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Solving the KYC & AML challenge for cryptocurrencies, tokens & ICOs Whitepaper commissioned by www.regtechinsight.com @RegTechInsight Search RegTech Insight

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Page 1: Solving the KYC & AML challenge for cryptocurrencies ... · startups, private blockchain networks, currency pegged tokens and other derived instruments. There have been many statements

Solving the KYC & AML challenge for cryptocurrencies, tokens & ICOs

Whitepaper

commissioned by

www.regtechinsight.com

@RegTechInsight

Search RegTech Insight

Page 2: Solving the KYC & AML challenge for cryptocurrencies ... · startups, private blockchain networks, currency pegged tokens and other derived instruments. There have been many statements

Solving the KYC Challenge for CrYptoCurrenCieS

2www.regtechinsight.com www.fenergo.com

The cryptocurrency market is at an inflection point. It has gained substantial momentum from early investors (private & retail), day traders and prop shops but it has failed to get substantive engagement from wider institutional players. Given JPMorgan's recent currency pegged token creation namely 'JPM coin' this may be about to change.

IntroductIon

Many observers believe that once institutional comfort levels tip toward the positive, crypto markets will start to be accepted more widely and perhaps viewed as another asset class alongside equities, fixed income, foreign exchange and commodities, with its own derivative securities to boot.

But what will it take to reach this tipping point? Does the arrival of JPM Coin & its associated private network, mark the start of a new departure.

The crypto marketplace today is a mix of exchange and OTC-traded activity with little of the market infrastructure that institutional players rely on in other asset markets. There are many types of cryptocurrency, each with its own characteristics. These are traded on many exchanges, each with its own trading rules. There is little in the way of risk protections; no custodians, little to no regulation, and – crucially – few protections around the identity of clients and counterparties: no KYC in many cases.

A Fenergo poll of 400 industry practitioners found that only 8% of respondents considered existing KYC / AML checks in cryptocurrency markets to be effective, with 40% describing them as ineffective. A majority of respondents said existing provisions failed to protect both investors and institutional practitioners. They identified weak regulation and lax enforcement of those regulations as the key factors in the lack of KYC / AML protections. In conclusion, one-third of respondents said a migration of institutional market structures to the crypto markets is what’s needed to address the challenge.

As a result of the lack of transparency around who is issuing crypto, who is buying and

selling, and their sources of funding, the wider crypto marketplace often gets a bad rap that is deterring institutional participation. Cryptocurrencies, ICOs and crypto exchanges are often perceived as a hot bed for fraudsters, money launderers and other unsavoury characters. Addressing this perception, and fixing the transparency issues around crypto, could unleash crypto as a legitimate asset class unlocking its potential to transform modern banking and finance across the globe.

What practical steps do financial services industry participants – and the authorities that regulate them – need to take to address crypto’s transparency issues in order to transform perceptions and bring it into the institutional mainstream?

Grassroots efforts are already afoot to put in place key market facilities that may ease institutions’ concerns about full-scale participation in cryptocurrency markets. This paper assesses the current state of play, and the infrastructure now in place to support it. It discusses ongoing initiatives to lend credence to the burgeoning cryptocurrency market. And it suggests steps that can be taken to regulate, de-risk and decriminalise the crypto space by addressing its current KYC and AML challenges.

"The crypto marketplace today is a mix of exchange- and OTC-traded activity with little of the market infrastructure that institutional players rely on in other asset markets."

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SOLvInG The KYC ChALLenGe FOr CrYPTOCurrenCIeS

Institutional players like JPMorgan see opportunities in cryptocurrencies as a new asset class, and one that has the potential to yield signifi cant profi ts. The ability to trade crypto anywhere at any time, its support of micro-transactions and its easy transfer between trading entities, including across borders, yields a kind of ubiquity that fi nancial institutions have recognised as valuable. Less philosophically, as one cryptocurrency market participant puts it, the ‘old world’ of global capital markets has noticed that the ‘new world’ of cryptocurrency markets are making vast profi ts and wants a piece of the action.

The old FIAT world has manifested itself so far in the emergence of 'investment grade' exchange startups, private blockchain networks, currency pegged tokens and other derived instruments. There have been many statements of intent from players like Blackrock, Morgan Stanley, Goldman Sachs and a myriad of other fi rms but little sign of adoption.

