PANEL: Navigating the International Regulatory Landscape of Stablecoins & Crypto Services

baby [Music] okay so we begin International regulation of stable coins uh just briefly I know a lot of people many people just saw my t-shirt so I will no deny I never worked for lemon Brothers I work for the French government the administration I am at the Cyber center of the gender Murray covering Financial or not Financial but cyber crimes and right before I was at a tax investigation directorate in France where I taught about blockchains and crypto since 2016 for people who don't like it at all so now that it is said and I am the most popular with the tax stuff I will let you introduce you and first question for all of you what was your first experience with the stable coins thank you very much thank you for the invitation so my name is Pierre um I'm a former MP of the French Parliament so I decided crypto in 2014 and I discovered blockchain when I was MP in 2018 at the start of of theater and and circle and uh yeah quickly I managed to create the first legal framework about crypto in Europe in France in 2018 2019 in order to attract capitals and and Company in France and innovate on on blockchain nice thank you I'm leor from Israel I'm the legal council of state capital a group with all the initiatives around and I started with the crypto in 2010 I was a white color criminal criminal White Collar lawyer then discovered Bitcoin then wrote my master thesis then it was one of the first studies on bitcoin theories of money since then I was a i shifted to the field I was a you know one of the activists I worked with a lot of projects in the beginning from colored coins still many others that were in the space during the icos after that worked with banks to on in Germany more mostly in Germany on implementation of blockchain projects and then in state capital also writing articles PhD on daos etc etc and for stable coins actually I met Brooke Pierce and and that was a very early pitch the idea of stable coins and then just used it from from the time they were with us all right hi I'm Peter um actually by the way I I have to apologize my voice isn't that good so take care or beware of computer viruses and also kindergarten viruses I can I can just say um so I'm originally a developer who these days is reading more law text than code I would say because over time I travel like into founding several companies and since eight years I'm in the fintech space so um first co-founded Solaris Bank as a CTO which was the first fintech startup in Germany that actually got a banking license in 2017 I also in when I when I got into the crypto space I tried to move them into the crypto space as well because also back then banks that like or especially crypto friendly banks have been needed like everywhere especially to to get the feared money into the system you can use stable coins but you can of course also use crypto friendly Banks and I think in the end we we managed to make sure it's been crypto friendly but I wanted to work full-time in crypto have to build up a like a data company for a stock exchange which was the first regulated crypto MTF in Germany um under under buffing regulation and uh two years ago we found it Unstoppable finance and with our product ultimate and we want to bring D5 to the masses and to to bring the fight to the masses we started with ultimate with a non-custodial wallet which is really easy to use but so we have to do more so we announced a few weeks back that we're going to found job's first D5 bank and in the end we will also issue a stable coin but we want to do this from from the full Bank um hello everyone I'm yatzik and you know my story stable going States back to 1997 I got my first PC for my parents but I'm just kidding of course um in 2016 um I was a part of like a small startup that wanted to do a stable coin uh with a guy from Goldman Sachs and another one who later became a CTO at trufai but it didn't happen later on shortly thereafter in 2017 I joined maker Dao as the first general counsel and spent a few years at that project um and you know spent a lot of time with global Regulators back at the time when maker was the only D5 project out there and later I was a little bit tired with stable coins so I left to to go to Harvard Law School for a year but after I came back I co-founded a company that is called l2bead it has nothing to do with stablecoins but I guess I couldn't help myself because I also became an advisor at gyroscope which is a stable stable gun project that presented yesterday and also I really wanted to come here to see what's going on in this stablecoin space okay thank you the first question will be um on the the framework we have a will have in in Europe uh because we know we have to deal with a International compliance and fatf rules the new oecd uh crypto asset regulation framework uh which I also uh contributed to to to build uh with the ministry of economy in France uh so we have a lot of new rules and we have separate uh Frameworks in different countries or continents and we talk a lot about Mika we have the opportunity today to have uh appear with us which help creating the the French legal framework in 2018 2019. can you tell us how uh Mika framework will change thing for stable kinds especially when we talk about EMT electronic money tokens and art asset reference tokens yes absolutely so for the moment all over the world there is no clear path and regulation for stablecoin um and since uh since the start of the work of EU Commission in 2020 uh we managed to create a regulative framework about stable coin that will extend the notion of electronic money for stablecoin so in the text there will be two different type of stable kind uh the first like you said is a EMTs or electronic money token it's a token which is backed directly by Fiat so you will apply directly to the notion of electronic money which were created in in in in 2029 and there is different text but really the idea is that your stablecon will be directly backed by shot and you will have the phone segregated in a bank account and you will have a strict uh Prudential policy on