Clifford Chance

Welcome to this month's global crypto round-up, summarising crypto regulatory developments that have happened around the world in May 2023 along with our Clifford Chance crypto publications and upcoming events. 

Details of these and previous developments can also be found on our Fintech Topic Guide on the Clifford Chance Financial Markets Toolkit.

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CLIFFORD CHANCE PUBLICATIONS

Singapore Court sheds light on scope of the payment services licensing regime for cryptocurrencies

In Rio Cristofle v Tan Chun Chuen Malcolm [2023] SGHC 66, the Singapore High Court recently considered claims arising out of a cryptocurrency trade that went awry.  The court confirmed that the Payment Services Act 2019 (PSA) does not impliedly prohibit contracts relating to the sale and purchase of cryptocurrency and analysed what would amount to carrying on a business of providing unlicensed digital payment services which would result in criminal liability.

Our case report examines the Singapore High Court's ruling in relation to the legislation regulating the provision of payment services in Singapore, including digital token services.

Securities and Futures Commission finalises new regulatory requirements for VATP operators

The Securities and Futures Commission (SFC)  has published the outcome of its consultation relating to updated regulatory requirements for virtual asset trading platforms (VATP). In this article, we outline the key SFC's responses and updates under the new regulatory requirements. 

SPOTLIGHT

Spotlight: A green future: how the cryptoasset sector can embrace ESG

We are delighted to have worked with leading payments platform Paysafe on an important new report:  A green future: How the crypto asset sector can embrace ESG on the key environmental, social and governance (ESG) considerations for the cryptoasset industry, including recommendations for UK policymakers to drive change. In the report we also analyse consumer attitudes towards ESG issues, look at current legal and regulatory ESG requirements and provide an overview of upcoming changes.

Partner Diego Ballon Ossio comments: "Much has been written about the environmental impact of crypto mining. However, this report also focuses on the social implications of new financial technologies, the governance of decentralised systems and other less scrutinised aspects of the crypto markets. Investors must consider all of these areas to make informed and responsible investment decisions."

Read our highlights here or download the report in full.

