society, in which diversity and inclusion are critical. This is important for our own culture, as as an organisation we benefit from our consultants and they, in turn, foster these values in their personal lives.

Blockchain, IoT and 5G: a Marriage a Trois

| 07-06-2020 | Carlo de Meijer | treasuryXL

Long-time Blockchain has been looked at as an isolated technology. Recently however we see a growing trend of blockchain being integrated with other technologies such as Big Data, Artificial Intelligence amongst others. An interesting development that can be observed is the growing attention of corporates to use blockchain for IoT or Internet of Things applications. And that is not strange. The IoT market is increasing drastically and this is expected to continue in an accelerated way triggered by the recent uptake of the 5G network. But with this there arise a number of big challenges that may limit its future growth. Blockchain is seen by a growing number of corporates as the technology that could solve a number of these issues. Let’s have a look!

But what is Internet of Things?

IoT or Internet of Things has emerged as a network of internet connected devices. These devices range from simple consumer-devices to heavy industrial machines and may include laptops, smartphones, smart gadgets, smart watches, smart and digitalized vehicles, smart bicycles, medical sensors, smart security systems etc. These IoT devices are integrated with high definition technology like sophisticated chips, sensors, or functional software, that makes it possible for them to communicate or interact over the internet smoothly and exchange information with each other. IoT involves first of all sensing, monitoring, and exchange of data, followed by efficient data storing and processing using technologies like cloud computing. Data is thereby transmitted from the device to the IoT network where the information is managed using analytics and then directed back to the IoT equipment. The analytics capabilities of the IoT use these data to convert insights into action, impacting business processes and leading to new ways of working.

In the meantime the Internet of Things has provided many services in the fields of intelligent transportation, smart cities, medical treatment, smart agriculture and many others. These IoT-based solutions allow the automation of daily tasks and enable effective monitoring and control of the connected devices. This may result in improved efficiency and convenience in performing tasks.

Challenges

The advancements in IoT have popularized the development of 5G-enabled-IoT applications. 5G, the next generation of mobile networks, promises remarkable performance improvements  and is envisaged to broaden IoT’s scope and fields of applicability. Such 5G IoT applications however  pose stringent requirements such as high capacity, assured privacy & security, scalability of heterogeneous applications, ultra-low latency, optimized use of network resources, efficient energy management and low costs.

Since current mobile networks including 5G and also more general IoT systems are based on centralized models they may face big challenges to meet-up the requirements of future 5G-enabled-IoT use cases. With the huge number of devices set to enter IoT networks in the coming years, these centralized arrangements have very restricted scalability, while exposing a large number of vulnerable points that could endanger network security and can become extremely costly and sluggish.

a. Scalability
One of the most crucial difficulties with current 5G IoT networks is that of scalability. IoT relies on centralised cloud-based architecture for their control and management. It would be an urgent task for the centralised cloud servers to scale up their capacity and computing power and handle the massive amounts of data collected by a large network of sensors. With the increasing number of devices and the huge amount of data they are generating, current centralised systems to authenticate, authorise and connect different nodes in a network may become a great bottleneck.

b. Security
Another fundamental problem with current 5G IoT systems that may hinder its large-scale development, is their security architecture. A centralised client-server model managed by a central authority would make it vulnerable to a single point of failure. Many IoT devices have very low security features embedded into them. As a result they may get affected by privacy and security breach, while there is reduced safety for users. That make them an easy target for cyber-criminals to exploit the weak security protection to hack them into launching DDoS attacks.

c. Privacy
Another problem is privacy. The IoT network can process data transactions across multiple devices that are owned and administered by different organisations. This makes it difficult to identify the source of any data leakages in case of a cyberattack. Additionally, the IoT generates a vast amount of data, and with multiple stakeholders involved, the ownership of the data is not always clear. This could potentially undermine the reliability of IoT sensors. Measures to ensure the integrity of IoT devices such that they cannot be altered by external interventions are thus key to securing a safe environment for data recording and transactions.

d. No common standards and protocols
The devices in an IoT network are part of different technology standards with different protocols, making it difficult to build a coherent system. The data generated in the networks have different ownership and are highly noncoherent, hence, hard to trace and audit. Data could either be locked in or may not be inter-operated because of different communication standards and protocols and operating systems.

e. Lack of auditability and control over data sharing/usage
In an IoT network a huge amount of data is generated from devices that are proprietary to several enterprises. It is difficult to manage and audit such data in terms of who owns them, where from are they generated and how can they be processed. Most of the times such data is not under the control of all the intermediate parties involved such as equipment vendors, service providers or users who share a common platform.

