EU, UK, US and UAE: multiple regulatory paths and one global digital asset market | EBC12

So, hello everyone. We can start. Our panel is probably the most convenient and really the easiest because we try to cover all the major regulatory issues in 40 minutes. My name is Stefan Lemus. This is my third European Blockchain European Blockchain Convention.

I am very fortunate to be a member of their advisory board, and I also work for the international law firm White & law firm White & Case. So we essentially advise the major players in this ecosystem on a variety of issues, from corporate mergers and acquisitions, capital markets, regulation, and so on. I am very pleased to be here and to give the floor to the keynote speakers who are among us, representing different regions of the US, the UK and the EU. Maybe we should start with you, Richard. My name is Richard Levine.

I am the head of the Fintech practice at Taft. I'm Colin Pine. I'm the head of innovation at the Financial Conduct Authority (FCA), and I'm also the chair of GFIN, the Global Financial Innovation Network Financial Innovation Network , which has about 100, er, members from global regulators and central banks. Hello everyone. I'm, uh, Patrick, I work in EU strategy and policy at Circle.

Uh , for those who don't know , for those who don't know , Circle is the largest, uh , Circle is the largest, uh , regulated stablecoin issuer in the world, but I think most of you do. Uh, I'm looking forward to talking. Hello everyone. I'm David Beckett, Head of Strategic Partnerships and Institutional Development at AML Incubator. Uh Development at AML Incubator.

Uh , glad to be here. I feel like I'm going to learn a lot from you guys. So I'm also happy about this panel. Thank you very much. There are so many issues, uh, in every country.

We, we certainly can't solve every one of them from the EU to my car yesterday, with the latest news in the US, with the Clarity Act, of course, with the Genius Act in the UK, we would be happy to hear the vision from the FCA. Maybe, to start, maybe to get a feel for the temperature on the state of regulation not globally but in key jurisdictions key jurisdictions , maybe it would be interesting for each of the speakers to point to one regulatory development or trend in our respective markets that perhaps best reflects the current state, the current direction of movement in your key jurisdiction, and potentially, if you see it for yourself, whether we have potentially moved from regulatory enactment to implementation. Well, I always like to start with a quote from Winston Churchill, who said that Americans can be counted on to do something completely wrong before they finally get it right. Uh, yesterday our United States Senate was unable to close the debate on the Clarity Act. Er Clarity Act.

Er , I'm not naming these legislative acts. Unfortunately, the Clarity Act was designed to create a framework for digital assets and would have shifted regulation to the jurisdiction of the CFTC and the Securities and Exchange Commission and actually provided a higher degree of clarity. Unfortunately, it was not accepted. So, we now have a small chance that this legislation, or parts of it, could be added to other binding legislation that will be passed after the upcoming elections in November, but I wouldn't count on it. Most likely, the Securities and Exchange Commission and the Commodity Futures Trading Commission will continue to cooperate on approving rules to regulate cryptocurrency either as a specific type of commodity or as a specific type of security.

The only problem is that the Securities and Exchange Commission is supposed to have five commissioners: three from one party, two from the other. We don't have any Democrats now. We only have three Republicans. The CFTC is also supposed to have five commissioners, and we only have one - the chairman. So while there is debate on both sides about whether this could undermine any established rules, I worry that even those rules that are adopted will be challenged in the courts.

Thank you very much, Richard. Well, uh, although you had bad news yesterday, uh, there was good news from the UK. Yesterday, at the latest meeting, the Treasury, ahem, made their final adjustments to ensure that their legislation is, ahem, appropriate from an industry perspective, which is ready to authorize the trading of stablecoins issued in the UK. And this morning I'm very pleased to announce that we've published our final set of rules for a comprehensive digital asset policy, which is great. Yes, thank you.

Um, that's great, because about a year ago I was at a discussion and I was criticized by various, um criticized by various, um , stakeholders for how slow the UK is and that we're going to miss out on everything because it's a disaster. Um, I think what you asked for is one thing that I think is really important, that really important, that I may have seen with my own eyes. I, um, joined FCA a few years ago. I'm on the other side of the tracks. I have offered many, I would say, cutting-edge digital products over the last 20 years.

And I was invited to disrupt some of the ways regulators look at some of their work. Before innovation, I have that right. One of my activities was that I joined the crypto crypto policy council last year. It was a great honor for me to receive the invitation to do this. With the clear intention of speeding up some work by using innovative methods and skills.

