digital currency

International Financial Regulatory Cooperation and Digital Currencies Daniel Heller and Edwin Truman

D igital currencies such as Bitcoin provide an entirely new way to transfer monetary value. Unlike

banknotes or deposit money, most digital currencies are not issued by a legal entity, but by a locationless software protocol. This allows for fast and relatively inexpensive payments across the globe on a peer-to-peer basis without the involvement of banks or clearinghouses. Users o f digital currency are pseudonymous— they are only identifiable by an alphanumeric string and not by their names or physical or digital addresses.

These novel attributes o f digital curren­ cies pose several challenges for national fi­ nancial regulators, on the one hand, and international bodies and committees seek­ ing to cooperate on regulatory regimes, on the other hand. For instance, the Commit­ tee on Payments and Market Infrastruc­ tures states “the borderless online nature of digital currencies, and the absence of an identifiable ‘issuer’ of the instrument, pose particular challenges to attempts at regula­ tion that a national authority might make. ” 1 The borderless nature of digital currencies also greatly facilitates regulatory arbitrage

making effective international regulatory cooperation more important than ever. The International Monetary Fund (IMF) staff has opined that when it comes to new financial technologies, “policymaking will need to be nimble, experimental, and cooperative.” 2

The borderless nature o f digital currencies also greatly facilitates

regulatory arbitrage making effective international regulatory cooperation

more important than ever.

This article focuses on three issues raised by digital currencies that are particularly challenging for policymakers: money laun­ dering (ML) and terrorist financing (TF), taxation, and crowdfunding through initial coin offerings (ICOs). To date, in general, policymaking has been neither nimble nor particularly cooperative. Policymakers are at risk of getting behind the curve. Interna­ tional financial cooperation with respect to digital currencies is most developed in the fight against ML and TF but falls short of what is needed. We recommend that in the area of ML/TF, policymakers should ensure that supervisors and regulators in all juris­ dictions are monitoring activities according to the agreed international standards. In the area o f taxation, authorities need to estab­ lish clear tax treatment of virtual currencies and include information on virtual currency holdings in the emerging regime of sharing data for tax purposes. W ith respect to ICOs, policymakers should develop a common framework for their regulatory treatment.

Daniel Heller is a visiting fellow at the Peterson Institute for International Economics. Previously, he held executive posi­ tions at the Swiss National Bank, the Bank for International Settlements, and the International Monetary Fund.

Edwin Truman is a nonresident senior fellow at the Peterson Institute for International Economics. Previously, he served as assistant secretary for international affairs at the US Treasury and led the international finance division for the Board of Governors of the Federal Reserve System.

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DANIEL HELLER AND EDWIN TRUMAN

Design Elements of Digital Currencies Digital currencies have gained in popular­ ity rather quickly in recent years. As of June 2017, close to a thousand digital currencies existed with an aggregate market value of more than $100 billion. The largest digital currency is Bitcoin with a share o f 46 percent followed by Ethereum (23 percent). At the current level, digital currencies are no lon­ ger a negligible asset class. Their aggregate value exceeds, for instance, the total value of banknotes issued by the Swiss National Bank or the Banco de Mexico. Close attention by regulators to this innovation is thus warranted.

As o f June 2017, close to a thousand digital currencies existed with an

aggregate market value o f more than $100 billion.

W hile differences among digital curren­ cies exist, they share the following features:

First, they enable peer-to-peer payments. This means they don’t rely on the interme­ diation of third parties like banks, credit card companies, or clearinghouses. The m onetary value is transferred in digitally encrypted form directly from the payer to the payee through the Internet.

Second, the transactions are validated by several independent notaries. In some schemes, becoming a notary is open to every­ one (“permissionless”). In others, the nota­ ries need to be authorized (“permissioned”). The notaries are compensated for their ser­ vices with newly issued coins or transaction fees. That’s why they are often called “m in­ ers.” The miners provide “trust” to a network in which the participants don’t know each other. This is different from the traditional financial system in which trust is typically provided by supervised entities like banks.

Third, the notaries also store all validated

transactions on their hard drives. Storing identical records on various separate de­ vices is called “distributed leger technology’' (DLT). Every few minutes the latest pay­ ments are bundled in a block. All blocks are linked together in a chronological order forming a “blockchain.” The transactions in the blockchain are not encrypted, which means they can be viewed by the public.

