The Evolving Crypto Regulatory Landscape - TOKEN2049 London 2022

before we talk about by Far and Away the sexiest issue of the day regulation now typically at conferences worldwide this is the panel where you go to sleep even though we have extraordinarily engaging guests the topic itself is typically something left for the lawyers you know when the business people have left the room but a funny thing just happened and right now you see why regulation compliance and policy is perhaps the single most important aspect of our industry today the topic that we need to talk about the most and debate internally within the industry before we can actually affect change globally so joining me as I mentioned are these three experts with different backgrounds so I'm going to give each an opportunity to introduce themselves before we delve straight into a series of topics so I'll start with you thanks David it's very loud um so yeah I am one of those boring lawyers I'm afraid so I would have been in this panel uh one way or the other uh so before becoming CEO Bishops Global I spent over a decade doing Financial regulatory advisory work at a global Law Firm join Matrix Global uh a year ago which in crypto terms is about a decade and taken over a CEO earlier this year and it's certainly an interesting time to have done that and an interesting time to appear on this panel so it's a real pleasure excellent Isabella thank you David I'm a boring policy person so I'm a senior policy advisor at trm Labs which is a blockchain intelligence company helping crypto firms and financial institutions trace and disrupt hopefully Financial crime and fraud on the blockchains prior to that I was at the center for financial requirement security studies looking at economic crime policy emerging Technologies and financial inclusion excellent black so my name is Lake Sharia and the wife is pretty good thankfully so my name is Lake chibi I'm a director in ey so I lead the Assurance practice when it comes to anything on blockchain and digital assets by background I'm an auditor not a lawyer and experts in in your respective area but yes in the traditional space but one of the first people to be joining the blockchain team back in quite a few years back so no happy to be here and be part of the band excellent and I'm David Waxman the founder and CEO of a company also called Waxman and we're the largest communication and strategy company in crypto so let's go straight into the not news and then it'll all dovetail a little bit we have recently seen Mika come out can someone hear Isabella explain a little bit about what Mika is sure so Mika the market in crypto assets regulation is the eu's attempt at creating a framework for digital assets um it it does that in a very rigorous and robust way I would say um so it creates three categories of digital of well three categories of assets so we have digital assets which is your sort of go-to cryptocurrency um we have asset reference tokens which are kind of stable coins and then e-money tokens which are kind of cbdc's uh there is layers to those definitions um there's also categories within categories so you have the standards of those and then the significant versions of all of those when you have your trading in certain volumes or you have certain numbers of customers what it asks of those categories is that everyone has to license under Mika you have to produce things like a white paper that explains exactly what you're doing your risks interestingly also your environmental impacts um it lays out a whole swathe of different reporting requirements um and also if you are licensed under Minka you are a obliged entity under the anti-money laundering regulation so all of the eu's financial crime on money laundering and terrorist financing now also applies to you so again that's licensing customer due diligence reporting lots of stuff and so ostensibly this is for the third largest economic Block in the world in the EU this creates a pretty comprehensive framework for at least a large swath as you mentioned of digital assets but not all no nfts and most of D5 don't fall under Mika and I guess until about two days ago people were concerned that those were the biggest offenders in terms of the most risky types of assets or asset classes within the industry like I mean you're ey which is of course in addition to being a top consulting firm and you work hand in hand with large 1450 14 500 companies all the time you're also different divisions of you are kind of also involved in auditing organizations you're also involved in the complying the compliance side and Advising companies on how to do things properly and write one of the issues has been historically with Comprehensive regulation uh or and policy I should say is that it's very hard to comply even if you want to so let me ask you this if someone just had to advise companies can organizations actually comply with Mika so it's a bit of a journey we have to appreciate the fact that look if you're if you want to make sure that you can have compliance at the Forefront of your organization I think the first and the most important thing is the mindset right well we always advocate for is getting things right the first time getting the boring stuff as often people say at risk governance unconscious blockchain.com we're also here talking about managing risks so I think the most important thing is can you comply from a Mika perspective yes you can but you have to have the right mindset towards moving in that direction and unfortunately we've seen that time and time again that things don't go right when whenever you're looking things under the hood so when it comes