INSIGHT REPORT

GLOBAL STANDARDS
MAPPING INITIATIVE 2.0
NOVEMBER 2021
GLOBAL BLOCKCHAIN
BUSINESS COUNCIL

DC Location:
1629 K St. NW, Suite 300
Washington, DC 20006

Geneva Location:
20 Rue de-Candolle
1205 Geneva
TABLE OF CONTENTS

Section I: Introduction to GSMI 2.0 2

Section II: Taxonomy Introduction 5

Section III: DIgital & Crypto Assets

6
Regulations (DCAR)

Section IV: Policy 15

Section V: Digital ID 23

Section VI: Technical - Landscape Assessment

31
of Standards in Blockchain for Industry

Section VII: Green Economy 42

Section VIII: Global Taxation 52

Section IX: Derivatives 60

Section X: Country Spotlight: Korea 70

Section XI: Next Steps/GSMI 3.0 72

Section XII: Endnotes 74

Section XIII: Appendix 79

1
 SECTION I

INTRODUCTION TO GSMI 2.0

The Global Standards Mapping Initiative (GSMI) This report is dedicated to the findings,
is an industry-led effort to map and assess key insights, and action-oriented guidance
the blockchain and digital asset landscape proposed by each of the working groups.
across five key areas: GSMI 2.0 also includes a comprehensive
update of the blockchain and digital asset
1) legislation and regulatory guidance regulations contained in the interactive
2) technical standards map, a catalogue of accredited academic
3) industry standards and recommendations institutions offering blockchain courses and
4) university courses and degree programs degrees, and an update to the outputs of 38
5) industry consortia. technical standards.

GSMI reports and resources are open GSMI resources and reports are referenced
access and intended to serve as a baseline and utilized by corporations, regulators,
for the establishment of thoughtful and government agencies, and academics
workable frameworks and standards to globally who seek a holistic view of the
enable adoption and innovation. The Global blockchain and digital asset landscape.
Blockchain Business Council (GBBC) and GBBC collaborated with seven academic
partners released version 1.0 of the GSMI institutions to launch the GSMI Fellows
in October 2020 as an interactive map Program, an eight-month fellowship for
of regulation and guidance across 185 exceptional students to contribute to GSMI
jurisdictions, a legal and regulatory report, 2.0 research and analysis.
and a technical report cataloguing outputs
from more than 304 technical standard- This report and the accompanying GSMI
setting entities. 2.0 resources are made possible by the
contributions of our partners, fellows, and
In response to key insights and feedback GBBC staff. GSMI 2.0 is intended to serve as a
from the initial release, the GBBC has comprehensive resource for stakeholders in
partnered with 130 leading institutions the blockchain and digital asset space.
to release GSMI 2.0, an expansion and
continuation of GSMI 1.0. We welcome feedback and additional
contributions as we build upon this release
GSMI 2.0 was spearheaded by nine working and continue to update the datasets,
groups, each focused on a topic of critical particularly the interactive map and
importance to the continued advancement of university program list.
the blockchain and digital asset ecosystem,
such as taxonomy, taxation, and derivatives.

2
 We would like to thank our many partners, members, and supporters who worked tirelessly and
enthusiastically over the past months to produce GSMI 2021, version 2.0.

Thank you to our team of contributors representing over 131 organizations:

• Accenture Australia • Her Majesty’s Government

of Gibraltar
• Affinidi • Deutsche Bank AG
• Her Majesty’s Revenue and
• African Tax Administration • Digital Asset (DA)
Customs (HMRC)
Forum (ATAF)
• Digital Gold Institute (DGI)
• Hut8 Mining
• Algorand
• Digital Impact and
• Hyland Software
• Amplyfi Governance Initiative (DIGI),
New America • Hyperledger Foundation
• Astana International
Financial Centre (AIFC) • Diversifi • IFC-Milken Institute Capital
Markets Program
• Australian Taxation Office • DLA Piper
(ATO) • Indicio.tech
• Ecosystem Services Market
• Baseline Consortium (ESMC) • International Securities
Services Association (ISSA)
• Blockchain Education • Energy Web Foundation
Network (BEN) • International Organization
• Enterprise Ethereum
for Standardization (ISO)
• Blockchain & Law Alliance (EEA)
• Institute for Austrian
• Blockchain Labs, Inc. • Eqonex
and International Tax
• Blockchain Technology • ErisX Law, Vienna University of
Partners (BTP) Economics and Business
• Ernst & Young (EY) Tax &
• Blok Solutions Law • Institute of Electrical and
Electronics Engineers (IEEE)
• Borsa Italiana • ESG Intelligence
• International
• Centers for Medicare & • Estonian Tax and Customs
Telecommunication Union,
Medicaid Services (CMS), Board
United Nations (ITU-T)
Department of Health &
• European Partners for
Human Services (HHS) • Interwork Alliance (IWA)
Environment (EPE)
• Central Bank of Seychelles • IOV Labs
• Evertas
• Caribbean Blockchain • JP Morgan & Chase Co.
• Filecoin Foundation for the
Alliance
Decentralized Web • Kaiko
• Circulor
• FTSE Russell • KAIST
• Cloud Compass Computing
• Genesis Global Trading • Kenya Capital Markets
• Commonwealth Association Authority
• Global Digital Finance (GDF)
of Tax Administrators
• Kenya Revenue Authority
• Government of Bahamas,
• ConsenSys
Ministry of Finance • Korea Blockchain
• ConsenSys Health Association
• Government of Bermuda,
• Continuum Loop FinTech Business Unit (FBU) • Korea Blockchain Industry
Promotion Association
• Credit Suisse • Government of Ontario,
Canada, Ministry of Finance • Korea Blockchain Startup
• Cumberland DRW LLC
Association
• Government of Tamil Nadu,
• Deloitte
India • Korea Society of Blockchain
• Department for Trade and
• GS1 • Latham & Watkins
Investment, Adelaide, South

3
• London School of • Rowet Capital • World Trade Organization
Economics and Political Management (WTO)
Science (LSE)
• SFS Enterprises & Advisory • Xpansiv CBL Holding
• London Stock Exchange Services Group
Group (LSEG)
• Shearman & Sterling • XReg Consulting
• Lumedic
• Singapore Management
• Lykke University
• Meta (f.k.a. Facebook) • Sovereign Border Solutions
• MetaMe • SITA
• Miami University, Ohio • SIX Digital Exchange (SDX)
• Milken Institute • Sky Republic
• MIT Media Lab • Soramitsu
• MLL Meyerlustenberger • Stellar Development
Lachenal Froriep Foundation
• Nasdaq • Steptoe & Johnson
• Nautilus Tech • Streami, Inc
• Nigeria Securities • Tangem
Exchange Commission
• The Digital Economist
(SEC)
• Tinianow Consulting
• nPerspective
• UK Department of
• Ocean Elders
International Trade (UK
• Ocean Plastics Leadership DIT)
Network (OPLN)
• United Nations Centre
• Odyssey for Trade Facilitation and
Electronic Business (UN/
• Open Blockchain and DID
CEFACT)
Association
• United Nations Economic
• OpenID Foundation
Commission for Europe
• Orbs (UNECE)
• Portland State University • University of Bahrain
(PSU)
• University of Dundee
• Power Ledger
• University of Wyoming
• Proctor & Gamble (P&G)
• VMWare
• Protocol Labs
• World Bank
• QR Capital
• World Economic Forum
• RecycleGo
• World Federation of
• Reformation Group Exchanges (WFE)

Special thanks to the GBBC team for their contributions:

• Sandra Ro • Jackson Ross

• Mercina Tillemann-Dick • Brandon Pelar
• Paul Rapino • Haley Fletcher
• Sofia Arend • Polina Belinskaya
• Sierra Lewis • Richard Shade (PTDL)
• David Acton
• Riyad Carey
SECTION II

TAXONOMY INTRO

Over the last eighteen months, Innovators creating solutions to address

understanding each other has become society’s toughest challenges need globally
both increasingly critical and progressively accepted standards to facilitate impactful
complex. As many have adapted to working, cross-border innovation. A necessary and
learning, and interacting remotely, the need significant piece of this revolves around
for clear and consistent communication has taxonomy; cooperation is frustrated when
been underscored. Technology has created common language is not established or agreed
new channels for sharing information, but it upon.
has limits. Even when common language is a
denominator, achieving real understanding Regulators are rarely technologists, which
can feel elusive. Operating with reduced or makes building functional regulatory
removed unspoken tools has heightened frameworks for new technologies a challenge.
the value and importance of the written and Over the last decade, numerous blockchain
spoken word, underpinned by universally or taxonomies have emerged, but so far none
generally accepted definitions. have been universally accepted or adopted,
making consistent regulations across (or
When carefully conceived, shared language within) jurisdictions difficult. Confused
can create an invaluable foundation for language remains a pain point within the
understanding and progress. industry.

Turning the potential presented by blockchain This working group has taken the work of
and other emerging technologies into other groups focused on taxonomy and used
substantive solutions that move our world it to inform a taxonomy that spans industries
in a positive direction is one of the great – including terms related to digital ID and
challenges and opportunities of our time. the environment, which are often left out of
We have seen these tools accelerate vaccine blockchain taxonomies. The taxonomy in this
distribution, improve the lives of refugees, report should be viewed as a work in progress.
change the way we create and consume art,
reimagine electrical grids, facilitate corporate We welcome recommendations, revisions,
responsibility, and reshape efforts to combat and additional resources that will enable us
climate change. At the core of these efforts to further refine the quality and scope of this
is a shared desire to understand each other effort.
better and collaborate more seamlessly across
traditional boundaries. The full taxonomy is listed in Appendix A of this
report.
 SECTION III

DIGITAL & CRYPTO ASSETS

REGULATIONS (DCAR)
Since GSMI 1.0, we have seen an extraordinary growth of activity and innovation across the
digital asset ecosystem, including in spot and derivatives markets, decentralized finance (DeFi),
Non-Fungible Tokens (NFTs), Central Bank Digital Currencies (CBDCs), and adoption by financial
institutions. This has heightened regulatory and policy attention globally, bringing with it new
warnings, statements, proposals, and consultations on crypto-market activity.

DCAR assessed how these regulatory developments are shaping the current global digital asset
landscape across eight categories. This year, we have focused on the G20 jurisdictions, as well as 31
countries with notable approaches.

Key categories are summarized below with the full report and text
available here

REGULATION OF DIGITAL ASSETS Warnings issued to consumers, investors,

and businesses concerning digital assets.

