GFMA welcomes the work of the Financial Stability Board (FSB) finalizing its global regulatory framework for crypto– and digital-asset activities, which promotes a comprehensive and internationally consistent regulatory and supervisory approach. This provides a strong basis for ensuring that crypto-asset activities and global stablecoins are subject to regulation that is commensurate to the risks they pose while supporting responsible innovations brought by the technological enhancements.
 
However, GFMA would reiterate that it is critical to keep sight of the differences between digital/crypto-assets (products), how these digital/crypto-assets are used (activities/services), and the distributed ledger technologies (DLT) underpinning them (infrastructure), as well as key differences within each of these categories.
 
While the functions and activities set out by the FSB are comprehensive, a critical distinction must be made between digital assets, cryptocurrencies, and tokenised assets, as well as the underlying DLT and blockchain infrastructure (e.g., private permissioned chains and other emerging solutions), which may differ in use across functions and activities, depending on the design choice.
 
The spectrum of digital assets, DLT and blockchain infrastructure encompasses risk-creating assets, but also risk-reducing permissioned processes that can mitigate key concerns, such as settlement risks. It is critical for policy makers to be mindful of these differences and not overgeneralize as to all manifestations of the underlying technology.
 
Read the GFMA’s response to the December consultation on these policy recommendations, which emphasized the importance of the principle of ‘same activity, same risk, same regulatory outcome’.

– 17 July 2023 –