GLOBAL LEGAL AND REGULATORY UPDATES, INDUSTRY GUIDANCE AND PUBLICATIONS

International

• (31 May 2023) Bank for International Settlements (BIS) Financial Stability Institute (FSI) Executive Summary of the Basel Committee on Banking Supervision (BCBS)’s December 2022 final standard on the prudential treatment of cryptoasset exposures, which outlines minimum regulatory, supervisory review and disclosure requirements of banks' cryptoasset exposures under Pillars 1, 2 and 3 of the Basel Framework. Internationally active banks in BCBS member jurisdictions are expected to adopt the standard by 1 January 2025. | Webpage
• (25 May 2023) BIS note on ongoing policy perspectives on central bank digital currencies (CBDCs). The report summarises key themes continuing to be discussed by the BIS and the Bank of Canada, the Bank of England, the Bank of Japan, the European Central Bank (ECB), the Board of Governors of the Federal Reserve System, Sveriges Riksbank and the Swiss National Bank, and follows the publication of a report in October 2020 on the common foundational principles and core features of a CBDC, and reports on system design and interoperability, user needs and adoption and financial stability implications in September 2021. | Webpage
• (23 May 2023) International Organization of Securities Commissions (IOSCO) consultation report on policy recommendations for crypto and digital asset markets. The recommendations cover: (i) conflicts of interest arising from vertical integration of activities and functions; (ii) market manipulation, insider trading and fraud; (iii) cross-border risks and regulatory cooperation; (iv) custody and client asset protection; (v) operational and technological risk; and (vi) retail access, suitability, and distribution. Deadline for comments: 31 July 2023. | Press release
• (18 May 2023) The International Institute for the Unification of Private Law (UNIDROIT) has announced that, on 10 May 2023, its Governing Council adopted the UNIDROIT Principles on Digital Assets and Private Law. Following the adoption by the Governing Council, the Secretariat has commenced the process of preparing the instrument for publication, which is expected in the coming months. | Press release
• (17 May 2023) BIS FSI Insights paper entitled ‘Crypto, tokens and DeFi: navigating the regulatory landscape’, which provides an overview of policy measures taken in 19 jurisdictions to address the risks associated with activities that incorporate cryptoassets and distributed ledger technology (DLT) programmability capabilities in financial services. The paper classifies policy measures into three categories and identifies different types of initiatives across jurisdictions, including bans, restrictions, clarifications, bespoke requirements, and initiatives to facilitate innovation. | Webpage
• (17 May 2023) Financial Stability Board (FSB) press release on the meeting of the Regional Consultative Group for Asia in Cebu, Philippines on 17 May. Discussions centred around recent financial market developments and their impact on the region, the role of non-bank financial intermediation (NBFI) in Asia and the development of an effective global regulatory framework for cryptoassets.
• (17 May 2023) Global Financial Markets Association (GFMA) report, prepared together with Clifford Chance, Boston Consulting Group and Cravath, Swaine & Moore LLP, highlighting the potential transformative benefits of DLT for capital markets and calling for market participants to proactively shape its future use, as well as for greater regulatory clarity from policy makers. The report evaluates the opportunities and risks of DLT and DLT-based securities and assesses the applicability of existing legal, regulatory, and risk management frameworks, examining three emerging use cases: collateral management; tokenisation of assets; and sovereign and quasi-sovereign bonds. The report also sets out five calls to action to help overcome existing barriers to adoption and advance the development of DLT-based capital markets. | Executive summary |  Press release
• (13 May 2023) G7 Finance Ministers and Central Bank Governors communiqué following their meeting on Niigata, Japan on 11-13 May 2023. Amongst other things, the Ministers and Governors emphasised that effective monitoring, regulation and oversight are critical to addressing financial stability and integrity risks posed by cryptoasset activities and markets. They looked forward to the FSB’s finalisation of its high-level recommendations by July 2023 and committed to implementing effective regulatory and supervisory frameworks for cryptoasset activities and markets and stablecoin arrangements, which are consistent with the FSB’s recommendations and standards and guidance established by standard-setting bodies. They also noted that a reliable, stable, and transparent global payment system is a key foundation for the G7’s economic and financial activities, and that CBDCs could have a substantial role to play in this context.
• (11 May 2023) The BIS has published a handbook exploring key aspects of how CBDCs could work for offline payments, as part of Project Polaris.  The handbook provides an overview of the key aspects of offline payments with CBDC and is intended to serve as a guide for central banks considering implementing offline payments capabilities. | Webpage
• (3 May 2023) International Swaps and Derivatives Association (ISDA) whitepaper, ‘Navigating Bankruptcy in Digital Asset Markets: Digital Asset Intermediaries and Customer Asset Protection’, which examines how digital assets may be held by customers through intermediaries and considers how those assets can be protected following an insolvency of the intermediary, with a specific focus on English and US law. While digital assets raise some novel questions, the key finding is that traditional and fundamental protections of clear legal terms and segregation of assets can be adapted to the world of digital assets. | Press release

AFRICA

Central African Republic:

• (2 May 2023) International Monetary Fund (IMF) Country Report No. 23/155 on the Central African Republic, comprising a press release, staff report, and statement by the Executive Director for the Central African Republic on the 2023 Article IV Consultation and request for a 38-month arrangement under the Extended Credit Facility. The IMF has approved an arrangement of about USD 191.4 million, subject to a number of policy commitments including de-risking crypto-related projects – specifically removing legal tender and guaranteed convertibility for cryptoassets. An accompanying report notes that the legal and regulatory framework for cryptoassets in the Central African Republic remains incomplete and uncertain, and that coordination with the Central African Economic and Monetary Community (CEMAC) in strengthening and clarifying the framework is of paramount importance going forward. The report also concludes that the country’s digital coin (‘Sango’) project appears too complex, creating interconnectedness between multiple sectors and private and public balance sheets in a manner which could raise systemic risks, pointing to the importance of reconsidering the existing blueprint.

Nigeria:         

• (16 May 2023) IMF working paper which reflects on the first year of Nigeria’s CBDC, the eNaira, and concludes that, despite the undisrupted operation for the first full year, the project has not yet moved beyond the initial wave of limited adoption. The paper adds that network effects suggest the initial low adoption spell will require a coordinated policy drive to break it and that the eNaira’s potential in financial inclusion requires a strategy to set the right relationship with mobile money, given the former’s potential to either complement or substitute the latter.
• (3 May 2023) National Blockchain Adoption Strategy, which has been approved by the Federal Government and outlines a roadmap and strategies for the adoption of blockchain technology and the creation of a blockchain-powered economy that supports secure transactions, data sharing, and value exchange between people, businesses, and the Government.

Zimbabwe:  

• (4 May 2023) Reserve Bank of Zimbabwe (RBZ) issuance note inviting applications from individuals, financial institutions, corporates and other entities to subscribe for the issuance of RBZ Gold-Backed Digital Tokens No.1/2023.

