The Crypto Regulatory Landscape - TOKEN2049 London 2021

thanks for coming everybody it's great to see a full house i don't know about you but i've had my full of zoom based conferences so it's nice to see everyone in the flesh um so this is a this is a panel about the current crypto regulatory landscape um i suggest we start with some brief intros from each of the panels and then we can you dive in with some questions uh and thoughts cindy we would like to start sure uh happy to start hi everyone great to be here live event uh we i think we all miss it um so i'm the managing director for europe for ripple um where i have responsibility for overall strategy and growth of the business right here um previously i'm coming from five years of mastercard in a variety of leadership roles driving the data and services business and uh and over a decade of consulting and financial services experience blair great hi hi everyone uh blair holidays i'm the head of uk gemini and for those that aren't familiar gemini is a crypto exchange and custodian founded out of the us by tyler and cameron winklevoss we just announced our six years anniversary last week and we've been live in the uk for about a year which is you know we're delighted to be here we're one of the very few fca approved uh crypto asset companies um so we got our willy wonka's golden ticket about a year or so ago um and you know uh prior to that my background is in a variety of different industries so banking payments fx and now into the uh the weird and wonderful world of crypto so nice to be here mary beth buchanan last but not least uh it is great to be here with you i'm the president of merkel science americas and also the uh chief global legal officer i um this company was formed in 2018 we're in bangalore singapore here in london and now in new york city and expanding hopefully to the to the west coast soon uh the company is a blockchain analytics company that offers you know four different products to make sure that all of you and your companies whether you're a traditional crypto or financial services can keep compliant with whichever regulator that happens to oversee your operations uh over the globe i've also been gc at kraken and at bitstamp and got into the space in 2013 representing companies uh in a private law firm and uh before that with the u.s justice department for 20 years great i'll mention who i am too i forgot to mention that didn't i uh i'm i'm oliver tonkin i'm the co-founder councillor of bcb group who are i think i can say the the um europe's largest payment services provider for the krypton blockchain industry so um that is us so let's uh let's dive in um and start off with a general kind of thought piece from everybody about you know where are we in the regular landscape you know uk us eu rest of the world what do you think about where we are right now cindy would like to start sure happy to um yeah it's quite interesting right there's a huge uh variety of approaches around the you know how the regulations happening in this space at the moment you know you have kind of the extremes of the china right straight out bands and you have you know on the other extreme the you know el salvador's rights uh making bitcoin legal tender and looks like brazil panama such as following a suit then you have the sort of more let's say u.s approach of like kind of regulation by enforcement uh which obviously has been a issue of um a news coming out in that space and then the the the other group that i would kind of classify as kind of the more thoughtful regulation more progressive which is you know where we see for example i would say you know japan singapore um and uk and and um eu with micro coming up i would classify the same way which is all about creating a framework that is you know bringing transparency clarity a common sort of definition taxonomy around the digital assets um and i think that's really important um to allow you know innovation to to really flourish while still protecting consumers um so it's it's a it's a broad i think diversity but i think what is really important is um i think the the jurisdictions the countries where we see this sort of more progressive approach i think they're going to go you know way further whereas in other places it's going to really stifle innovation and um and you know i think we might you know move some of the industry moving in those jurisdictions where it's a lot more progressive right and blair you mentioned that a gemini was lucky enough to have one of the golden tickets from the fca all done um i mean how do you think the the the the uk are um perceived as a sort of crypto regulatory yeah look i i think in in terms of the uk and this is kind of somewhat across the uh the eu as well um i think you know certainly the landscape here is indicative of the emerging kind of crypto landscape in general um and crypto firms in general uh and by that i kind of mean look you know crypto legislation is definitely focused on the aml uh financial crime side of things so uh we have the fifth money laundering directive which is uh the barometer of which uh that the fca and other other regulators across the eu are allowing firms to be registered and so as i say we um we're one of the i think 10 12 whatever it is uh firms that have got through the fca's quite stringent process and we know that that is a more broader process than just literally looking at aml that's probably more you know for like a better word kind of uh e-money institution flight and and so with that kind of in mind they're looking at it from an aml perspective but for crypto firms um because we're you know from a gemo perspective we're also you know uh we're allowing onboarding and uh on ramping and off ramping uh with fiat uh it also means that we're kind of we're also part of the e-money institution license process so i think what kind of you know people kind of look at it from the perspective of crypto isn't regulated or blah blah blah but actually um crypto is kind of looked after from an aml perspective but there are so many other constituent parts that a firm that wants to do business in certain kind of uh certain kind of product sets they have to seek other sorts of regulations so as i say for us uh we are off on ramping and off rampings sort of holding a fiat so that means that we kind of fall into that emi uh