Fourth, the participants in digital cur­ rency networks are pseudonymous. They are identifiable only through a unique alphanu­ meric string/address. Each participant can choose to have as m any addresses as he or she wishes to have (they can have many “pseudonyms”). So while all the transactions are public on the open ledger, this does not mean that the names or addresses o f the par­ ties to the transactions are revealed. Using data from Bitcoin, Tasca estimates that Bit- coin holdings are highly concentrated and that the five hundred largest Bitcoin ad­ dresses (pseudonyms) hold 30 percent to 4C percent o f the Bitcoins in circulation.3 But for the general public, it is not possible tc know who the actual owners are.

As each digital currency has its own de­ nomination; exchanges play an essential role in their use. O n these exchanges, digi­ tal currencies are traded against each other or against sovereign currencies. They oper­ ate electronically on a 24/7 basis. These ex­ changes are located around the world and are generally registered with the local authorities. Exchanges that offer the conversion of a digi­ tal currency into a sovereign currency need tc be linked to a bank account, either through a direct or a correspondent banking relation­ ship. This bank account is used by customers who want to buy digital currency or to credit customers who have sold digital currency.

As an additional service, exchanges usu­ ally also provide so-called wallets to their clients. Akin to a safe deposit box at a bank, such wallets allow the participants to store

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their various digital currency addresses; the wallet also contains the cryptographic signa­ tures that are needed to make a payment in digital currency. O ne wallet can hold several different digital currencies with multiple “pseudonyms.”

These elements o f digital currencies offer both attractive features and pose regulatory challenges.

Potential Attractions and Challenges of Digital Currencies Digital currencies offer a num ber o f poten­ tial social benefits. They are an example of FinTech innovation, and innovation in gen­ eral provides social benefits. Consequently, many governments are actively encouraging experimentation in this area. Innovation via digital currencies can promote more ef­ ficient, faster, and potentially more secure payment systems. They can potentially lead to less expensive remittances and promote greater financial inclusion. They also offer privacy advantages, which is a plus for the user. Finally, digital currencies have the po­ tential to become significant funding sources for firms through peer-to-peer lending (crowdfunding) and similar mechanisms.

Digital currencies are a mixed blessing, however. While their impact on the conduct o f m onetary policy is minor, they provide new avenues for illegal activities such as money laundering, terrorism financing, and tax evasion.4 W hen used in crowdfunding, digital currencies raise issues o f consumer protection, money laundering, and possibly financial stability.5

Digital currencies provide several chal­ lenges for financial market regulators, both domestically and internationally. First, many o f them do not have an owner or a specific location of incorporation. They are run on open-source software. There is also no headquarters or identifiable issuer o f the

currency. Changes to the rules or parameters o f the currency scheme are typically made by consensus or by a supermajority of the users. Thus, there is no direct “addressee” who is bound by the requirements o f any regulator or regulators.

Second, as mentioned previously, the us­ ers o f the digital currency scheme are pseu­ donymous as their names and addresses do not appear in public records. Therefore, dig­ ital currencies are attractive for underworld users. In this respect they are similar to banknotes. For instance, the originators of the W annaCry virus asked for a m inim um ransom o f $300 equivalent in Bitcoin from infected computer owners.6 Similarly, Silk Road, an online darknet bazaar for drugs and weapons, relied solely on Bitcoin as the means o f payment. It was shut down by the US authorities in September 2013, and $16 million in Bitcoin were confiscated. Several users, as well as the operator o f Silk Road, were later charged, convicted, and sentenced to prison. This indicates that while users o f digital currencies may not be identifiable for the public, they are not im m une from dis­ covery by criminal investigators.

The United States was the first country to initiate regulation of digital currencies. In 2013 the US Treasury’s Financial Crimes Enforcement Network (FinCEN) published guidance on the application o f FinC EN ’s regulations to persons administering, ex­ changing, or using virtual currencies. This regulation targets the exchanges located in the United States that convert digital curren­ cies among themselves and against sovereign currencies. Such exchanges are categorized as “money services businesses” (MSB) like Pay­ Pal or Western Union. Their principal obliga­ tions are three: (1) to register with FinCEN; (2) to have a risk-based know-your-customer (KYC) and anti-money-laundering (AML) program, and (3) to file suspicious activity reports (SAR).