the asset so you will not be able to do what you want uh with uh with the asset behind the stable coin the second type of stable coin is characterized by different type of assets so many Securities Commodities uh and so on and the idea is to have a stable coin which is not directly linked to uh to Fiat uh and so uh they share some some aspect in terms of Regulation about uh capitals about segregation about uh Prudential policy but the collateral is not the same so it's why EU commission EU Parliament uh strictly uh separate these two Notions and in order to create two different setup for protecting uh asset and the collateral behind the stable coin for for investors any reaction or because it will basically like be like PayPal you know it's electronic money so PayPal is electric money what's what's the change what's the difference well I I would also um change the start like with with me kind of like from from another angle because um I think when it was introduced or when the conversation started it was like a Lex Libra yeah so that was Facebook with um with the stable coin idea and um even like not being the biggest fan of Facebook I must really say so when I read the white paper and looked into the technology and so on and I've talked to a few people I really thought like whoa Facebook is doing this really really good so like really broad uh kind of set of companies and partners and uh kind of like really trying to make this as decentralized as possible and not only not owned by Facebook but kind of like owned by by really a big community and then the reaction of the European Union was like oh no so we don't want to lose the control over our monetary system because if a company like Facebook comes around the corner with two billion plus users around the globe so this is very likely to become the like the main money rail and that's what we don't want and that's kind of where my criticism would already start because in the end regulation has always been something something proactive yeah so that's at least how I learned it for myself from being a developer's wise regulation there so I thought okay there's some misbehaviors on the market where some people are politicians or parties think okay so we need to jump in and we need to regulate whatever front running on on exchanges has been a problem because it's some some sort of fraud like in the traditional markets like in the 80s okay so there has been some reaction in the regular regulation was introduced and in the end um kind of all the all the markets need to apply to this and and so this is the origin of Mika so where I still think like okay wait there there wasn't really a problem so kind of like of markets or defects and so on but still this this regulation came fast forwarding a little bit um I think the Mika is not only about like stable coins there's also other parts so it's also about regulating and harmonizing centralized offered crypto services and I think in the meanwhile the the tonality when talking about Mika changed a bit because we've seen Celsius crashing we've seen f2x crashing and all the centralized models crashing so in the end Mika is like a reaction like a counter reaction to it so or I think when we're talking about centralized Services it's a good idea but um yeah so I still want to raise that that finger kind of so we should introduce regulation if we if there's really misbehavior on the markets and that was not the case here but you're talking about the goals what those regulation stand for to correct the bad effects and to implement policies and so on but the the means and the tools are legal Concepts so I have another question for legal legal Concepts do you think uh yeah do you think the traditional concept we we all know the territory uh the legal personality and so on as we we see with the Dao do you think they really can apply to cryptocurrencies in general and stable coins in particular or we have to win them something different I I guess it would take me like two hours to answer the question but I'll try two minutes yes I know so first of all I fully agree with Peter I mean Mika is like full of um like good ways to solve real problems I mean the fact that we don't have regulation of centralized exchanges or Market manipulation is just a joke and Mika is gonna finally fix it at least in the EU so that's great for the stablecoin part totally agreed this is a political reaction to a problem that has not even existed and its implementation is also poor so we're gonna get to it now in terms of like the legal Concepts it's like you know before we get to the legal Concepts let's start with the economic ones there is this super old um concept by Ronald Kos of the nature outer of the nature of the firm it is 80 years old and he provided a very good insight about what is a firm he said a firm is a next Nexus of contracts that is like combined together to reduce transaction costs of just inter acting with three actors on in the market so people can together to not be forced to like contract arm's length with every other person to reduce transaction costs now it absolutely makes sense right and the legal concepts are built around this concept right if there is this like tight group of like interests and contrast this is where the legal personality came from but in the context of new technologies and including blockchain smart contracts look smart contracts reduce um the transaction costs right you don't have to worry about transaction costs of like someone behaving in a bad way if you have a self-enforcing smart contract that is just going to behave as expected so that's why suddenly in the concept of in the in the context of crypto you have like the concept of firm kind of like falling apart right because you don't need those firms because people can deal with transaction costs in different ways and now in the concept of in the context of stable coins that means for example that you don't have a single issuer right because you have stable con functions like usually like manufactions separated from each other and you can have a stablecoin project and you have many of them including decentralized ones like maker in