GFMA submitted a response to the International Organization of Securities Commissions (IOSCO) Crypto and Digital Asset Recommendations consultation (May 2023). The response was prepared with the support of legal counsel from Sullivan and Cromwell.
The response includes six foundational pillars for consideration when finalizing the Recommendations:
Pillar I: Provide Classification Approach Delineating the Types of Digital Assets Covered by Each of the Recommendations to Avoid Conflicts and Overlaps with Regulation of Traditional Financial Markets
Pillar II: Clarify the Scope of CASPs Covered by the Recommendations to Avoid Conflicts and Overlaps with Regulation of Traditional Financial Institutions
Pillar III: Tailor the Application of Its Recommendations to Account for the Capacity in Which a CASP Is Acting
Pillar IV: Tailor the Application of Its Recommendations Depending on Type of Client or Counterparty
Pillar V: Modify Its Recommendations to Account for Varying Market Structures
Pillar VI: Recognize the Need to Accomplish Settlement Finality and Legal Certainty Within the Different Circumstances of Applicable Network Structure
The response also provides detailed recommendations and proposed revisions in Annex A, as well as GFMAs Proposed Approach for the Classification and Understanding of Digital Assets as Annex B.
– 31 July 2023 –