These organisations are now assessing the cryptocurrency ecosystem to identify opportunities. As they delve into the marketplace, they are discovering a mix of coins (Bitcoin, ethereum et al), initial currency offerings (ICOs) issued by corporate entities to raise capital and often characterized as ‘utility tokens’, securitized token offerings (STOs) that take a form not dissimilar to asset-backed securities, and a range of so-called digital assets that are often free-form in nature.

Cryptocurrency and related instruments are typically launched and traded on exchanges similar to other listed securities. But most cryptocurrency exchanges have no standardized

Today's Cryptocurrency Landscape

function, and each has its own set of rules, conventions and nuanced business models. Given that there may be more than 200 exchanges already in existence in the crypto space, getting a clear view of the exchange landscape is diffi cult, if not impossible.

While there are clear market leaders – the likes of Coinbase, Gemini and Binance have enjoyed a degree of fi rst-mover advantage – new exchanges, including some aimed directly at the institutional marketplace, are emerging almost weekly, adding to the general complexity. Like traditional exchanges, these cryptocurrency marketplaces each bring their own access technologies, market data and related trading services and facilities, including – to a greater or lesser extent – Know Your Counterparty (KYC) checks.

Crypto also enjoys a robust secondary market. This is typically traded by phone, email or Skype or other IM. Where exchanges offer trading in cryptocurrency and fi at (traditional) currencies, they play an additional role as fi at on-ramps, allowing traders to exchange their fi at currencies for crypto – often under some or other level of KYC due diligence, depending on the particular

"Given that there may be more than 200 exchanges already in existence in the crypto space, getting a clear view of the exchange landscape is diffi cult, if not impossible."

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“People are building SOR (smart order router) tools to address this kind of stuff, and calculating TCA (transaction cost analysis) vs. price. They want to know: Where can I buy this instrument and make money on an arbitrage play? There is a cap at the moment on coins out there, and it will be interesting to see how the big Wall Street firms will use these kind of tools, and whether they look to CFDs (contracts for difference) and other derivatives to trade the underlying without the headache of doing it directly. That can take on a life of its own.”

The pace of change – with new coins, ICOs, STOs and other digital assets, as well as cryptocurrency exchanges themselves being launched almost weekly – makes for a complex environment.

Now with JPMorgan establishing a private blockchain network, issuing their own currency pegged crypto token which they aim to use to: settle payments between their clients and themselves; facilitate cross border payments and debt issuance could see further transformation take place across the sector.

exchange – but then move into other currency types or derivative instruments with little, if any KYC or other form of checking. Perhaps the entrance of JPMorgan is an extension of this pattern.

In short, the public cryptocurrency market is a multifaceted one. It is characterized by a high degree of volatility, with relatively easy entry and exit points. Market practitioners draw parallels with the emergence of ECNs in the US equity markets of the 1990s, with the 2010s Chicago derivatives markets and the early days of spot FX. And therein lies the appeal.

“If we take out the illicits, then we’re left with a lot of speculators in the market,” says Emilio Mercado, Chief Operating Officer at emerging crypto prime broker True Trade. “It’s a lot like the early days of ECNs: you can see arbitrage opportunities, across difference in price, depth of book across exchanges. And so it becomes: what’s the cost of transaction? Can you get in and out?

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Solving the KYC Challenge for CrYptoCurrenCieS

Why Most Institutional Players Have Cold Feet

characterises crypto markets heightens the risk of regulatory censure, threats to banking licenses and other serious problems.

“There have been a lot of AML censures and fines, even within the traditional marketplace, which demonstrates that this is not easy,” said David DeLeon, Senior Manager within accenture’s Finance and Risk practice. “Most large firms have had some kind of issue. Crypto is playing catch-up.”

indeed, the fenergo poll of institutional market participants found that less than 5% of respondents considered existing cryptocurrency KYC and aMl processes to be effective, with 40% describing them as ineffective. More than 45% found existing processes failed to offer adequate protections for private investors with 40% agreeing that there were inadequate protections for institutional market practitioners.

furthermore 57% of respondents said that they noted a clear lack of regulatory obligation to verify counterparties & 27% said that existing counterparty iD processes were lax. one respondent said "any client, whether institutional or retail, should be verified against a global policy and procedural onboarding standards within a customer identification programme. Weaknesses remain within custody services for holding digital assets, regulatory oversight within the myriad exchanges that offer entry into this marketplace, and overall security issues surrounding safe and sound practices against nefarious actors putting investors’ assets at risk of being hacked.”

understanding this wide-ranging and rapidly changing sector is a significant challenge. the level of change, in addition to a lack of transparency and KYC controls has contributed to institutional reticence.