REGULATION OF ILLICIT ACTIVITY & A look at illicit activity in crypto, and which
THE TRAVEL RULE jurisdictions have implemented the FATF
Recommendation 16

MARKET SURVEILLANCE The laws and guidance in place to ensure market

integrity across digital assets

CONSUMER PROTECTION Warnings issued to consumers, investors, and

businesses concerning digital assets

INNOVATION: BARRIERS VS. The barriers to innovation, the regulatory

ENCOURAGEMENT sandboxes in place, and the innovative
approaches to regulating digital assets

ADOPTION: INSTITUTIONAL Regulations on banks interacting with digital

PARTICIPATION assets and digital asset businesses, as well as
pilot projects in the banking sector

CENTRAL BANK DIGITAL CURRENCIES The active retail and wholesale CBDC projects
(CBDC)

TAXATION How regulation is being developed through

taxation

6
REGULATION OF DIGITAL ASSETS
Approaches to digital asset regulation are split between those who have brought these assets
under existing legislation, some with opt-in regimes, and those who have created new frameworks
designed specifically for virtual asset service providers (VASPs). As a result of fragmented and unclear
approaches, industry leaders have ranked a lack of regulatory clarity as one of the top challenges
that their businesses face.

On 24 September 2020, following a comprehensive consultation, the European Commission

published its proposed Markets in Crypto Assets Regulation (MiCA).‑­1 To date, this is the most
comprehensive framework for digital assets, proposing a harmonized and mandatory regime across
the entire European Economic Area (EEA) that would replace existing national frameworks and allow
cryptoasset issuers and VASPs to offer their services across the Single Market.

The increase in regulatory and policy attention has not necessarily been followed by concrete
actions. Many public consultations have been issued in 2021, including from the FATF,­2 the UK HM
Treasury (HMT),­3 the Bank of International Settlements (BIS),­4 and Dubai Financial Services Authority.­5
A clear focus area for these consultations have been stablecoins, with special attention to consumer
protection and monetary stability. MiCA includes substantial coverage of stablecoins.­6 The UK HMT
consultation regarding digital financial market infrastructure similarly focuses on stablecoins. This
keen focus is reflected in the acceleration of many CBDC programs globally.

Other jurisdictions have issued blanket bans on cryptocurrency. Qatar has issued a ban on
cryptocurrencies,­7 citing price volatility, the possibility of financial crimes, and lack of central
government support. The UK FCA ban on retail access to crypto derivatives became law in January
of this year.­8 and there is talk of “tough love” for the crypto sector from the Governor of the Bank of
England. On September 24, 2021, China issued a blanket ban on cryptocurrency trading,­9 declaring
all forms of digital asset transactions and financing as illegal activities that are strictly prohibited due
to the risks to consumers.

In the U.S., SEC Chairman Gary Gensler has testified multiple times that the cryptocurrency sector
needs stronger investor protection,­10 particularly in the instance of platforms that allow investors
to borrow against cryptocurrencies. Chairman Gensler has told lawmakers that investor protection
rules should apply to crypto exchanges,­11 and said that the SEC will regulate cryptocurrency markets
to the maximum extent possible using its existing authority,­12 while asking for more scope and
resources for the SEC to oversee the sector.13

DECENTRALIZED FINANCE (DEFI)

Additionally, the growth of DeFi caught many policy makers and regulators off guard, with the total
value locked (TVL) in the global DeFi ecosystem rising from $5 billion in August 2020 to $80 billion
in August 2021.14 In response, IOSCO organized a private call earlier this year with some DeFi
market leaders and included other regulators. CFTC Commissioner Dan Berkovitz has indicated that
many DeFi apps could be illegal,15 and SEC Chairman Gensler is concerned about protection for
retail customers and has questioned the level of “decentralization” of DeFi, citing concerns about
the nature of financial incentives of some of the networks. Chairman Gensler has kicked off an
investigation into the DeFi industry using a software analytics firm to analyze industry transactions.16
This will remain a top emerging priority for regulators in the following year.

7
REGULATION OF ILLICIT ACTIVITY AND THE TRAVEL
RULE
The increase in crypto activity has come with an increase in attention to the apparent risks of money
laundering and terrorist financing activity across digital asset markets. However, market analysts
estimate there was a decrease in illicit activity — from 1.1 percent of total market activity in 2019 to
0.34 percent in 202017 — while market activity tripled in the same period.

Nevertheless, regulators and central banks have issued statements warning of the risks of illicit
activity. In January 2021, U.S. Secretary of the Treasury Janet Yellen stated that cryptocurrencies were
being used “mainly for illicit financing.”18

THE TRAVEL RULE

The FATF published updated guidance for virtual assets (VAs) and VASPs in October 2021.19 For the
FATF guidelines to function effectively, there needs to be complete adoption to ensure that there
are no regulatory gaps. Though it has been noted that the industry has made considerable efforts to
develop and implement solutions in preparation for Travel Rule compliance, there are still concerns
that only 58 out of 128 reporting jurisdictions have implemented the recommendations into their
legislation.20 A further 26 jurisdictions have reported that they are in the process of implementing
the recommendations.

Of the 58 jurisdictions, 52 reported that they have implemented regimes that permit VASPs, while six
jurisdictions have prohibited them. 31 jurisdictions have established registration regimes for VASPs,
while 17 have established licensing regimes and a further four have implemented regimes with both
licensing and registration.21 The registration requirements for VASPs seem to be a challenge globally,
with many regulators approving only a handful of VASPs despite having implemented these regimes.

The FATF monitors countries to ensure they have fully and effectively implemented the
recommendations, and to hold countries accountable who do not comply. Since 2000, the FATF
has maintained a blacklist and a greylist of non-compliant nations that FATF members believe to be
uncooperative with other jurisdictions in international efforts against money laundering.22
IMPLEMENTATION OF
THE TRAVEL RULE

Evidence on the status of Travel Rule implementation for VASPs in the following jurisdictions is
based on the FATF’s 4th Round Ratings Document.23 The FATF’s reviews are done periodically.
Some jurisdictions’ last reviews were before the guidance on VASP was issued. Where this is
the case, further evidence has been provided to bring clarity to the status of the jurisdiction’s
progress.

On May 25th, 2021, the CEO of AU.S.TRAC announced that talks are
underway to decide if the agency should implement the FATF Travel Rule
2018 MER: for crypto asset exchanges. In August 2021, the Australian Department
Australia COMPLIANT of Home Affairs said it agrees with submissions from industry that the
government currently does not have the technological capability for
implementing a travel rule for cryptocurrencies.24

In Feb 2019, the Central Bank of Bahrain introduced new legislation,

2018 MER: including rules for licensing, governance, minimum capital, control
Bahrain LARGELY environment, risk management, and AML/CFT. It is unclear if these meet
COMPLIANT FATF’s R16 requirements for VASPs.25

NON-
Brazil Unclear
COMPLIANT

Canadian VASPs are expected to comply with Travel Rule guidance as of

June 1, 2021. Under the new rules, Money Services Businesses (MSBs) and
2021 MER: foreign MSBs are required to identify clients from which they are receiving
Canada LARGELY the virtual currency equivalent of $10,000 CAD or greater. The transfer,
COMPLIANT exchange, or remittance of virtual currency equivalent to $1,000 or greater
will likewise trigger KYC verification requirements.26

2020 MER: China was partially compliant with R16; it has recently banned all
China PARTIALLY transactions related to cryptocurrencies.27
COMPLIANT

El Salvador UNCLEAR Unclear

The Crypto Travel Rule is mandated in the European Union as of June

European 20, 2021.28 The European Commission published a proposal to regulate
MANDATED information accompanying transfers of funds and certain crypto assets,
Union
which called for consistency with the FATF Travel Rule.

9
 The Crypto Travel Rule is mandated in the European Union as of June
20, 2021.29 The European Commission published a proposal to regulate
France MANDATED information accompanying transfers of funds and certain crypto assets,
which called for consistency with the FATF Travel Rule.30

Germany mandated the Travel Rule on May 26th, 2021, the Federal
Ministry of Finance (BMF) released a draft bill, Crypto Securities Transfer
Regulation (German: KryptoTransferV), which mandated the Travel Rule.31
Germany MANDATED The Crypto Travel Rule will be mandated in Germany by the end of 2023,
once the German Federal Ministry of Finance approves the ordinance.
Minimum threshold for the applying this rule will be E.U.R 1,000

Though Gibraltar’s last MER was in 2019, in March 2021 the government
published the Proceeds of Crime Act 2015 (Transfer of Virtual Assets)
2019 MER: Regulations 2021 (Transfer of Virtual Assets Regulations).32 These
Gibraltar COMPLIANT regulations implement the Travel Rule and introduce new terms such
as ‘virtual asset service provider’, ‘virtual asset transfer’ and ‘virtual asset
account’. The rule applies to transactions equal to or above €1,000.

The framework proposed by the Securities and Futures Commission (SFC)

will extend Hong Kong’s traditional AML obligations for wire transfers to all
2019 MER: VASPs operating in Hong Kong.33 If passed, fund transfers above $8,000
Hong Kong LARGELY HKD will require the originating institution to send information that would
COMPLIANT comply with the Travel Rule. The final proposal for this framework is set to
be introduced to the Legislative Council in 2021.

While Israel applies the basic requirements for originator and beneficiary
requirements for cross-border transfers, Israel otherwise relies on general
2018 MER: Customer Due Diligence (CDD) obligations instead of providing specific
Israel PARTIALLY requirements for wire transfers. Particularly, MSBs whose business model
COMPLIANT often entails the provision of wire transfers are not subject to specific
obligations.34

2021 MER: The Financial Services Agency (FSA) will enforce the travel rule in the crypto
Japan LARGELY industry effective April 2022.35
COMPLIANT

Korea’s amended Act on Reporting and Use of Specific Financial

Transactions requires VASPs to register an authorized real-name bank
2020 MER: account and report it to the Financial Intelligence Unit (FIU).36 In addition,
South Korea LARGELY each Korean VASP will have to apply for an information security certificate
COMPLIANT that requires them to first fulfill new regulatory requirements, specifically
implementing a suitable technical travel rule solution.