AMERICAS

Brazil:          

• (26 May 2023) The Banco Central do Brasil (BCB) has selected 14 institutions to take part in the Digital Brazilian Real pilot project. The onboarding of selected stakeholders into the platform of the pilot will begin by mid-June 2023. In the first phase of the pilot, privacy and programmability features will be tested through the implementation of a specific use case – a delivery versus payment protocol (DvP) of a Treasury bond between users of different institutions, in addition to the services that support this transaction. | Press release

Canada:       

• (8 May 2023) The Bank of Canada has launched an online public consultation on the features that could be included in a digital Canadian dollar. Deadline for comments: 19 June 2023. | Press release

US:  

• (30 May 2023) Commodity Futures Trading Commission (CFTC) Division of Clearing and Risk (DCR) staff advisory on the risks associated with the expansion of derivatives clearing organisation (DCO) clearing of digital assets. CFTC Commissioner Kristin N. Johnson has issued a statement welcoming the staff advisory, but also calling for the CFTC to initiate a formal rulemaking process for CFTC-registered DCOs engaged in crypto or digital asset clearing activities. | Webpage
• (18 May 2023) Project Cedar Phase II x Ubin+ (Cedar x Ubin+) report by the Federal Reserve Bank of New York’s New York Innovation Center (NYIC) and the Monetary Authority of Singapore (MAS) on improving wholesale cross-border multi-currency payments and settlements. The project examined whether wholesale CBDCs developed using DLT could improve the efficiency and transparency of cross-border payments involving one or more vehicle currencies. | Project Cedar webpage
• (18 May 2023) The House Financial Services Subcommittee on Digital Assets, Financial Technology and Inclusion has held a hearing entitled ‘Putting the “Stable” in “Stablecoins:” How Legislation Will Help Stablecoins Achieve Their Promise’. | Hearing page with video
• (15 May 2023) The Securities and Exchange Commission (SEC) has filed its response to Coinbase’s petition for a writ of mandamus to compel the SEC to issue new regulations regarding digital assets, in which the SEC asserts that no statute or regulation requires it to take such action on a specific timeline and that Coinbase cannot demonstrate a right to the mandamus relief it is seeking. The SEC has also rejected as baseless Coinbase’s allegation that the SEC has secretly decided to deny its July 2022 rulemaking petition but is refusing to say so to avoid judicial review, and has indicated that it is continuing to consider Coinbase’s petition in the ordinary course.
• (5 May 2023) New York Attorney General Letitia James has announced the Crypto Regulation, Protection, Transparency, and Oversight (CRPTO) bill, which would introduce independent public audits of cryptocurrency exchanges, mandatory disclosure and prudential requirements and prevent individuals from owning the same companies, such as brokerages and token issuers, to stop conflicts of interest. Crypto platforms would also have responsibilities to customers similar to banks under the federal Electronic Fund Transfer Act by requiring platforms to reimburse customers who are the victims of fraud. The bill would also strengthen the New York State Department of Financial Services’ regulatory authority over digital assets. This program bill will be submitted to the State Senate and Assembly for their consideration during the 2023 legislative session. | Press release
• (3 May 2023) SEC final rule on amendments to Form PF, the confidential reporting form for certain SEC-registered investment advisers to private funds, to require new reporting related to certain key hedge fund and private equity fund events, as well as to require reporting of additional information regarding certain advised private equity funds. The SEC had originally proposed adding ‘digital assets’ as a new term to the Form PF Glossary of Terms, but has now indicated that, while it is continuing to consider this term, it is not adopting ‘digital assets’ as part of the final rule at this time.
• (2 May 2023) Florida’s State legislature has approved a Bill prohibiting the use of a federally adopted CBDC as money within Florida's Uniform Commercial Code and prohibiting any CBDC issued by a foreign reserve or foreign sanctioned central bank. The Bill is expected to take effect on 1 July 2023.
• (2 May 2023) White House Council of Economic Advisers blog post on the proposed Digital Asset Mining Energy (DAME) excise tax, which would, following a phase-in period, impose a tax equal to 30% of the cost of the electricity firms use in cryptomining.

APAC

China:            

• (15 May 2023) Supreme People's Procuratorate of the People's Republic of China guidance (in Chinese) on the legal attributes and risk governance of non-fungible tokens (NFTs), which states that NFT digital collections have the attributes of virtual assets and calls for strengthened risk research and judgment as well as the accurate punishment of related crimes.