Blockchain can be of great help

These  issues have become key in IoT systems and if not solved may aggravate when the increase in IoT products will accelerate. Continuing the use of centralized solutions 5G IoT driven applications will not only struggle to meet the demands but will also adversely affect the projected visions of IoT. To solve these issues blockchain or distributed ledger technology (DLT) is increasingly seen as a promising solution to help address these challenges in a unified and decentralised way.

Blockchain, can play an important role in how devices will communicate directly between each. Blockchain, as a distributed database system, can record all information about transactions. This fits perfectly into the basic functions and architecture of the IoT. The distributed nature of blockchain allows the industrial entities and various IoT devices to exchange data to and from their peers, eliminating the centralized operational requirement. Blockchain thereby enables users of 5G IoT networks to interact and transact (store and retrieve data) with ensured data provenance and authenticity, accountability, immutability, and non-repudiation for every user. Blockchain can thereby help alleviate the security, privacy and scalability concerns associated with IoT, by building trust, cost reduction and the acceleration of transactions, without relying on central participants.

How will Blockchain bring these benefits for IoT?

a. Immutability
The distributed ledger in a blockchain system is tamper-proof. Each transaction is recorded, put into a data block, and added to a secure, immutable data chain that cannot be changed. No single organisation has control over the vast amount of data generated by IoT devices. This immutability is regarded as a principal strength of blockchain-based smart contracts, as it removes the need for trust among the involved parties.

b. Improved security
Blockchain’s strong protection against data tampering helps prevent a fraudulent device from disrupting synergy of communication systems by injecting or relaying harmful information. Using blockchain to store IoT data would thus add another layer of security that hackers would need to bypass in order to get access to the network. The blockchain technology thereby holds the potential to securely unlock the business and operational values of 5G networks to support common tasks, such as sensing, processing, storing, and communicating information.

c. Transparency
Blockchain also provides transparency, by allowing anyone who is authorised to access the network to track the transactions that happened in the past. Compared to the ordinary database systems in IoT ecosystems the distributed ledger provides capability to transparent record keeping of the events logged, while the ledger is protected against alterations with the utilization of digital signatures. Through transparency of smart contracts, the trust in 5G IoT networks is decentralized. The deployment of smart contracts in IoT makes the nodes trustworthy and compliant in the specific business ecosystem.

d. Guaranteed integrity
Blockchain as well as blockchain-based smart contracts may also ensure the accountability and integrity of IoT related networks. Smart contracts can be defined as software codes enforcing the regulatory criteria and make them transparently available. These contracts entirely depend on transparency and consistent integrity of all member nodes. The much more robust level of encryption provided by blockchain makes it virtually impossible to overwrite existing data records.

e. Accelerated data change
The performance of the entire IoT ecosystem in terms of higher throughput and latency depends on the accelerated operation of data change in the IoT nodes. As the number of interconnected devices grows, blockchain and smart contracts may provide a viable solution as it can enable fast processing of the growing number of transactions and coordination among the huge number of connected devices. The centralized validation of a particular data can be replaced by decentralized validation with the use of smart contracts deployed on the IoT node itself. This may drastically diminish the data validation time, as well as the chances of manipulation or access.

f. Reduced costs
And as a result of all this, the operational costs of an IoT ecosystem can be minimized when  blockchain and smart contracts are utilized. Blockchain and smart contracts can allow IoT companies to reduce their costs by eliminating the processing overheads (deploying expensive high-end computing infrastructure) related to IoT gateways, associated with middlemen and intermediaries.

Applications of Blockchain IoT

Blockchain IoT applications are increasingly used in various sectors like supply chains, transportation and logistics, retail, automotive, healthcare, manufacturing, construction, government, energy and utility. Corporations are thereby focusing on increasing operational efficiency through real-time data management and automation of tasks. Blockchain IoT applications are  thereby used for purposes like process automation, supply chain management, smart cities, smart homes, asset tracking and monitoring, data analytics, data sharing and communication, smart cars, decision analytics, home automation, and smart grids.

Supply chain
Blockchain and smart contracts may be of great added value in the 5G IoT smart  supply chain. Blockchain IoT applications for tracking purposes are especially used by supply chains to track the location of goods as they are shipped, and ensuring that they stay within specified conditions. The blockchain can store, manage, protect and transfer all this smart information, such as the temperatures, position, arrival times, and status of shipping containers as they move. Sensors give companies end-to-end visibility of their supply chain by providing data on the location and condition of the supplies as they are transported around the globe.  Immutable blockchain transactions help ensure that all parties can trust the data and take action to move products quickly and efficiently.