The Monetary Authority of Singapore (MAS) covers the Travel Rule in

paragraph 13 of Notice PSN02. This requires VASPs to prove ownership
2019 MER:
Singapore of non-custodial wallets. The minimum threshold is not specified, but
COMPLIANT transactions under $1,500 SGD have a reduced set of requirements. The
act came into effect January 28, 2020.37

10
 The Intergovernmental Fintech Working Group (IFWG) introduced a policy
paper for the crypto industry on April 14, 2020.38 It states that crypto
businesses must comply with the Travel Rule, but it does not specify a
transaction threshold. The paper estimates that it will take 6-9 months
South Africa UNCLEAR for local regulators to implement these guidelines. It introduces the
term Crypto Asset Service Provider (CASP) as a new class of regulated
institutions that aligns with the FATF VASP definition. CASPs are required
to comply with FATF’s AML/CFT measures like FATF’s Recommendation 16
on the Travel Rule.

The Crypto Travel Rule went into effect on January 1, 2020.39 It requires
2020 MER: VASPs to implement the travel rule for transaction amounts above
Switzerland LARGELY 1,000 CHF and prove ownership of non-custodial wallets. The minimum
COMPLIANT threshold was originally set at 5,000 CHF, but this was lowered to 1,000
CHF in February 2020.

Thailand has largely fulfilled the requirements for accurate originator and
2021 MER: beneficiary information accompanying cross-border wire transfers, and
Thailand LARGELY explicit provisions for wire transfers below 50,000 THB ($1,000 U.S.D).
COMPLIANT However, there are still deficiencies, such as retaining originator and
beneficiary information with all cross-border wire transfers.40

In its 2019 Mutual Evaluation Report, the FATF determined that Turkey
is largely compliant with the travel rule.41 There are some minor gaps
2019 MER: regarding lack of explicit requirements for VASPs to consider information
Turkey LARGELY on both originator and beneficiary sides, but FIs must verify the identity of
COMPLIANT customers when the amount of a single transaction or the total amount of
linked transactions in wire transfers is greater than 2,000 TRY.

In Feb 2020, the Financial Services Regulatory Authority (FSRA) of Abu

Dhabi Global Market (ADGM) announced the enactment of various
amendments to the FSRA’s regulations and rules concerning the
authorization and supervision of virtual asset-related activities within
United Arab 2020 MER: ADGM. The key amendments include changing the terminology of “Crypto
Emirates COMPLIANT Asset” to “Virtual Asset”, to be aligned with the terminology used by the
Financial Action Task Force and moving the applicable regulations and
rules from a bespoke category of “Operating a Crypto Asset Business”, to
their respective underlying Regulated Activities (e.g. Providing Custody; and
Operating a Multilateral Trading Facility, Dealing in Investments, etc.).42

On July 22, 2021, HM Treasury released Amendments to the Money

Laundering, Terrorist Financing and Transfer of Funds (Information on
the Payer) Regulations 2017 Statutory Instrument 2022, which included
United 2018 MER: a chapter on the transfers of crypto assets. This will be an update to the
Kingdom COMPLIANT Money Laundering Regulations, will include an unspecified grace period
for compliance solution integration, and proposes that full Travel Rule
data transfer requirements will apply to all VASP-to-VASP transfers over
£1,000.43

United The Travel Rule has already been implemented in the U.S. but was
2020 MER: seldom enforced, although it has been refocused on since 2020 with the
States of PARTIALLY introduction of a proposed rule change that would dramatically reduce the
America COMPLIANT transfer amount that would trigger collection of data.44

11
 MARKET SURVEILLANCE Network ($611 million U.S.D) and Compound
($147 million U.S.D), and many other, smaller
Market manipulation continues to be a top exploits. Consumers may be exposed to a
concern for regulators. Most upcoming variety of risks, including smart contract risks,
licensing regimes emphasize the need for scams (i.e., “rug pulls”), and blockchain failure
demonstrably intentional, comprehensive risk risks. The non-custodial nature of DeFi (and
programs that automate and unify transaction crypto generally) means that users can choose
monitoring and market surveillance. In early their crypto wallet; this presents new risks, as
2020, Hong Kong,45 Singapore,46 Japan,47 users may be unaware of the implications of
and Indonesia48 implemented licensing their choices. Regulators, including the FATF,
regimes which had strict trade monitoring have expressed concerns in addressing these
requirements. risks across P2P platforms.60

Regulatory frameworks in development INNOVATION: BARRIERS

across the E.U., Hong Kong, and Singapore
are expected to include requirements for
VS ENCOURAGEMENT
specialized third party-provided surveillance The focus of this section is two-fold: Firstly, the
systems. The E.U.’s proposed MiCA framework bid for protection of consumers and market
would aim for continent-wide digital asset risk integrity may create barriers to innovation
monitoring requirements.49 in the industry. Secondly, it is worth noting
the jurisdictions that have had innovative
CONSUMER PROTECTION approaches towards the regulation itself.
Hong Kong’s voluntary opt-in registration
The increase in activity across crypto scheme61 has been relatively efficient,
markets has seen many regulators express demonstrated by the fact that it is a popular
concerns over consumer risks associated jurisdiction for service providers. A more
with digital assets. In 2021, the India Reserve unorthodox approach towards cryptocurrency
Bank,­­50 Saudi Arabia,51 the UK’s Financial innovation was taken by El Salvador, which
Conduct Authority,52 Australian Securities and was the first country to adopt Bitcoin.62 Brazil’s
Investment Commission,53 Bank of Ireland,54 legislature recently approved the draft of Bill
and the European Supervisory Authority55 were 2.303 / 15, which seeks to regulate digital
among the many regulatory bodies to issue or currencies; there is also a proposal to update
renew previous warnings against consumer the draft bill and give Bitcoin legal status as a
risks of trading digital assets. “payment currency” in the country.63

China named consumer protection as the In 2021, the Central Bank of Argentina took a
main reason for its ban on all virtual currency- novel approach towards innovation by asking
related business activity.56 Although they have domestic banks to forward them information
issued similar warnings in the past, there is a about their customers who perform any other
consensus that this ban will be followed with kind of crypto transactions.64 The purpose of
stricter enforcement. The announcement the measure is to provide further information
has already had an impact on the industry: to evaluate whether the crypto market needs
as of September 2021, leading exchange further regulation. Elsewhere, regulators have
Huobi has announced it will discontinue provided sandboxes to encourage innovation.
service for mainland users.57 Users of OTC
services also appear to be leaving the market,
with stablecoin issuer Tether breaking its
peg against RMB in the aftermath of the
announcement, suggesting heavy outflows.58

DeFi has exposed further issues in consumer

protection, as evinced by large exploits of Poly

12
JURISDICTIONS THAT HAVE
REGULATORY SANDBOXES
Bahrain The Regulatory Sandbox is a virtual space for both CBB-licensed financial
institutions and other firms to test their technology-based innovative
solutions relevant to FinTech or the financial sector in general. The
Sandbox will last up to nine months with a maximum extension of three
months.65
Brazil In 2020, the Securities Commission launched its Regulatory Sandbox
Framework with the Central Bank and the Private Insurance
Superintendence (SU.S.EP), which is expected to give regulatory waivers
for innovative projects testing new technologies in the capital and
financial markets infrastructure.66
Canada Launched a securities law regulatory sandbox for fintech businesses in
2017.67
Caribbean In 2018, the Financial Services Commission and Central Bank launched
a regulatory sandbox for the financial services sector. The government
then extended its regulatory sandbox to include blockchain and crypto
companies.68

European Union The E.U. launched a sandbox-like regulatory regime for the issuance of
DLT-based security tokens in September 2020.69

Israel A regulatory sandbox was proposed in July 2020 that will give Israeli
financial technology startups an environment to experiment with
products and services.’’70

Japan In June 2018, the government introduced a sandbox regime to accelerate

the introduction of new business models and innovative technologies.
Organizations and companies, both domestic and foreign, can apply
to experiment with new technologies such as blockchain, artificial
intelligence, and Internet of Things in fields such as financial services,
healthcare, and transportation.71
Mexico The Financial Technology Institutions Law created a regulatory sandbox
for startups, which allows them to operate for two years with a temporary
license without meeting all regulatory requirements. CNBV issued its
first license on January 22, 2020, to a cryptocurrency market, and as of
February 2020, at least 85 entities had filed applications.72

Singapore Singapore created a regulatory sandbox to help firms receive Capital

Markets Services Licenses.73

South Korea There are a series of sandboxes in different municipal ordinances around
South Korea, including BU.S.n.74
Switzerland Launched a regulatory sandbox in 2017.75

Thailand The Bank of Thailand launched a sandbox under regulatory guidelines

introduced in 2019. The regulatory sandbox allows financial service
providers to test their financial services that incorporate new
technologies and fintech innovations. In addition, the regulatory sandbox
encourages financial service providers to cooperate with one another in
the development of fintech innovations and new technologies.76
United Arab The Abu Dhabi Global Market launched a sandbox in 2018. The ADGM
Emirates digital sandbox provides a marketplace for open collaboration between
FIs, FinTech firms, and regulators to facilitate testing and adoption of
innovative digital financial products and services that can benefit the
industry.77

13
 ADOPTION: INSTITUTIONAL broker reporting to crypto asset exchanges,

PARTICIPATION the U.S. Congress has passed a law to expand

the definition of broker to “any person who
This year saw a considerable increase in (for consideration) is responsible for regularly
institutional activity in digital assets. Fidelity providing any service effectuating transfers of
Digital Assets’ report showed that U.S. and digital assets on behalf of another person.”84
European interest in digital asset investment Industry participants are concerned that the
products increased by 12 percentage points language could be applied to participants in
year-on-year, with 84 percent of surveyed the ecosystem that are not acting as traditional
investors interested in purchasing institutional brokers and do not have insight into the
investment products that hold digital assets.78 underlying transactions, such as miners, stakers,
providers of hardware/software wallets, or
Within Europe, there is a concern that MiCA developers of digital assets or protocols.
favors incumbents over new market entrants. For
example, existing providers with MiFID licenses Similarly, the E.U. has been working on its
can provide cryptoasset services, provided they eighth update of the Directive on Administrative
comply with the operational requirements of Cooperation (DAC8),85 which would expand
MiCA; credit institutions that comply with the the collection and exchange of information to
Capital Requirements Regulation will not have include transactions involving crypto assets. The
to apply for authorization under MiCA;79 and OECD is working on proposals for reporting and
cryptoasset service providers are required to be exchange of information with respect to crypto
authorized as a payment institution under PSD2 assets.86 It is unclear how these developing
in order to make a payment. These requirements information reporting regimes will apply to
operate on the assumption that traditional decentralized protocols.
market participants are in the best position to
manage risk. SHARIAH LAW
TAXATION The topic of Sharia compliant products and
services in the context of cryptocurrencies is
An emerging trend across jurisdictions is growing and warrants further development
market guidance and legislation occurring into 2022. For example, Rain is the first
through taxation, rather than through direct cryptocurrency exchange in Bahrain to graduate
regulation. Jurisdictions around the world from the regulator’s sandbox and apply for
continue to diverge in their tax approaches to a license and be compliant with Sharia law.
cryptocurrency. India has announced plans to The Shariah Compliance Certificate is issued
tax cryptocurrency,80 while South Korea may by the Shariah Compliance Body, licensed by
further delay its law to tax cryptocurrency.81 the Central Bank of Bahrain to be a Shariah
consulting company, and authorized to issue
Most jurisdictions treat cryptoassets as non- Shariah compliance certificates.87
currencies for tax purposes, which means that
transfers of cryptoassets can result in tax liability LOOKING AHEAD
in many jurisdictions. With bitcoin reaching an
As the digital and crypto assets markets
all-time high price in 2021,82 tax authorities are
continue to grow, additional areas of research
trying to ensure that they can collect any taxes
and mapping should include NFTs, DAOs, social
that are due and are increasingly focused on
tokens, and the metaverse. As these markets
information reporting by exchanges and other
become simultaneously more developed and
VASPs.
more complex, novel legal and regulatory
issues will arise. It is critical that stakeholders,
In the U.S., the Internal Revenue Service (IRS)
regulators, and legislators maintain an
has the authority to collect information from
understanding of new developments, and
brokers regarding transactions they effectuate
thus GSMI 3.0 will likely address some of the
on behalf of customers.83 Although the IRS
aforementioned areas of focus.
has been working on regulations to extend

14
SECTION IV

POLICY
Blockchain is a fundamentally borderless technology that exists in a world with many borders.

