The FMLC Secretariat’s attention was drawn to an evidence gathering survey published ahead of the next public-private Innovation Working Group (“IWG”) on Legal Entity Identifiers (“LEIs”). The FMLC has published letters and papers in the past on the usefulness of the widespread adoption of LEIs.
The FMLC has submitted a response to the Consultation to draw attention to concerns with regards the definition of a “qualifying cryptoasset”.
FMLC CEO, Joanna Perkins, moderated the panel on Central Bank Digital Currencies (“CBDCs”): tokenised sovereign money which is made available to the general public for ordinary commercial purposes. Her remarks provided an overview of the response from policymakers and the market to the development of CBDCs.
The European Commission has launched a public consultation to gather stakeholder views on the possible enhancements to the E.U. anti-money laundering/countering the financing of terrorism framework. The FMLC would like to draw attention to two areas.
In Q3 2020 the European Commission is scheduled to propose a new Digital Finance Strategy/FinTech Action Plan that sets out a number of areas that public policy should focus on in the coming five years. A Consultation designed to gather stakeholders’ views on policies to support digital finance, which will inform that strategy, was published in April 2020.
The FMLC has drafted a response to the Consultation in the form of two complementary reports. Part I comprises comments on the classification of cryptoassets. Part II comprises comments in response to the section of the Consultation dealing with cryptoassets which fall within the E.U. regulatory perimeter.
In this paper, the FMLC explores the ways in which regulators and legislators have attempted to grapple with the many varieties of virtual currencies and in particular those which have arguably come to function as money for legal purposes. The definition of “virtual currencies” in the E.U.’s Fifth Money Laundering