Maintenance
Blockchain IoT asset tracking devices are also used by a lot of businesses for long-range identification of assets and machinery to record activity and output as an alternative to cloud solutions. This is especially important for predictive maintenance modelling. The ability to track components/spare parts that go for instance into an aircraft, automobile, or other products is critical for both safety and regulatory compliance. IoT data stored in shared blockchain ledgers enables all parties to see component provenance throughout a product’s life.  From engines to elevators, blockchain provides for a tamper-free ledger of operational data and the resulting maintenance.

Smart city and smart homes
Blockchain IoT solutions are increasingly being used in smart cities to enable the services such as payments, e-Governance, security, and surveillance of the smart cities. Smart cities are the implementation of advanced modern techniques in the urbanization to improve the quality of human life.

Blockchain IoT solutions also find their way in smart homes, that are intended to automate the entire home environment comprising of home appliances and devices. Blockchain can thereby fuel different use cases such as smart home monitoring, remote accessing, energy optimization, surveillance and so on.

Data Analytics
Blockchain IoT can also be applied to data analytics to investigate different types of data. It can be used by businesses for predictive and descriptive analysis to improve customer knowledge, enhance operational efficiency, and create business value. Businesses are increasingly using Blockchain IoT data analytics to determine trends and patterns by analysing big and small data to extract meaningful insights.

Smart healthcare 
Blockchain IoT has numerous applications in the healthcare industry. The technology can be used to provide high-quality medical services using smart devices. IoT devices can collect health care data, and these data is stored online. They can be accessed anytime by a physician, Blockchain can as a result enable secure and trusted IoT medical automation systems for real-time monitoring, logging privately medical history, sharing securely medical documents and supporting vital data which can help in making clinical decisions.

Smart farming
The concept of smart farming can revolutionize the agriculture industry. Farmers can use smart blockchain IoT farming applications for optimizing a lot of different activities such as determining the best time to harvest plants, as these devices can detect weather conditions and other environmental data. But also creating fertilizer profiles based on the chemistry of soil, and sensing soil nutrients and moisture levels. Blockchain enabled IoT applications for agriculture purposes can help to boost both the quality and quantity of agriculture production,  while minimizing the cost.

Key players in the Blockchain IoT market

A growing number of companies are leveraging blockchain technology to allow any IoT device to securely connect, interact and transact independently of a central authority. Key players include big tech companies like Amazon, Cisco, Huawei, IBM, Intel, Microsoft and SAP as well as big blockchain platforms such as Ethereum, the Linux Foundation and R3. And a growing number of smaller companies using blockchain to make the Internet of Things safer and smarter have entered (or are entering) the market. Some interesting newcomers:

Ambrosius
Ambrosius is a public permissioned blockchain ecosystem with a large number of decentralized node operators securing the network. The Ambrosus blockchain is optimized for interconnectivity with IoT devices, sensors, existing ERP systems, and other enterprise management software. Ambrosius is used for decentralized applications, securing the Internet of Things, physically tracking real-world assets, and integrating blockchain into enterprise software.

Atonomi
Atonomi is an open platform that encourages third-party development. Atonomi provides IoT developers and manufacturers with an embedded solution to secure devices with blockchain-based immutable registration of identity and reputation tracking. While device identity is recorded and validated on an immutable ledger, device  reputation is calculated and recorded based on monitored transactions. This enables fluid interactions between validated IoT devices, regardless the manufacturer, across the Atonomi trust environment.

Chain of Things
Chain of Things (CoT) is a consortium of technologists and leading blockchain companies. It investigates the best possible use cases where a combination of blockchain and IoT can offer significant benefits to industrial, environmental, and humanitarian applications. So far, CoT has built Maru, an integrated blockchain and IoT hardware solution to solve issues with identity, security, and interoperability.

IOTA
IOTA is a protocol for fast transaction settlement and data integrity, with a Tangle distributed ledger that eliminates the need for expensive mining (validation of transactions). IOTA is an infrastructure for IoT devices that need to process large amounts of micro data. Features of the Tangle ledger are machine-to-machine communication, fee-less micropayments, and quantum resistant data. IOTA has built a sensor data marketplace and is entering the market for data-driven insights, supported by more than 20 global corporations.

Modum.io
Modum.io combines IoT sensors with blockchain technology, providing data integrity for transactions involving physical products. The modem sensors record environmental conditions, such as temperature, that goods are subject to while in transit. When the goods arrive at the next transit point or end customer, the sensor data is verified against predetermined conditions in a smart contract on the blockchain. The contract validates that the conditions meet all of the requirements and triggers various actions such as notifications to sender and receiver, payment, or release of goods.