The tension that this reality creates will continue to lead to difficult policy decisions for governments.
The most successful jurisdictions will find a way to balance anti-money laundering/know-your-
customer (AML/KYC) requirements, consumer protection, taxation, and more with innovation. But it
is not enough for individual governments to develop effective regulatory frameworks as delineated
in the DCAR section; governments must work together, facilitated through international bodies
(See Appendix B), to minimize frictions that stand to hamper blockchain technology’s potential. The
GSMI Policy Working Group examined two crucial cross-border policy topics that are currently at the
forefront: AML/KYC and CBDCs.

AML/KYC
Cryptocurrency users carry out many transactions around the world every day; the Bitcoin and
Ethereum blockchains facilitate around 260,00088 and 1,260,00089 transactions daily. The active
universe of transactions conducted in cryptocurrency, however, remains stymied by a variety of
policy challenges. According to the Bank for International Settlements (BIS,) the key challenges facing
the use of cryptocurrency in cross-border transactions include “aligning regulatory, supervisory and
oversight frameworks for cross-border payments, Anti-Money Laundering/Combating the Financing
of Terrorism (AML/CFT) consistency, Payment versus Payment (PvP) adoption and payment system
access.”90 The BIS has framed the problem with two perspectives: (a) the “practical perspective” for
how one would set up a cross-payment infrastructure; and (b) the “macro-financial perspective,”
including “examining the potential increase in cross-border flows, possible financial stability risks and
currency substitution, and reserve currency configurations and backstops.”91

The “practical” concerns related to anonymous payments are largely associated with money
laundering and terrorist financing. The “macro-financial” concerns involve the difficulty in
coordinating the relationship between central banks to allow for access to, and settlement of,
funds transfers to facilitate the cross-border use of digital currency from two or more jurisdictions.
Such an arrangement would require strong cooperation among central banks, and a network
of relationships that is not currently sufficiently robust to handle cross-border cryptocurrency
transactions, especially if adoption becomes more widespread.92 The BIS has recognized that an
international system of cross-border transactions in cryptocurrency requires countries to agree on
the design of a transfer system that limits the risk of currency substitution.

Central banks are also concerned that cross-border transactions

would create volatility in the flow of capital that will upset markets
as well as “contagion risk,” or the fear that financial instability in one
country will spill over into another country through high numbers
of these transactions.
A lack of standardized definitions of virtual currencies, cryptocurrencies, and cryptoassets poses
further challenges for cross-border transactions and regulations. India offers a prime example of

15
 these challenges. Indian law defines “currency” cross-border transfers of cryptocurrency
with a specific list of categories, including may fall under India’s Foreign Exchange
currency notes, money orders, cheques, Management Act, which would regulate
and credit cards.93 But virtual currencies are cross-border cryptocurrency transactions as a
not included in this list. In 2015, the Reserve movement of “goods.”98
Bank of India issued a regulation interpreting
the statute which added to the definition of Despite ongoing debate about whether
currency to include “debit cards, ATM cards or certain cryptocurrencies are securities, some
any other instrument by whatever name called regulators treat virtual currency under the
that can be used to create a financial liability.”94 current regulatory framework for “goods”
The challenge here is that “in the case of virtual or “property” as part of their efforts to apply
currencies such as Bitcoin, there is no entity existing rules applicable to guard against
that is accepting financial liability in connection money laundering and terrorist financing to
with the instrument.”95 virtual currency.99

HOW COUNTRIES AND FATF AND CROSS BORDER

ORGANIZATIONS ARE CONSIDERATIONS
ADDRESSING THESE According to the FATF guidance, Virtual Asset
ISSUES Service Provider (VASP) is defined as any
National regulators and organizations around natural or legal person who, as a business,
the world are working to develop rules to conducts one or more of the following
govern digital assets. The G20 is focused activities or operations for or on behalf of
on enhancing cross-border payments and another natural or legal person:
has endorsed a comprehensive program to
address challenges.96 Regulators also see the • Exchange between virtual assets (VA) and fiat
value of digital currency in the world economy. currencies.
According to the BIS, “Faster, cheaper, more • Exchange between one or more forms of
transparent and more inclusive cross-border virtual assets.
payment services would deliver widespread • Transfer of virtual assets.
benefits for citizens and economies worldwide, • Safekeeping and/or administration of virtual
supporting economic growth, international assets or instruments enabling control over
trade, global development and financial virtual assets.
inclusion.”97 • Participation in and provision of financial
services related to an issuer’s offer and/or
The consistent theme, however, indicates sale of a virtual asset.
that while some governments have become
increasingly receptive to virtual currency and As set out above, the definitions do not
cryptocurrencies, many have yet to develop depend on the technology employed by the
laws that specifically regulate virtual currency. service provider. The obligations in the FATF
The lack of clarity in the marketplace has Standards stem from the underlying financial
made accepting virtual currencies for cross- services offered without regard to an entity’s
border payments difficult because their use operational model, technological tools, ledger
still involves risk under some laws. Moreover, design, or any other operating feature. One key
it is unclear how and whether enforcement advantage of the FATF guidelines is that they
authorities would apply these laws to focus on the types of services provided, not on
cryptocurrencies. terminology or nomenclature used to describe
the services, which could lead to greater
Some countries, such as India, have attempted consistency within the global regulatory
to regulate the transfer of cryptocurrency framework.
across borders through their customs laws.
Several commentators have suggested that However, the FATF recognizes that its

16
approach can bring practical challenges to supervisory action in the pre-launch phase.
competent authorities in identifying which
entities are VASPs and defining their regulatory NEXT STEPS FOR
perimeter. Launching a service that will provide
virtual asset services, for instance, does not
CROSS-BORDER
relieve a provider of VASP obligations, even if
COLLABORATION
those functions will proceed automatically in The law, and technology, is constantly
the future, especially, but not exclusively, if the changing, and there will need to be an effort
provider will continue to collect fees or realize to provide more direct guidance to users of
profits, regardless of whether the profits virtual currencies. The international community
are direct gains or indirect. For purposes of will need to reach a consensus on whether
determining VASP status, launching a self- regulation should focus on stopping the use
propelling infrastructure to offer VASP services of virtual currency or on monitoring and
is the same as offering them, and similarly reporting on its use.
commissioning others to build the elements of
an infrastructure is the same as building them. Cryptocurrencies are facing increased
regulation in several countries, including the
Where there is a central developer and United States. The focus of the regulations,
governance body which is a financial institution however, has largely been on increasing
(FI) or a VASP, it could be held accountable transparency and central management in
for the implementation of AML/KYC controls exchanges rather than structuring more
across the arrangement and for taking steps efficient means of exchange. U.S. regulators
to mitigate ML/TF risks. These organizations proposed reducing the threshold for
should consider taking steps to limit the scope transaction reporting from $3,000 to $250
of customers’ ability to transact anonymously because of claims that
and/or ensuring that AML/KYC obligations are
fulfilled on an ongoing basis (e.g., by using “[c]riminals are using smaller value transfers
software to monitor transactions and detect and virtual currencies to facilitate terrorism
suspicious activity). Not all stablecoins may financing, narcotics trafficking and other illicit
have a readily identifiable VASP/FI central activities, like cybercrime.” 100
body once launched. However, it may be
more likely that a party needs to exist to It will be important, as regulation moves
drive the development and launch of such an forward, to have accurate data on actual
arrangement before its release. If this entity use patterns by both legitimate users and
was a business and carried out VASP functions, illicit actors. Some have argued, however,
this would create scope for regulatory or that this feature is built into cryptocurrency

17
 transactions.101 issued an open letter to FATF calling for
“well-balanced” regulations, including ways to
It is still early, but there is technology streamline AML and KYC requirements; for
being developed to improve and manage example, by allowing financial intermediaries
processes for KYC and AML compliance, to collaborate when identifying clients so that
including some which offer zero-knowledge these checks don’t have to be run multiple
proof (ZKP) solutions that protect personal times to execute a single transaction.102
information without having to sacrifice safety
and functionality. These and other “reg tech”
offerings seek to leverage the security and
CBDCS
verifiability of blockchain technology and In a relatively short period of time, CBDCs went
provide regulators with assurance that bad from a niche technological idea to a concept
actors are not using decentralized systems that over 80 countries representing over 90
to conduct illicit transactions. Companies like percent of global GDP are investigating.103
Coinfirm, Chain Analysis, and Ciphertrace
are among the burgeoning field of crypto While most central banks are first considering
analytics companies that monitor blockchain the domestic implications of CBDCs, there have
transactions and provide real-time alerts to been numerous cross-border experiments.
flag potential sources of risk, among other Central banks are interested in CBDCs for
services. a variety of reasons, including limiting the
influence of private stablecoins, improving
In July 2021, a group called the Global financial inclusion, and reducing costs. As the
DeFi Coalition, which includes a half-dozen response to COVID-19 demonstrated, CBDCs
international blockchain-related trade groups, could also be used to improve the efficiency of
representing more than 350 companies, “helicopter drops,” as stated by the U.S. House