And that's exactly what we did. We have accelerated this to an incredible scale. And we have reached a point where, in my opinion, an important shift in cooperation with industry is a very pragmatic approach. The UK has always been very pragmatic, but working with industry to test ideas, get data, use those ideas to feed back to policy and our colleagues in authorisation and supervision – that's a really holistic view. We really look at what the market needs, and this pragmatism translates into policy.

So, I think policy. So, I think you've seen an acceleration and convergence of what policy, oversight, and innovation are doing together, and I think that's critically important. So critically important. So , in my opinion, this put us in a kind of pole position. So I'm very happy with what we did there.

As for the EU, this is where I personally spend the most time, probably too much time dedicating to MiCA the last few years, but there are a few trends worth highlighting... worth highlighting... maybe the first terms in the EU are a bit different, right? They were so early, MiCA was proposed almost 6 years ago, politically agreed in 2023, finally adopted and entered into force in 2024. I would say the first trend is that we are already in the implementation phase, at a stage where companies, both issuers and crypto asset service providers, are actually implementing the rules and have received the first, you know, feedback from the market, operational feedback on what works and what doesn't.

And this is one of the main points that is currently being considered. So, I would say that the first trend is a review of the current rules. The second trend is the focus is shifting a little bit from, I mean, almost so-called, traditional crypto activities like exchange, custody, brokerage, etc., to the tokenization of capital markets and the settlement of traditional capital market assets on the blockchain. So, this is, you know, something that was considered and addressed, um, under the Market Integration and Supervision Package or MISP.

Um, and then the third one, maybe, and this is a bit related to the Mika review, that is, 4 years after the start of Mika, that is, next summer, there will be a comprehensive review of Mika and maybe the first legislative amendments to Mika, which are currently being prepared by the European Commission after consultations. So, I think the biggest difference from other jurisdictions is just the timing. We are already at the stage where we are considering what to adjust after the first few years of use. Um, so, first of all, I want to congratulate Colin on your success. And for those of us who work in the American sphere, we just think that's our reality, right?

I think we talked about this before, when you look at how it's all managed. The big parents in the room, the mature people in the room, develop rules based on the regulator, and sometimes ideological regulation just doesn't work. This is a trend that I'm seeing, and we're seeing a divergence in which regulators are really regulating and building rules based on the regulator, and which are building them based on ideological or political ideology political ideology , and that has a big impact on how we work together, how we have convergence, how we have interoperability. It is very important to note this. We do n't have anyone to speak for the UAE, but I would just add that the UAE is one of those types of regulators regulators that doesn't regulate from an ideological perspective.

They regulate on the advice of the regulator, on the principle of the regulator principle of the regulator . We saw the UAE this year, in 2026, introduce enhanced rulebooks that really clarify what companies need to do in terms of operations to succeed and operate in the Caspar and Boss space. So, this is a very interesting dynamic that we are seeing among regulators. Thank you very much. As we discussed in the preparation of this roundtable, this is perhaps the first time that each of these major jurisdictions, the US, the UK, the EU, in almost a century have created all the rules on securities, on payment instruments.

And now instruments. And now , less than a decade later, they're potentially moving into tokenization of securities, into digital payments, and also we see this trend of potential copying at some level; and at the same time, from the perspective of the political cycle, we see more views of the National National Socialist perspective and a greater willingness to fragment. So how do each of you perceive potentially this trend toward greater fragmentation, and at the same time potential trends toward greater convergence on these new issues? Well, I think we're seeing a huge level of competition. Er level of competition.

Er , and focusing on bringing new products and new models to market in a way that protects the public. Uh, you know, I praise Singapore, I praise the UAE, the UK, the EU for doing their jobs better more often than the United States. We flirted with regulation by law enforcement agencies, with numerous lawsuits. We flirted with enforcing laws passed in the 1930s and passed in the 1930s and 40s that were never passed. I think other jurisdictions are not burdened with these late 19th late 19th -early 20th century remnants as is the case in the United States.

Therefore, I think there is healthy competition in the world to promote innovation in financial services. However, I believe that convergence is difficult because we have countries that have a Napoleonic code system. We have countries that have common law systems. And often each of these countries and these alliances has different political initiatives. I mean, hell, we have a president of the United States who was elected on the back of cryptocurrency adoption, and the reason the Clarity Act failed was largely because the was largely because the opposing party thought there should be a piece of legislation that would curb him and his family's activities.