Since their inception, cryptocurrency markets have been beset by bad publicity, with new examples of fraudulent activity coming to light seemingly every week. often, the incidents relate to cybersecurity, with many instances of hacking into exchange systems and digital wallets leading to the theft of large sums of cryptocurrency. But perhaps more worrying for institutions have been the examples involving KYC and aMl, where market participants have eluded usual identification processes thereby enabling other types of fraud and theft.

this has resulted in censure and other measures by regulators. for example, earlier this year crypto exchange Coinbase was forced to comply with a court order to hand over details on some 13,000 customers to the uS tax authorities, some of whom the internal revenue Service (irS) suspected of evading cryptocurrency taxes.

Controls Found Lacking

although hotly debated, many fear of the lack of robust and consistent controls with respect to Know Your Customer/Counterparty (KYC) and anti-Money laundering (aMl) is a major barrier to institutional embrace of cryptocurrency markets. given the challenges presented by KYC / AML in traditional market segments, firms of all types ultimately fear that the lax approach that

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SOLvInG The KYC ChALLenGe FOr CrYPTOCurrenCIeS

Pan-Jurisdictional Inconsistency

Part of the issue surrounding regulatory oversight relates to inconsistency across jurisdictions. According to Laura Glynn, Director, Global regulatory Compliance at Fenergo, “There isn’t truly a global standard, so there are differing approaches.”

Some are taking a ‘do no harm’ approach – by letting cryptocurrency start and flourish while waiting to see what others do. Other jurisdictions are outlawing and banning cryptocurrency exchanges altogether, China being the most extreme example.

There is substantial variation in terms of how regulators are viewing crypto / digital currencies. Are they currencies? Are they assets? Are they property? Some countries, like Australia, have determined that they should be subject to tax regulations: there, cryptocurrency doesn’t fall into the definition of a financial instrument and therefore is being treated as a property subject to tax.

In the uS, there is IrS guidance going back several years, but how cryptocurrency is viewed remains an area of contention, particularly whether crypto qualifies as a security, and while the SeC has made some statements in this regard the marketplace is awaiting further clarity. Specific discussions have revolved around whether various incarnations of cryptocurrency should be subject to uS rules relating to private placements, securities or sovereign currencies.

In short, there is no standard view on how to categorise cryptocurrency. regulation is handled on a per-jurisdiction basis. Where Japan regulates crypto as it does traditional instruments, other jurisdictions like Malta, Singapore and Switzerland are far less stringent, making the global crypto market open to regulatory arbitrage.

Against this backdrop of regulatory inconsistency, financial crime fighters are also hindered by the

absence of the ‘follow the money’ techniques available to them in traditional markets. Crypto’s core structure – based on the use of blockchain /distributed ledger technology (DLT) – guarantees a high degree of anonymity.

As such, regulators are unable to monitor transactions for patterns of behaviour that may signal suspicious activity. This places more emphasis on KYC and the use of client screening, sanctions monitoring, and identification of beneficial ownership and politically exposed persons (PePs). But many ‘anti-establishment’ protagonists, often early adopters, consider KYC anathema to the entire crypto project – “KYC has no place in crypto,” said one such practitioner interviewed for this report. With KYC / AML a major challenge even in traditional markets, crypto’s characteristics add a layer of complication that makes it harder still. Different crypto products are subject to different levels of KYC check.

While there are no hard-and-fast rules, the following table provides a basic rule of thumb with respect to how KYC checks are currently applied:

This mixed bag of product and associated KYC processes – along with broader regulatory inconsistency – has been a major factor in precluding the wholesale entrance in crypto markets by institutional trading firms.