to auditing compliance and various functions that we have looked at I think from a quality perspective we do often see that you know there are often gaps so whilst Innovation is great you know we should be focusing on Innovation and moving forward in the right direction but you know you have to have that in your mindset that we need to do the right thing for the customers protect the consumers investors and the ecosystem so it's very important I think these are very pertinent issues that we've been seeing in the market well Oliver you're running an exchange which happens to be based in many in Europe so can you tell us about how your organization is handling Mika and I'm going to call it pan-european compliance sure so your questions like is a really good one can you comply with Mika we're doing it we've been doing it for years because make here is just the EU catching up with what individual member states have actually been doing since 2018 so we are Bishops Global is regulated in Liechtenstein and in 2018 19 they brought into a into effect the the blockchain app the tbtg and Mika is based in large part and sometimes explicitly on the cbtg so everything that was explained by Isabella on Mika we've been doing that for years and we know what it takes it does take a lot of effort it's difficult it's a real pain sometimes but it imposes incredibly high standards on us well let me ask you a question is it possible that that has created in some sense a regulatory mode that prevents new players from entering the space it should prevent new bad players from entering the space yeah but it should create a path for new good players for people to take uh regulation and compliance seriously to actually be able to go out to people and say these are the standards that we are complying with you know what you're getting right and we do this all the time the idea that there could be um a a bank that says it's regulated but you don't know what standards and applies well we we wouldn't do it and you basically consider that an unregulated Bank well you wouldn't put your money in another bank why would you put your money on a magnetic exchange yeah people do all the time because we haven't done a good enough job of explaining the importance of Regulation the standards that apply to that regulation where you're doing it how you're doing it and most importantly of all why that makes Market safer okay so is the UK falling behind because Mika we're talking about is in the EU um I I fear that it risks falling behind now Mika we say is here actually it's not here but it won't even be implemented until the back end of next year maybe pushing into 2024. well in regulatory terms worth noting to everyone in crypto a year is a long time but not when it comes to policy oh that's definitely true but the UK now has the opportunity to really Galvanize itself you know when Michigan was Chancellor he said some very good things about crypto and really wanted to make the UK crypto hub but then at the same time the FCA banned crypto derivatives for retail in the UK we're not naive here we realize that people are going to do these things there's going to be workarounds for Bad actors I would much rather see the UK say okay how do we get to grips with regulation do it properly and regulating doesn't mean Banning regulating means creating a path whereby people know what they're buying know what they're getting themselves into and make that decision in a fair way that's what we do Under the tbtg in Liechtenstein that's what we do under Dabba in Bermuda and we think our customers really benefit from that whether that's institutions being able to offer products that are direct comparators to the Chad fire products or whether that's retail customers who are just interested in getting into crypto or want to get more into crypto perhaps lesser in the last couple of days but there's going to be the interest there and people are going to be saying okay how do I do this in a way that's predictable how do I do this in a way that I know that when I buy something I'm going to get that thing okay so so to that end I mean I think we've just heard and Peter Smith described it extraordinarily on articulately the regulated entity for FTX seems like it's operating well one to one asset-backed for example it's it's it's it's doing well whereas The non-regulated Entity is not have we just seen a seismic shift within the industry Isabella have we seen that organizations that comply with regulation aren't just more popular with government but are going to be much more popular with consumers investors and Traders very good question and just to come back to a previous point on Meeker and will that stop Innovation well I and to answer this question um one thing that it does do is it brings in the prohibition on Market abuse and Market manipulation and as a consumer I think you're much happier to enter that Market when those prohibitions are in place and you do know in the EU that is likely to be enforced so I think um what we will see is especially as the UK establishes its framework which I also would say I personally don't think the UK is falling behind um there is a lot more activity happening in the UK than I think sometimes we give the UK credit for so the financial services and Market markets bill should be done this year that will give the FCA the ability to create a similar regulatory framework that we have in the EU and they will be able to do that much faster than if they went down a similar route as the EU but we also have things like you know the economic crime Bill uh coming through which makes it easier for law enforcement to seize crypto assets we have a