So, I think that from a global perspective, it is difficult to achieve convergence with the United States in our current political environment. I think once President Trump leaves office, it will be easier to achieve a higher degree of convergence with other jurisdictions. Yes, I mean we see the role of the UK after Brexit. So, there's one more thing we had to deal with. Brexit was, uh, unsettling, obviously, for most of us who went through it.

Uh, and me, as someone who has a house in Barcelona and a house in London, uh, this whole period has been very, very unsettling. Uh, we've had to deal with the economic fallout over the last 5 years. Uh, I think the only positive thing is that as a regulator I now have complete independence from my friends in Europe my friends in Europe . Uh, and that gives us a lot more flexibility and a lot more speed. Uh, but that doesn't mean we can't ignore all those other jurisdictions that we do business with and that our consumers want to do business with.

Er want to do business with. Er , but the UK is traditionally a fairly diplomatic and, er, attentive participant on the world stage. Uh, we will chair the G20 next year. And, uh, I work with the FSB and IOSCO. Standard-setting bodies are currently facing difficulties.

It's difficult when, well, one of the regulators just got kicked out of IOSCO from the states. Hmm, it's really difficult to achieve such consistency and harmonization across jurisdictions. You are absolutely right. Hmm, I personally, um, do a lot of work. I mentioned GFIN to you before.

So I actually work a lot through GFIN because I think setting standards not only in European countries but also in countries around the world is a really challenging task. So if I can conduct experiments with maybe a small number or subset of, um, regulators who are really interested in a particular subject area. Hmm, for example, with GFIN I have an AI stream, a quantum stream, and a tokenization stream. We're doing really great work that's much, much more advanced than we could do in any standards-setting body standards-setting body , and much faster. So, I can run experiments using the tools we have, the labs I run, and I can share them with organizations organizations like MAS, RBI, Hong Kong, Dubai, etc.

And this is a great opportunity to use. I think we're doing very practical work, and I want, I want to take this data to the larger standard-setting bodies and say, "Look, guys, you know, I'm working with IOSCO in Madrid in a couple of months." We can show them what it means to conduct meaningful experiments and then try to turn that into a more worldview.” But you are absolutely right. The current environment is not conducive to such work.

Yes, I would say that there is definitely an increased appetite and commitment to alignment and collaboration, but it is still very early days. I mean, if you think about the EU, when MiCA was adopted, to be completely honest, they didn't spend a lot of time thinking about how to make MiCA consistent with other frameworks in the world? How do we deal with, for example, the business with, for example, the business models of, you know, the largest stablecoin issuers like us, or the largest crypto exchanges, which typically have one globally liquid order book, right? They are, for example, the largest trading platforms. So, MiCA didn't spend much time thinking about this and is now trying to address these issues in the review and then in next year's adjustments.

I think the US, the UK, I'm not a perfect expert on this, but there are already some reflections, for example, on the recognition of genius and equivalence frameworks for foreign issuers. In the UK, there is respect, at least, for systemic stablecoins, right? I think there is a little more flexibility when it comes to liquidity on global platforms. Hmm, but it's still very early, and I mean, uh, just one example uh, just one example , right? Me and Colin, correct me if I'm wrong, but if I'm going to issue a pound stablecoin under your new FCA, er, stablecoin structures, I think it's at least impossible or very, very difficult to ensure it's MiCA compliant at the moment, because the only way to ensure it's MiCA compliant is to issue it locally in the EU, right?

So there are still these compatibility issues that need to be addressed, and I mean, hopefully, conversations at the international level will help with that. But for us, as you all know, as an issuer operating globally, this is one of the biggest regulatory challenges we face, and one that we are trying to overcome together with the regulators. So, I want to, I mean, without repeating some of the things we've already talked about, I really want to be on a positive note. In theory, most regulatory regimes have the same interests and the same consistent approach when it comes to things like compliance, right? I mean, all of us at FATF are focused on this area.

We focus on travel regulations, anti- money laundering, and terrorist financing. All this is theoretically agreed upon theoretically agreed upon . I think the real problem with harmonizing these processes is that it's almost operational, right? So the difference between GDPR and data protection is how we handle it in the US or how the UAE shares information. So, I think when we talk about it from a regulatory perspective, almost all the different regimes are aligned when it comes to compliance.