Crypto type KYC Process

Fiat-to-crypto Basic KYC checks

Peer-to-peer crypto Few/no KYC checks

ICOs/utility tokens Few/no KYC checks

STOs Basic KYC checks

eTFs Stringent KYC checks pending

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The Drive Toward Mainstream Acceptance

Obstacles to institutional acceptance remain in the form of inconsistency of KYC across different products, the lack of a standard regulatory stance across jurisdictions and general reticence about the perceived moral character of a significant tranche of crypto early adopters.

“With respect to KYC, the issue is institutional to retail,” says true trade’s Mercado. “A traditional crypto investor often has secrets and so he wants to retain the purity of the market. But now the IrS has made Coinbase reveal records of clients’ trading accounts and it appears to be stamping out money-laundering and tax evasion. To be safe, players need standard KYC/AML checks, and the marketplace seems to be saying ‘If we apply the rules as appropriate, we should be okay with regulators.”

According to the Fenergo survey, market practitioners believe increased regulation may provide the required level of comfort. What’s less clear, though, is which players and processes should be regulated. The survey found that 31% of respondents believed greater regulatory oversight of crypto exchanges would address many of the challenges, while 24% said greater oversight of market practitioners was the answer. A further 21% called for the migration of institutional market structures to cryptocurrency markets to address these issues.

Standardisation was a common theme, with one respondent calling for “standardisation of various types of digital assets and clarity about the most commonly used forms” as well as “education of private investors and their protection in cases where ICO or cryptocurrency-related businesses

declare themselves ‘outside’ of the regulatory requirements.”

From the survey and wider interviews with practitioners it’s clear that firms are concerned that existing KYC processes are insufficient to insure them against regulatory censure. They fear severe repercussions, including in extreme cases loss of banking licenses in certain more stringent jurisdictions.

As a result, they are anxious to see greater and more robustly enforced regulation of cryptocurrency markets, and are looking at a series of current initiatives as the catalyst for a safer crypto trading environment. Indeed, many institutions are now assuming they will need to apply market accepted KYC/AML techniques to crypto in the wake of the forthcoming regulatory pronouncements if and when they come.

As these initiatives wend their way toward acceptance, the marketplace continues to make do with haphazard approaches: use of largely cursory and inconsistent checks for fiat-to-crypto transactions; pre-ICO institutional checks for institutions involved in utility tokens; traditional

"One notable advance has been the use of third-party fund administrators to provide the kind of custody services that have been missing in crypto."

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checks for STO participants; and exploration of the use of third-party custodians to perform client due diligence for new offerings of coins, tokens and other digital assets.

At the same time, the past six months has seen the emergence of a wave of so-called institutional-grade exchanges, some still at launch phase, that aim to address the broad range of concerns that’s making institutional trading firms reticent. One notable advance has been the use of third-party fund administrators to provide the kind of custody services that have been missing in crypto. under this arrangement, any prospective exchange member or user would be required to undergo KYC checks by an independent third party before getting approval to join.

elsewhere, several traditional exchanges – including the Swiss exchange and the Chicago Mercantile exchange (CMe) – have launched derivatives underpinned by cryptocurrencies, with the intention of applying mainstream market disciplines to the segment.

Perhaps with the usage of private DLT networks, used by players such as JPMorgan and the wider usage of DLT for KYC utility purposes we may see the platforms by which smart contracts are used to evolve further. equally we may see more players issue their own currencies and/or tokens like JPM Coin.

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As Accenture’s DeLeon points out, “There are still challenges in the transaction monitoring space but it’s a priority and it’s on the agenda. It’s just earlier on the maturity curve,” which is why much of the action in this space remains around AML and KYC.

he goes on: “Traditional financial institutions have spent years – perhaps the past five or 10 years – with most of the larger FIs spending enormous budget and time and resources building AML and KYC programmes, including Know Your Customer and risk scoring and monitoring. It’s quite a challenge because the rules are complex, it’s global in nature, and a traditional FI [also] has to worry about legacy technology and data infrastructure, and in many cases that infrastructure is quite outdated.”

So, will these firms be able to leverage their investment to date in order to protect themselves in cryptocurrency markets? Many institutions hope so, and some are planning on the basis of a more rigorous regulatory stance going forward.