treasury select committee inquiry into crypto which will directly um impact and influence what happens next during the regulatory framework development we have a crypto you well crypto appg inquiry there's there's lots going on so I don't think we're falling behind we're just having a considered thought events like this week inevitably wool I was going to say this is going to either resuscitate the conversation or bring it to a totally new level I mean how could it not I I guess we're kind of forced to talking about FTX and binance so let me ask uh our our friend from ey here um what is this going to mean for regulation worldwide what are what's the net effect going to be as far as you can tell at this point I think so if you think regulation and you think of quality and if you think of risk you have to try to bring that all together so fair enough you had a regulated entity but you have to also appreciate what's underneath that I what's under the hood right and if you've done the right thing from the very beginning if you've got the right controls governance in place you know you're really going to survive and I think that's what the regulator is even looking for because fair enough you go through regularly I'm conscious most of you if you've gone through a process with EFC it could perhaps be a bit challenging it can be you know what it's a long process but they do go out of their way to appreciate what you're really doing as a business are you going to be resilient what if things fall down how are you going to survive insolvency many questions I think those are all the important things that matter from a regulation perspective because what are they focused on protecting consumers investors and also making sure you're doing the right thing from an ecosystem perspective so I think that's what matters it is going to go to the next level yes but I think we've always been saying and I think I was last week at another event and even F3 Summit where he basically said you know bat actors are going to struggle and it's going to flush things out but I mean fair enough it's bad for the ecosystem as a whole because everyone's here working really hard to make sure we can bring that element of trust in this ecosystem or for that matter blockchain or digital assets let me let me ask a follow-up question in cz's note one of the notes he posted to Twitter yesterday he mentioned that one of the bits of Fallout from this was it was gonna be harder in the future for regulate on these or would-be regulated entities to receive licenses in jurisdictions worldwide do you think that's true I think you have to strike a balance right if this if if the view is the fact that you're not going to get license I mean fair enough but the question is why right are you doing something wrong are you not got your your ecosystem or your organization in order right if you don't it's going to be hard again no doubt but I think the fear is that if I'm a regulator I might in order to look good or look like I'm not taking any doing anything risky slow down everything right now no no so I think you have to appreciate that the regulations are based on principles or they're based on whatever they prescribe other rules or they'll say outcome based I think the important thing to bear in mind is that the hurdle will become higher but that doesn't preclude people from saying you know I'm not going to get the license so you'll have to work hard for it and you have to convince so for example if things fell apart from a liquidity perspective or proof of reserve a point of view they'll ask the question do you have something in order right and then you'll have to go the extra mile as to all of us point you know really proving doing the boring stuff or or so to say the risk of earnings Etc to make sure that you can give confidence to the regulator that you know you're at it and indeed we've seen interestingly enough in just the last couple days a number of digital asset exchanges posting proofs of reserves some on chain and some using third-party Auditors but it seems like a step in the right direction Mr Bill I do want to talk a little about financial crimes not only is it your specific expertise but it's of course a great interest would you be able to give the audience here um a bit of a snapshot of the scale of financial crimes in this industry how much money has been lost to hacks for example it's it's been a year um for financial crime and crypto um so I mean I really I don't love putting a figure a definitive figure on um the amount of illicit finance that goes through crypto we'll quote you on this we only know what we know but there's kind of like a consensus amongst the industry that we're looking at around two percent of the whole industry volume is linked to a list of Finance what is the breakdown of that illicit Finance um well this year you cannot get away from the D5 hack we're looking at about 3.1 billion dollars taken in hacks this year 95 of that is in the D5 ecosystem um in fact I think between January and August there was a defy hack every three and a half days so these were lending protocols Bridges so on the whole what we see is decentralized exchanges and Bridges bridges are less frequent in terms of hacks but they are so much bigger when they do occur because there's like this quadratic risk exactly and and why are they attacked um what's the low-hanging fruit right this is all relatively new um pieces of software and it's easier to exploit who's going after them um it's a whole range of actors um of course you've got your sort of organized hacking groups uh but a particularly prolific actor in the space and do you fly hacks is North