which you don't have like all of the features of a stablecon project in one person in One legal person you have or in one country exactly you're right it can just live on ethereum and then you can have like exactly no issuer and then those functions distribute it in different ways and this is something that the regulation does not solve right because there is this privately private law part to it whether to treat it as illegal person or not but let's leave it aside this is the two hour part but then there's a regulator perspective how to license this thing and how regulation works is exactly to license this specific entities and it's not the case especially for the centralized projects and the centralized stable coins you have those functions splitted in different ways um so this is uh this is my short answer to that but also in the context of Mika this is where Mika fails right because it doesn't recognize this real reality it just regulates single issuer and of course it does work for some players on the market it doesn't work for many other players especially those Innovative ones also if I may add stablecoin is as usual it's a term it's a term it's like tokens so it's a it's a it's a diverse so you have already different kinds of stable coins if you try to classify them I would say it's an asset baked whether it's a it's a Fiat or or other other asset it's a on-chain collateralized like a dye and it's a non-collateralized like a Terra Luna and but you have many kinds and you have beside of the many kinds of the functions that the Stables stable coins could could show there is also the the the people that behind it that carries or the entities people entities slash many kinds of things that can carry the liability or the the responsibility for this project so it's a it's open the you know stable coins are really diverse and when Mika Mika actually is a reflection of the market so it's a reflection you know the the regulator where not I think didn't see it and think what would be the next Innovative or what is the best no we have this in this those are the character character heuristics and we need to cover them wrap them so that's how regulation is is coming to to to to to us I'm totally agree with um with this approach I think we start the EU commission start to build Mika on a defensive approach uh really against Libra and all the French politicians and and European politicians wake up and say okay there is a lack of certainty we will have a problem if uh United States if on USD or maybe another basket there is a a private money private money in a sense that the issue is private but really um I think the the main not problem because it's a it's a debate you know it's very a political subject in uh the beauty of the term um there is two axes the first active is a competition between all currency in terms of euro dollar what is the aim of uh each currency against each other and what is a the strength of of DOTA behind error and so on and there is a second axis between uh we who is the issuer uh is it a private issuer or is it a public issue and and for this debate we don't have the solution yet so there is cbdc and so on but there is a big fight again traditional actors that doesn't want to to be to see a new paradigm of uh issuance in terms of monetary because cbdc um is not a welcome for Traditional Bank um and um there is um what will be the new standard art of money and I think the the greatest question about stable occurring it what is a collateral is it directly by Fiat and if it's Fiat it's directly ECB you know because the ratio will be the ecb1 and and so on is it uh treasurables and treasurability debt from States so it's not directly uh uh ECB uh ratio but it's like it's on either indirect some term money or is it anything else maybe Bitcoin and so on so I think this uh political question has to be seen as less than what is the issue is it decentralized is it public one is it a private one but mostly what is a collateral is it fin hair like ECB they print money each time they want into in order to uh to build their uh budgetary policies or budget policy or is it uh many many other assets that can create a another type of money the practices and reserves and so on sure then when you have sorry when you have the Amica then you have the big starting point of uh of a debate you have the starting point of a debate so if I am an alien that is coming with my own product I can have something to relate to and then I can start to initiate and to create the the framework that they need also picking up from from your points because um you guys about centralized companies so so that's that's that's how it was designed and how it's also now going to be interpreted and when it comes to e-money kind of tokenizing e-money and um making enabling the euro to be sent around the globe like in real time it's like putting two rockets on on the Euro and you can send it around to Globe I think that's that was a very easy regulation because Iman is already there we learned from the from the previous talk and um in the end with e-money there's an issuer you can kind of tokenize the e-money there's this blockchain infrastructure I think that I think that that really worked out in I think in in a good way I would say because um from from my core I believe so maybe some of you also follow the discussions around the digital Euro and I think like the digital Euro how it's currently planned it's like a complete disaster from my point of view so like expecting so if we really wanted to be the best for our citizens so that Texas kind of being spent to build it and to kind of to launch it I think it's it's a pure Nightmare and and I really believe that with even with Mika regulation and having like stricter rules on e-money than we had until until now I think it's still a good step forward because I think um we the community can build with Mika the the real digital Euro from my point of view it can be it's permissionless it can live on public blockchains it's open kind of to build defy around it and make it programmable and it's it's available for everyone so I think that's that's a that's a good good step