A number of current regulatory initiatives may shine a light on what future KYC/AML checks could look like in the cryptocurrency environment. The uS Financial Crime enforcement network (FinCen), a uS agency that offers guidance to crypto administrators and exchanges on bank secrecy requirements, has been working to add language to aid in coordinating efforts and exchange information with other enforcement agencies around the world.

FinCen has been emphasizing the importance of suspicious activity reports and its guidance has led to the inclusion of new requirements

relating to cryptocurrencies in the forthcoming fifth eu AML Directive, due to come into force in 2020. Meanwhile, the Financial Action Task Force (FATF), a uS agency whose guidance has often formed the basis for AML/KYC regulatory language in the uS, europe and elsewhere, plans to report to the G20 on its analysis of crypto market regulation this autumn.

More widely, other regulators around the world are turning their attention to the cryptocurrency markets. In the Asia/Pacific region, for example, the Securities and exchange Board of India (SeBI) has launched a fact-finding mission to understand how crypto is being adopted in other countries, Australia is already seen as one of the most heavily regulated jurisdictions, while China has banned crypto exchanges and ICOs altogether (though the resultant exodus of market participants may yet force a regulatory rethink there).

According to deLeon, these actions by FinCen and others have led to “some of the more crypto established players introducing compliance and AML programs - hiring chief compliance officers, hiring AML officers, establishing formal programs, putting in place processes around KYC and client screening.”

What Future KYC/AML Regulation May Look Like

"Many market participants, though, are closely monitoring the progress of the CBOE’s ongoing Bitcoin ETF application, which some believe may emerge as a benchmark for crypto KYC / AML regulation."

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CBOE’s Bitcoin EtF Application as Benchmark

Many market participants are closely monitoring the CBOe's varying eTF applications. Although they formally withdrew their application due to a uS government shutdown, they are very likely to re-submit. Should they or another exchange secure regulatory approval for an eTF then the market may transform rapidly.

Although their application is based on uS legislation, the CBOe application was expected to have wider ramifications on the basis of FinCen’s assertion that any third-party platform that intended to facilitate the purchasing or selling of cryptocurrency in exchange for fiat currency (such as uS dollars) must be treated in the same light as a Money Service Business, defined as an entity that transmits or converts money (although cryptocurrencies such as Bitcoin fall within this scope). As a result, entities must employ the same AML and KYC controls as detailed under the uS Bank Secrecy Act, as well as ensure they remain fully compliant with FinCen regulations.

The application stated that the majority of its trading would have been conducted on an OTC (over the counter) basis. This means that transactions can be agreed in a peer-to-peer manner, with volumes and spot prices to be negotiated between the two transacting parties (for example over the phone or Skype). Outside out this, the CBOe planned to transact with counterparties that operate as a cryptocurrency exchange – however, these volumes will be much smaller.

The identified exchanges from within the application are:

• GDAX/Coinbase

• Bitstamp

• Gemini

• itBit

• bitFlyer

• Kraken

All the above exchanges currently facilitate fiat currency deposit and withdrawal facilities and they all have AML/KYC procedures in place. however, their underlying framework is not suitable for large scale injections of capital, notably because of a lack of security and/or institutional-style custodianship.

It’s important to note that all counterparties mentioned in the application are uS-based. regarding the OTC entities, the application also states that all parties are well established and includes organizations that are regulated by the SeC and the Financial Industry regulatory Authority (FInrA) as registered broker-dealers (or affiliates of broker-dealers). This implies that the platform will deal with counterparties who – although are well established – are not currently regulated by the aforementioned agencies.

The CBOe made it clear that all chosen counterparties are registered with FinCen as a Money Service Business with respect to their AML / KYC obligations, which ultimately means there will be a ready-made framework – backed by stringent domestic legislation. The application also mentioned that potential counterparties will be subject to the CBOe’s AML / KYC procedures – all of which are currently in place. The CBOe previously released a circular to all its trading permit holders, detailing its expectations regarding AML and KYC compliance, as well as ongoing filing requirements. These expectations mirror the regulatory demands of FinCen.

CBOE’s Bitcoin EtF Application: the take-Aways

Given the institutional interest on an exchange traded fund application, what are the key take-aways from CBOes former application?

"Although banks do not fall under the remit of a Money Service Business, they are still covered by the Bank Secrecy Act, which is essentially the primary AML framework in the US."