It's about how we build policies and procedures and align them so that companies don't have to build a separate technology stack for each jurisdiction they enter because they deal with a different data protection regime. They use a different mode of information exchange. So this is where I want to be positive about the fact that from a regulatory perspective, the goal is pretty much the same across the world. It's just a matter of how world. It's just a matter of how we harmonize it to make business easier and actually compatible.

I was just about to continue. I mean, we should thank the Bank for International Settlements. We do a whole bunch of work with them, and that's exactly it. There is the Nadine project, the No project, AI, this is a fraud across the border. So we're looking at common datasets that can be shared.

So I think there is work that is really being implemented in a very practical way. And the UK is looking at the alliances we already have with Singapore, with India. And I think there's a real positivity in that. You are right. I think we're kind of focusing a little bit on the issues that are happening in the states at the moment, in this particular administration.

And so administration. And so maybe we need to be more positive and say, well, you know, I think the intention is there. There are principles. Of course. Now it's just a matter of implementing this technology.

And we are, by and large, all technologically neutral. So we should be able to fix that. Well, I mean, if you look at the fight against money laundering through the Financial Action Task Force , it's quite effective. Most of the leading, I would say, industrial economies of the world are very similar in their archetypal core principles, are n't they? I think if you look at a lot of the regulation of cryptocurrencies, digital assets, and stablecoins, it's very similar.

We are concerned about security. We are concerned about reliability. We are concerned about any contagion that may be caused by introducing assets into traditional banking systems. When I say that Churchill was right, we will eventually achieve this in the United States. We will United States.

We will likely do this through rulemaking, not legislation. But I agree with you. I think we are all very similar. The world's leading economies have similar views on how to regulate these assets. Thank you very much.

It is very interesting to highlight the fact that, as you pointed out, there are similar philosophies on how to regulate how to regulate . But nevertheless, a significant part of this, because these topics, not products, are inherently cross-border, and many international firms want to have a potentially single model of target audience surveillance that could be applied regardless of jurisdiction type. Where do you think the potential differences between jurisdictions' regulations could become much more significant? Is it more related to capital and prudential requirements regarding the characteristics of the asset, e.g.

tokenized securities, digital assets, stablecoins? Is this more related to localized licenses? Where do you think these key differences between this key regulation could potentially become significant? Well, I think if I had to pick one area, I think it would probably be think it would probably be derivatives. The United States has deep concerns about derivatives because they have not been regulated.

They were virtually left to the discretion of insurance regulators until the 2008 financial crisis , which led to huge off-balance sheet risks and threw the global economy into a virtual depression. So, we have very strong concerns about this asset class. When you then combine that with blockchain, it's almost like mixing oil and water, and it's potentially dangerous. So, I think when we talk about putting traditional securities on the blockchain, private, public, it's not a big deal. Blockchain options, again, are not a big deal.

Stablecoins, not such a big deal. I think derivatives are the real area of greatest concern in the United States. While in other jurisdictions like the UK, CFDs are a widely used derivative product, I would say the UK has a high level of comfort with it, as do other jurisdictions, but in the United States they still call it spread betting or gambling. Yes, I think there is another point of view. Hmm, I mean, we're just looking at, you know, looking at legislation on all tokenized assets.

So, we, we, we , we, we are looking at this broadly. The bank is obviously concerned with the systemic aspect, i.e. the prudential side and systemic stablecoins. The conversations we have on our side, of course, I bring non-system stablecoins into my sandbox for testing.

We did a lot of that this year, and it went really well it went really well . I mean, I think you're right. Regarding derivatives, there is a difference. I was a derivatives trader in the 80s. So , you know, I grew up with it , you know, I grew up with it as it developed, and during that period, everything was difficult.

I think we care less about that, as you say. I think what we're concerned about is what is actually real money, what is a real asset, and the point of distribution that you mentioned. I think that's absolutely appropriate. So, I think we're looking at all of that we're looking at all of that . Hmm, maybe moving from derivatives to stablecoins, which is our core business, right?

