Will MiCA Be the Silver Bullet to Make EU the Global Crypto Leader? | European Blockchain Convention

[Music] good morning everybody I'm delighted to see such a big crowd on such a hot topic of Regulation I thought I'd have to close the doors um delighted to be here this morning and um my name is Jillian Lynch I'm CEO for Europe for Gemini and um we are here this morning to discuss um a very hot topic a new Milestone regulation that has come into play in Europe the MAA regulation Market in crypto assets um it's a milestone because Europe is leading the way in providing some clarity some clarity around regulations so it's leading globally and before I kick off we'll do some just brief introductions to my panelists so I'll start on my left sudu hey good to be here Julian hi everyone uh my name is sudu Aram and I'm the Chief product officer at M2 which is an abitab based and regulated exchange hell hi it's great to be here I'm VP of regulatory and public affairs and bit bu and uh we rock the crypto World Marina hi uh I'm Marina vong partner at Asados a Spanish Law Firm specialized in Regulatory and compliance especially for digital assets at blockchain hello I'm Anna kolina I am the chief compliance officer at wenga we are right now in our process to Mika so it would be a pleasure to talk to you today and finally Eric hi guys um pleasure to be here um I'm Eric I'm managing director of um crypto Finance um in Germany we are a crypt broker and custodians so offer institutional investors and Banks uh the infrastructure um and the access to the market regulate in Switzerland and Germany now so also um right in the middle of the Mika um license upgrade process thanks guys and as you can see it's a very diverse panel um so we're going to get stuck in and as a starter we'll just have a little chat about like for us sitting on the panel we're living and breathing Ma at the moment um so I think it might be a really good starting point um and maybe Eric you can chat to us a little bit about what you think the impact or implications for you and your company are for ma yes and I think um a lot of people also on the station in the audience are actually working on the same topic now so for the companies that are already regulated um they have to of course get a get get a Mika license and it's not just them I think it's a lot of um companies who are not regulated at the moment who need to um become mik compliant and and get a license and um of course Mika is is is is a pretty nice thing it has a lot of uh benefits you um if you are um located in one of the EU member states you can use this license um for offering your services across the whole EU so it has a pretty big uh benefit but it also comes um of course with a lot of work I mean um at the moment a lot of companies are struggling and trying to find a way how to become Mika compliant and their different ways to do that um mainly there are three different ways actually uh either you can if you are not regulated yet um go through the normal licensing process and um get a Mika license if you are already um regulated in one of the member states um you can um use the so-called simplified procedure where you basically just have to fill in the gaps of your local regulator and ma um which should hopefully not take too long that's also what we are at the moment doing and um the third group is basically mid institutes in in the EU who can then notify into um MAA which is a bit it's still not a walk in the park but um you can um get it in a bit more structured and shorter way the regulator also has some time frames until when they have to approve this licenses we for us since we are already regulated we are in the simplified procedure so we are at the moment filling the gaps we have also um submitted already um um documents and policies and so on to the regulator so we are almost there I would say um but to to to just mention this for a lot of companies it's going to be really um a lot of work and a lot of stuff to do so if a new company for example wants to enter this space and wants to become Mika compliant it's it's a lot um so there are a lot of benefits but it's also a lot of work yeah it's I suppose for those that may not be as of with Ma you won't be able to offer crypto services in Europe Beyond mid 2026 unless you are ma compliant so I think um Eric was outlining it's it's a mammoth task um and I think Anna we were talking earlier about some of the challenges in that um you know particularly if you're a small company so I think it might be useful just to give a sense of um you know proportionality and and how if you're a smaller company how do you approach actually becoming M compliance sure sure um because when we start looking at MAA this is a massive piece of of Regulation that brings together not only uh Tech compliance but also uh financial markets compliance so when we look at it this massive piece we need to we need to think that this regulation is not the native language of tech companies so we need to adapt when we we need to put very big and complex uh worlds together is like this huge part of Regulation and also the Innovation and the the technology so we have some challenges in in terms of how do you make this compliance effective Ive you're not hitting the brakes all the time of the development and Innovation and at the same time you also are in the in the situation of warning your Tech Team about their wonderful and creative ideas that may imply some risks Now That We Are all uh applying for for MAA and we want to be compliant with this regulation because we want to create companies to last so my point of view right now like either you like it or not ma if you want to create a crypto asset service provider they are going to last and they're going to have the trust of the users in Europe you need to comply very much with this um with all those steps and in in my point of view as a compliance officer I cannot be neutral on that I would say that on boarding the right people is the key and having a compliance team that are on board with you and they are um listened by the product team is the I think