in between to make the Euro more digital so when it comes to the Arts to the asset reference tokens I still think the and also that's also some of the criticisms criticism from the from The Regulators community that the regulation is too strict so it's almost feels like like e-money token is halfway easy to to achieve but as asset reference token is almost impossible and and I'm also again looking at this from from a citizen's perspective I'm a little bit sad because let's think really 20 years 40 years 80 years in the future so do we believe that the euro is the most stable currency until then yeah and we're making debt like unlimitedly we need to finance Wars there's like the climate crisis and so on and we all know like depth is is kind of poison for the for the finance system and and maybe um the citizens money in the future need to evolve from first it's Euro pounds like with an e-money token that's great but maybe in 20 years or 30 years we need to have an asset reference token so where you have like a basket of Euro and some other more stable currency in there because um kind of the citizens wants to to keep their money and I think that's what I'm a little bit sad about because kind of this technological innovation is now somehow killed by by the regulation that's the the point I wanted to to make and to ask uh for all of you uh the last question will be on power and control because there is a paradox which apply to whole cryptocurrencies and the whole uh distributed Ledger technology sector in general but particularly on stable coins is as a civil servant for the French government and as a Linux user from 20 years ago I have two voices in my head the first voice is from blockchain forensics company such as chain analysis or elliptical or others saying well we did the maths and there is one two percent of the volume of the transaction with criminal activities with the links between the public addresses and from the other side we have the bis reports fed FCA Vincent all the authorities saying that we need to regulate cryptocurrencies but especially stable coins represent a threat to the financial stability but why does it represent a threat to financial stability because it it's a bridge between the cryptocurrencies sector and the traditional centralized Finance where there is the liquidity and the interoper operability and what I what I want to say is if the policies and the regulation which is made at International level is set to protect us from criminal activities that represent one percent and if on the other side we have a switch from centralized Network to decentralized network can we just cut the crap and say the world it's just about the power and the control so to be like brutal I would say if you think there is room in the future for stable coins and cbdc if you don't think there will only be cbdc do you think stable cons developer or lawyers are ready to be like a subsidiary of the Central Bank Leo I would take it maybe a bit to the theoretical side so according to the legal Theory actually anarchism is bad because in anarchism people are eating each other and then you know we created rules so the whole judicial system in every country is shaped in order to to prevent us from killing each other okay and that's those are the laws because you know I create law that is preventing you from murder and then you can of course justify it from a economic perspective or value perspective but basically the theory is that you know the Leviathan of hopes and the theory is that we can function only if we have a a a king the state is here to protect us yes it's for your protection and that's the solution yeah but but guess how guess what actually the we have cryptocurrencies and from the beginning coin was something that the governments could not control so Bitcoin was there deal with it use it deal with it do whatever you want but then it's an open it's an alien it's an alien and then this early and technological animal you need to there was always the question when I wrote my thesis every day I came to the university and they asked me no so how many people are using Bitcoin how many people so Amazon is accepting payments this one is accepting payments you know with 2011 12 and um and then they tried to find evidences in the usage but but then yes the users people could use Bitcoin and then it became a social convention and then who cares what the government wants or don't want if you have this super decentralized products that no one can can stop so then Bitcoin depends on us a specific doubts maybe but you know depends on the decentralization level and then of course the industry started to build companies and entities etc etc etc when you have an entity you are in a in the field of the government so you can the governments can come and blame you and you can claim against the government and then the question of stable coins stable coins are are created by people by entities as as uh as a compete maybe competition maybe not to the to the uh to the National money or to other Financial products I I have a last question very last but just to be concise I didn't tell my reaction when I stumbled the first time on stablecoin the first time I say what the but I don't need what what I I just go into cryptocurrencies and Bitcoin and ethereum to escape Fiat currencies and I have the digital dollar or digital representation of Euro doesn't work there is no so if you saw the movie Inception stable coins are basically a digital representation of a digital representation which is Fiat of Gold Silver and so on in the median age so it's it's not a feature of cryptocurrency it's a bug it exists it only exists because people cannot use for now cryptocurrencies directly in the retail to buy stuff to buy water or to sell contracts they have to go across the most the the first pair trading in the whole industry is usdt and BTC so it's like a failure for the cryptocurrencies industry in my point of view let's just finish them actually I would like to respond also to your previous question and also to this one because I like starting with the last one um I would slightly disagree because um from my point