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In te rn a tio n a l C o o p e ra tio n on Iss u e s R ais ed by D ig ita l C u rre n c ie s When it comes to international cooperation, digital currencies present unique challenges because they are essentially stateless, imply­ ing that all states must cooperate in any at­ tempt to monitor or regulate their activities. The traditional “risk-based approach” that has been favored in dealing with similar is­ sues is more difficult to apply because, first, the approach implies that the activity should not be entirely eliminated (zero tolerance) and, second, at this point there is no well- established consensus among financial su­ pervisors and regulators about the risks that digital currencies pose. Indeed, some juris­ dictions (such as Australia, Canada, Hong Kong, Singapore, Switzerland, and the UK) have set hubs for FinTech activity and “sandboxes” that can benefit from limited regulation for a time. Sandboxes provide a contained environment with light-touch regulation in which startups can test their innovations in a small market. Sandboxes are established by governments that hope to promote innovation centers that will cre­ ate jobs and enhance welfare. At the same time, these sandboxes illustrate the poten­ tial for regulatory arbitrage or competition that could undermine a consistent, coherent global approach.

Over the past several years, authorities have begun to cooperate with respect to technology-enabled innovation in financial services. Their cooperation has not produced a single, unified regulatory regime; rather, it is best described as cooperative monitor­ ing and mutual education. For example, the Financial Stability Board published a report on the financial stability implications of Fin- Tech.8 The report “concludes that there are currently no compelling financial stability risks from emerging FinTech innovations.” But it identifies “ten issues that merit au­

thorities’ attention” from a financial stabil­ ity perspective, “of which three are priorities for international collaboration.” The prior­ ity areas are (1) managing operational risks of third-party service providers, (2) mitigat­ ing cyber risks, and (3) monitoring macro- financial risks. Regarding digital currencies, the report recommends that their implica­ tions “for national financial systems, and the global monetary framework should be stud­ ied” and that “the potential implications of digital currencies for monetary policy, financial stability and the global monetary system” should be analyzed. Going forward, a great deal of vigilance by the Financial Sta­ bility Board (FSB) will be required in this area given the rapid spread of digital curren­ cies as a funding tool for corporates— as we illustrate in the following.

A n ti-M o n e y L a u n d e rin g (AML) an d C o m b a tin g th e F in a n c in g of T e rro ris m (CFT) International cooperation to combat money laundering and the financing of terrorism has a long history.9 The Financial Action Task Force (FATF), an international organi­ zation of thirty-five jurisdictions that devel­ ops and promotes policies to combat money laundering and terrorist financing, has is­ sued two reports on digital currencies. FATF develops key definitions and outlines poten­ tial ML/TF risks.10 It indicates that in the near-term only digital currency exchanges are likely to present ML/TF risks. FATF provides guidance to national authorities on how to address ML/TF risks of digital currency exchanges.11 It provides guidance for countries and competent authorities on the application of eight of its forty recom­ mendations concerning AML and CFT to digital currency exchanges. The guidance follows a risk-based approach, which means that countries, competent authorities, and

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MSBs are expected to identify, assess, and understand the M L/TF risks to which they are exposed and take A M L/C FT measures commensurate to those risks in order to mitigate the risks effectively and efficiently. In other words, this approach implies that not all risks m ust be eliminated but that they should be understood and limited ap­ propriately.

The eight FATF recommendations rele­ vant to digital currencies cover customer due diligence (KYC), record keeping, registration or licensing requirements, identification and mitigation o f risks associated with new tech­ nologies, A M L/CFT program requirements, and reporting o f suspiciousactivities.

The FATF has opened a dialogue with the private sector on FinTech and RegTech. The FATF Private Sector Consultative Forum m et in Paris in February 2017 and Vienna in M arch.12 In May, FATF convened the FATF FinTech and RegTech Forum 2017 in San Jose, California. That gathering pro­ duced the San Jose Principles, which seek to “strike the right balance between sup­ porting innovation and managing any ML/ TF risks that may arise in the framework” o f the agreed principles.13 The headlines of the principles read like an endorsement of m otherhood and apple pie.