it will be helpful for the Innovation and we'll also um help to get this ma license for good right yeah I agree I think that when we're engaging with Regulators it's important to show that you mean business and that you have a team of substance I think um starting out from a position where you you kind of trying to get away with the minimal amount sometimes you you you spend two years trying to get the regulator comfortable um I think if we talk about the the topic of the the the panel itself um much has spoken about Ma and is it the is it the Silver Bullet do we think that it will drive adoption um philli I'll hand over to you maybe and and then open it to the berer panel as well thank you I would like to start to go a little bit on the last question on what M does and I would like to go one step back and say for me ma is a transformation and transformation of a company and and then uh industry when we when we go back and think about what the industry has started with um and I seeing like the little speed boats uh that really kind of raised to somewhere but now the speed boats got bigger heavier and now you need a different steering you need a different governance and if you go on and take this regulation not at something what you just have to comply with but think about why people think that this makes sense for your company to be then you see the sense of it because then you see yes you cannot uh steer a large Fleet a large tanker the same way as a little speed bolt and this is where we're coming there and this is all going to be a race to the top and is it going to be the silver bullet and and I want to go back there that really depends on your business if you really believe your business is a small speedboard business then maybe it is more diff difficult to be there because you will need processes that will hinder you in some cases because we want the trust of the people and the everybody wants to have you think about it but if you are a player who really wants to work with bigger institutional with the financial industry then this interaction will be the Silver Bullet because what bit B has in there our corporations with uh DOA bank with lb and with many others is they care for regulation because that's the in the world they know and understand and then they integrate with you so this is where you come in a Sil bullet and for the other parts we need to just transform ourselves and see where do we are able to build a p2c market that has one Level Playing Field and is fair where not like players from outside Europe out European footprint are going in a market direction that doesn't work in there so going there it really depends on your Market size if you really want to work with the industry if you really want to work on a good high scale uh Target then it can be a silver bullet but it also depends a little bit more on what the rest of the world is going to do but this I think is another question it is and and thanks Philip and interested to see if any of the panel think that the we see consolidation as a result or people leaving the Market because the regulatory burden or hardle is too high um just one thing absolutely I I want to go go back and see I've been now in the industry for too many years um and for that I was in the financial industry and when meit one was coming that was the same thing every time an regulation comes in but the European regulator very clearly then says you need to have a minimum size I don't agree with this uh approach and I think in many cases the US firms uh in US regulation makes it clever by having a better proportionality to be able for firms to grow to a certain size in Europe we don't like that as Regulators they say basically okay you have to do everything and the worst thing they usually do is they then put somewhere in there oh you can work with proportionality so the smallest firm with the least capacity now has to explain to the regulator why there are approach is still proportional that doesn't work that's resource wise if you would need to do it different we really should go and see what what does other do either have clear limits where firms are able to grow until they pass that and then have the size to go in there or really Define proportionality on a policy level and not as something you as a small firm have to explain I am bit buer I can explain things to my regulator but that is because I have the best experts I have um experts in many countries I have money to get legal advice I can do that but the next firm with a couple of employees who starts how are they going to have this noow maybe hey jul I just want to add you know it's interesting question around consolidation because if you look at the UAE where they you know where we regulated out of um you know they put their virtual assets regulations out back in 2018 and it's I think you know I know I'm bias but I think it's very very clear what's expected of firms both from a administratively and operational perspective and so what we've seen is actually the reverse IE huge growth in in digital assets businesses coming in and so I think it's I think it's not so much proportionality but Clarity you know I think that it's both's important yeah I agree sorry Eric yeah work ahead prop proportionality is actually um um there there's a lot to discuss because I completely um um I mean the big players yeah the big players that come out of miid and so on it's not completely new to them yeah and a lot of stuff is already there and you know how to deal um with this stuff and especially when you're a company also like bitp and and ourselves who Target really institutions and Banks and so on this regulatory certainty um is wanted and is actually it the last years it has been used as a very big excuse of a lot of big firms to not enter the market into crypto because they said oh we don't have regulatory certainty well now you have regulatory certainty so it actually helps the market to really develop and I think we really see a next stage in in Europe and it's one of the like from next year and it's one of the very few examples where we are actually ahead of