process as well and likewise other firms have kind of gone down a um multilateral trading facility uh process as well so i think you know as the whole landscape kind of develops um it's going to be interesting to see how the legislation comes to kind of encapsulate all of those different areas and i know we've got mika coming down the road um for the european uh for the european entities and we'll have probably an equivalent um for the uk as well um that'll kind of look more on the uh more on the side of uh bringing it all in under one umbrella but at the moment we have a very you know it might look like the ferns are only been looked after from the five mld perspective but actually there's a whole bunch of different other parts of regulation that they have to consider as part of their process yeah excellent i mean mary beth you've got a you know a wealth of experience uh sort of you know globally i mean i'm how are you seeing you know the landscape from so i remember being on a panel in 2014 around this time of year in new york city and nobody on the panel could agree well you know what is it is it property is it income is it commodity security and i think we've come a bit past that in the u.s but we still don't have the clear regulation that you have in other parts of the world what really brought me into this to stay in the space i represented a company at around that time 2014 2015 that was almost put out of business by a u.s regulator and they were almost put out of business because they were not registered even though under the law they didn't have to register and this particular agency wanted to fit them into one of their boxes but they didn't fit and the agency basically just said we'll sign this you know consent order or else and so i spent the better part of a year uh educating the agency educating uh the the senate committee that oversaw the regulator and really just letting them know that we were not going to simply you know fold up the tents and go away and that if they wanted to litigate we would and i recognized that what we needed was a lot more clarity for our regulations in the u.

s and unfortunately i think other i mean maybe it's fortunate for the rest of the world that other countries have looked at this in a more holistic manner and they have created regulatory frameworks that really look at what is the asset what are you doing with the asset how do we clarify how do we classify this and then set some pretty clear regulations and i think the way they've been able to do that as cindy said in places like singapore in abu dhabi even in japan to a certain extent they sought input from the from the community and they put out some draft regulations and they asked people to comment on it and i think they came up with a lot better products because when you put industry together with regulators and it's an open conversation you can try to avoid those unintended consequences so i agree with i think what's been said there are different approaches uh you know in different parts of the world and those that have a singular uh regulator seem to be doing a better job at this point and in the us we still have a bit of a uh jump ball i guess with regard to who's going to have the the greater authority over regulating individual types of cryptocurrency let's come back to that in in a second question but i mean i'm i'm really interested to hear the panel's views about kind of where we're going so one of the one of the critiques about the you about the european system is that you've obviously got all the all the eu member states and the uk have have implemented now i think amld5 but different different states have taken a different approach and some some of them said a much higher bar than others so you've got sort of you know clusters of firms in let's say estonia which was one of the early early countries and there's and there's i think there's hundreds still hundreds of of crypto asset firms there as opposed to uk there's lots of people applied but there's only kind of 15 or so that have that have been granted somebody's there aren't there aren't any so i mean i mean what's i mean what's the future hold for for you know a more uniform dispersion of of crypto firms across across europe do you think yeah i think um i think that yes so uncertain there are jurisdictions with different sort of differences in terms of how rigorous right their their standards may be um but i think um i mean you know as as you know when we look at sort of kind of um different jurisdictions the the key is to i think to take a longer term view as well right you might be a lot quicker you know getting your registration getting up and running in a jurisdiction with less rigorous standards but kind of you know getting that registration in in a place like uk for example uh kind of sets the bar higher and um is kind of is a good signal i guess to the industry and and to customers or everybody else um that you know you're here to you know to to to work with the regulations to you know um protect consumers and whatever it may be um so i think for me it's it's more about i don't think there will be you know one i wish at one global uniform kind of you know standard or registration there will always be some differences maybe a bit more uniform with the eu with mica etc coming up um but at the end of the day there will always be some differences but kind of as a business the way we look at it is you know it would be quite short-sighted to just you know go in and do it just because it's quicker whereas you know going somewhere with maybe the bar might be higher um it sets you up for longer term success yeah i think that's i think that's that's true isn't it it's you know you you want a more sustainable industry i mean blair the one of the things that the fca are very excited about in the uk is is consumer protection yes i mean we've seen you know london buses you know covered in in in crypto adverts that then get taken off when yes they get rather unhappy i mean as an as a as a registered firm now i mean have you had any liaison with the fca about the consumer protection aspects and and the kind of the whole kind of financial promotion regime which is you know which is going to be coming into into force at some point next year yeah look and to take it back a step before i answer that uh well look we you know we're in