Korea um so what we see it's about a billion dollars this year well they put a billion dollars through tornado cash um which are you called the sanctions which is another topic we can talk about but in addition to D5 hacks I mean they get a lot of the press but um fraud and scams are your next biggest category and at trm we just released a bunch of research just yesterday um looking at these uh well what we call Mega frauds so these are frauds that in 2022 alone have taken a hundred million dollars in deposits um 11 of these make up 74 of the four billion dollar total that has gone into these investment scams so think one coin the missing crypto Queen it's not over it's continuing they're happening all the time and from like a wider risk perspective this is consumers retail funds that are going to disappear one day in these frauds so the big Focus for us in illicit Finance D5 hacks Investments frauds scams involving nfts but you also have your more traditional money laundering from.net marketplaces a sprinkling of terrorist financing and sanctions of Asian so I mean look that's a lot of bad words there but if I may re-encapsulate that you mentioned about two percent of I'm going to call it assets digital assets this past year I mean somehow you believe have been involved in financial crimes that sounds both like a lot at the same time like 98 has nothing to do with financial crime meaning this industry is it is indeed robust and has real utility already and isn't just theoretical um so to that end let me ask you this how can we solve how can we cut Whittle away at that two percent what can we do like um so I think you have to appreciate standards I think there are quite a number of existing standards that do exist for the market now we'll have to you know how from a crypto industry perspective you sign innovatively how we can do things differently but equally I think we as in the industry needs to appreciate what already exists in the market like sock Isa ISO reports use that because those are standards that can easily be converted from from your own use case and use them and apply them to make sure that you can cover yourself from hacks and so many other uh perspectives so again goes back to the Prominent Point of risk controls governance making sure your ecosystem is is tight same thing from a hacks from a smart contract point of view yes you can you can do audits of them but how robust is the audit I mean that that question really pops up as well for us so existing system standards that do exist try to immerse them and do that and you know what you'll you'll make sure you're quite robust and tight well it certainly does seem like not every smart contract audit is made equal yeah I agree there's been a lot on the rec database that's rekt that one should look up and you can see what I mean so Oliver you've been leading a regulated exchange a centralized exchange you know the custodies assets how are you putting down or creating measures to further I guess in the entire ecosystem prevent Financial crimes so I think this is important to distinguish you there's two types of financial requirement that we need to protect against uh at budgets Global and we have an important role to play here the first is protecting our customers from hacks and from other Bad actors within the industry and security for us if it's just Global is everything our Founders uh when they created the original bittrex they did so coming from a security engineering background and wanted to get involved in crypto this is way back 2012 2013 right real OG crypto stuff and they looked out there and they were like well everything that's out there right now kind of sucks from a security perspective let's create our own thing so security is in our blueprint is in everything we do from the very beginning so that's one aspect of it and that's protecting the platform and protecting the users of the platform from Bad third-party actors but the second bit is making sure that our platform isn't used by third-party actors to perpetuate criminal activity and so what that means is having real genuine kyc requirements enhanced due diligence when we identify uh you know additional risks filing suspicious activity reports and transaction reports working with The Regulators to clamp down where we see suspicious activity so that we can actually take those people and drag them does that happen more frequently than we in the public might know oh absolutely absolutely it does and what what the what the market as a whole doesn't see and what perhaps the whole industry should be better at doing is is the effort that is uh going on behind the scenes and what compliance when we say oh we're compliant well that really means you know we are applying the same standards as banks have to do when it comes to AML kyc right we're subject to precisely the same laws implemented by precisely the same Regulators two precisely the same standard so this is not a soft uh a soft touch for people provided that you're talking about those platforms that take it seriously and are regulated so we voluntarily put ourselves in a position where we had to comply with those standards by getting regulated in Liechtenstein by getting regulated in Bermuda and these are jurisdictions that are used to regulating Financial Services right Liechtenstein in particular for private wealth and banking Bermuda with a very sophisticated insurance industry you know these are Industries these are therefore Regulators that are used to doing this stuff and so when we said we'll apply this these standards to us as well please they said sure it's going to be really difficult and we were like yeah sign us up because that's what everyone should be doing interesting I wonder if every exchange is going to go and take the honorous path forwards but perhaps it is the right one and might be more attractive as I was saying earlier to uh on a commercial basis as well and I think that might be kind of the Hallmark of the latter half of 22.