18 18
 of Representatives Committee on Financial increased volatility in FX rates.
Services:
HOW COUNTRIES AND
“In CBDC models where every citizen has ORGANIZATIONS ARE
a digital wallet, or the government has
ADDRESSING THESE
visibility into wallet ownership, the speed
at which these distributions can be made
ISSUES
increases considerably while also ensuring Perhaps most significantly, China has
that those who are traditionally not served undertaken a number of pilots, including a
by the banking sector and most in need of trial with the BIS and the central banks of
countercyclical assistance would be able to Hong Kong, Thailand, and the U.A.E, called the
benefit.”104 mCBDC Bridge. According to the post-phase
two report, the prototype tested enabled the
WHAT ARE THE MAIN central banks “to control the flow of their CBDC
ISSUES THAT CBDCS and to monitor transactions and balances
PRESENT? of their issued CBDC, with programmable
levels of transaction privacy and aspects
As detailed in a joint BIS, International of automated compliance. The prototype
Monetary Fund (IMF), and World Bank Group demonstrates a substantial increase in cross-
report to the G20 on CBDCs for cross- border transfer speed from days to seconds,
border payments, the proliferation of CBDCs as well as the potential to reduce several of
has a wide variety of opportunities and the core cost components of correspondent
consequences which will vary widely depending banking.”106 The next phase will involve “further
on the design of each CBDC. The report states experimentation with design choices and
that “cheaper and more accessible remittances technology trade-offs and a future roadmap
will benefit senders and recipients, help to from prototype to a production-ready network
buffer economic shocks, and stimulate growth. that can serve the broader central banking
Markets should also become more integrated, community as a public good through open-
thus offering investment and risk-sharing sourcing.”
opportunities. This would facilitate hedging,
though it could increase contagion risks.”105 This is just one example of central banks
collaborating to test cross-border CBDCs.
Additionally, as CBDCs could make it easier and In July 2021, the Banque de France and the
cheaper to store and spend foreign currency, Monetary Authority of Singapore completed
“already established international currencies an experiment that “simulated cross-
[could become] even more attractive… border and cross-currency transactions
This would contribute to more widespread for Singapore Dollar CBDC and Euro CBDC,
currency substitution via the adoption of a and was conducted using a permissioned,
foreign CBDC, especially in countries with high privacy-enabled blockchain based on Quorum
inflation and volatile exchange rates.” This technology.” 107
could have significant effects on countries’
ability to control their monetary policy and Recently, the central banks of Australia,
“increase risks for runs on both domestic Malaysia, Singapore, and South Africa
banking sectors and currencies.” The report announced that they would be conducting a
speculates that currency substitution could cross-border CBDC trial.108
also undermine central banks’ ability to act as a
lender of last resort. Reflecting the general attitude towards current
CBDC research, China’s e-CNY whitepaper
These represent just some of the manifold stated that “cross-border payment involves
risks associated with the proliferation of various complicated issues such as monetary
CBDCs. Other risks include consumer sovereignty, foreign exchange policies and
protection, privacy, tax avoidance, and arrangements, as well as regulatory and

19 19
 compliance requirements… Therefore, though technically ready for cross-border use, e-CNY is still
designed mainly for domestic retail payments at present.”109 President Xi Jinping has also called on
the G20 to “discuss developing the standards and principles for central bank digital currencies with
an open and accommodating attitude, and properly handle all types of risks and challenges while
pushing collectively for the development of the international monetary system.”110

NEXT STEPS FOR CROSS-BORDER COLLABORATION

It is encouraging to see central banks, especially those of some of the largest economies in the
world, are closely examining the risks associated with CBDCs. Countries engaging in cross-border
research and experimentation should continue these efforts, and more countries should join the
effort. Thoughtful and deliberate planning and design, including information sharing between central
banks, will become more critical as larger economies, such as Nigeria,111 begin to release their CBDCs
on a wider scale.

In October 2021, the G7 released a statement on CBDCs, stating that strong “international coordination
and cooperation on these issues helps to ensure that public and private sector innovation will deliver domestic
and cross-border benefits while being safe for users and the wider financial system.”

The statement further notes “the importance of considering interoperability on a cross-border basis,”
while also recognizing “a shared responsibility to minimise harmful spillovers to the international
financial system.”

The G7, G20, Financial Stability Board, BIS, regional blocks, and other international organizations
must facilitate international coordination and ensure that countries are not rushing to release
a CBDC in competition with one another, creating a race to the bottom that could have serious
consequences.

MARKET MANIPULATION
Today’s digital assets market closely resembles the capital markets that existed a century ago.112
Cross-border transactions of digital assets can add yet another layer of complexity, making
manipulative transactions more difficult to track and flag. While it has been confirmed that
intentional market manipulation does occur, there are also instances where market manipulation

20

Figure 2: Geographic Distribution of Market Manipulation Activity (Source: Amplyfi.com/insights)

occurs through unintentional transactions.113 Either way, regulation and surveillance are paramount
in ensuring equality and fairness in newly emerging exchanges, while ensuring that cross-border
transacting is not used to camouflage intentional manipulation.

Other than some anecdotal events, little research has been done to confirm the intentional
manipulation of cryptocurrency across borders, or to identify how traders may leverage the lack of
regulation across borders to gain quick wins. However, what is known is the potential that cross-
border transactions have to cause more confusion around both intentional and unintentional
transactions, resulting from the lack of transparency among the various regulated and non-regulated
exchanges, and across regulatory bodies.

HOW CRYPTOCURRENCIES ARE MANIPULATED BY

MARKETS
There are several known strategies used by some nefarious traders to intentionally manipulate the
cryptocurrency markets. Some will use initial coin offerings (ICOs) to gain leverage on a particular
exchange, especially where ICOs are not regulated to prevent unfair leverage through large
purchases of digital assets. These ICO events, if not properly regulated, can lead to unfair leverage
and temporary spikes in market price that will work to the advantage of the buyer. Some will use
the classic pump and dump strategy to create the illusion of an artificial increase in market activity,
also leading to temporary spikes in market prices, which can lead to quick gains through the sudden
selloff of digital assets.114

Other manipulation strategies involve setting up ghost accounts that can help disguise large trade
volumes by a single company or individual, thereby manipulating market prices. This is known
as wash trading, which takes advantage of the anonymity associated with some cryptocurrency
accounts. Spoofing is yet another strategy; it uses illegitimate orders, often leading to manipulated
spikes and dips in prices. The introduction of leveraged derivatives has made these price-impacting
strategies even more effective, especially when combined with the ability to quickly sell on the spot
market. The combination of wash trading, spoofing and leveraged derivatives can potentially have an
impact on cross-border manipulation, and can potentially be used as an act of international political
aggression if not properly regulated.

CHALLENGES WITH TRACKING AND

CONTROLLING MANIPULATION EVENTS
The digital currency marketplace has evolved so quickly that
regulators continue to struggle to keep up.115
 Additionally, transactions can occur so so that events showing signs of deception can
rapidly that it is virtually impossible to detect be flagged and addressed.117 Self-certification
intentional acts of manipulation and prevent requirements in spot markets can also thwart
them from happening in real time. New trading devious activities, as well as imposing tighter
instruments and services are constantly being controls and requirements around highly
created, thus perpetuating the complexity leveraged crypto derivatives.
and difficulty to regulate. To add to the
challenges of regulation, traders will often Artificial intelligence and machine learning
use multiple exchanges and instruments, and technologies offer another means of actively
transact across multiple borders. With all of monitoring the transaction landscape across
these avenues for potential fraud and abuse, diverse trading platforms. Vetted AI and
it can be difficult, or impossible, to detect machine learning algorithms could be used to
legitimate transactions and trades from those detect nefarious patterns in trading. This can
that are done with the intent of fraudulent be done at a pace and consistency level that
manipulation. would be impossible for humans to achieve,
potentially leading to a more preventive type of
NEXT STEPS IN control mechanism.
PREVENTING MARKET
MANIPULATION ACROSS CONCLUSION
BORDERS The cross-border nature of blockchain,
Regulation alone will not provide the security cryptocurrencies, and CBDCs is creating novel
and safety for all traders and investors in this problems and opportunities for legislators,
space. Addressing this problem will require regulators, businesses, and organizations to
transparency and cooperation among various address. When crafting guidelines for this new
national regulatory bodies, exchanges, and industry, it is important that governments do
service providers. For example, the formation not become fixated on cryptocurrency as a
of one centralized governing body, or the tool for criminals. Its illicit use is a problem,
expansion of an existing cooperative work but as the FATF estimated in 2015, “between
group like the Financial Action Task Force hundreds of billions and a trillion U.S. dollars”
(FATF), that can work to oversee the activities are laundered each year in cash, with a
of all exchanges in all countries and provide majority of countries surveyed indicating “that
guidance and tools towards enhanced cash smuggling is an increasing problem.”118
regulation and control within the exchanges.116 This is not intended to serve as whataboutism,
but rather to indicate the vastly different
In any type of financial market, there are two scopes of the problem: the total crypto market
approaches used for internal control. These cap is $2.5 trillion as of this writing, with an
are preventive and detective controls. While estimated $10 billion in criminal activity in
the latter attempts to quickly identify and 2020.119 Governments therefore must attempt
prevent an unauthorized transaction from to balance innovation and regulation, ideally
occurring, the latter relies on the belief that in communication with other governments so
such a transaction cannot be prevented, as to harmonize regulations and learn from
but can be detected, and followed up with a mistakes and successes.
reversal of that transaction, or a penalty, thus  
discouraging such events from happening.
Applying such controls around those areas
most likely to be abused, such as leveraged
derivatives, spot markets, etc., could be a first
line of defense for regulators.

Exchanges themselves must provide real-time

surveillance and monitoring of transactions,

22
 SECTION V

DIGITAL ID

EXECUTIVE SUMMARY
The rapid deployment of global decentralized networks has created large gaps with respect to
data disclosure, financial transactions, and the degree of privacy to which individuals are entitled
regarding digital assets. Digital assets come in many forms, but the Covid pandemic and rapid
development of Web 3.0 decentralized networks has incited a need for a foundational, global,
interoperable framework for modern digital identity. Personal data also carries value, which can be
protected and exchanged on decentralized ledger technologies (DLT) with the individual in control.
Beyond that goal, decentralized exchanges (which are often autonomous with no central governing
body,) in combination with non-custodial wallets, provide a major hurdle for regulatory and
enforcement agencies to use existing KYC/AML frameworks to prevent illicit activity.