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Firstly, it appears that the only aspects of the application backed by a set of pre-defined regulatory controls and measures relate to AML obligations. For example, OTC and third-party exchange entities – referred to in the application as counterparties – are subject only to the application’s AML / KYC provisions.

This may reflect the SeC’s earlier eTF application rejections, which expressed no concerns with applicants’ treatment of AML / KYC but focused instead on the operator’s inability to satisfy the regulator that it could effectively detect and prevent market manipulation in the same manner as traditional commodity markets.

Secondly, all proposed counterparties envisaged by the CBOe are currently registered as Money Service Businesses. under this designation, regulatory compliance demands the submission of suspicious activity reports (SArs); transactional reporting and storage of records; internal AML controls, policies, procedures and safeguards; and appropriate personnel training.

Although banks do not fall under the remit of a Money Service Business, they are still covered by the Bank Secrecy Act, which is essentially the primary AML framework in the uS. Furthermore, entities that are already regulated by the SeC or the Commodity Futures Trading Commission (CFTC) are not classed as Money Service Businesses. however, once again these are also covered by the Bank Secrecy Act with respect to

their AML / KYC obligations. In other words, the CBOe application extends to all potential parties covered by the uS Bank Secrecy Act.

It is also worth considering the long-standing reputation of the CBOe. Compared with other rejected applicants, the CBOe is a well-established trading venue, arguably the largest uS options exchange in terms of volume, that has been operational for more than 45 years; its founding entity – the Chicago Board of Trade – has been in operation since 1848. By contrast, the Winklevoss Brothers-backed Gemini, with two SeC eTF rejections under its belt, was launched in 2014 and clocks up significantly lower trading volumes than the CBOe.

In December 2017 the CBOe became the world’s first platform to facilitate Bitcoin futures at an institutional level, receiving the full green light from the SeC. This indicates that the CBOe has the required underlying framework to at least satisfy the demands of the SeC, which almost certainly contains the AML / KYC procedures outlined in the CBOe’s eTF application.

Its clear that the CBOes application has many lessons for other exchanges around the world. Time was taken to map put many of the KYC, AML and transparency requirements needed to meet the needs of institutional players. unlike private networks this application could have delivered a commonly available eTF.

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As Conor Coughlan, Chief Marketing Offi cer & RegTech Infl uencer at Fenergo, concludes: After conducting this market research it is clear that a lot more has to be done if the non private (openly traded) cryptocurrency market is to mature and become a viable option for institutional players and other regulated investment entities.

Overall we have noted four shared challenges that need to be addressed and they are:

1. a lack of transparency when it comes to who market players truly are,

2. a form of central clearing counterparty or new form of insurer,

3. suitable market supervision or regulation, and

4. stable and secure places to exchange currencies (infrastructure).

"Many crypto market players have stated openly that they do not see the need for any form of obligated transparency or KYC & AML controls or processes." This is often stated on the basis that this new sector does not need to adhere to the requirements of the 'old FIAT' world.

It is clear that many retail investors (and other players) have suffered badly from a lack of suitable regulatory obligations & market mechanisms being in place and that the open market won't mature without the aforementioned four challenges being addressed.

JPMorgan's deployment of a private DLT network & issuance of a currency pegged crypto token is a step forward for institutional players. However it's usefulness is currently limited to approved network participants. The ultimate value of a 'JPM Coin' is open for debate. What's clear is that this sector is evolving rapidly and unforeseen opportunities are now starting to arise.

Notwithstanding the extreme levels of market volatility, the institutional markets appetite for cryptocurrencies is growing. JPMorgan's recent private token issuance is likely to stimulate increased interest. However until more formal KYC & AML regulatory frameworks are put into place, it is unlikely we will see a mass adoption of publicly traded currencies or related tokens.

CONCLUSION

ON DEMAND WEBINAR, VIDEO & BLOG

KYC, AML & Transparency for Cryptocurrencies & ICOs.