I think that, um, there are common goals, I completely agree with the rest of the panelists, who are generally, uh panelists, who are generally, uh , perfectly aligned. Then there are some operational requirements that are different, say for example, for Genius and Mika. And these may be differences that are easy to reconcile for global issuers global issuers like Circle, which issues both, let's say USDC as an example under Mika in the EU as an example under Mika in the EU , er, in the future under Genius in the US. Some things can be agreed upon, right? Mika requires a white paper as a product for disclosure disclosure .

For example, Genius requires monthly attestations. Or, um, Mika, um, offers the flexibility to theoretically invest some of the reserve assets even in long-term bonds or covered bonds, right? Which is impossible with Genius. What issuers can do is essentially race to the top and just, um, essentially invest in assets that are, um, legal and legitimate under both regimes. Hmm, and there are a whole bunch, I don't want to bore you with them, but there are dozens and dozens of such examples.

But the more critical ones are more critical ones are those that make it difficult to coordinate across borders, such as reserve, capital, or issuance requirements. So if each jurisdiction, for example, wants a large percentage of the capital buffer of the total circulation of a stablecoin, it's no longer a viable business, right? If you have to hold that kind of capital in dozens of different jurisdictions for the same transaction. Or if, uh, regimes want to keep a significant portion of the reserve in their jurisdiction, that also, uh, violates the fungibility and cross-border circulation of the stablecoin. Potentially the same goes for emissions, right?

If each jurisdiction requires a local issuance, this makes accounting very difficult for the issuer. Uh, I guess I would just distinguish between those technical requirements that are easy to overcome and then the reserve capital requirements for the release, which is a make- or-break principle. We hope that in the medium to long term we will move to a future where it is my personal hope and also I think it will be that euro assets will be issued under the auspices of Mika in the EU and then eventually be recognized in other jurisdictions for wider circulation and business, perhaps with some safeguards and conditions, right? And vice versa for dollars and pounds sterling in the UK. But there is still a long way to go until that moment.

I agree with everyone's opinion. I think I have two areas and a bonus area that I think are problematic for regulators to come to terms with. One of them is decentralized platforms. I think this will be a topic of discussion for many years to come. How do we deal with this?

How do we deal with identification? How do we address a number of issues related to a decentralized platform, which I believe every regulator has a different perspective on, and they're almost all right. But I don't know if we can agree on every point. I think the second issue is unplaced wallets, which is almost as problematic an issue. And then the bonus that applies to the US, this is such an interesting case, is the prediction markets.

I think when we look at the prediction markets now, we look at them as if they are being traded as if they are actually in the crypto are actually in the crypto space or the money space. However, if you get rid of the name prediction markets, you put a definition of put a definition of what you are doing on it , next to it, it will almost always be classified as gambling if you didn't know that they are prediction markets. If you were just looking at it by definition. So, I think this is going to be a problem area where regulators are going to start looking at this and saying, “Okay, this is not our area. This is actually a gambling area."

You see, I probably disagree with you a little. Gambling and trading are all about math. One side buys, the other side buys, the other short, one speculates on rising prices, the other on falling prices other on falling prices . The question of whether parties have a greater informational advantage than others, whether in gambling or in traditional financial products financial products , has always existed. In the United States, the prediction markets, and I agree with the chairman of the CFTC, are swaps.

These are derivatives. The legislation has made this clear. State gambling authorities may not like this. They will have to deal with this . But we expect one or more cases to reach the United States Supreme Court within the next 12 months.

And if they do, the question will be whether they say it's gambling, whether they say it's derivatives, whether they split the " they split the " baby" and allow states to have some level of regulation. But I was pointing it out to the people I live with in Colorado. We had the worst winter in 50 years. If ski resorts in Colorado did away with ski resorts in Europe, and did so for at least a decade, that is, buying weather contracts with precipitation, they would make a lot of money. Okay, sorry.

It's my job to protect people. And I think, you know, you can sell season passes to people who ski and are angry and are going to sue you, or you can buy derivatives. Just as the airlines that survived 9/11 hedged their fuel risks. There are now airlines that have learned this lesson and are hedging their fuel risks much more effectively much more effectively than they were 25 years ago. So than they were 25 years ago.

So , I think the joke about event contracts is , you know, the old adage that the Internet was started by the Department of Defense and pornography. Just because gambling is the most common use of prediction markets today does not mean that it is the only use and that it will be the only use in 10-20 years. And we are currently looking into this issue because in the UK it is gambling. Hmm, and of course, Polymarket is not available to UK residents . But wait a minute, isn't that called spread called spread betting when it's a derivative instrument?