Hong Kong

• (23 May 2023) Securities and Futures Commission (SFC) consultation conclusions on the proposed regulatory requirements for virtual asset trading platform operators licensed by the SFC. The guidelines for virtual asset trading platform operators will become effective on 1 June 2023. The guidelines cover safe custody of assets, segregation of client assets, avoidance of conflicts of interest and cybersecurity standards and requirements expected of licensed trading platforms. On 31 May 2023, the SFC provided additional guidance on the new regulatory requirements, other implementation details including licence application procedures, as well as more information about the transitional arrangements. | Circular on transitional arrangements of the new licensing regime for virtual asset trading platforms | Circular on implementation of new licensing regime for virtual asset trading platforms | Press release
• (18 May 2023) The Hong Kong Monetary Authority (HKMA) has announced the commencement of the e-HKD Pilot Programme. 16 firms from the financial, payment and technology sectors have been selected to participate in the first round of pilots for 2023, which will investigate potential use cases in six categories, including full-fledged payments, programmable payments, offline payments, tokenised deposits, settlement of Web3 transactions and settlement of tokenised assets. | Press release

Singapore:             

• (18 May 2023) Project Cedar Phase II x Ubin+ report by the NYIC and the MAS on improving wholesale cross-border multi-currency payments and settlements. The project examined whether wholesale CBDCs developed using DLT could improve the efficiency and transparency of cross-border payments involving one or more vehicle currencies. | Project Cedar webpage

EUROPE

EU:  

• (31 May 2023) European Banking Authority (EBA) consultation on amendments to its guidelines on money laundering and terrorist financing (ML/TF) risk factors. The proposed changes extend the scope of the guidelines to cryptoasset service providers (CASPs) and set common regulatory expectations of the steps CASPs should take to identify and mitigate risks effectively. The amendments introduce new sector-specific guidance for CASPs and highlight factors that may indicate a CASP’s exposure to higher or lower ML/TF risk. Deadline for comments: 31 August 2023. | Webpage | Press release
• (30 May 2023) EU Parliament study on remaining regulatory challenges in digital finance and cryptoassets after the Markets in Cryptoassets Regulation (MiCA). The study analyses the need to adopt further EU financial regulation on decentralised finance after the implementation of MiCA and the revision of the Transfer of Funds Regulation, with a special view on crypto lending, crypto staking, crypto custody, the use of non-formal information, non-fungible tokesn (NFTs) and sustainability. | Webpage
• (26 May 2023) The ECB has published the results of its digital euro prototyping exercise and market research, which were both conducted as part of the investigation phase of the digital euro project. The market research indicates that there is a sufficiently large pool of European providers that are able to develop digital euro solutions and that different types of architectural and technological design options are available to build a technical solution for a digital euro. The prototyping exercise concluded that it is possible to smoothly integrate a digital euro into the existing payment landscape, while still leaving scope for the market to use innovative features and technologies when distributing a digital euro. The findings also confirm that a digital euro could, in principle, work online and offline using different technical designs. | Market Research Outcome Report | Digital euro – Prototype summary and lessons learned | Letter to ECON Chair | Press release
• (25 May 2023) ESMA public statement warning investors of risks that arise when investment firms offer both regulated and unregulated products and/or services, including cryptoassets. | Press release
• (25 May 2023) European Systemic Risk Board (ESRB) report outlining the systemic implications of crypto markets and proposing policy options to address the risks stemming from cryptoassets and decentralised finance (DeFi). The report proposes three areas of main focus: (i) improving the EU’s capacity to monitor potential contagion channels between the cryptoasset sector and the traditional financial sector, and within the cryptoasset sector; (ii) carrying out assessments of risks posed by cryptoasset conglomerates and leverage using cryptoassets, and identifying potential additional actions to mitigate observed risks; and (iii) promoting EU-level knowledge exchange and monitoring of market developments, focusing on operational resilience, DeFi, and cryptoasset staking and lending. | Press release
• (17 May 2023) Presentation (slides) by Fabio Panetta, Member of the ECB Executive Board, on the digital euro – ‘for everyone, everywhere in the euro area’.
• (16 May 2023) The EU Council has adopted the MiCA and the recast Regulation on information accompanying transfers of funds and certain cryptoassets. MiCA establishes an EU regulatory framework for the issuance, offering, intermediation and dealing in cryptoassets, including licensing, conduct of business requirements and enhanced consumer protection, as well as a market abuse regime. The recast Regulation on information accompanying transfers of funds, which is part of a package of legislative amendments designed to strengthen the EU's anti-money laundering and counter terrorist financing (AML/CTF) rules, is intended to improve the traceability of cryptoasset transfers and the identification of suspicious transactions. Commissioner McGuinness has previously indicated that it is anticipated that both texts will be published in the Official Journal by the end of June and enter into force in July 2023. This would see the provisions under MiCA in relation to stablecoins start to apply in July 2024, with the remaining provisions on issuers of other cryptoassets and cryptoasset service providers applying from January 2025, together with the transfer of funds rules. | Press release on MiCA | Press release on Regulation on transfers of funds
• (16 May 2023) The EU Council has reached agreement on its position on the EU Commission’s proposal for a Council Directive amending Directive 2011/16/EU on administrative cooperation in the field of taxation (DAC8), which is intended to improve Member States' ability to detect and counter tax fraud, tax evasion and tax avoidance by requiring all cryptoasset service providers, irrespective of their size or location, to report transactions of clients residing in the EU. The Directive also aims to establish a common minimum level of penalties for situations of serious non-compliance, such as the complete absence of reporting despite administrative reminders. The Directive is not subject to the ordinary legislative procedure but the consultation procedure, which means that the EU Parliament may present its views but has no legislative power to make changes to the proposal. The final outcome of the legislative process is decided by the EU Member States in the Council, by unanimity. The new reporting requirements with regard to cryptoassets, e-money and digital currencies are expected to enter into force on 1 January 2026. | Press release
• (15 May 2023) Main results of the Eurogroup meeting on 15 May, which included an exchange of views on the international aspects of CBDCs and on the progress on the digital euro project. The discussion was based on an issues note, presentations by the institutions and an update by the Swedish minister for finance, Elisabeth Svantesson, on the state of play of the e-krona project. | Webpage: Towards a digital euro | Webpage: Digital finance | Slides: International aspects of CBDCs – update on digital euro
• (8 May 2023) ECB working paper (No. 2811) on CBDC and business cycle dynamics in a New Monetarist New Keynesian model.