constant liaison with all of our partners banking partners uh fca and all of that kind of good stuff and i think you know further on to cindy's point there you know about the uk kind of landscape and the in the higher bar i think you know we talk about gemini in particular gemini's founded on four kind of foundational pillars which are compliance licensing security and product and with all of that in mind you know and so every in every jurisdiction we go to we seek we have the seek permission not forgiveness and so um moving to kind of the the authorization process now and you kind of references you know there's 10 or 12 whatever it is now and there are i think there are 200 300 maybe firms that have gone through that process i don't necessarily see only 12 firms getting through and i know i kind of was flipping about start i don't see that necessarily it's indicative of something bad on the fca i think it's actually a point in which you know we're we're in this crypto landscape now it's um you know we're 12 odd years old in terms of you know from bitcoin's development you know firms need to get a little bit more serious about how they're engaging with the fca and what the and what regulators are expecting when they're um when they're looking to approve a firm and you know we've gone through that process we know what it's like with the trust license from the new york dfs and we've gone through you know a very lengthy process from the emi perspective and the crypto asset perspective from the fca and i think a lot of firms are now kind of understanding what it really takes to get a license you know the fco very clear you know license is a gift um and it's a privilege and you need to kind of work to get that and build that kind of trust with that in mind um on the other side of the fence you know you also have to work really hard to to retain it um and you know the fca is very good i think about making their expectations very clear and they go through it's a very long and protracted process when you go through that application process um but after the event it's kind of clear on you that you need to kind of you know work with the regulator but also do as much as you can to ensure that they don't have any concerns with you so you don't have supervision or um or any of those other kind of instruments coming after you effectively so from from our perspective um you know customer consumer protection is is a hallmark and a fundamental requirement for our for our business going forward so that's why we've invested so heavily in compliance uh and financial crime detection uh to make sure that we um you know that the way our customer win customers are coming into our platform that they're secured in the best way possible and um we've also very very very recently signed up for the take five to stop fraud campaign we're the first crypto uh nato firm to do that we're extremely proud and delighted to be part of that and i think this is one of the things that you know i talk about jim and i here but broadly in the crypto landscape we need to be conscious that crypto has a lot of great benefits and a lot of great components to it but there are definitely bad actors in that space and we have to be mindful that they're the ones that are eroding trust and eroding faith in crypto and and recognizing that our responsibility as a company in gemo we we kind of embrace that with education through cryptopedia and a variety other different things and you know it's important about educating people that aren't as well versed in the security and the other components of crypto so that they can come and enjoy it and not be you know and not have uh their investments taken from them or anything kind of negative in that format so it's a very long-winded way of saying consumer protection is a fundamental part of it's really important yeah no sounds good um mary beth from the kind of point of view of the the us in terms of the future i mean there are lots of regulators at state level and also federal level i mean is there any prospect of there ever being a kind of just one regulator for crypto or is that is that unlikely yeah unfortunately i think that's extremely unlikely and and we've been living with in the us the 50 state money transmission license system which requires you to get a license in every state that that requires one or or get a no action letter and this is really difficult when you are doing business within one country and you have to have 50 separate licenses to do business and up until recently you know a lot of the states didn't really have expertise in cryptocurrency and so they were trying to figure out whether the crypto companies even fit within the in the statute the dfs has been one of the more tough regulators in the u.s but one of the things you have to say about the dfs you know it was a rough start you know trying to get the first couple of companies through and get licensed but the goal that they have is actually not a bad one which is the consumer protection piece there are certain requirements that they have in place whether it's you know having certain assets that have to be held certain security measures that have to be demonstrated uh governance uh token uh approvals and they're they're trying to get it right and they are doing it in part i think because there isn't another federal regulator that's actually trying to look at at the whole piece uh in the u.s if if we're ever going to have a single regulator to regulate pieces of crypto it's going to have to come from congress and congress is going to have to say here's your piece occ here's your piece sec and here's your piece cftc because they're not going to settle it themselves and it really is going to take congressional action to do that and it's important that we have it in the u.s because for companies that are already there i think they're going to stay and and you know try to figure it out deal with the uncertainty but for companies who are not in the us i think they're going to look to other jurisdictions that have figured it out that have given a single uh you know monetary regulator and who have made some clear guidelines and one that is one that is open to answering questions and until that happens in the u.s i think we're going to see slower financial adoption because there's just too much uncertainty and if that happens the u.