1. Fight terrorism financing and money laundering as a comm on goal.

2. Encourage public and private sector en­ gagement.

The headlines o f the principles read like an endorsement o f motherhood and

apple pie.

3. Pursue positive and responsible innova­ tion.

4. Set clear regulatory expectations and

smart regulation which address risks as well as allow for innovation.

5. Fair and consistent regulation.

This framework may be short on substance, but it accurately reflects the tensions involved with the introduction of new technologies in a world of diverse views on the desirability of promoting innovation and the appropriate goals of international cooperation to provide stability and prevent misuse of innovations. While the authorities cooperating in the FATF should continue to explore the strengths and weaknesses of FinTech, they should also more closely monitor members’ consistent imple­ mentation of the FATF guidance with respect to digital currency exchanges.

Taxation o f D ig ita l C u rre n c ie s A digital currency has a clear, positive m ar­ ket value as an asset for holders. The assets, per se, are in principle taxable. M ost coun­ tries have clarified how holdings o f digital currencies are taxed, but the treatm ent var­ ies. In the United States, the Internal Rev­ enue Service (IRS) issued guidance on the taxation of digital currencies in 2014. The guidance states that

1. digital currencies are taxed as property and not as foreign currency;

2. wages paid in digital currency are taxable and m ust be reported; and

3. payments made in digital currency are subject to the same information report­ ing as any other payment.

In 2016 a federal court authorized the IRS to serve a John Doe summons on the largest US-based digital currency exchange, seeking information about US taxpayers who conducted transactions in the years 2013 to 2015. W ith court challenges to the legality o f the IRS request ongoing, the

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IRS narrowed its demand for information in July 2017.14 Meanwhile, international cooperation on the tax treatm ent of digital currencies has been limited.

Since holdings of digital currencies are assets, they should be included in the framework for the Automatic Exchange o f Inform ation (AEIO) that the Global Forum developed for bank customers.15 The C om ­ m on Reporting Standard o f 2014, which was updated in 2017, however, does not m ention digital currencies as an asset on which information among country authori­ ties should be exchanged automatically.16 Given their market value o f more than $ 100 billion, the Global Forum should include digital currency exchanges in the framework for the AEIO. This would prevent digital currencies from becoming a loophole in an otherwise comprehensive international framework against tax evasion.

C ro w d fu n d in g an d In itia l Coin O ffe rin g s In recent years, peer-to-peer lending and equity crowdfunding have gained in popu­ larity.17 A recent variation of crowdfund­ ing used by Internet startup companies is ICOs. In an IC O transaction, investors provide funding in the form of a digital currency (Bitcoin or ether) to the startup. In exchange, the investors receive tradable digital coins or tokens o f the startup. These coins provide the right to receive rewards on the basis o f the company’s success. Some tokens can also be used to pay for services o f the company. Typically, the coins do not define any rights to ownership o f the com­ pany. Thus, economically, ICOs are a hybrid between equity and debt. Usually, they are created deliberately in a way that they are not considered a security by current laws.

As with other digital currencies, these coins are stored on a distributed ledger.

Some see ICOs as a successor to angel and venture capital funds. Autonomous Next re­ ports that more than $1.2 billion was raised through these types of ventures in the first half of 2017, compared with only $222 million in all o f 2016. The 2017 figure is a substantially larger figure than what venture capital firms have allocated to similar proj­ ects in this period.18

National regulators have not reached de­ finitive conclusions about how they should re­ spond to ICOs. One key question is whether ICOs should be subject to securities laws, laws on commodity trading, or both. Autonomous Next reports that ICOs are assets and not se­ curities in Switzerland and Singapore, juris­ dictions cooperating on FinTech regulation.19 They are nonmonetary digital assets in China, private currencies in the United Kingdom, fi­ nancial instruments (but not currency) in Rus­ sia, and commodities but potentially securities in the United States. Other related questions are whether the issuance of tokens is a deposit­ taking activity subject to banking law or an MSB. Consequently, the number of different national regulators potentially involved in this area is substantial.