the the US which is nice but we also have to really make use of it because we all know that um in the US things can also maybe also even in November change quite quickly and then um other country other regions can pick up and then um the the advantage we have here and we are creating now here can be also um gone again so um that for for for this companies and so on this space it's fine but I completely agree the proportionality for small firms and it's not just MAA it's Dora coming coming up it's um deck 8 coming up for for um um for Tech um so we are also bit at risk at the moment to really drown the small companies um and hinder actually The Innovation because I think in a standardized product and so on we have a good framework for Mika to um to bring the market really forward but the small companies I mean it's it regulation really can also hinder the um Innovative factor and when we think one or two years or three years ahead that could also be negative in the end now if if we if we don't have proportionality and really kick out these firms out of Europe because uh they cannot keep up with the with the regulation if I could add um pointing out about proportionality and and small companies and startups because we don't have to forget that um there are plenty of startups and small and mediumsized companies that are trying to be compliant with MAA they don't have the internal resources as big companies so they need to put a lot of time stuff uh resources money uh by trying to be compliant maybe they don't have enough resources to be totally compliant um they are not like financial institutions banks with huge amount amounts of uh resources this is uh one of the challenges uh we have to face with Micah but um there are many more um for example the the national Regulators are still learning with us I mean they are as new as we are and when we go to them we answer them whatever we we we need to to to question they say okay I'm not sure I don't know let's wait for esma's opinion or let's wait for interpretations so there's very much so we're still learning because there's a yeah there a great point of uncertainty here so uh so we have Clarity but we actually we're still getting a lot of opinions so there're still we're learning as we go along and even though we have to be compliant by latest mid 2026 it's interesting very few Regulators have opened their application process yet so there's a lot that there's a lot of Engagement to come yes that's it and in fact uh there are so many interpretative issues in M regulations that we don't know how to how to deal with for example matters regarding reverse solicitations public offers uh sustainability uh exchanges will need to indicate the the enal impact of the tokens they are listing but how do we how do we do this or for for tokens that are about to be issued okay they will include this information in the white paper but for tokens that are already listed how we know the environmental impact I mean these are the little things that we we don't know how to manage right now and and for example in Spain the the Spanish regulator uh issued some guidelines in July and and it's okay it's a great start point but of course it leads to an enormous and huge amount of questions and and we have to deal with this that's the issue maybe if I just want to chip in especially for the smaller entities I think the one thing that we need to consider and that uh these entities need more to consider is more ways of collaboration be it on a technical level uh be it on on on different assets uh we worked with uh work with some of them uh to really be able to provide them it infrastructure and it things not everybody has to build everything on their own and I think that's something a way forward for a lot of these firms uh will say Okay I want to be in the meas space I have a good business but I will not be able to scale large enough to do it all myself so let's find Partners like bit bu or others who can say okay you what do you need to still sustain a good business uh without going in there and the last thing I really like is about The Regulators I think it's also an opportunity for us and I see them very receptive when we go to regulators and say hey I know this is open this is an opinion we have this would be singing there they take this usually very very seriously and we are able to I think really lead that there but what this also means that we still need maybe more cooperation between the industry that we have more One Voice going in there and uh have a leadership position yeah I I think Regulators definitely um in the last couple of years they're more welcoming for us to go in and have discussions and most regulars have Innovation hubs now and they do welcome people coming in but I think to your point philli as an industry we're probably not as cohesive as we should be in terms of really attacking the material interpretations absolutely one thing I want to add to that and sometimes we are not as let's say we don't use the same language we should and in the MAA process in some cases how the industry did lobbying was not good and I just kind of say because we use the way we are used to communicate and honestly you can't work MPS and commissions like that you need to speak their language and that is something where really also need to grow up a little more and not think that writing them 100 thousand of emails is going to solve everything that's not there we need to be we are now part of the larger industry and we need to act that back and just switching slightly so I think a lot of us in the crypto world just think about crypto companies and things about ourselves but I think when MAA comes into play it'll be interesting to see how um banks operate um banks will more than likely become ma compliant as well um Eric Maybe because a lot of us have Trad five backgrounds so I'm very interested to see how banks will come to play in the crypto space or what they would do I think banks play a very crucial role going forward maybe even the most crucial role to be honest because I think there's still a very hidden a big hidden