of view stablecoin is not tokenized Fiat or like digital Fiat so it's something different because also if you look at all the kind of like reports of circle kind of showing how they invest the money and so on it's way way lower risk than than the Fiat system and um and in the end because because the people agree with this maybe because they kind of the companies try to hold it like in very kind of like short duration papers and and so on so like as risk-less as possible and even the Imani institutes are kind of claiming to get a central bank account these days because this is like the the lowest risk possible and um and therefore so I think so because just just to put that clear that it's not another digital layer around Fiat it's I would say something in parallel but to the to the previous question um because you were referring to like the anti-money laundering and kind of like one percent of the transactions being uh correlated with with crime um so I agree to that part of the of the question that uh this somehow like especially when being in the crypto industry somehow feels bad like um because it's much more transparent it's like all the prosecutors at least that I met on conferences and so on they're always saying like please don't take away Bitcoin because um we have to follow the money all day and and it made our life easier um so so therefore it feels somehow somewhat bad when when are these these wood scad introduced um but we need to be clear that Mika is not about ml doesn't doesn't contain kind of new rules for AML so therefore with with Mika there's there's no new Rewards or fatf and yeah so there's like other regulations coming up kind of like the um the new amlr the TFR that also has become kind of in parallels with with the Mika um and um and also all these even like the new mlr is still relatively open to to decentralized networks and I think that's also what I really want to put out as a message here that we really need to fight for keeping things as decent place as possible because there could also be an interpretation of e-money to make it closed loop so which would mean performing for that so yeah of having the license yeah so because because at the moment because at the moment um for example ustc is an open loop stable coin open loop e money so you can send it to somebody else who's not kyc with circle and then kind of it travels back and then can kind of get paid into interfered again and I think so that's super important for the crypto industry to keep it the open loop um for the for the future because um so also when whatever like uh also putting it in a broader perspective I think the The Innovation that we have with with stable coins is that we for the first time can have an internet of money so which means so far we can send zero until like the borders of Europe with separ and then we need to do Swift and money conversion and so on correspondence bank system so not like the internet which was like a like a Global Information System we don't have a global money system right now and I think if we can come up with stable coins keep it open keep it open source with the technology that we use and make it accessible I think we really can introduce the internet of money which never existed uh shortly we will take question after that yeah just to react to what you said about like the possibility of stable coins becoming a subset of cbdc's just two practical points the first one is that I mean it's not only this room where people are skeptical about cbdc's um I mean this is becoming one of the main topics in the presidential campaign in the US right now like literally some of the candidates are calling for the ban on cbdc's so like a huge them like that debate about um you know democracy and legitimacy is gonna do is gonna start of course we don't fill it in Europe right because this is happening and not at the national level but it's gonna happen and second look for Mika Mika proposal was made in September 2020 it took three years until it was adopted that it will not gonna enter like practically it's not gonna be applicable uh on over the next year right so it's four years like how long do you think it's gonna take for digital euro is it going to the class for me the guess is at least five years right so it it means that we have like at least five years and come on 2028 it's gonna I mean we are gonna just rock the world with all the stable coins that are gonna come out of this room I'm sure about it we'll probably have a war with China and Russia so we won't be able to talk about cbdc so everything got to be fine uh we will take a few questions you said you were a member of parliament here in France so my question is obviously you're Advanced thinking but what percentage of people in Parliament actually not only gets this want to get it or uses this as somebody will give them a bribe like in the U.S to vote no on something because they want to do a farm bill like what is the politics of this you know what percentage of the people actually even understand it close to zero now I think a few few people few people really are I was lonely because I'm a former MP so yeah I I try my best to convince my colleagues to educate and I think education is is very important you know so it's good regulation and bad regulation good education is to protect people and I think it's not a bad world we need to protect people we have seen with our industry that we need more protection and really actual nowadays we need always more protection because I'm not totally sure that usdc or usdt protects people uh more than fat really we don't have seen that with svb and so on the second Potter is bad regulation and bad regulation is because regulation will protect the Insiders so people which are in the game right now so Banks and for that banks are very powerful uh EU commission EO Parliament uh have a lot of information from Banks but just one point of view um binance coinbase train analysis so we are totally absent of this debate and really is the education of uh my my former colleagues are very important to explain what is crypto what is blockchain not just to uh to to see what is a widen in