W hile national regulators are engaged in a dialogue with the IC O industry, no official rule making has taken place yet other than registration requirements for exchanges that, in principle, are subject to AML/KYC regulations. Because treatm ent by individual national authorities has not been uniformly established, there has been no international cooperation in this area. Clearly, ICO s are in a gray area of current regulation, national or international. ICO s bear some similari­ ties with securities, b u t they also raise issues of consumer/investor protection from fraud. The fact that potential investors in ICO s are spread around the world and their locations are potentially only guessable by the IP ad­ dresses o f their computers could be prob­ lematic, not least from an AML perspective.

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National regulators should act to move ICOs out of the gray zone in term o f the ap­ plication of rules, regulations, and reporting requirements. This would increase the protec­ tion o f investors from fraud, but it would also provide more certainty to the issuers. And again, because o f the borderless nature o f dig­ ital currencies, an internationally coordinated regulatory approach should be employed once there is more international consensus on the treatment of these innovations.

Conclusion Digital currencies are evolving rapidly and possibly will change dramatically how many payments are made and how certain funding markets function. Ow ing to the locationless nature o f digital currencies, it is relatively easy to circumvent national regulatory stan­ dards, and the risk of regulatory arbitrage is substantial. Therefore, the international regulatory com m unity should focus on a consistent development and application of standards for digital currencies, including the use o f ICOs, across countries.

Digital currencies are evolving rapidly and possibly will change dramatically

how many payments are made and how certain funding markets function.

Unfortunately, international activity to date has largely taken the form o f m onitor­ ing activities involving digital currencies and exploring their potential benefits and costs, rather than the development o f a compre­ hensive framework for supervision and reg­ ulation. Because o f the potential benefits of digital currencies, some degree o f caution by policymakers may be justified. At the same time, the current measured and cooperative approach means that it will be impossible to

put the genie o f digital currencies back in the bottle o f tight regulation, to say nothing o f prohibition, if the authorities decide, or one authority decides, to do so. Because dis­ tributed digital currency schemes are quint- essentially global, international cooperation on a regulatory regime is essential. Exist­ ing institutions o f cooperation such as the FATF, the Global Forum, the International Organization o f Securities Commissions, the FSB, and the Com m ittee on Payments and M arket Infrastructures should be suffi­ cient to accomplish the necessary tasks. But to date there has been a general lack o f ur­ gency or collective concern in these bodies.

Notes We thank Adam Posen, Olivia Rockwell, and Nicolas Vernon for their excellent comments.

Digital currencies are a fast-moving area o f innovation and controversy. This piece was com­ pleted in the middle o f July 2017. Since then the principal new development as o f the end of August has been a further acceleration in activity in the IC O space for startups. The publication o f an investigation report by the US Securities and Exchange Commission (SEC) on July 25 on the DAO (a crowdfunding IC O that failed) did not slow this m omentum. The SEC report determined that the DAO tokens were invest­ m ent contracts that should have been registered with the SEC. The SEC also warned that many ICOs may be fraudulent. O n August 1, the M on­ etary Authority o f Singapore issued similar guid­ ance, noting that it will assess how to regulate money laundering and terrorism financing risks o f ICOs. Nevertheless, the IC O space, as well as other aspects o f digital currencies, remains an international regulatory vacuum. See the blog post by Daniel Heller, “Initial Coin Offerings: Crowdfunding in a Regulatory Vacuum,” Peter­ son Institute fo r International Economics (blog), August 25, 2017, https://piie.com/blogs/realtime -econom ic-issues-w atch/initiai-coin-offerings -crowdfunding-regulatory-vacuum.

1. Committee on Payments and Market Infra­ structures, “Digital Currencies,” Bank for

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International Settlements, November 2015, http://www.bis.org/cpmi/publ/dl37.pdf.

2. Dong He, Ross Leckow, Vikram Haksar, Tommaso Mancici Griffoli, Nigel Jenkinson, Mikari Kashima, Tanai Khiaonarong, Celine Rochon, and Herve Tourpe, “Fintech and Finan­ cial Services: Initial Considerations,” International Monetary Fund, June 19, 2017, http://www.imf .org/en/Publications/Staff-Discussion-Notes /Issues/2017/06/16/Fintech-and-Financial-Ser vices-Initial-Considerations-44985.