Decentralized identity solutions, sometimes synonymously referred to as “self-sovereign identity”

(SSI) frameworks, have been recommended for many use cases and align well with the UN’s
sustainable development goals (SDGs), especially SDG 16, and can serve as a foundation for Web
3.0 and beyond. Applications include globally interoperable frameworks for government, healthcare,
finance, and physical interactions. In combination with biometrics, digital asset wallets, and other
technologies, SSI may serve as a foundation to enhance KYC/AML integrity while affording financial
access to underserved populations. It can help remedy archaic administrative costs in different
verticals like healthcare and financial services. A decentralized approach to identity can also offer the
least fortunate among us some form of documentation by which one can verify another for issuance
of first aid, food, water, and other essentials in times of crisis. As reports suggest, over a billion
people lack proper identification.120

Access the full version of the Digital ID report here.

Government Issued/ National IDs like SSN, Passport, Driver’s License, Standard ID, Real ID,
attested primary birth certificates
credentials and identifiers

Attestation Acknowledged evidence or confirmation of the existence of something,

whether by an individual or organization.The broader community
must prioritize finding greater consensus on common definitions and
taxonomy.

Credential A qualification, trait, achievement, or authority assigned to a person

or entity which can be issued in physical or digital form.The broader
community must prioritize finding greater consensus on common
definitions and taxonomy.
 Digital Identity Identity issued by an organization that is considered to be either “Siloed” or
“Federated.”121

Federated Identity Means of linking a person’s electronic identity and attributes, stored across
multiple distinct identity management systems.122 Federated identity is related
to single sign-on (SSO), in which a user’s single authentication ticket, or token, is
trusted across multiple IT systems or organizations. SSO is a subset of federated
identity management, as it relates only to authentication and is understood on
the level of technical interoperability and would be impossible without some sort
of federation.

Decentralized A globally unique identifier developed specifically for decentralized systems as

Identifier (DID) defined by the W3C DID specification. DIDs enable interoperable decentralized
Self-Sovereign Identity management: A DID is associated with exactly one DID
Document.123

Decentralized A portable set of identity credentials (which may be issued or attested to by third
Identity parties) controlled by the individual owner in a digital wallet underpinned by a
DLT platform.124

Self-Sovereign An identity system architecture based on the core principle that identity owners
Identity have the right to permanently control one or more identifiers together with the
usage of the associated identity data.125

Verifiable Much existing regulation and standardization focuses specifically on digital

Credential assets, as opposed to blockchain or DLT technology more broadly. As new uses
for the technology continue to emerge, dynamic or principles-based guidance
will be better suited to adapt. Regulators should take advantage of regulatory
sandboxes and innovation hubs to create more effective regulations.

Zero-Knowledge A Proof that uses special cryptography and a Link Secret to support Selective
Proof Disclosure of information about a set of Claims from a set of Credentials. A Zero
Knowledge Proof provides cryptographic proof about some or all of the data in a
set of Credentials without revealing the actual data or any additional information,
including the Identity of the Prover.

SSI Principles Elaboration

Table 3: Various “Principles of Identity”

Table 3 courtesy of New America. View the original here.

In an increasingly complex global internet and financial system, black swan events can pose
greater economic risk. The right to owner-centric control becomes a prerequisite to digital
identity and its corollaries constitute basic human rights. To ensure personal identity and
related data are protected, the individual should have the option to take complete ownership
and custody of her data. Shifting trust to the edges of communication networks also has the
potential to reduce complexity and increase security.

PRINCIPLES AND the forefront of international economic and

SOLUTIONS social threats. The need for privacy-protecting

infrastructure embedded in global data
• Privacy transfer networks grows every second.126
• Inclusion
• Security GLOBAL
• Global Interoperability and Economic INTEROPERABILITY AND
Efficiencies ECONOMIC EFFICIENCIES
• Decentralization
• User Focus Increasing globalization calls for frictionless
trade of physical and economic resources,
PRIVACY cross-border transactions, and valued
data exchange. Thus, sound digital identity
Under a digital ID solution, entities should infrastructure and governance should be
control the privacy of their information, integrated with Web 3.0 architecture.
including minimal, selective, and progressive
disclosure of attributes or other data. The DECENTRALIZATION
sheer volume of data and value in aggregate
makes centralized systems much less resilient. Decentralization can create new economic
Affording control to the user enhances privacy, models that incentivize “good” behavior;
which becomes especially valuable in the DLT infrastructure base layers allow for
healthcare and financial services verticals. security, decentralized custody, peer-to-peer
transactions, a programmable spectrum of
INCLUSION privacy, and automation of modern financial
and identity data transactions.
Inclusion for all is the first step toward a
brighter shared future. SSI technologies USER FOCUS
and principles align congruently with the
Sustainable Development Goals in their unique Personal data is currently monetized in
purpose to provide irrevocable agency of an commercial settings as well as through social
individual’s identity to any human on Earth, media and advertising channels. Because of
regardless of place of birth, bank account, or the ever-present tension between hacking and
social status. cybersecurity, individual ownership of identity
in a decentralized framework may allow for
SECURITY the greatest security of our personal data.
Those preparing for Web 3.0 and decentralized
Cybersecurity infrastructure is an absolute technology should consider a transparent
prerequisite for the safe creation, issuance, and viable governance framework capable of
storage, and transfer of all digital data for achieving the virtues invoked by Self-Sovereign
purposes of commerce or verification. Identity principles.
Those credentials or claim sets relatable
to an individual person typically carry value
and are broadly disseminated and traded.
Unfortunately, and ubiquitously, global data
breaches have become the norm, putting
identity fraud and identity-related crimes at
 VERTICAL FOCUS #1:
HEALTHCARE & TRAVEL
APPLICATIONS

CURRENT STATE OF PRACTICAL DID APPLICATION FOR

CROSS-BORDER TRAVEL AND “COVID HEALTH PASSES”

• The
Commons Project Foundation and the World Economic
Forum have launched the Common Trust Network in collaboration with a broad voluntary
network of public and private stakeholders. CommonPass is the traveler App, which will store,
and display COVID-19 test results and eventually vaccination records. Five airlines are part of this
initiative as well as the Airport Council International, representing 2000 airports globally.127

• IATA Travel Pass is a mobile application (available in March 2021) allowing travelers to
store and manage certifications for COVID-19 tests or vaccines. The information provided through
the IATA Travel Pass can be used by governments requiring testing or vaccination proofs as a
condition of international travel during and after the COVID-19 pandemic. Emirates Airlines is one
of the first Airlines to partner with IATA for the adoption of Travelpass.128

• World Health Organization (WHO): Initiated the development of a digitally

enhanced International Certificate of Vaccination, a ‘smart yellow card’. WHO also set out the Smart
Vaccination Certificate Working Group. It is intended to bring together experts to focus on defining
specifications and standards for a digital vaccination certificate.129

• International Chamber of Commerce (ICC) has partnered with International

SOS, to launch the new ICC AOKpass mobile app, to provide trusted recognition of individuals’
COVID-19 compliance status. Singapore Airlines has trialed the AOKpass service for inbound
travelers from Malaysia and Indonesia.130

• Vaccine Credential Initiative (VCI) is working to enable individuals vaccinated

for COVID-19 to access their vaccination records in a secure, verifiable, and privacy-preserving
way. The coalition (CARIN Alliance, Cerner, Change Healthcare, The Commons Project Foundation,
Epic, Evernorth, Mayo Clinic, Microsoft, MITRE, Oracle, Safe Health, and Salesforce) is developing
a standard model for organizations administering COVID-19 vaccines to make digital credentials
available in an accessible and interoperable.131

• Good Health Pass Collaborative is a cross-industry group, established in 2020,

in response to COVID-19 shutting down international travel, to provide guidance on travel pass
creation and use. The resulting Interoperability Blueprint makes recommendations for adoption
that include the early standards and specifications from Trust Over IP, DIF, and W3C.132

26
IMPACTS ON STANDARDS & INTEROPERABILITY
Despite the number of initiatives listed above, there are no unified standards to define precisely
how Digital Health Credentials mechanisms — from issuance to verification — would work. For
example, the Good Health Pass Interoperability Blueprint proposes a new set of interoperability
specifications while acknowledging that there is a lot of work remaining to reach true standardization
and interoperability.133 Additionally, technology firms have their own way to implement standards
specifications which often limit interoperability. The (limited) list below shows standards,
consortiums, and foundations that are working on various technology stack layers used in a Digital
Health Credentials solution (authentication protocol, communication, encryption data storage, etc.)

• World Wide Web Consortium (W3C) has been working on building web
standards since the early 2000s. They have primarily focused on developing the browser and
have been instrumental in making browser interoperability possible. They are specifically involved
in a working group to specify the architecture, data model, and representation of Decentralized
identifiers (DIDs) that enable verifiable, decentralized digital identity

• JavaScript Object Notation (JSON) is an open standard file format, and data
interchange format, that uses human-readable text to store and transmit data objects. JSON is
used for passenger QR code presentation. It is important to note that though JSON is a standard,
the schemas required for interoperability have not been standardized.

• Decentralized Identity Foundation (DIF) is an engineering-driven

organization acting as a center for development, discussion, and management of all activities
required to create and maintain an interoperable and open ecosystem for the decentralized
identity stack. DIF has the capability to set up intellectual property rights (IPR) protected working
groups, deliver specs and standards, and offer infrastructure for the community.

• Trust over IP Foundation is an organization hosted at the Linux Foundation that is

defining a complete architecture for Internet-scale digital trust that combines both cryptographic
trust at the machine layer and human trust at the business, legal, and social layers.

• Hyperledger Foundation is an organization hosted at the Linux Foundation which

promotes collaboration from a variety of industry stakeholders building implementations in open-
source communities for a variety of use cases around decentralized ledgers and blockchains (Aries,
Ursa, Indy).

• The DID Communications Working Group (DIDComm) was spun

out of the Hyperledger Aries community and is now hosted at the DIF. This group develops and
contributes to the standards and technology for authentication protocols. It is working to enhance
and standardize protocols over the next year, with an emphasis on interoperability.

• The Sovrin Foundation is a 501(c)(4) non-profit entity that provides business, legal, and
technical support for the Sovrin Network, an open-source project. Using DID technology, the Sovrin
Network allows for digital credentials to be privately issued, controlled, managed, and shared.
The growth of the Sovrin Network partly depends on contributions from an active open-source
development community.

• The Kantara Initiative is an international ethics-based non-profit industry commons.