so um let's change topics a little bit at trm one thing I I know from from experience even working with some of our clients is that when there is a hack one of the very first things that happens is you look to trace the funds eventually it might turn into something criminal or presumably it would it wasn't the first place not some wife hat hacker but that's of course one of the things that trm is famous for of course is it's forensics to what extent are are your Suite of products at trm able to help regulators and force those rules true um well and kind of also to what Oliver was saying just that like he can go to a regulator and say please regulate me and you can also then say I can also do a way better job at following the rules than Banks do because I have so much more visibility of what goes on can you explain that a little bit to the audience please sure so if I'm a bank I can only see what my transactions are what what's coming to me I don't see what happened to the transaction before it came it's a black box before it arrives pretty much like the only traditional financial institution who has a really good view of what's going on are the msbs so like Western Union and MoneyGram but if I'm like a Traditional Bank I let you just see what's appeared at my front door and I go okay cool well it's coming from a person I know it's fine but who did it come from before that I I just don't know um but in blockchain because it's so transparent I can see exactly where every single transactions come from what has been what that wallet address has been associated with someone said to me recently it's like imagine if you took I don't know if anyone in this room has cash on them I find they probably don't but if you took a hypothetical 10 pound note out of your pocket and you search the serial number in a like a Google like search engine and you were able to see exactly like every which pocket that 10 pound note had been in all of the temp all the pockets had ever been in that's what we have in blockchain and analytics and intelligence so we have a way more advanced ability to trace and track Financial crime because we can really understand the networks and the movement of funds to an extent that just hasn't been possible in the past um your question was how can Regulators use our tools well also to your point earlier about like licensing and why is it is this going to become more difficult um I think we see Regulators around the world we work with a number of regulators adopting blockchain analytics and intelligence tools to perform the components that they need on the people that they're like licensing so they can um really have a deep level of understanding of the vasps that are operating in their jurisdictions um how do we Trace funds well there's a whole range of different methods um but yeah when an incident like a hack for example occurs straight away we can look at the associated addresses we can tag them we can follow the funds as they move through different what we call signatures or more traditionally money laundering typologies that they're using peeling chains or webflows to try and hide the origin of funds and then we can work with law enforcement agencies to try and recover assets and it does it does happen for prime time and certainly we've seen exchanges for example uh stopping wallets from receiving blacklisted funds for example because of course it's all on chain I've got to ask though um is does regulation have its limits so one of the things that we talked about in our prep call was that it's possible that we shouldn't over regulate to such an extent that we're not actually solving the real problems here and and I must admit some of the problems here perhaps not what occurred at FTX but some of what we talked about today really are cyber security issues and of course it's something ey consults on um is that the bigger problem here I think there are multiple problems and it's very difficult to appreciate that how can you immerse them all together to either say is it regulation or is it cyber security or what is it what we can do from a market point of view is learn from history right we've had the financial crisis we've had hacks we've had so many situations that have happened so regulation is an aspect of it but what we often say is your mindset you want to make sure you're doing the right thing for the organization shareholders customers and the ecosystem and how can you do that and when we start to break that down regulation is one aspect of it but equally what do you have under the hood how do you prove that level of assurance and how can you give that level of assurance be it using a third party or not right self-regulation is also a big concept that people said that you know what we we we're just going to go Bank style regulation and we're going to go really hard so that when when it comes to the point where we need to be regulated we'll basically said we've been doing it all along right so I think you have to break it down into many facets of what do we really want to do and it's really starts from the Top If you get that right you'll make sure that everything starts to make its way down and you will do the right thing with the ecosystem that you need to build be it regulation Financial crimes sanctions um ifpr reporting pillar 2 reporting pass reporting there's so