newspaper about yeah like you said antimony blundering and terrorisms and so on so really um this is the duty for for the crypto Community to uh engage a fight in order to educate people uh people like uh or parents but people like uh these public visitors and this is very important because if we don't do that uh the remote qualitisation of crypto will be very hard and since what we have seen with FTX and so on we we can see that retails are far away from us so really we need to to to build but we need to educate to all the politics because it's not only the thought of politics I think when we need to to do better and maybe one way to turn the narrative on on this point is kind of we can explain the politicians that it's a huge opportunity to make the Euro more relevant in the world right because suddenly you can send it around the globe and other people can use it of course they need to be able to use it in whatever country they they they receive it but then there might be countries or people who use the euro to really have like a safe asset in their wallets because their their home currency is not as stable so in the end I think the politicians more or less by the strategically um came to this to this regulation and it's in the end a huge opportunity and I think we need to educate them that they have this opportunity right now just just having one thing the parliament is uh the front but you have the back office of the administration in the high Administration make the low and then you have Pierre and his colleague just signing what has been done in the house but yeah yeah suppose the administration is very the real the real long-term uh stuff to do is my job inside the administration and it's much much much harder than the whips and uh dealing with the lobby and and so on uh last question sorry we only have a time for another question yeah hey hello um AML was mentioned because Mika is obviously not covering AML aspects and I was wondering uh to foster adoption what are the chances that the debate will shift from let's impose AML requirements on crypto to how to find an Innovative way of handling AML because obviously it's all burdensome costly and it will not work with crypto so if we just extend AML it will not be very fruitful right just to clarify maybe own chain regulation it could be like all these Solutions like but just one wall a very quick zero knowledge proof uh it will be the future of uh kawasi I think we need some risk approach but not the actual one and zero knowledge is a protection for privacy in blockchain and I guess it's also a matter of values and and again education and writing because whatever technological solution that you will have you need a support you need a theoretical support for it it needs to it needs a theory behind it it needs articles and it needs uh Advocates that will support this and then it will be a combination of those those two things I guess and yeah I think in the end we have to distinguish kind of the centralized and the decent last Concepts like for the centralized It's relatively easy you can do this like as in the bank but for the decent lives it's super complicated because AML and control and intermediaries can really kill the whole concept of being decentralized right and so I agree also kind of um so I I believe um kind of like in in AML so you have this term of an obliged person yeah so for example like a like a bank is an obliged person so they have to apply all the other laws like for for ML um and and they're kind of like the counterparty for whatever state and the prosecution and so on and um from my point of view like in a decentralized world also us individuals like being self-sovereign like with a self-sovereign identity living with our wallet can become an obliged person ourselves he also kind of like being responsible for kind of like uh whatever uh following whatever rules we want to follow and kind of making sure that we don't do criminal transactions or whatever so because if we do we might get found somewhere and then we need to take the the the consequences for that but I think so I think the individual room needs to become more self-sovereign also in terms of like applying to the to the rules and I think that that would be the way kind of into including kind of uh like a digital identity with your knowledge proofs um to really um achieve that yes um I would just add to that I obviously AML is one of the key topics here uh perhaps even more important that your regulation of stable coins I just want to to say that we should appreciate what we have now because the fact that we can send and receive stable coins around uh without kyc it's not a given it's actually I think that we're quite lucky that this is the case um uh I think I see like two legal reasons on why stablecoins um their economic reasons for sure but legal reasons why stable coins did not happen in the EU one thing is Imani uh that's that's obvious the other one is um AML because it's not obvious in many countries if you can actually issue a stablecoin at standard without complying with AML um and you know it's not a given that those favorable interpretations in the US right now with um you know fence and interpreting you know just giving very favorable interpretation to decentralized finance and to the fact that non-custodial wallets and transactions between them are not subject to ml I think that this is at risk this is always a trick at risk and we can just wake up in a reality in which all of those transactions are subject to ml and this is the first problem we should try to tackle and just to just a last last point to answer the from the technical uh solution there that just said it but for the low point of view and political power uh AML and know your customer is considered too serious to be at a level of uh only one country or a continent so it cannot be just Europe or just the U.S it's more like a transatlantic and G20 fatf topic than anywhere else so it's only G20 and fhef so I think we went on yeah thanks guys now we're going to break for just shy of 10 minutes and reconvene at 4 15 for a fireside chat with stani from Ave thank you thanks so much