Can you truly regulate cryptocurrencies and ICOS? Read this linkedin pulse to learn more: https://www.linkedin.com/pulse/can-you-truly-regulate-cryptocurrencies-icos-conor-coughlan/ Can you truly regulate cryptocurrencies and ICOS? Read this linkedin pulse to learn more: https://www.linkedin.com/pulse/can-you-truly-regulate-cryptocurrencies-icos-conor-coughlan/

If you would like to watch a recent on demand webinar based on this reports topic. Simply click on this link and you will learn what speakers from Fenergo, Accenture & Invyo shared.

https://www.fenergo.com/resources/webinars/kyc-aml-transparency-for-cryptocurrencies-icos.html

KYC, AML & Transparency for Cryptocurrencies & ICOs

If you would like to watch a recent video interview about this topic please click here: https://www.youtube.com/watch?v=PXrgtFia3Ro

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For more information on Fenergo, visit www.fenergo.com andcheck out our latest whitepapers and client case studies.

Alternatively, please email us at [email protected].

www.fenergo.com [email protected]

Fenergo is the digital enabler of client and regulatory technology for financial services. It provides Client Lifecycle Management (CLM) software solutions for Financial Institutions including; Corporate & Institutional Banking, Commercial & retail Banking, Asset Management, Private Banking & Wealth Management. Counting 70 global Financial Institutions as clients, its award-winning CLM suite transforms how Financial Institutions manage clients; from initial onboarding to KYC / AML and regulatory compliance, to client data management and ongoing lifecycle KYC reviews and refreshes. Fenergo CLM empowers financial institutions to deliver a faster, more efficient and compliant client experience and achieve a single client view across channels, products, business lines and jurisdictions.

Fenergo’s community-based approach to product development allows clients to collaborate on solution design on a global scale. Its rules-driven solution ensures compliance with multiple global and local regulatory frameworks including AML, KYC, Tax (CrS, FATCA, 871M), OTC Derivatives (eMIr, Dodd-Frank, MiFID II, Margin requirements) and data privacy rules (GDPr). It supports the collection, centralization and sharing of client and counterparty data and documentation across the institution and deploys an API-first approach to advanced integration with a host of external KYC, AML and entity data providers, KYC and industry utilities. The solution is underpinned by next generation Artificial Intelligence, robotics Process Automation and Machine Learning technologies, using advanced OCr and nLP capabilities to extract information, expedite compliance and improve operational efficiencies.

ABOut FEnErGO

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ClientCommunity3

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Future-Proofed5

Fenergo invests heavily in building internal expertise and proactively brings recommended solutions to the table though our team of regulatory experts and with legal and regulatory support.

The product and regulatory roadmap of Fenergo deliverables are directed and validated by our clients through monthly regulatory and design forums.

The product solutions are reviewed and refined with a community of experts to ensure they

meet our clients requirements, leveraging the legal, regulatory, tax and operational expertise

across more than 30 financial institutions.

We focus solely on the delivery of CLM product solutions to the financial industry so every cent of r&D goes into improving the product we provide for our clients.

We are committed to providing future-proofed product solutions for new and changing

regulation as part of our regulatory update package.

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A-Team Group helps financial technology vendors and consultants – large and small – to grow their businesses with content marketing. We leverage our deep industry knowledge, ability to generate high quality media across digital, print and live platforms, and our industry-leading database of contacts to deliver results for our clients. For more information visit www.a-teamgroup.com

A-Team Group’s content platform is A-Team Insight, encompassing our regTech Insight, Data Management Insight and TradingTech Insight channels.

A-Team Insight is your single destination for in-depth knowledge and resources across all aspects of regulation, enterprise data management and trading technology in financial markets. It brings together our expertise across our well-established brands, it includes:

regTech Insight focuses on how data, technology and processes at financial institutions are impacted by regulations. www.regtechinsight.com

Data Management Insight delivers insight into how financial institutions are working to best manage data quality across the enterprise. www.datamanagementinsight.com

TradingTech Insight keeps you up to speed with the dynamic world of front office trading technology and market data. www.tradingtechinsight.com

You can tailor your experience by filtering our content based on the topics you are specifically interested in, across our range of blogs with expert opinions from our editors, in-depth white papers, supplements and handbooks, and interactive webinars, and you can join us in person at our range of A-Team Summits and briefings. visit www.a-teaminsight.com

Become an A-Team Insight member – it’s free! visit: www.a-teaminsight.com/membership.

ABOut A-tEAM GrOuP

www.regtechinsight.com www.fenergo.com