3. Paolo Tasca, “Digital Currencies: Principles, Trends, Opportunities, and Risks,” UCL Cen­ ter for Blockchain Technologies, September 7, 2015, https://papers.ssrn.com/sol3/papers.cfm ?abstract_id=2657598.

4. Daniel Heller, “The Implications o f Digital Currencies for Monetary Policy,” European Parliament Committees, May 29,2017, http:// www.europarl.europa.eu/committees/en / econ /monetary-dialogue, htm 1.

5. Committee on the Global Financial System and Financial Stability Board, “FinTech Credit: Mar­ ket Structure, Business Models and Financial Stability Implications,” Bank for International Settlements, May 22, 2017, http://www.bis.org /publ/cgfs_fsbl .pdf; International Organization of Securities Commissions, “IOSCO Research Report on Financial Technologies (Fintech),” February 2017, https://www.iosco.org/library /pubdocs/ pdf/IOSCOPD554.pdf.

6. Andy Greenberg, “WannaCry Ransomware Hackers Made Some Real Amateur Mistakes,” Wired, May 5, 2017, https://www.wired.com /2 0 1 7 /0 5 /w an n acry -ran so m w are-h ack ers -made-real-amateur-mistakes.

7. He et al., “Fintech and Financial Services: Ini­ tial Considerations.”

8. Financial Stability Board, “Financial Stabil­ ity Implications from FinTech: Supervisory and Regulatory Issues That Merit Authorities’ Attention,” June 27, 2017, http://www.fsb .org/wp-content/uploads/R270617.pdf.

9. Peter Reuter and Edwin M. Truman, Chasing Dirty Money: The Fight against Money Launder­ ing (Washington, DC: Peterson Institute for International Economics, 2004).

10. Financial Action Task Force Report, “Virtual Currencies: Key Definitions and Potential

AM L/CFT Risks,” June 2014, http://www .fatf-gafi.org/m edia/fatf/ docum ents/reports /Virtual-currency-key-definitions-and-poten tial-aml-cft-risks .pdf.

11. Financial Action Task Force Report, “Guid­ ance for a Risk-Based Approach: Virtual Cur­ rencies,” June 2015, http://www.fatf-gafi.org /p u b lic a tio n s/fatfg en eral/d o cu m en ts/g u id ance-rba-virtual-currencies.html.

12. Financial Action Task Force, “Chairmans Summary o f Outcomes from the Industry Roundtable on FinTech and RegTech,” Feb­ ruary 18, 2017, http://www.fatf-gafi.org/pub lications/fatfrecom m endations/docum ents /fintech-february-2017.html; Financial Ac­ tion Task Force, “Dialogue on FinTech and RegTech: Opportunities and Challenges,’ March 24, 2017, http://www.fatf-gafi.org /publications/fatfgeneral/docum ents/fintech -regtech-mar-2016.html.

13. Financial Action Task Force, “Chairman’s Summary o f Outcomes.”

14. Jeffrey Berns, “IRS Narrows ‘John Doe’ Sum­ mons on Coinbase, in a W in for Users,” E T H News, July 7, 2017, https://www.ethnews.com /irs-narrows-john-doe-summons-on-coinbase -in-a-win-for-users.

15. The Global Forum is an international body with 142 member jurisdictions for ensuring the implementation of the internationally agreed on standards of transparency and exchange of information in the tax area.

16. Organization for Economic Cooperation and Development, Standard for Automatic Exchange o f Financial Account Information in Tax Matters, 2nd ed. (Paris: O EC D Publish­ ing, March 27, 2017), http://www.oecd.org /ctp/exchange-of-tax-inform ation/standard -for-automatic-exchange-of-financial-account -inform ation-in-tax-m atters-second-edition -9789264267992-en.htm.

17. IOSCO “IOSCO Research Report on Finan­ cial Technologies (Fintech)”; Committee on the Global Financial System and Financial Stability Board, “FinTech Credit.”

18. Autonomous Next, “#Token Mania,” 2017, https://next.autonom ous.com /dow nload-to ken-mania.

19. Ibid.

6 6 GEORGETOWN JOURNAL OF INTERNATIONAL AFFAIRS

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