many of them but you know you'll get into the hang of things and you'll do the right thing but the main thing is start from the Top If you get that right I'll start trickling down and you've got existing like I said before you've got the right standards that do exist in the market and that has evolved for digital assets too so if someone says well we don't have the right level of standards for ourselves well it has evolved and professional bodies like ey and others contributed to that ecosystem as well to say you know what we've got this ecosystem of stock reporting how will that apply to digital assets and that report basically I think came out last year one of the intricacies that we need to be conscious of so that the whole ecosystem in this market can understand what they need to do right well one of the things that um we crypto people are really looking forward to in 2023 is the implementation of What's called the travel rule yes we talk a little bit about that today because um some in the industry liken it to asking a one-armed man to clap um is it even possible to implement uh and uh and beyond that to a certain extent is it compatible with the morals that made Bitcoin and crypto in the very first place Isabella I'm gonna ask you that first it's a big question lots of questions in a question why don't we start with what is the travel travel let's start there all right so fundamentals yeah so the travel rule it's existed in traditional finance and for ages or need something that would apply to a wire transfer and you're basically asking uh the sender to send some information to the beneficiary on who's sending money and the beneficiary sends some money back some information back on who's receiving the money and more or less what information is being shared between the Sandy or the sender to the Cindy yeah great question no it's um name bank account number it's it's more on the sender than no more on the beneficiary than on the sender and um since 2018 um so a little bit of History um in as digital assets were becoming more and more popular the financial action task force which is the international standard setup a money laundering terrorist financing and proliferation finance and got very nervous about some of the risks that could um Financial Congress that could come from this asset class and to try and mitigate those risks they thought well we will change something called recommendation 15 which brings in The Wire Tran the wire transfer rules or travel rule um for this asset class and since 20 yeah 2018 there was people supposed to implement it globally there was a kind of agreed grace period because there was no technological solution to be able to send this type of information between Bitcoin doesn't have a metadata layer to put who you are as an individual and who the recipient is for example and where they might be physically located so this I think is a really good example of how industry participants and Regulators need to do a better job of working together because the principles of the travel rule like I don't think any anyone really objects to like we should be doing it that we should be finding a way to do it but certainly some people do but perhaps not the well but but not us right we we are fine with the principle which is asabella said has been in the industry for a very long time um but we can only do what is physically possible to do and it doesn't really help anyone to promulgate rules and then immediately say oh no but we didn't really mean those rules because the technology doesn't exist so kind of don't worry about it we won't enforce it yet that doesn't help anyone it creates uncertainty it creates doubt and we've been working away working you know that we have a the trust network has been working away diligently trying to create the technology to do this stuff but we need to be better at working with The Regulators so that we don't get into this kind of bizarre situation and I think historically um industry participants in crypto have been less willing to engage with the regulators and they've seen them as Like You Know The Enemy that you wouldn't want to talk to and what that creates is just bad regulation and help anyone we want good regulation we want effective regulation but it's the art of the possible there's no point telling people you said trying to tell a one-handed man to clap like given time and technology and and you know I don't want to milk the metaphor too much but someone will develop a prosthetic and allow him to clap but saying do it right now well that didn't help anyone so we need to be better I think in the industry of going to the regulator saying right what do you want to achieve what are the principles we need to get out there okay here's how we can do that here's what you should be well Isabella was about to give us an update on kind of where things stand so well no I was about to say well now you have nine other prosthetic hands to clap with because there is no Solutions out there at the moment that you could engage with um the problem it like yeah it's just pretty difficult and it's new and we need to iterate um a big issue is that these nine solutions they don't talk to each other so if if I'm Oliver do I just use the trust Network well I can only use the trust Network which was built by coinbase if and with other participants within the trust framework so you can speak from bittrex to coinbase but you couldn't speak to someone else who's not in the network so then you need another technology provider for that and then all of a sudden you're like wow I have all these travel a lot of bureaucracy and it's quite difficult um so the interoperability