s may lose out uh to some of the other countries uh who who really have worked hard to try to issue clear clear guidelines and clear regulation and keep an open door with the industry and if i if i may add i think you know sometimes the discussion kind of almost becomes like kind of regulation and consumer protection or innovation it's not really a either or question really you know you you can't have it all and that's really the sort of i guess the art and science of the regulation right um again we look at i think michael is a good example i'm not gonna you know claim that everything is is perfect it's very hard to do so uh but you can have a you know a holistic regulator framework which is done with you know partnership as as members with explaining in partnership with the industry with consultations taking into different considerations and really being open to being educated and understanding the different players and perspectives to have this you know holistic still holistic regulation that you know creates kind of the sets out the rules of the road which allows innovation to to happen still you know protects consumers and still you know allows the the companies to prosper uh we're trying to innovate and do something interesting and you know solve some of the real problems we have um in the world today yeah and i completely agree with that um maybe we can move on to um the issue of stable coins which is a is a you know an ever more important you know part of the crypto ecosystem i mean you've got also institutional issues stable coins which are you know crypto asset tokens right now you've got the the the you know thought about issue of of of kind of central bank issued issues currencies maybe you know the kind of eu one or i know the treasury in the uk have thought about it as well i mean i think the commission the central banker um in frankfurt has as well i mean how do we feel about about the the um equilibrium between you know the you know the circle coin you know the tethers of this world versus the prospect of of of central bank issued you know stable coins have you have you got any thoughts cindy on that yeah i i mean i think sort of kind of just i mean it's very hard to predict the future but look at kind of future you know stable coins and cbdc's and crypto and very various sources of digital assets or kind of where is it going and what it kind of almost like will look like you know i don't i'm i'm not i we don't particularly see the you know the digital currencies you know completely supplanting fiat i think it will be a world of a number of different digital assets and fiat sort of interplaying and coexisting for various different you know use cases and i think here the kind of the role of the policy and regulation is to again create that environment where it gives basically choice to consumers and the businesses to use whichever one is best for whatever they're doing while again you know still providing the the consumer protections so i think in a world like that what will increasingly gain more importance is interoperability essentially and that's one of the things we're you know heavily investing in that ripple is while um you know we have created a private version of our of the xrp ledger which allows uh sancho banks to kind of issue um cd cbdc's uh and manage them and we see that the sort of digital asset xrp to act as a bridge currency um to to allow this inter interoperability and liquidity across all sorts of these kind of let's say digital assets and fiat um across the world so i think yeah again i think the regulation policy should create that environment where all of these coexist and um give people people and businesses choice to use the right one for the right purpose and mary beth there's been a lot of focus certainly in terms of tether and more recently circle actually about you know really what what supports these um these assets um mean what's the us approach right now i mean i did see that there was a subpoena recently issued circle i'm not quite sure about what but there was a subpoena issued i i mean what's what's the u.s approach in terms of stable coins right now do you think yeah so in the u.s they're concerned about you know a couple of things first they want to know what is it you know what what are the assets that back the stablecoin and then once they get comfortable with that they want to make sure that the assets that back it are really there i think that stable coins are going to go to go the way of the entire you know crypto industry remember at the beginning everyone was afraid of it you know what is it it's it's just used by criminals there's no you know good reason to have cryptocurrency and the longer that we are here the the more responsible that the industry is you see some of these same players who now want to figure out how can they play how can they get on board and stable coins is you know perfect example they work you know and and they're great particularly in certain jurisdictions where it's it's hard you know to get the the financial banking rails to have these exchange uh and so i think that some of the same governments who didn't want to trust the stable coins i think we're going to see those governments coming coming forward and creating their own because they're seeing by example you know how well they really work and as long as they truly are backed and the um creator can show that that it's there then i i think that stable coins are are definitely here to stay and we're probably going to see a lot more of them and i mean you're in