It used to be called that. I think it's a rebranding, right ? This is called rebranding. Hmm, I mean, it depends on what you...I mean, it depends on whether the casino always wins.

Hmm, I always look at, um, I always look at the numbers, um, of the markets in this case. So it's interesting to look at the numbers behind the, um, front door. Thank you very much. I want to go back to what Patrick said about the form that cross-jurisdictional convergence could potentially take . Do you think there is a need for more conventions to facilitate the distribution of products between countries, to facilitate the provision of services across borders?

Do you think we need actual global organized harmonization, or do we need a potentially more achievable goal, which would be interoperability? So, what requirements must a regulator meet to adopt them or rely on another jurisdictional system jurisdictional system ? Is it more about mutual recognition, equivalence of rules, reliance on supervision by the country of origin? Does this apply to cooperation between supervisory authorities? How do you see potential steps towards greater convergence greater convergence , more “from the ground up”?

Oh, that's a huge question. I don't know if I even remember everything, but, uh, okay, let's talk about breaking it down into parts to be fully harmonized. No. Okay, and first of all, I mean, it's just impossible. That's impossible because you have different, uh, as I mentioned earlier, you have different data privacy rules, you have different rules about whether, you know, securities rules, you have different rules, uh, for everybody.

I think we need to agree on a goal or outcome, right? And then you can work under that. So, make it as simple as possible, but still follow the rules and regulations of your jurisdiction. Because you're not just dealing with the FCA when you go to the UK, you're also dealing with whoever is responsible for privacy, who is responsible for data control. So I think we still have to consider the fact that each regulatory authority will have its own rules.

And we need to agree on all the rules, I think compliance compliance is a great starting point. We need to agree on all the rules. Our results and our goals should be the same in this. But once we get there, it's simply impossible that we're going to completely agree on everything. Just to completely coordinate everything is just a utopian dream.

Now, going back to the fact that every regulatory regime requires a multi-layered stack of technology complexes, I think we can start to simplify this. Solving problems the way the FCA does: looking at our interoperability, looking at data sharing in a way that suits each regime, finding ways when we look at FATF, how we look at FATF, how we ...the outcomes are the same and the goals are the same for everyone, but how do we achieve that in a way that we don't have to have different technology stacks for different regimes when we look at FATF travel rules or anti- money laundering rules? So, I think, simply put, we can't fully harmonize. This is impossible.

This will never happen. But can we make the goal to be achieved, especially compliance, the same and then make it much easier? I'm sure it's possible. I don't have all the answers because I'm not a techie, but that would be exactly what I would say. Yes, I completely agree.

Ultimately, this should be a results-based equivalence assessment that should be pragmatic in nature. And maybe just to add an industry and operator perspective, I think there are just a few key elements of the cryptocurrency market infrastructure that need to be considered in this regard, right? We don't need to do these equivalence assessments for everything, right? If you, if you are a broker in the EU or, for example, a transfer agent, you just have to follow these rules in the EU, and you have to apply these rules as they are legally required. But for some key infrastructure elements, like, for example, liquid globally operating, uh, trading platforms or, uh, storage systems, where companies have been building the safest, most reliable technical storage infrastructure for decades, you don't want to replicate those market structures in every single jurisdiction, right?

It doesn't make sense, nor does it protect the consumer, if a global business is required to replicate the same, say, security setup for their key storage or if they have to try to replicate the same liquidity for a trading platform. This doesn't work. And that's what I always pray for MiCA, right? Because it's a great structure, where there's still a lot of work to be done in this regard, because what have European cryptocurrency exchanges done in the last few years? They have, in essence, become mostly brokers for the EU.

And as an EU consumer, I am now trading bilaterally against these brokers, and these intermediaries are added to the value chain, whereas a few years ago I was trading directly on the most liquid order book. Which is usually the cheapest and best option for me as a consumer for me as a consumer . So, I think if we can get, you know, the technical storage, set up global trading platforms and liquidity, and a stablecoin part stablecoin part where I can also rely on and distribute stablecoins issued in a secure framework, I think if we do those three things right, I think we're 90% there think we're 90% there , right? As a rule, 80/20. We don't need to be perfect here, but let's just focus on what's important.