Xage Security
Xage is the world’s first blockchain-enabled cybersecurity platform for IoT companies. Their technology can manage billions of devices at once and can even self-diagnose and heal possible breaches. Xage is proximality used by IoT companies in the transportation, energy and manufacturing industries.

Blockchain IoT market 2020–2026

An interesting report was recently launched by Markets & Markets, forecasting the development of the global Blockchain IoT market till 2026. Especially the need for IoT security, simplified processes supported with transparency and immutability, and high adoption of blockchain-based IoT solutions using smart contracts and Artificial Intelligence (AI) are expected to surge demand for the blockchain IoT market globally.

Main highlights

  • The global Blockchain IoT market is expected to grow tenfold from USD 258 mio in 2020 to more than USD 2.4 bn by 2026, an average yearly growth of more than 45%.
  • Whereas the hardware segment (including IoT sensors and crypto wallets) showed the highest share up till now, due to growing demand and infrastructure for deploying, developing and managing blockchain applications, software and platforms are forecasted to take the lead.
  • Data security held by far the largest market share in 2020, due to the crypto mechanisms used of the blockchain. The smart contracts segment is expected to be the fastest growing during the forecast period due to the increasing use of blockchain IoT in the construction industry.
  • While the government segment held the largest market share up till now due to the increasing government initiatives and use of blockchain IoT across the many smart city projects, verticals such as supply chain, logistics, automotive, healthcare, manufacturing and construction are also expected to register a high demand for blockchain IoT.
  • The growing adoption of blockchain and IoT technologies across the retail sector is also expected to drive market growth during the forecast period. Retailers increasingly use IoT and blockchain technology to track products in stores, prevent product tampering, and increase security across retail stores.

Final remarks

The expected potential of  the 5G IoT market today is limited by an extremely fragmented IoT ecosystem. Blockchain technology appears as potentially the most suitable and efficient way to the various 5G IoT challenges. For optimising the value of blockchain the creation of common ecosystems with commonly accepted standards and global protocols is thereby of utmost importance. To achieve that, standardized infrastructures, open application programming interfaces (APIs) and collaborations among stakeholders are urgently needed. That means that many stakeholders, even competitors in the same industry, should collaborate and adopt a shared distributed ledger platform with compatible standards protocols enabling users to access all connected applications. If so that would be a great marriage a trois between blockchain, IoT and 5G.

 

 

Carlo de Meijer

Economist and researcher

 

 

 

 

Source

Should corporate treasurers stop ignoring bitcoins and other crypto currencies?

26-5-2021 | treasuryXL | Pieter de Kiewit

This is a blog by someone who does not own bitcoins or other crypto currencies and does not intend to purchase any soon. Someone who is not a subject matter expert. Someone who told his colleagues not to consider the topic relevant for corporate treasury for a long time. Someone who thought bitcoins are only relevant for extortionists or those who speculate, gamble and hope to get rich quickly. You understand, that someone would be me.

Slowly I am getting this “One wrong-way driver? I see dozens!”-feeling. Newspapers are filling up with blockchain news. Pension funds start seeing crypto currencies as a relevant asset class. Auction houses start accepting payments (Tesla stopped again) and in countries with hyperinflation in South America, people are fleeing into cryptocurrencies, especially stable coins. After a first attempt with the Libra, Facebook is introducing a stable coin with the so-called Diem that seems to be connected to the US dollar.

My main objection always was that I did not see the underlying value. Real estate is bricks, shares are a piece of ownership, bonds should be paid back and with fiat currencies you can buy in a store. I cannot live in bitcoins and my baker does not accept them as payment. But with gold I cannot buy bread either. It has some practical use as a metal but that does not justify its current value. So why measure bitcoins in practical use and underlying value?

The core discussion is about speculation and trust. There used to be times we knew a dollar or gulden could be exchanged for gold, so we trusted our money. But the gold standard is not so standard anymore. Of course the prices of dogecoins, ethereum and bitcoins are extremely volatile but how about the rates of Argentine Pesos, Venezuelan Bolivars, Turkish Liras or pre WOII German Deutschmarks? When you cannot stand the heat, stay out of the crypto currency kitchen but I do not consider volatility a reason to disqualify the asset class.

As to myself, perhaps I just have to accept that I am a laggard or at best member of the late majority in accepting the technology/solution. As to corporate treasurers, the survey shows they have the ambition to educate themselves better on the topic. Of course to be able to answer questions from their colleagues and perhaps to initiate some form of a practical application of crypto currencies. I hope that, next to the Tesla example, in further blogs we can inform you about relevant business cases. About successful implementation but of course also about the bottlenecks like taxation and reporting. There will be enough happening for many future blogs. And I will be someone who communicates differently about crypto currencies.