France:          

• (25 May 2023) A Joint Committee of the French Senate and National Assembly has reached a unanimous agreement on the Bill on social media influencers. | Press release (in French) | Agreed text (in French) | Legislative file | Further information on the Bill (in French)
• (22 May 2023) Speech by Denis Beau, First Deputy Governor of the Bank of France, on the types of risks associated with crypto activities that particularly need to be considered for regulation and supervision, and the importance of a convergent and coordinated regulatory approach on cryptoassets at the international level. Beau highlighted DeFi and the challenges raised by worldwide crypto conglomerates as two new issues requiring a global regulatory response.
• (3 May 2023) Speech by Denis Beau on the perils and potential of digital currencies. Beau argued that confidence requires maintaining central bank money as the anchor of the financial system and that central banks need to revisit the central bank money services they provide in order to adapt them to the digital age. He emphasised that, in the wholesale space, central bank money is the dominant settlement asset because it is the safest and most liquid settlement asset, and that these attributes cannot be matched by stablecoins or commercial bank money. He added that adapting central bank money services might also be necessary in the retail space and that a digital euro would contribute to the anchoring role of central bank money.

Germany:          

• (27 May 2023) Cryptoasset Transfer Ordinance (Kryptowertetransferverordnung – KryptoWTransferV) of 22 May 2023, which has been published in the German Federal Law Gazette. The KryptoWTransferV entered into force on 27 May 2023, replacing the previously applicable ordinance of 24 September 2021, and will expire on the date on which the recast Regulation (EU) 2015/847 on information accompanying transfers of funds begins to apply. The new KryptoWTransferV is intended to reduce the risk of money laundering and terrorist financing in the context of cryptoasset transfers by stipulating increased due diligence obligations for obliged entities pursuant to section 1 para 1 no 1 and 2 of the German Anti-Money Laundering Act (GwG) which carry out transfers of cryptoassets within the meaning of section 1 para 29 GwG. These obligations (which include the analogous application of certain provisions of the Wire Transfer Regulation (Regulation (EU) 2015/847)) relate to the collection, storage and verification of information in respect of the payer and/or the payee in order to improve the traceability and transparency of cryptoasset transfers.