Yes, I would say that by 2050 it will be done, probably. Uh, yeah, no, no problem here. Um, you're right, there's no chance. Harmonization is not possible due to the laws of different jurisdictions. And, um, we're doing our best to address compatibility issues.

I think this is the only way forward. Yes, but if you think about it, the way derivatives are traded around the world, securities lending , securities financing , repo markets, equity markets, while they're not all fully harmonized, they have common themes and principles of operation. They have a similar accounting approach, a similar focus on solvency protection and investor protection. I think these are laudable goals to strive for without arguing... without arguing...

Sorry, I'm in Spain. I fight windmills and strive for the unattainable goal of full convergence. Thank you very much, Paton. I may invite you for closing thoughts or statements. This can be tricky due to the variety of jurisdictions, but a final thought from each of the panelists on the potential state of regulation and how you perceive emerging trends in the coming years.

Uh , okay. We focus on four types of territorial and national regimes national regimes when it comes to this space. But I think we also need to look at harmonization, not just harmonization, but compatibility and cooperation with many other jurisdictions. We didn't talk about Canada, the MSB regime and FinTRAC, AUSTRAC. There are so many regimens that also work and succeed.

And I think, you know, I want to see them. We have two types of paths. We either take these current systems, these regulatory bodies, and force everyone to play by our rules, or we say, " or we say, " Okay, we'll work with you." We will interact with you. We will have some convergence with you.

"Um, but we're not going to force you to do it you to do it our way." And I think that's also part of what also part of what we need to talk about. It's not just these four regulatory, uh, regimes, but we also have a whole globe of active players in the financial markets, in the cryptocurrency markets, who are doing some things that are working. I mean, Canada works. This, uh, Australia is working.

So this is just my opinion. Uh, for my part, I think I shared most of what I meant, which is the need for interaction, cooperation. I would end on a positive note and say that after all, cryptocurrency markets are global, right? So, for jurisdictions, as mentioned earlier, it's competition. And in the end, the market and the numbers will also show what works and what doesn't, right?

Taking MiCA as an example, we have been using it for 2 years. The CASP framework, 300 CASPs it for 2 years. The CASP framework, 300 CASPs that meet MiCA requirements, works for the most part, does n't it? There are things that need to be fixed. Stablecoins exist, but right now, with over 20 regulated EMT issues, it’s mostly for Euro stablecoins that it works, right?

Circulation is a problem. However, for global stablecoins, if you look at the top 50 by market cap, only three meet MiCA requirements, two of which are issued by Circle. This is part of the structure that clearly shows that the numbers are potentially correcting something. So I hope and I'm optimistic that eventually, in a few years, we'll have the experience, the data, that will lead us to the right conclusions right conclusions . Yes, I think it's time.

This is still a relatively immature market. Maturity takes time. And when it comes to derivatives, it took 30 or 40 years for this situation to develop. That's why I was talking about 2050. This really takes time.

And I know that may be an inconvenient truth, as GPT chat can tell me. But it's a fact. These things take time. Relax. You know, we're going to do it right.

We will do the right thing for consumers. We must protect the system. We must protect those who use the system, the companies that operate within it. This is our job. And as the world of cryptocurrency becomes mainstream, of course it will have a different flavor.

Of course, this takes time. Everything is maturing. Things will be demanded of him that were not demanded 10 years ago. I mean 2012 when I first bought Bitcoin and 2016 when I started building on Ethereum. Not much time has passed.

It's like a decade and a half . So these things take time. I remember the first time I read Satoshi Nakamoto's article in 2010, early 2010 . If you told me that years from now, Larry Fink from BlackRock would be talking about putting everything on blockchain and every other word would be blockchain, or that Jamie Dimon would be talking about blockchain, or that the Bank of New York would be so focused on it, Fidelity, State Street and all these global regulators, I would have laughed at you . But that's exactly how we are today.

So, for everyone at this conference and in this room, this is a great guarantee of employment. The people here are the people who help innovate and help traditional institutions understand how to integrate this technology in a way that is compliant with the law, and how the law needs to be changed. So I'm very optimistic , even though we had a little setback in the United States. Overall, I'm still very positive . Thank you.

My sincere thanks to the participants in the discussion and the audience. Thank you. Have a nice day. Thank you.