PS You might enjoy the slides of a recent presentation by Tristan Verhagen, recent Register Treasurer graduate, a great introduction into Bitcoins with provoking insights. See link.

Take care, Pieter

 

 

Pieter de Kiewit

Owner at Treasurer Search

 

 

 

Bank connectivity 2.0. New solutions offer new opportunities! (Dutch Item)

05-05-2021 | treasuryXL | Enigma Consulting |

Veel organisaties hebben voor het betalingsverkeer een zogenaamde ‘Payment Hub’ geïmplementeerd voor de connectiviteit met de banken. Zo’n hub zorgt voor een veilige, automatische connectie om betaal- en incasso opdrachten naar de bank(en) te sturen en dagafschriften te ontvangen. Veel van deze hubs zijn in 2012 bij de overgang naar SEPA geïntroduceerd. Sindsdien is de technologie echter drastisch veranderd en bieden nieuwe oplossingen, via Software-as-a-Service (SaaS), rijkere functionaliteit aan tegen een veel efficiënter bedrijfsmodel. “Het wordt dus hoog tijd om uw bankconnectiviteit opnieuw onder de loep te nemen!”, aldus Roderick Kroon, partner bij Enigma Consulting.

“Het gebruik van een Corporate Payment hub voor bankconnectiviteit tussen de corporate ERP / TMS-systemen en de bankrelaties neemt in aantal toe. Trends als digitalisering, standaardisatie en de toegenomen aandacht voor fraude- en risicomanagement maken het automatiseren van de connectiviteit met banken een onderwerp op de managementagenda.”

Er zijn volgens Kroon momenteel drie interessante ontwikkelingen die resulteren in een verhoogde focus op bankconnectiviteit in de Nederlandse markt:



1. De toegenomen focus op het ‘in control’ willen zijn

“In het verleden waren Treasury en Finance vooral gefocust op de hoge waarde / laag volume Treasury betalingen en niet te veel op de commerciële betaalstromen. Uit de discussies van Enigma met veel corporate treasurers zien we een grotere focus op het ‘in control’ zijn door bijvoorbeeld handmatige activiteiten te verminderen, het aantal tokens voor elektronische banksystemen te verminderen en realtime inzicht in liquiditeit te hebben. De verbeterde proposities van TMS-systemen en netwerk partijen zoals SWIFT, leiden tot de logische stap om de bankconnectiviteit te automatiseren. Dit omvat niet alleen de automatisering van de betaalstromen, maar ook de ontvangst en distributie van bankafschriften intern.”

2. Er zijn nieuwe (payment hub) oplossingen met een revolutionair bedrijfsmodel

“Ook aan de oplossingszijde zien we interessante ontwikkelingen. Nieuwe (Fintech) leveranciers zoals Cobase, Nomentia, Kyriba of TIS nemen (multi-tenant) SaaS als uitgangspunt om de IT-footprint te verkleinen en zorgen ervoor dat klanten direct profiteren van verbeteringen die voor andere gebruikers wordt ontwikkeld. Vooral op het gebied van bankconnectiviteit zien we een verschuiving van ‘maatwerk voor de klant’ naar ‘best-practise oplossingen van de leverancier zelf’. Gebruikers profiteren direct van investeringen die reeds gemaakt zijn voor andere klanten en bankkoppelingen die al deel uitmaken van de standaardoplossing. Sommige leveranciers gaan zelfs nog verder en bieden de gehele bank onboarding aan als ‘service’.”

“Kennis van de details van betaalformaten, (bank)kanaalopties en noodzakelijk contracten is dan niet meer noodzakelijk zelf te hebben. Andere (eveneens SaaS) leveranciers zoals COUPA Treasury of Serrala richten zich op het creëren van complete ecosystemen en samenwerkingen met derde partijen om de waarde propositie en relevantie verder te versterken.”

3. Vervanging van (verouderde) Payment Hub-oplossingen

“Een derde interessante ontwikkeling is dat ‘early stage’ payment hubs aan het einde van hun economische levenscyclus zijn gekomen en aan vervanging toe zijn. Sterker nog, één grote speler (CPH van FIS) heeft haar klanten geïnformeerd einde 2021 te stoppen met het product waardoor tientallen bedrijven op zoek moeten naar een andere oplossing.”