potential of clients who just enter the crypto space if their belof bank is offering something yeah I think there is still a big potential but not just on the retail side also on the institutional sides I mean Banks also need to enable this asset class because they very often act as Prime Brokers for asset managers and so on so it's they they have a very crucial role for for the retail and also the institutional um adoption um and I think a lot what what what we see actually in the client calls um and meetings we have that a lot of the Big Bangs are going for own infrastructure and they really approach it and they have uh Pro projects to really offer crypto to their clients um next year but we also talked to a lot of smaller Banks um who basically think now o nice there's a regulatory framework we can just notify because we have a bank license it's not a big deal we just do it uh and sometimes we have to ground them and say no it's it's not like this I mean if you don't have the processes and so on notification doesn't mean that you can just fill out a form hand it in and say okay from tomorrow I'm doing crypto custody or something it's a it's a lot of work it's a lot of work of integrating um the technology of doing a new um product uh process internally adjusting all the um Frameworks from risk compliance you name it everything so it is it is a big deal and I completely agree with uh with philli here and I'm not so sure if I like the um Direction where it's heading at the moment when I um have these client talks because it seems like everyone thinks now okay it's easy to go into MAA um so we are going into M and we do our completely own infrastructure setup our own Tech we do everything by ourselves which is not a good direction when we think about the um post-trading environment in Europe because in the traditional space we already have a very fragmented Post Trading in landscape compared to the us and that hinders the market massively on the European level if now every bank is trying to build an own infrastructure and have a own custody solution own processes and so on you end up in a super super fragmented post rading environment that is not efficient at all um which hinders us uh further down the road massively yeah because in the end every bank has to have a business case um for offering this asset class and this business case is just basically there when you have also the efficiency that blockchain sometimes um uh promises um and at the moment it looks a bit like everyone wants to do do it by themselves which is I think not a good uh not a good direction so what we also always um always advise especially smaller Banks because there are some big Banks where it completely makes sense that they build their own Tech and so on if they have the scales but a lot of banks for a lot of banks they don't choose the right approach of doing it by themselves they should rather really use um and and choose a partner wisely basically to cooperate with them like bit or also also us here and that comes back also to the question you had before a bit of consolidation I think further down the road there will be massive consolidation on the Post Trading side because it doesn't make sense to have daily alignment process between 20 custodians um having thousands of onchain transactions that make also the um whole set up more unsafe and so on so I don't like at the moment the direction that it's looking like for the next year and how some banks approach it and I think further down the road there will be consolidation on this bace but Banks play Massive role under Miko may I just add to that I think sometimes the complexities are not seen uh not only custody IML how to do onchain are kind of um real uh proof of funds proof of that there are so many things in there that are very very different and the one thing I always tend to tell is you know um banks have not been used to be really being robbed in the past anymore because luckily that isn't happening anymore but um your crypto that can be stolen and that is a whole different deal you need to really be very very differently ready for that and I feel like and that's the whole door system for me shows that they are not as far operationally yes they will be better and kind of writing down the little Fields the regular tasks but operationally in uh security I think we are for far before them um we're all living and breathing and in the middle of doing MAA work um I wouldn't mind asking each of you what's the one thing that would keep you awake at night uh that would worry you about ma that um or an uncertainty that you're grappling with um Anna start start with Anna maybe that's a good question I have like a long list of things that keeping me awake at night when I think about MAA uh but with the legal background I think it's the implications of when we think about creating a Casp right now it's almost like creating a small bank so what do you need to have in place and how do you take this huge list of policies that you need to develop and implement and you work you're not working on a on a solid ground the ground is constantly moving because we are it's evolving we are listening to the asthma guidelines and then we go back to the asthma guidelines with all the hunger in the world like I'm going to find all the answers but it's still not there so what I would say is like um it is very good to have like the the three pillars of of of MAA like not certification licensing regulation we will need to comply with all those lists of policies before applying for the licensing before even knowing that we are going to be operative in the in in the due time and then we need to deal also from a legal point of view with the complexities of the each policy that maika is demanding we have experience on the anti-money laundering policies because we are dealing with that from the past five years we know already that we need to have the same kind of risk approach banking system from the anti-money laundry in the case of crypto but now with MAA we will have like the credential uh safeguards insurance we will need to adopt a business