Its mission to grow and fulfill the market for trustworthy use of identity and personal data.134
Currently, numerous organizations, including governments, financial
institutions, and technology companies, are taking a “working code
first” approach. Stakeholders recognize that the standards are not
ready for broad adoption and are building out ecosystems using
code that meets their needs while also shaping the standards and
specifications that will be required for full interoperability. One key
trend is the adoption of a consistent technology stack of Hyperledger
Aries and Hyperledger Indy and the establishment of ecosystems
around the globe (Canada, Finland, Germany, and more). These
projects are driving several things forward:
- Interoperability Testing
The Hyperledger Aries Interoperability Test135 is being used to drive multiple areas of alignment,
which is particularly crucial for governments. This approach is being used to drive other specifi-
cations such as the Wallet and Credential Interaction (WACI136) effort hosted at DIF.

- Trust Over IP 4-Layer Mode

The Aries/Indy codebases align well with the Trust Over IP 4-layer model. Aries operates at
Layers 2 and 3, while Indy provides the Layer 1 utility. Each project that is operating provides the
Layer 4 ecosystem.

- Machine Readable Governance (MRG)

This is a way of orchestrating governance rules and the functions of a conventional trust registry
at the agent software level. MRG was developed by Indicio.tech and SITA for the Cardea Project,
a complete ecosystem based on Indy and Aries for sharing digital health credentials and data
in a privacy-preserving way. After a successful pilot with the Aruban government and health
authorities, it was donated to Linux Foundation Public Health for use by public health agencies.
The key advantages of MRG are flexibility (everyone can publish their rules, and these can be
incorporated and updated according to hierarchy and need), speed (there is no transaction
delay required by the need to contact a Trust Registry), and the ability to cache governance rules
so that the system can work offline. Critically, Indicio and SITA found that Machine Readable
Governance was the most effective way for the Aruban government to exercise its sovereignty
over the process of COVID testing.137

The adoption of Digital Health Credentials will increase if interoperability allows travelers to share,
issue, hold, and verify digital credentials across multiple networks. In practice, this would allow a
traveler who received their COVID-19 test result credential from a health information exchange in
one country and is able to present that credential to immigration officials in another country.

Thus, it is unlikely that there will be a single, shared ledger where credentials are anchored. Many
ledgers will likely be involved in exchanging verifiable credentials, often referred to as a “network of
networks.” The governance and technical architecture of these networks must be carefully designed
for interoperability and governed by principles that are consistent with privacy, security, and
individual data ownership.
VERTICAL FOCUS #2:
GOVERNMENT AND
INTERNATIONAL
INTEROPERABILITY
Various governments have started initiatives (some of them are listed below) in Decentralized
Identity with user privacy as a key focus. Importantly, the trending privacy legislation of Europe,
Canada, the U.S., and other global leaders addresses data transparency in commercial settings
and the right as the data owner to have full control of their personal data and how it is used.

Province of Ontario’s Digital ID Plan

The Pan Canadian Trust Framework
Canada Public Sector Profile of the Pan-Canadian Trust Framework
CIO Strategy Council - an official standards development organization

Estonia Estonia Global ID Solution

Video Highlights of the European Commission Proposal

European Union Proposal for New E.U. ID
News on Proposal for E.U. Digital Identity

Great Britain Framework Solution

India’s Digital Identity Program - Aadhar

India Digital IDs to Land
Family Digital ID

ISO/IEC 29794 Series

ISO/IEC 29109 Series
ISO/IEC 24745
ISO/IEC 24761
Adoption of VC ISO/IEC 19784-1:2018
standards and/ ISO/IEC 24709-1:2017
or “progressive” ISO/IEC TR 29194:2015
ISO/IEC TR 29196:2015
or potentially ISO/IEC TR 30125:2016
Decentralized or ISO 19792:2015
Self-Sovereign ISO 24714:2015
Identity ISO/IEC 29100
Privacy ISO/IEC 27018
Privacy ISO/IEC 29190
Privacy ISO/ IEC 29184
Management ISO/IEC 24760 Series

The Hindawi Survey on SSI provides a summary of the pioneering technical working groups and
technology leaders in the space. But more comprehensive lists and descriptions may be found in
the accompanying appendices, which may be updated.136

29
VERTICAL FOCUS #3:
FINANCIAL SERVICES AND
TAXATION
DeFi platforms are built upon DLT infrastructure and many expected CBDC deployments are
expected to leverage the same technologies. A universal, user-centric access point to global financial
infrastructure would create efficiencies alongside the development of these transaction networks.
The Institute of International Finance published a detailed framework in the Global Assured Identity
Network (GAIN) white paper which also details use cases.139 The U.S. Financial Crimes Enforcement
Network (FinCEN) is also pursuing solutions, using collaboration and innovation platforms to explore
the efficacy of SSI implementations for financial services.140

Beyond creating an interoperable global financial network which allows rapid value exchange
without an expensive intermediary, privacy engineering made possible by Decentralized Public Key
Infrastructure (DPKI) would allow for efficient compliance tools to be developed such that capital
markets participants can protect the anonymity of holdings while still being properly identified to
challenge source of funds and identity of end users. This can root out bad actors and create further
safeguards to prevent illicit activity.

Perhaps the most valuable application of Decentralized Identity in the long run will be the
automation and standardization of tax laws. Currently, there is great political impetus to reduce tax
avoidance and evasion, as evidenced by the new Global Minimum Tax proposal.141 A more complete
description of Taxation, standards, and applications can be found in the Global Taxation section of
the GSMI 2.0 Report.

GAPS AND CHALLENGES AS

IDENTIFIED IN THE HINDAWI SURVEY
Standards for Data Management and Wallets
Standard protocols, practices, and policies around user experience, data management, and data
exchange should be carefully defined and implemented.

Key Management
In the SSI model, the responsibility for key management and its associated risks are placed on the
shoulders of the users.

Consent
As stated in the General Data Protection Regulation (GDPR) consent given by the user must be
meaningful, well-formed, unambiguous, specific, and freely given, specifying clear decisions.

Access
Certain DLT systems are public, allowing any entity to read or write to the ledger, while others are
permissioned and allow only a selection of authorized entities to read or write new records into
the ledger. If not carefully designed, the permissioned approach possesses the risk of forming a
centralized architecture similar to an oligopoly among the few authorized entities.
Accountability and authority. But in an SSI framework, the
Governance user will control their identifiers and with
Certain identity management operations such whom they would like to share them. Most
as identity claim issuance, identity lookup, developed nations are providing a legislative
and secure storage of data may rely on some template for the rest of the world to follow.
degree of centralization and dependence on
trusted intermediaries. • Interoperability and inclusion will be critical
features in decentralized identity solutions
Trust in Data going forward.
While there may be trust in the underlying SSI
network as a secure, robust, and decentralized CONCLUSION
platform, the methods to form trust among
the entities, and the trust in data including Leveraging decentralized public key
the verifiable credentials exchanged must be infrastructure as the basis for SSI frameworks
carefully designed. The authentication and is a frontier development. Standards for DID
data validation may need to be done through a methods, protocols, verifiable credential
trusted authority and outside of the blockchain formats, and other technical ambiguities
network. are being explored through trial and error.
Although the end goal involves direct
New Technology Adoption interaction with the individual, enterprise and
As a new identity model, SSI requires
government adoption are critical for rapid
various modifications to the existing system
iteration and proliferation.
architectures. Particular attention must be
given to the user experience, including the user Institutions which adopt SSI frameworks will
interactions from the operator’s perspective. create economic efficiencies and rebuild
eroding public trust. The open-source nature of
Investment and early implementations will help create a robust
Commercialization and interoperable framework which laggards
Any entity intending to adopt SSI must design a will benefit from, but early adopters will pave
strategic plan that supports the investment and the way forward. The more intangible benefits
risk involved in the deployment and operation of SSI will be portrayed in human form. By
of such a system. The SSI economic model may providing agency, basic digital identification, the
lead to the chicken and egg problem where ability to prove ownership of digital property,
user adoption depends on the support of the and banking services, each human being will
service providers and vice versa. have greater potential to self-actualize.

RECOMMENDATIONS Data exchange networks envisioned by

leaders today will allow for the “self-sovereign
• Governments are gradually adopting versions individual” to monetize their own data with
of the SSI framework, and this trend is control, autonomy, and privacy without
likelyto continue. The first solutions will not sacrificing convenience. Travel across borders
be perfect, but experimentation will prove will be seamless. Electronic healthcare records
valuable. The beauty of Web 3.0 is the open- will be accessible by the user regardless of
source nature of documentation, projects, location or insurance provider.
pilots, and case studies made available to all
who can contribute. Financial services will be accessible to more
people, who will be able to prove their identity
• Open standards and technologies will pave with multiple sources of attestation without
the way for wider adoption of decentralized recurring registration or the creation of another
identity standards globally. Stakeholders set of siloed credentials vulnerable to data
should stay informed of open-source breaches.
community developments. The Hyperledger
Foundation and other open-source The combination of public communication
consortiums frequently publish vast research networks and privacy-preserving identity
repositories and case studies. management tools will allow frictionless flow
of data and value with automated accounting
• Basic identifiers like national IDs, passports, trails and transactions. To learn more about
etc. will always be issued by the founding Digital ID, read the full report here.
31
 SECTION VI

TECHNICAL
Landscape Assessment of Standards
in Blockchain for Industry

TECHNICAL STANDARDS MAPPING

Building upon the work of GSMI 1.0 which mapped 34 technical standards, the GSMI 2.0 technical
mapping matrix includes updates to existing mapped standards, removing two dormant standards
initiatives, and five additional standards, expanding the net total mapping to 37 blockchain and
distributed ledger technology (DLT) standards.

This landscape assessment updates the state of standardization for blockchain technology and
DLT and specific examples of some of these efforts discovered in our research. Three case studies
are highlighted: 1) ITU, 2) MOBI, 3) IWA TFF, as well as an update summary of technical upgrade
proposals, and we conclude with next steps for GSMI 3.0 in 2022.

FORMAL ORGANIZATIONS
ENTITY GEOGRAPHY PURPOSE TOPIC
*Denotes New

The Baseline Protocol is an open-source initiative that combines Data; Tokens;

Baseline advances in cryptography, messaging, and blockchain to execute secure Security; Zero
Protocol142*
GLOBAL and private business processes at low cost via the public Ethereum Knowledge
Mainnet. The protocol will enable confidential and complex collaboration Proofs
between enterprises without leaving any sensitive data on-chain. (Cryptography)

The British Standards Institution (BSI) is the national standards body

BSI143
UNITED of the United Kingdom. It aims to share knowledge, innovation and DLT
KINGDOM methodologies to help people and organizations make excellence a requirements
habit.