Met de introductie van SEPA in 2012 maakte een groot aantal bedrijven de keuze om een payment hub te implementeren, vertelt Kroon. “De belangrijkste focus in die tijd was het verminderen van de complexiteit van veranderingen in het bestaande IT-landschap. In die tijd speelden Payment Hub-oplossingen vooral een rol bij:

  • Bestandsconversie of -verrijking van (in NL Clieop) formaten naar SEPA formaten
  • SEPA-machtigingsbeheer voor automatische incasso om de (te complexe) ‘FIRST versus ‘RECURRENT’ richtlijnen te volgen en het nieuw vereiste ‘machtigingskenmerk’ te administreren
  • Het bieden van een alternatief voor kanalen die banken besloten uit te faseren om hun SEPA-programma’s te vereenvoudigen (bijvoorbeeld het ING Finstream-kanaal)”

“De stand van de techniek was echter totaal anders dan tegenwoordig. API’s, SaaS of Cloud bestonden niet. De implementatie was veelal ‘on-premise’ met een aanzienlijke IT-voetafdruk en initiële CAPEX-investering. In de afgelopen maanden heeft Enigma Consulting meerdere discussies gevoerd over de noodzaak om deze ‘vroege’ payments hubs te vervangen en zijn wij betrokken bij meerdere selectie en vervangingstrajecten. De leverancierselectie projecten die we hebben gedaan ter vervanging van bestaande oplossingen hebben interessant genoeg een zeer positieve businesscase als resultaat:

  • Er zijn grote extra investeringen (soms upgrades) nodig in de legacy-oplossingen om de IT-beveiliging te verbeteren of om nieuwe bedrijfsfuncties beschikbaar te maken. Nieuwe oplossingen zullen deze kosten onmiddellijk elimineren;
  • De huidige kosten zijn in vergelijking met de kosten van nieuwe oplossingen een stuk duurder;
  • Sommige leveranciers zijn van eigenaar veranderd en de focus op payments én bankconnectiviteit is verdwenen, terwijl nieuwe oplossingen de huidige marktfactoren en ontwikkelingen in het betaaldomein zeer groep begrijpen;
  • Nieuwe SaaS / Cloud-oplossingen verkleinen de IT-footprint aanzienlijk en vereisen veel minder (vaak schaarse) capaciteit van IT voor onderhoud / upgrades;
  • De huidige payment hubs bieden een breder scala aan diensten en kunnen veel eenvoudiger (via API’s) worden geïntegreerd met andere systemen (bijv. cashmanagement, fraude, treasury, ERP, transactie monitoring);
  • Veel payment hubs bieden mu volledige ondersteuning voor ‘on-behalf’ (POBO / COBO) verwerking in combinatie met in-house bankieren en / of virtuele accountoplossingen.”

Is bankconnectiviteit een apart onderwerp?

Kroon: “Niet per se. Hoewel het onderwerp zelf perfect als individueel vraagstuk kan worden aangepakt, zien we dat onze klanten de benodigde verandering op dit domein koppelen aan een bredere discussie over hun financiële waardeketen. Vaak gaat een noodzakelijke verandering in het connectiviteitsdomein van banken hand in hand met bredere discussies over de visie ten aanzien van ‘betalen’ en het gerelateerde Target Operating Model, waarin alle marktontwikkelingen (outside in), interne ambities (inside out) en discussie over de bankrelatie (s) worden meegenomen. De selectie van de best passende leverancier voor de payment hub moet dan worden gezien in het bredere perspectief van een routekaart (roadmap) voor Payments op de middellange termijn.”

Dus wat nu te doen?

“We raden aan om de oplossing die is gekozen voor de bankconnectiviteit opnieuw te (laten) beoordelen. Indien deze nog niet geautomatiseerd is kan er een sterke businesscase zijn om dit te veranderen, de efficiëntie te verbeteren en risico’s te verminderen. Indien er al wel een oplossing is kunnen er argumenten zijn om te profiteren van vervanging door een van de nieuwe oplossingen die ‘meer bieden voor minder’.”

“Wij adviseren om verder te kijken dan alleen bankconnectiviteit en het volledige betaaldomein in beschouwing te nemen om te valideren of men voldoende voorbereid is op de toekomst, rekening houdend met alle nieuwe ontwikkelingen in het betalingsverkeer. Enigma Consulting kan de business case versterken door een efficiënt traject met behulp van de unieke ‘RFP-as-a- service’ en ‘Payments Road map’.”

ECB and a Digital euro: positive consultation results

03-05-2021 | Carlo de Meijer | treasuryXL

Last year I wrote a blog on the ECB plans to investigate if one should introduce a Digital euro. They announced to launch a public consultation on the desirability of such a central bank digital currency for the euro zone.

Now we are a half year later and in a comprehensive analysis of the results of this consultation the ECB published the findings of this inquiry that mirrored a rather positive attitude. The report thereby provides important input into the ECB’s analytical and experimental work and into the upcoming decision of the Governing Council on whether (or not) to launch a formal investigation phase in view of the possible issuance of a digital euro as a payment instrument. So nothing has been decided so far!