continuity policy that is very much intertwined with daa requirements and it's not possible to have a business continuity policy like a regular company is like oh if I have covid if I have a catastroph no I need to think about a solid ICT security system and to have it implemented uh internally as well I have I need to have um complaints handling policy I need to have whistleblowing policies but what does whistleblowing has to do with uh crypto asset service providers well a lot right now because we we want to create this trust from the users that we are developing a safe environment for the customers funds so we also need to implement all the the the security for the custody of customer funds and segregation of funds so when we look at this long list of policies I want to highlight to to the audience here that please don't go to a law firm buy a paper and keep this paper in your drawer because this is going to leave you uh in dark Waters in the future because the The Challenge and the interesting thing for MAA is to take these policies understand your product and understand how you're going to make these controls and these procedures alive in your daytoday basis like how you're going to talk to your team and make them understand that security systems it's not only um keeping your record safe in some place um in your office in Barcelona or on your office in in in Frankfurt and we also need to be very sure that we need to ensure that your top management the board um understand this policies and we need to put share with them the risk approach because we are dealing you mentioned proportionality at the beginning and what I would like to add to the proportionality discussion is that we need to go back to the anti-money laundering thinking and think about risk-based approach of course we cannot develop this whole list of policies in their integrity being a team uh that it's just starting but we need to explain our risks and we need to explain how um we are going to prevent those risks implementing the um the policies we had I think that um I would like to point out something else because from the law firm perspective I told toally agree with you uh in fact we need to know exactly what the client's business is about we need to draft the policies test them correct them it's a lot of time uh implementing everything it's and and at the end of the day it's not only about MAA it's about anti-money laundering it's about Dora it's about travel rule it's about many many uh compliance rules regulatory uh uh regulations that we need to follow so uh I mean the the compliance department is is gaining an increasingly um important role in the company um I mean we it's key it's a key Point still not their reportings after all of that we still need to go back to regulators and report on ESG on tax anti-money laundry suspicious activity reports in the case of Spain we need to report to the tax Authority about the amount of funds that the user is uh transferring along the year so so I think what the audience are getting a sense of is the regulatory burden um and it's it's akin to actually being a bank being honest um and I think it's just it's a realistic view of what MAA means um it's not a tickto exercise it's quite onerous um and I think that that's what Anna and uh Phillip I think maybe you might like to add a little bit I I honestly all of this is true but it doesn't keep me up at night and the reason for that is not only because we have amazing experts and we do it what keeps me up at night is two things first of all we do all this and this produces cost and burden but are everybody in the market going to have the same or are we still going to have players from the outside we cannot protect ourselves in because that is a real Market problem when we don't have this Level Playing Field we do all of these things and suddenly somebody comes in it's an open internet website people go in there and buy it the second is well I always tell the regulator we can't say no I accept governance I accept work but I cannot ban users from getting products they get on other platforms because that will drive them away think about any ubility of any service when you have to say no clients want it they find a different way and that goes a little bit to the first one the less I protect my market and I have to say no to my clients you don't get this here then this is a problem we do the work it's hard but what keeps me up at night if we lose these two things the European market is there I think it's a very good point I think as a for a lot of you here on the panel you guys are exchanges and platforms already in Europe when you look at it as a as M2 coming you know how do we position ourselves to offer our services in Europe and if we do the interesting thing for us is is not okay yeah you know we need to report tax we have no idea how to do that because we don't do anywhere else and you know separating it and that's a operational administrative headache but fundamentally for us is how do we enter Europe and where do we do it and for us you know we're looking at do we look at a partnership model do we look at a direct model you know we're speaking to a partnering um in Germany regulated by barin we're speaking to someone in in Cyprus Slovenia as well and of course every one of them's like you know yeah we can do it super fast for you you know come with us is that true what does super fast mean and and so you know we have a different set of problems to those who are already here and I think one of the challenges is and I think you've touched on it one is we talked about proportionality but the other one is consistency um and I think the biggest challenge will be um will each regulator apply MAA in a consistent way to your point sud that you're you're shopping almost at the moment and you're hearing I can get it fast here I can get it faster there and I think the biggest challenge will be for regulators and for esma and the supervisors is consistency so that if you apply in one jurisdiction that it's the same measurement that you're going to be measured by if you apply somewhere else yeah