your money firm right gemini or any any money if i'm in the uk i mean one of the takeaways from the kind of beaker and the uk consultation was that step current issuers in the in uk and europe would probably need to be at a minimum have i have any money license and possibly even a banking license i mean what's what's generalized position on on on stairway issuance use well i mean gemini has a gemini dollar um so that's the out of the u.s i mean look i think the whole stable coin situation in the uk market in particular is still developing i think it wasn't all of that long ago that the um the fca kind of stated that um it was probable that a stable coin fitted under an e-money token and they listed a whole bunch of um different criteria that that would mean that it may fall into that category and they've since kind of retracted in it and it's still kind of in the subject of further discussion i think you know to the to the broader point um to both cindy and to to mary west point i think we definitely see a future um for both uh cbdc's and um company issued stable coins i think it's pretty clear that um you know there is there is value and there is interest out there there's no single coin that is um you know that is now dominant you know it's uh usdc has risen enormously since it's um since its inception uh general dollar has grown enormously and we're really proud about what that product looks like um and obviously tether and other ones uh have been around for a little bit longer um i think the the beauty of uh of stable coins such as gemini dollar and others is about the barrier to entry component about people that are in jurisdictions that are that are controlled by a fiscal policy that means that there there's an erosion of value in their in the traditional currencies so the you know the ability to utilize stable coins um such as general dollars such as usd such as whatever and you know that's you can understand why there is enormous value globally and with that in mind i think you know looking at the the fca will will develop their kind of their appetite on this further as they kind of bring in a more holistic um legislation that covers kind of more components of crypto than just um the 5 mld component and seeing whether they can segment or kind of shoehorn things into the e-money licenses or whatever else so um things that you know so gemini's approach is definitely that we see it all been able to marry and work together and we're definitely happy to kind of see how it develops and let consumers drive um you know the the future of stable coins great yeah excellent um we can carry on talking or we can um take some questions i don't know if anyone's got any questions that they'd like to ask and get the get the combined wisdom of this panel lots of lots of hands up excellent is there a mic somewhere knocking about great um let's start with sir hi um i have a question about the uh how regulation is going to impact the gaming industry as well so we we saw what happened with dfi uh having the world fight the world finance attract the attention of the regulators a lot and what is happening now with the gaming industry is that we're using the same technology where taking like a stacking protocol where you put some token in they get the token plus x you have the same thing in the gaming now so how do you think this will affect uh the gaming industry and if the regulator is going to see the similarities and say that also those technologies need to be regulated yeah i mean i think there are probably there are some equivalents between dfi and i i'm not intimately acquainted with with the example that you give but i mean yeah defies yeah underwear are becoming huge right i mean there's there's you know there's billions of dollars in all these protocols and and i'm not sure people really really really really know what to do about it i mean i've i've not really heard much from anyone about how they feel about d5 i mean has anybody here heard any any any definitive positions from any regulator anywhere about it well yeah they've been i mean the fat off has suggested that maybe the developers need to build in yeah you know to the protocol um i mean other than aml yeah sure you know i i think that um the industry probably has to come up with a solution not unlike the travel rule remember you know a couple years ago when you know fative came out and said everyone has to comply with this the industry's initial response is we can't possibly do it like it's not technically possible but over time when when companies have come together and you know tried to figure it out they've come up with good solutions which is the better approach to not have the regulators come in and set requirements that are just not achievable and to let the industry try to come up with some solutions and and i hope that that's what happens in in the device space because it's got you know limitless possibilities and and it should be allowed uh to you know to continue and to innovate and to you know address concerns without regulators you know squashing it yeah i think further to that i think there's two parts to your question there there's a defense part and then there's the gaming kind of component so we took the d5 part further to meribeth's comments there yeah it's a gemini it certainly acts as a as a gateway to d5 uh and we you know we could have embraced the space and i think you know what we're definitely seeing is you know more interested in the d5 providers working with us and i know there's you know people have a particular view