Why a digital euro?

In that same blog I mentioned the various reasons why central banks all over the world, including the ECB, are investigating the need and viability of central bank digital currencies (CBDCs). Such as the further digitalisation in the payments world and the continued trend towards a more cashless society. And China’s advancements with their own digital Yuan and the fear that it would become a dominant currency eroding other international used currencies like the dollar and the euro. But also Facebook’s  plan to launch its stable coin named Diem that could be used globally and the big interest of private people and companies to invest in cryptocurrencies such as Bitcoin and Ether with the danger of crowding out fiat currencies.

According to the ECB these developments may undermine central bank’s control over monetary policy and endanger financial and monetary stability in the EU. So in fact the launch of a Digital euro is increasingly becoming a strategic issue for Europe. EU members like France but also the Netherlands have recently begun experimenting with a Digital euro. But any decision would require intensive cooperation between member states.

ECB Digital euro consultation

The ECB recently released its report on the consultation on a digital euro. The consultation that was launched in October last year, received over 8200 responses. The large majority of respondents were private citizens (94%), of which mostly men between 35 and 54 years old, while the other participants were professionals, including banks, payment service providers, merchants and tech companies. Most responses came from Germany (47%), Italy (15%) and France (11%).

Main findings

The consultation report shows that Europe’s citizens are in favour of a digital euro, but under a number of conditions.

The results show that citizens as well as professionals (esp. merchants and other companies) are in favour of such a development, provided that the Digital euro respects privacy (43%) and confidentiality of transactions and that it is sufficiently secure (18%) to prevent fraud. They also support requirements to avoid illicit activities with fewer than one in ten responses from members of the public showing support for full anonymity.

 

“The record level of participation in our public consultation and the willingness of citizens and professionals to support a digital euro are encouraging. Their responses show the high expectations that prospective users have for a digital euro and provide valuable input for our work.” Fabio Panetta, ECB Board member 

 

According to the document, two in five respondents thought that “Digital euro transactions should be visible to either intermediaries or the central bank, which would effectively allow the application of anti-money laundering and combating the financing of terrorism (AML/CFT) requirements.” Additionally, one out of ten respondents believes that transfers under a certain threshold should remain private.

 

“A digital euro would therefore allow people to make payments without sharing their data with third parties, other than what is required by regulation. This differs from private payments, where services are generally offered in exchange for personal data that are then used for commercial purposes.” Christine Lagarde, president ECB

 

The respondents also want a Digital euro that is easy to use, without additional costs (9%), and that allows for fast and reliable payments via payment cards and iPhones (8%).

More than two-thirds acknowledge the importance of intermediaries providing innovative services that allow access to a digital euro and indicate that it should be integrated into existing banking and payment systems. They would like additional services provided on top of basic digital euro payments.

Around a quarter of the respondents take the view that a Digital euro should make cross-border payment faster and cheaper. They also want to be able to use the digital euro outside the Eurozone, though with limits.

 

“A digital euro can only be successful if it meets the needs of .Europeans.” “We will do our best to ensure that a digital euro meets the expectations of citizens highlighted in the public consultation”. Fabio Panetta, ECB Board member

Next steps

The feedback is now to be communicated to the European Parliament as well as the Commission and the Council. And it is up to the Euro system – which includes the ECB and central banks of countries that have adopted the euro – to decide whether the project should be launched.

Following the findings of the consultation, the ECB is set to take a decision on starting formal investigation on a Digital euro on whether to commence central bank digital currency trials by the middle of 2021, before a further six months to one year practical trial of the technology.

And if this decision will be a positive and the green light is given, the Digital euro, a complement (not a replacement) to banknotes and coins, could see the light of day in four years from now, according to ECB president Lagarde. She indicated it may be 2025 before any digital currency would be ready.

 

“Because it’s a technical endeavour as well as a fundamental change because we need to make sure that we do it right. We owe it to Europeans, they need to feel safe and secure. The need to know that they are holding a central bank-backed equivalent of a digital banknote. We need to make sure that we’re not going to break any system, but enhance the system”. Christine Lagarde, president ECB

 

The ultimate design of the digital euro lies with the ECB that will take the public consultation into consideration and look into various possibilities, including use of distributed ledger, definition of spending limits, use of a device for transfers and payments, online/offline capabilities, or availability of cross-border transactions outside Europe.

The Dutch positive stands towards the Digital euro

In narrow cooperation with the ECB and the other national banks in the Eurozone, the DNB is also exploring the possibility of issuing a Digital euro in addition to euro banknotes and coins.