Ireland:        

• (5 May 2023) Blog post by Central Bank of Ireland Governor, Gabriel Makhlouf, on crypto and consumer protection, in which he notes that the Central Bank remains cautious on the benefits and risks of crypto, stresses the need to differentiate between ‘backed crypto’ and ‘unbacked crypto’, and argues that the claimed benefits of ‘unbacked crypto’ should be treated with a large dose of scepticism and that the purchase of such products can be “similar to purchasing a lottery ticket”.

Italy:        

• (15 May 2023) Law No. 52 of 10 May 2023, which converts into law, with amendments, Decree-Law No. 25 of 17 March 2023 containing urgent provisions on the issuance and circulation of certain financial instruments in digital form and simplification of fintech experimentation (the Fintech Decree), has been published in the Official Gazette (No. 112 of 15 May 2023). The Fintech Decree aligns the Italian national system to the provisions of Regulation (EU) 2022/858, which establishes a pilot regime for market infrastructures based on DLT.
• (5 May 2023) The Bank of Italy and the Commissione Nazionale per le Società e la Borsa (Consob) have, as competent authorities under Regulation (EU) 2022/858, confirmed their intention to comply with the European Securities and Markets Authority (ESMA) guidelines on standard forms, formats and templates to apply for permission to operate a DLT market infrastructure, incorporating them into their respective supervisory practices. | Press release (in Italian)

Norway:

• (25 May 2023) Norges Bank Financial Infrastructure Report 2023, which notes that the Bank is stepping up its efforts to study whether the public should have access to a CBDC in addition to cash, and argues that Norway should consider a national strategy for regulating cryptoasset markets. | Webpage | Press release

UK:

• (22 May 2023) The Economic Secretary to the Treasury, Andrew Griffith MP, has answered a written question on the progress the Financial Conduct Authority (FCA) has made in its registration process for cryptoasset businesses under the Money Laundering Regulations. The FCA has received over 300 applications for registration and approved and registered 41 firms; 223 were either refused or withdrew their application, 29 submissions were rejected and 23 applications were under assessment as of 28 April 2023. The cryptoasset firms that were refused were unable, in the FCA’s view, to meet the required AML/CTF standards.
• (17 May 2023) House of Commons Treasury Committee report on regulating crypto, which concludes that cryptocurrencies pose significant risks to consumers and calls for consumer trading in unbacked cryptoassets to be regulated as gambling. The Committee is concerned that regulating consumer crypto trading as a financial service, as proposed by the Government, would create a ‘halo’ effect, leading consumers to believe this activity is safe and protected when it is not. | Summary | Press release
• (5 May 2023) Minutes from the BoE's CBDC Technology Forum, held on 14 March 2023. Members discussed the digital pound consultation paper and technology working paper and engagement in the next phase of work on the digital pound.
• (3 May 2023) The draft Financial Services and Markets Act 2000 (Financial Promotion) (Amendment) Order 2023 has been debated in the House of Lords Grand Committee and subsequently approved in the House of Commons. The draft Order proposes to expand the scope of the financial promotion restriction in section 21 of the Financial Services and Markets Act 2000 (FSMA), by amending the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (2005/1529) (the FPO), to include financial promotions in respect of certain cryptoassets. It will amend the FPO by creating a new controlled investment (defined as a 'qualifying cryptoasset'), as well as amending relevant controlled activities to incorporate reference to qualifying cryptoassets. The draft Order will also apply and modify certain existing exemptions in the FPO to qualifying cryptoassets and create a temporary, limited exemption to the financial promotion restriction (imposed by section 21(1) of FSMA), for cryptoasset businesses (which are not authorised persons) on the FCA's anti-money laundering register.

EVENTS

Payments – a primer on recent and upcoming developments for in-house lawyers (online, 8 June 2023):
In this online webinar in collaboration with Lexology, international Clifford Chance payments experts will provide a focused update on the key global legal and regulatory updates for lawyers working in the payments sector. Our expert panel will pick out the main developments in the EU, Middle East, Singapore, UK and US, including a look at legislative changes, AML and sanctions, safeguarding of client monies, crypto and CBDC developments. | To register, please complete the online registration form.

Global Financial Markets Perspectives Series: International data flows - navigating the global legal landscape (online, 15 June 2023):
The legal landscape for cross-border data sharing is complex and evolving. Privacy laws and data localisation requirements are developing globally, and data transfer is in the regulatory spotlight. Joining this legal landscape are legislative proposals requiring the sharing of certain data, which may include personal data. We will examine recent legal developments impacting data flows, related international cooperation efforts and how organisations can navigate the challenges of international data transfer. | To register, please see the event series registration form