on the economy there between uh centralized exchange like ourselves and the d5 space but we definitely see you know a balance here and we're really excited about the opportunities that d5 provides and and will continue to work in that space but um and and see how it kind of further develops but you know on the gaming side of things um understanding the legislative kind of viewpoints and the way that things have been developed uh from a you know on the e-money on the token side and on the the directive side um there there have definitely been occasions where um you know through dialogue with the regulators that there has been uh you know occasionally the gaming kind of component has been brought in under that umbrella without people understanding same with stored value cards or air miles or or whatever else and i think you know what we're definitely seeing is the regulators kind of talking about legislation and directives that are going to kind of capture more on the on the gaming side and i think i appreciate gaming in general and kind of certainly in the uk falls under the uk gaming commission um or you can gaming whatever it's called these days but i think um you know the fact of the matter is that it is getting some of that and some of the you know the game issued tokens and whatever else are getting closer and closer to to other tokens that have been kind of that have been regulated or overviewed by elsewhere so it is going to be interesting to see how it develops whether it stays standalone or whether it kind of eventually crosses into a path where it's all kind of under the same umbrella cool very good um gentle yes thanks um so you know i think cindy made the point earlier that it's it's obviously important to have a good interface between you know yourselves and then on the regulatory side they need sort of a good dialogue um my question is to what extent do you think there's an education gap or like an understanding gap between you know people like yourselves and then on the regulatory side you know mary beth said earlier you know the us they're trying to figure out what is a stable coin i know it's maybe slightly hyperbolic but you know we're now talking about regulating gaming d5 is there a huge gap between you know people the cutting edge and the regulatory side and if so what's the most pragmatic uh way to close that so you actually get some something good from them yeah come on send me a kickoff yep yeah sure so look let's look at the so to answer that on one component um you know the fca did a uh a bit of research about let's say six months ago uh and they claim about two million people in the uk hold crypto um at any one stage either now or have so that leaves what's the uk population at 70 odd million so that's you know 68 million people who either have no interest in crypto or are nervous or you know or they sit wherever they sit um so using that as a percentile um you know think about the fca is a very large you know looking at the fda in particular um it's a very large organization and i think it's fair to say that the level of understanding in the regulator will vary enormously and so their crypto policy team their crypto authorizations team they'll have a very strong understanding of crypto but you know there's a lot of other teams in that space in terms of you know people are looking at marketing and financial promotions um they're looking at supervision um so you know to your point um certainly looking with the uk lens i think you know the fca and regulators in general are representative of society i think it's really important that we kind of you know stand up accept that we've got a responsibility uh to you know to help them and to make to help them understand it because we're at the cutting edge of all of this and we're the ones kind of developing new products and new services and all of that good stuff and they're the ones that are kind of you know reacting to it and so and so to your point 100 we have a responsibility to educate in the in the clearest safest and best way possible to make it inclusive you know and that's the thing that's what that's what we're that i'm really passionate about is making crypto available to everybody and um and making it understood by everybody and if the more we focus on that as a key objective the easier it will be for people to understand what the future case sets yeah i want to agree with that i i think the regulators are trying to catch up but think about what happens you have regulators who who get it and then they go out and they join one of you you know and so that that knowledge doesn't always stay you know with the regulator so we we have to keep in mind that you know just because we went into the lab last year it might be a whole new crew this year and so you just have to keep going back and showing them you know what is possible so because they really need to understand you know how cool this innovation is and and and want to to learn more about it and so it's unfortunately you just have to keep doing it and in the us so many of the regulators are creating or have created you know the fin hubs where they invite people in and i think this is happening in other parts of the world too yeah i agree certainly i think there's a gap but that is also not um anyway surprising or unexpected it happens i think with all the sort of new emerging technologies happening right it's always sort of regulation catches up once it's big enough you know what has changed in the last you know 18 months two years right like crypto became a two trillion