In a recently published report, the Dutch Central Bank said it was ‘ready to play a leading role’ with research and development into its own digital currency as well as a Europe-wide digital currency. The Netherlands would be a suitable testing ground, according to the report, being well placed to develop and trial a Digital euro. The Netherlands is the country where the move out of cash is the largest in Europe. Nearly two thirds of all payments in the country are digital.

The main findings of the report

In this report the DNB researched the satisfaction with the current payment system and the willingness to hold a Digital euro account among a representative group of Dutch citizens. The findings are broadly in line with those of the ECBs public consultation.

While citizens are very satisfied with the current payment options, half of the Dutch population would be interested in opening a current account for Digital euros, an electronic form of central bank money that is available for all citizens and businesses – similar to banknotes and coins, but exclusively in digital form. Relating top the amount they would be willing to deposit into a digital euro account, most of the, opted for €101-500.

Main condition is that privacy is well protected, security features should be adequately safeguarded if people want to open such an account and the risk of theft and fraud of their assets is minimized.

Familiarity with the concept of a Digital euro increases people’s willingness to use it as a means of payment. Almost half of Dutch citizens are familiar with the concept, although most people indicated they did not knew exactly what it entails. 53% said they had never heard of it, 33%had heard about it but do not know what it means while 13% knows exactly what it means.

The most frequently cited reason why the Dutch public believe a Digital euro would be useful and could be a reliable complement to cash and existing electronic payment instruments, is that central banks, unlike commercial banks, do not operate on a for-profit base.

Balancing act

While earlier discussions on CBDC were mostly academic, the focus has increasingly turned to the technical aspects and financial and monetary issues. The ECB received many technical suggestions from the respondents. According to a quarter of individual respondents, end-user solutions comprising (smart) cards or a secure element in smartphones would be preferred to facilitate cash-like features. Building a Digital euro for retail payments may require an infrastructure that is interoperable with existing point of sale terminals or with digital platforms

What may it bring?

A Digital euro could bring many benefits to the population as it would grant greater usability, speed and safer payments transactions while it could leverage technology. It could also enhance digital inclusion, facilitate monetary policy implementation, and help protect against frauds and thefts. Being issued by the ECB and supposed to be not more expensive than the use of cash, it would be a cost-efficient payment solution for individuals and businesses with limited interchange fees, if any.

What about the future of commercial banks?

A digital euro however could pose a number of problems in a number of areas. These should be attention points in the further discussion that should be addressed before the release of the Digital euro to ensure the stability of the financial and monetary system.

First of all for banks, what will be there future?  What about the already identifying competition by fin techs and big techs using crypto currencies?

Lagarde raised that certain intermediaries – that is, banks – are apprehensive about what the issuance of this Digital euro may mean for them, noting that they should not be concerned.

 

“We need to also make sure that we are not going to break the system but to enhance the system.” “Those intermediaries will continue to co-exist, to develop their business and conduct their activities with cash which will continue to be available as will digital currency.” Christine Lagarde, president ECB

 

But in an increasingly digitised world banks may increasingly have to ask themselves how they may serve their customers’ future needs and how they can distinct themselves from their competitors.

And what about financial and monetary stability?

And how to avoid in times of financial crisis that a digital euro will “blow a hole” in commercial bank’s balance sheet. Especially in the event that savers would massively transform their deposits in banks into central bank money, in case of economic or financial crisis. This bank run could increase the cost of financing for banks, and in turn the interest rates on bank loans.

Almost half of the respondents of the ECB Consultation mention a need for holding limits, tired remuneration, penalty rates to excess balances or a combination of the two, to manage/control  the amount of digital euro in circulation and prevent a massive flight to digital euros in times of a financial crisis. A similar share of professional respondents agree.

Competition or cooperation?

Another issue is: will CBDCs trigger competition between central banks or cooperation? With the exception of China, most central banks are looking for (some sort of) cooperation. Under the auspices of the Bank for International Settlements (BIS), the ECB is part of a core group of central banks including the Bank of Canada, Riksbank, the Bank of Japan, the Swiss National Bank, Bank of England (BoE) and the Fed, who are jointly exploring CBDC.

The way forward

The topic of a Digital euro has gained much more public attention in the Netherlands and that is not strange as a much higher proportion of their payments is digital compared to other countries in the Eurozone. But for a Digital euro to get more footing in Europe, what is required is a more in-depth policy debate to be held more broadly across the euro area. This given that it is the Euro system that will decide on the potential introduction of a Digital euro.

If the decision should be taken within the Euro system to experiment with some more concrete type of digital euro the Netherlands said it is ready to play a leading role!

 

Carlo de Meijer

Economist and researcher

 

 

 

 

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