issue is is really at the for all right now and then at that International policy set of set setting level um the conversation is around this thing called the sunrise issue that you have certain countries that like in the UK it's in law but it comes into force on the 1st of September 2023. in Europe it is 2024 I think um and so what you end up with is countries at completely different stages of implementation so again what if I want to speak to I'm a vast when I want to speak to another vast minute country that has no traffic virtual asset service providers sorry yeah acronym like all over the acronyms all over the shop but um yeah it's a bit do you just end up like what do I do if I need I want to do this transaction but that jurisdiction doesn't have those rules implemented and it's not just sending information it's about doing due diligence on the vast to ensure that they have the right information security to look after the information I'm sending even bigger problem if I operate in the EU and I'm under gdpr and I need to make sure that the person I'm sending the information to can comply with gdpr standards so the sunrise issue has meant that because we don't have Global adoption at exactly the same time um there's lots of agility needed to make this work on a global level sounds exceedingly complicated that's what it sounds like so I think having experts on board are available is in order for all the organizations within this space um it would be wrong to have a conversation about regulation without at least touching on my home country the United States of America where perhaps and we've just seen it had elections for example that was uh just on Tuesday which may decide what the kind of the fate of Congress is and just to a large extent Congress oversees the three-letter or four-letter agencies that to that seem to oversee crypto today so I just love your perspective I'm like of what's happening over in the U.S so I I think it's regulations are happening but is it as clear as one would say that you know what I don't have an element of uncertainty it's unfortunately not there yet but is it moving in the direction that we're all hoping for that you know they're taking steps towards making sure there's Clarity yes uh will we get there eventually I'm sure we will so I think our perspective is regulations is important for the industry um is it all clear and certain unfortunately not but do we think we're going to get there eventually and I think from not just ey there's so many of us uh part of the ecosystem they're trying to help the regulator and better understand how we can best do it right all right so let's let's talk about that because I think that's really important how can we we being the industry best help Regulators create great rules that they could then enforce Oliver what do you think well on the U.S side um one of the joys of working with Matrix Global is that I don't need to engage with that discussion because we do not serve U.S clients at all we engage with Regulators around the world but on the broader question how do we engage with them well this is so uncontroversial in Chad fi that an exchange will be speaking to the regulator there are models out there right the Liechtenstein model has been followed in the EU the Bermuda model shows how that can work within a common law jurisdiction they it's not as big a challenge as everyone would have you believe and there are people who for their own purposes say oh it's so difficult throw their hands up in the air and say it can't be done it can't be done it has been done and it is being done and so just as it's so uncontroversial for the London Stock Exchange for example to respond to a consultation paper to work closely with legislators and Regulators in the UK why is it any more controversial for a crypto exchange or a crypto fund or any other kind of Market participant to speak to the regulators and say what do you want to achieve here's how we can do it here are some models that have been tried and tested and worked yeah we've been doing this in 2018 this is not new stuff now all right and and people that say it can't be done normally they're pushing their own agenda for why they don't want to have to do it well it also seems like The Regulators today know a heck of a lot more about the technology they did a few years ago when business is complete Greek to them one thing I would say though and I completely agree what Oliver has said and I do think there are forums becoming which are becoming much more matured for that um regulator or crucially also legislative voices because if you're only engaging with Regulators you're a little bit late you need to engage with people who are writing the laws not just the people enforcing the laws so people in Congress people in Parliament people in the home office and Treasury and Bank of England um but what I would definitely say is if I if I am a regulator my job is to find risk and to mitigate that risk and we should all love Regulators for that it's a public service um what we need to do is help them see the opportunities and see that all the great use cases and all the good that can come from this technology because they are very good at finding the risk but let's help them see all the good things as well and I think that will lead to better regulation when you think okay there are these bad things we can deal with them but let's enable this amazing art of the possible which will give us the economy of the future well I would like to end on that positive note we have an opportunity to help regulators and policy makers worldwide understand the good in this Tech well with that thank you folks thank you