especially when you add derivatives so we have derivatives and spot and I'm not sure you know for it some of the other ex changes his spot only which is maybe clearer maybe not but when you combine miid and MAA now it's now it gets super confusing and that's not even to layer things like Dora um and so the the regular Tre overhead is huge um but from what you're hearing sudu are you at the moment are you are you going to and would you think that companies thinking of coming into Europe are going to sit and wait or investigate and say well I might as well bite the bullet even yeah no I I don't think we can sit in wait I think that time has passed uh and I also think that you know we looked at Ireland for example and uh where you guys are from and I think that's an 18mon process at least and so I don't think two things I don't think we can sit and wait as exchanges if we want to offer services in Europe and secondly it has to be a partnership model with the existing regulated entity cuz otherwise it's just way too long and and and too complex um in terms of um and I know we touched on it earlier um the competitive advantage and I think Eric you touched on it earlier Europe has an opportunity at the moment because we do have regulatory Clarity it's not perfect but we have a good idea as to what the guard rails are that doesn't exist in a lot of regions do you think that other regions will follow suit or how do you think they will follow suit like look at the states it's kind of Regulation by enforcement at the moment I do think they follow because we also hear from other people talking about this from other jurisdictions outside of the EU that a lot of regulators are actually waiting for maika to be completely final and there's still some rtss and so not not completely final yet and they will use is most likely as a as a blueprint because when you look at at it holistically and it was said before yes there is a reason why the regulator wants certain things because of learnings from the traditional world and also learn new learnings from the crypto world and uh the um and the FTX uh stuff that that was happening in the past so there is um um there is a reason so I think a lot of regulators outside of the U will also look at this and use this as a blueprint question is a bit do they do go a bit softer I would expect some jurisdictions to go a bit softer because sometimes it's just too much I mean when you for example look at um um data recording in uh Mika it's completely copied from mid and it I mean there the regulator tells you exactly how you have to report which Fields you have to fill which data format and so on that's that's too much I mean a lot of a lot of other jurisdiction will probably not follow but I think um also the US I mean they they they will catch up on this yeah if they use exactly MAA as as as blueprint in the US I'm not sure um but once they once they allow um also their Banks to enter this space it will they will enter it fast I mean the US Banks all have have projects in their drawer and they they they know how to address the market as soon as they uh as they are allowed to so they will will um um speed up quite fast maybe just to add to that first of all I think it's extremely exciting that this indust is even part of the election topic think about back what this means for this industry and whatever the outcome is it will be on the topic there to do something and on the regulation part I would have a simple solution use Ma but not level two um honestly MAA the cortex does most of these things quite right it just started with the level two text where they just copied things out of other regulations even though when they weren't there so even though M level one didn't have a connection to recordkeeping they decided just in level two well you still need it and very very detailed so going this direction will be interesting what I also like is that a lot of marketplaces not only us are going there I think Dubai is is a great great example of where they start going more and more dis regulated route and find those things that make sense like Market abuse I think we all can agree that this is an important topic to get solved and to have a clean Market out there so yes it's quite exciting and good uh from my perspective what what do you think that Dubai got right sudu when you were like they had Clarity early on as well and they got significant investment from key players in the market what what did they do right that maybe the EU could learn from I think I think it was um a couple of things they got right one was I mean Abu Dhabi is well well but it's it's that it was a centralized venue that you could kind of a simple thing as a website with with forms and and the to-do list before you can even approach them I think was one and the other thing was they gave Banks confidence to to bank crypto firms now it still isn't perfect because they're different Regulators there's Vara in Dubai uh the FSR Abu Dhabi Global markets and then the central bank is a separate um now if you look at Bahrain for example you know that's a good example I think for me how I'd like to see regulation because the the regulator regulates both crypto businesses and the banks so the banks have no fear because it's the parent regulator um but I think this is what the region is doing right there whereas you know even with coming into Europe I mean you know we're getting a bank Cent money bank account and we have no idea do this it it on a practical basis that's one of the biggest challenges any crypto and I'm sure people in the audience that have been trying to set up getting a bank account is is so hard to do such a basic piece um and I know when we had chats with Dubai it was it was part of their process that they introduced you to Banks Anna oh sorry Marina apologies uh in fact about the bank accounts uh last week that I was on Singapore and I had the opportunity to talk with some colleagues from all over the world uh we met made like a run table uh commenting on how difficult was to opening a bank account for exchanges or for caps and it turns out that Europe is