Public Policy

Global DCA Comment Letter to H.M. Treasury on U.K. Regulatory Approach to Cryptoassets and Stable Coins

“Creating a regulatory environment in which firms can innovate, while maintaining the highest regulatory standards so that people can use new technologies reliably and safely is especially crucial as the UK seeks to maintain its leadership position as a global centre of excellence for fintech firms in the digital era and attract and retain investment post-BREXIT. Moreover, the industry participants recognize that the current post-Brexit era may create significant incentives for the UK to take a global leadership role in the development of a regulatory framework that will provide the digital assets industry with clear directives and regulatory requirements, allow for ongoing industry engagement in the evaluation of applications as well as the development of standards, and finally include a data-driven assessment process.” – Global DCA Read Response Letter

Global DCA Comment Letter to FinCEN on Proposed Rule for Transactions in Convertible Virtual Currency and Digital Assets

“While the GDCA fully supports protecting U.S. national security and acknowledges the concerns surrounding unhosted wallets raised by FinCEN, we suggest […]to focus on the source of funds and the concept of “Know Your Customer” during the KYC/AML onboarding and monitoring process instead of focusing on the means and in effect penalizing a specific technology solution that is believed to be utilized by bad actors.  The GDCA questions whether applying extensive reporting, verification and recordkeeping requirements on the holders of self-hosted wallet solutions is the most effective approach to capture illicit activity and suggests that closer consideration should be given to the source of funds and the risk profile of a customer or a counterparty while evaluating transactions in digital assets.” – Global DCA. Read Response Letter

Global DCA Proposal to SEC on Amending the definition of “Accredited Investor”

“…amending the “accredited investor” definition to more broadly permit professionally qualified or industry certified individuals to participate may better protect investors and the public interest. When investors are well-informed and capable of making sound investment decisions, they are better able to allocate their resources in the market, ensure sound investment decision-making, and contribute to financial sector and economic growth. As such, the benefits of better educated and qualified individuals participating in investment activities may not only provide additional protection to the investors themselves, but may benefit the overall stability of the financial system as well as the broader economy.” – Global DCA. Read Response Letter