dollar asset class right and all of a sudden there's a realization that it's not just the fad it's not something just for criminals like it's here to stay it's a new technology and it will underpin the new the economic the financial economic system so i think with that realization and institutional investors coming in etc time regulators kind of start stepping a bit i'm not saying they were interested in before but again there's also a big variation i think across the world you know how open interested how you know how many years ago they started looking at it as a huge variation um and i think to you know to the point that meredith and blair it is a continuous education i think it's not so much about is there a gap i think it's more about what is the approach and the attitude right i i think we as an industry have to be very proactive and and educating and also listening understanding concerns but also the same from the regulator side and i think that's why those public private sort of partnerships and consultations and engaging in all of those are extremely important to close that gap because it's not something you can just you know switch off it has to be an ongoing process and we see again you know ripple is you know we say acquired in the us we have global operations nine offices around the world a ton of our customers are in europe and asia we see that you know differences across regulators every day thank you for that uh question you sir mike or you can just speak loudly so if you've got legal entities you've got software protocol company dow structure and an asset management treasury operation what countries would you stick them in and why i'm not i'm not sure i'm supposed to be offering legal advice sir uh it's kind of interesting i mean is there any countries you'd say steer away because it sounds like pretty negative on the us i i'm not going to engage in in in recommending jurisdictions i mean i would i would i'd urge you to ask legal advice that's what the pacemaker is do anything unless anyone wants to wants to uh i'm drinking yeah [Laughter] not the cayman next hi uh this question is for blair so once gemini is i mean it's fc regulated what is the impact it brings to the traders or the investors um in tokens on your platform the other question is for new coins or tokens to be listed on your network what is the impact do they have to go through extra process or they can't uh does it allow non-uk residents not to invest in those tokens on your platform um well look gemini is a global platform so um so there are certainly some coins that um yeah if we look at it we'll leave there are some coins that are that are in the us but not necessarily here like for example we don't we don't offer z cash in this uh in in the uk um i think and you know i won't necessarily get into the whole um the way we evaluate the coins that go onto our platform but you know it's reasonable to say that there is a different kind of level of criteria and process that goes through our evaluation process then for example some other exchanges that have a lot more coins than us um but at the same time we still you know when i joined the gemini we had six seven eight coins and now i think we're somewhere between 30 and 50. so it's it's you know it's developed enormously and we've kind of moved away from um derivatives of the uh of bitcoin or forks of bitcoin to a much more um erc 20 tokens d5 tokens or all that kind of good stuff so um so in the way that we evaluate our tokens is very much kind of in line with uh what our regulators for the new york dfs require of us what the requirements are for the uh for the fca as well so yeah there's there's a whole lot that goes into that and i won't gonna get into all of that um but anybody that comes on to our platform and wants to you know to put money into a you know to buy a token or whatever they they can do that in whatever we offer now in the different countries that we're in so for the uk as i said we've got an enormous list of coins and i would encourage you all to download the gemini app right now and to feel free to cut yeah but but also it's just um you know our platform is the same wherever you are in the world wherever we can offer those services in the world if there's just certain coins that are available and some of that one more question i need to have one more question i'm going to uh you sir sorry sorry guys hi can you comment on the sec coinbase argument over stable coins and lending and how that's a security that might have to be mary beth i'm afraid you know i think that coinbase has been trying uh to work with the sec two years ago they helped organize a group of industry leaders to form the crypto rating council which put together a framework based on the supreme court howie test and other guidance by the supreme court and i'm sorry by the sec and try to come up with ratings from zero to five to uh you know zero obviously being farthest from a security five being a security and the sec hasn't adopted that and they still um you know want companies to apply their own guidance and try to determine on on their own whether something is a security or not i feel like i'm not answering your question so uh i think i think uh um we're supposed to be finished at quarter two there's supposed to be a little clock which is kicking down but it's not working so are we done one minute one more question um someone from the back uh you sir there um gentlemen no no more i'm done sorry we're done one minute we're over guys thank you so much for listening to this um session