the best place to do it because yeah it's so so complicated this is this is uh a problem that we are sharing all across the world in every jurisdiction uh they are worried about the same and it seemed that like Europe was the less one of the less complicated so yeah we we we are struggling with with this I just wanted to point it out that we share this a global it's a global issue very much it's a global issue that's it I would like to add just something that popped up in my mind um because um well I come from Brazil so when we look at the market the crypto uh U Market there like in Brazil Argentina Venezuela uh they don't have regulation yet but they a big market and what happened in those countries is usually that they don't implement the law but they take it at Best Practices in the compliance so I think that when we look at the us maybe they will create their own way of regulating putting people in jail uh electing some somebody else for the SEC but um I would bet my coins that we would have the Latin American Market looking very closely to Europe and adopting MAA even though if it's not a law but as best practices in compliance to approach the European market and have European customers interesting and I know we're coming towards the end of our time um I think maybe to to look less at the regulatory aspects and more in the business side so we have our regulatory Clarity so whether we like it or not we know what the guard rails are if you were giving advice what's the one piece that you will be focusing on in your business to try try and grow adoption um to to grow your business what's the priority now assuming that mea is and all our regulatory hurles are are tackled Eric do you want to start for me it's Partnerships but Philip you were probably saying the same for me it's really Partnerships because um it doesn't make sense for the clients to start with the most difficult piece and the most difficult piece is like I said building own infrastructure and getting the license approval for this and because that is that is a harder hardest piece but still a lot of um a lot of clients a lot of banks and Z start with their hardest piece and that doesn't that just doesn't make sense yeah that that we need to actually use the time to have a transition period And I would advise everyone to do so because otherwise we will lose at some point the advantage we have now with with with Mika in the European market and um I think it's a great chance and even though we also mentioned a lot of negative aspects about well lot of challenging aspects about Mika it's still it's still good I mean for us for example as a company we of course didn't want to set up shop in 20 plus different EU countries and get licenses there no one wants that and there we have a massive chance here so it's overall really really good um um development here but we really have to make use of it uh and that is really by doing Partnerships from my point of view hello um I think our new new slog Ben group to then bit and I think this is going to very much to the core integration and Partnerships we don't need 20 30 hundreds of firms trying to do the same we need this Consolidated and not only because for the singular firms who will make useless Investments uh but also very much for as a European market look we have the opportunity to have the biggest Market unified with one license systems let's use this and create strong European home firms that have an competitive possibility in the world and I think that's that's the thing be going in there and last but not least let's champ Champion the European market from European players and if we are able to do that I think we have one another all thanks philli and S for you um coming into or looking at Europe as a an investment proposition why would you look at Europe what's attractive about it yeah uh well for us it's uh I think our thesis is very much if you look at um exchanges and and casts if you look at it sort of you know trading volume versus assets under management um you know you look at you know Asia is very very strong in in in trading coins particularly the the weirder esoteric ones if you look at Europe for us it's very much around the earned product and investment products and so you know it's it's you know Germany France Spain for example you know along with South America you know these are areas that we're looking at particularly because our Flagship products they earn product and and everything that we can find within Europe that makes it simple and understandable not just for the venue but also for the End customer you know can they stay can you know what what what are they allowed to do and not allowed to do and what are the rules around it I think I think it's the key to Growing the market because I think Europe is much more mature people will like to you know like the yields that come from there from these products and and how do they touch it operate with it and and and benefit from it and I think that even though we've gone through a very difficult time in crypto a real a difficult crypto winter even in um a survey that we did in Gemini it showed that in the last two years we're growing to now one in four or one in five now hold crypto so like I think we're seeing huge growth in adoption so I think the opportunity is huge um and I think there's some and the EU is a hug huge part to play in in growth globally um anything in terms of South America do you see crypto adoption growing in South America or a lot yeah a lot I saw statistics this morning um putting Brazil as the third or four main areas for adoption we have we have Venezuela we have so much political instability there that you see people really learning how to use uh crypto to keep this your your money value save so I would I would say go for that I've been told by ooshi that I think our time has come to an end and thank you and thanks to everybody for staying for what sometimes uh regulation can mean that people leave the room so thank you for everybody and thank you to the panel as well for the time and consideration given to all the topics thanks guys [Applause]