The China Communications Standards Association is a professional

standards organization responsible for developing communications
technology standards.
CCSA China 1. Blockchain Innovation and Intellectual Property Development White
Communications Paper: 33 blockchain standards were included.
Standards CHINA
Communication
Association144* 2. Financial Distributed Ledger Technology Application Guideline is the Technology
first financial blockchain international standard project led by China. It
was approved in 2020. China wants to use this standard as a framework
to: Contribute to the planning and layout of the financial blockchain
international standards system; Create sub-standards such as reference
frames, risk control, security and privacy protection, and financial
blockchain business specifications in various fields.
 Defence &
Security,
The European Committee for Standardization (CEN provides a platform Quantum
for the development of European standards and other technical Technologies,
documents in relation to various kinds of products, materials, services Artificial
CEN144 BELGIUM and processes European Committee for Electrotechnical Standardization Intelligence,
CENELEC145 (CENELEC) prepares voluntary standards in the electrotechnical field, Smart Grids,
which help facilitate trade between countries, create new markets, cut Environment
compliance costs and support the development of a Single European and
Market. Sustainability,
Cybersecurity,
Digital Society,

The China Electronic Standardization Institute (CESI) works with

standardization, conformity assessment, and measurement activities
in the field of electronic information technologies. In the past couple
of years, CESI has come up with a vision to introduce three blockchain
standards on smart contracts, privacy, and deposits in a bid to better
guide the development of the blockchain industry in the country
The 2021 Global Industrial Internet Conference opened in Shenyang,
CESI146 CHINA the capital city of northeast China’s Liaoning Province, on Oct. 19, 2021. Tokens; Security
CESI released the White paper on the Integration and Development of
Blockchain and Industrial Internet at the Conference.
According to the “Made in China 2025” national strategic plan and the
current development of industrial blockchain in China, the White Paper
aims to accelerate the adoption of industrial blockchain applications by
making a standard system for industrial blockchain in China.

The Digital Container Shipping Association (DCSA) was created to develop Cross-
DCSA147 NETHERLANDS standards that facilitate the interoperability of technology solutions technology
across the container shipping industry. interoperability

The European Telecommunications Standards Institute (ETSI) provides Permissioned

ETSI148 FRANCE the opportunities, resources and platforms to understand, shape, drive distributed
and collaborate on globally applicable standards. ledgers

GS1149* GS1 develops global standards for business communication. Best known
BELGIUM for the barcode, GS1 standards aim to improve the efficiency, safety and Data; traceability
visibility of supply chains across physical and digital channels. Blockchain
technology is addressed by certain standards.

Internet of
things (IoT),
IEC150 SWITZERLAND The International Electrotechnical Commission (IEC) promotes quality Infrastructure
infrastructure and international trade in electrical and electronic goods. Development,
Sustainable
energy

Internet of things
(IoT);
cryptocurrency
exchange and
payment; tokens;
energy; digital
assets;
- Focus on
Blockchain in
The purpose of the Institute of Electrical and Electronics Engineers (IEEE) Healthcare (IEEE
IEEE151 U.S. is to promote the development and application of electrotechnology P2418.6)
and allied sciences for the benefit of humanity, the advancement of the - Agriculture DLT
profession and the well-being of its members. (IEEE P2418.3)
- Blockchain
Governance
(IEEE P2145 &
IEEE P3212)
- Smart Legal
Contracts (IEEE
P2963)

Cryptocurrency
The purpose of the Internet Engineering Task Force (IETF) is to make payment,
IETF152 U.S. the Internet work better by producing high quality, relevant technical Internet of
documents that influence the way people design, use, and manage the Things (IOT),
Internet. Security and
Privacy
 International The ICC launched the Digital Standards Initiative (DSI)to enable Digital
Chamber of FRANCE interoperability between blockchain and other technology platforms in interoperability
Commerce (ICC)153 the global trade space.

IRTF154 U.S. The Internet Research Task Force (IRTF) aims to promote research for the Identity; digital
evolution of the internet. assets

Security;
The International Organization for Standardization (ISO) is an privacy; identity;
ISO155 SWITZERLAND independent, non-governmental, international organization that interoperability;
develops standards to ensure the quality, safety and efficiency of governance;
products, services and systems. smart contracts

Security; IoT;
identity; DLT
The International Telecommunication Union Telecommunications (ITU-T) requirements;
sector ensures the efficient and timely production of standards covering mobile payment
ITU-T156 SWITZERLAND all fields of telecommunications and information communication security;
technology (ICTs) on a worldwide basis, and defines tariff and accounting digital financial
principles for international telecommunication services. inclusion; digital
assets including
digital currency

The Standardization Administration of the P.R.C. (SAC) exercises DLT

SAC157 CHINA administrative responsibilities by undertaking unified management, requirements
supervision and overall coordination of standardization work in China.

Standardization
Standardization
Technical The Standardization Technical Committee is responsible for verifying Technical
Committee of China CHINA all drafted standards and making development strategies for the Committee of
Food Association Association. Recent updates: Management Requirements for Food China Food
New* Traceability Blockchain Application (under released). Association

Security; DLT
Standards AUSTRALIA Standards Australia coordinates standardization activities and facilitates taxonomy
Australia158 the development of Australian standards.

The World Intellectual Property Organization (WIPO): 1) promotes Application

the protection of intellectual property throughout the world through of blockchain
WIPO 159 SWITZERLAND cooperation among states and, where appropriate, in collaboration to intellectual
with any other international organization; and 2) ensures administrative property
cooperation among unions.

The Worldwide Web Consortium (W3C) is developing protocols and

W3C160 N/A guidelines that ensure long-term growth for the web. It is an agreement Identity,
amongst 4 host participants: MIT, INRIA (France), Keio University (Japan), Verifiable claims
and Beihang University (China) + its nearly 400 members.

The Blockchain Standardization Technical Committee was initiated by the

Zhejiang Blockchain Economy and Information Technology Department of Zhejiang Province
Standardization with committee members like Zhejiang University, Ant Financial and
Technical CHINA 8BTC. dApps, DID
Committee*
The Committee is working to promote the advancement of the
blockchain industry by undertaking and developing blockchain standards
for Zhejiang Province.
 INDUSTRY GROUPS
ENTITY GEOGRAPHY PURPOSE TOPIC
*Denotes New

The Blockchain Industrial Alliance (BIA) seeks to promote cross- Interoperability,

BIA161 ESTONIA blockchain transactions and interconnectivity. The goal of this alliance is Smart Chains,
to create a globally accepted standard for connecting blockchains and to Blockchain
bring innovations together. Platforms

DLT
The Blockchain Industry Group (BIG) is dedicated to the advancement requirements
BIG162 CANADA and adoption of blockchain technologies through the development (in progress),
and promotion of blockchain standards, education, certifications and Governance,
collaboration. Education

The Blockchain in Transport Alliance (BiTA) Standards Council is seeking Interoperability;

BiTA Standards U.S. to develop and embrace a common framework and standards from DLT
Council163 which transport/logistics/supply-chain participants can build blockchain requirements
applications.

Interoperability;
The Enterprise Ethereum Alliance (EEA) builds, promotes, and broadly security; cross
EEA164 U.S. supports Ethereum-based technology methodologies, standards and a chain, NIST-
reference architecture. compatible
Ethereum;

Global Digital Finance (GDF) is an industry membership body that

promotes the adoption of best practices for cryptoassets and digital DLT
GDF165 UK finance technologies, through the development of conduct standards, requirements
in a shared engagement forum with market participants, policy- makers
and regulators.

The Hyperledger Foundation is an open-source community focused

on developing a suite of stable frameworks, tools and libraries for
enterprise-grade blockchain deployments. Interoperability;
tokens;
Hyperledger
Foundation166
U.S. It serves as a neutral home for various distributed ledger frameworks, blockchain
including: Hyperledger Besu, Burrow, Fabric, Sawtooth, Iroha, and Indy; platforms;
tools such as Hyperledger Avalon, Caliper, Cactus, Cello, Explorer, and identity
Firefly; domain-specific projects such as Hyperledger Grid; and libraries
such as Hyperledger Ursa, Aries, Quilt, and Transact.

Core Carbon
Principles (CCPs),
The Taskforce on Scaling Voluntary Carbon Markets (TSVCM) is a private Governance,
Institute of sector-led initiative working to scale an effective and efficient voluntary Legal Principles
International
U.S. AND carbon market to help meet the goals of the Paris Agreement. The task & Contracts
Finance (IIF) and
GLOBAL force is led by the Institute of International Finance (IIF) The Taskforce’s Credit Level
TSVCM167 OFFICES OF IIF unique value proposition has been to bring all parts of the value chain to Integrity in
work intensively together and to provide recommended actions for the Voluntary
most pressing pain-points facing voluntary carbon markets. Markets

The InterWork Alliance (IWA) is working to: develop standards-based Interoperability;

interworking specifications at the token and smart contract level; tokens (Token
simplify and standardize multi-party exchanges; and build specifications Taxonomy
and tools to define tokens and smart contracts in a platform-neutral Framework);
IWA168 U.S. way. IWA does not focus on the underlying technology, as digital smart contracts
interchanges of value must work regardless of the underlying technology (InterWork
to grow at scale. Instead, IWA focuses on defining token/smart Framework);
contract requirements, and developing taxonomies and definitions for carbon markets;
tokenization and smart contracts for identified use cases such as carbon debt/equity
markets and debt/equity issuance. issuance
 The Joint Working Group on interVASP Messaging Standards (JWG)
identified the need for VASPs to adopt uniform approaches and establish
common standards to enable them to meet their obligations resulting
U.S. from the FATF recommendations as they apply to affected entities.
JWG169 AND UK Tokens
To tackle this, a cross-industry, cross-sectoral joint working group of
technical experts was formed in December 2019 and a new technical
standard developed by the group.

Vehicle identity;
usage-based
insurance;
electric vehicle
grid integration;
The Mobility Open Blockchain Initiative (MOBI)’s Vehicle Identity Working connected
MOBI170 U.S. Group (VIWG) aims to use DLT to make mobility safer, greener, cheaper mobility and data
and more accessible. marketplace;
supply chain
and finance;
securitization
and smart
contracts

National Blockchain
and Distributed DLT
Ledger Technology CHINA This is a group of organizations that have joined a national committee requirements;
Standardization focused on creating standards for blockchain technology. DLT terminology
Technical
Committee171

MAJOR STANDARD-SETTING EFFORTS – PROPOSALS

• Bitcoin improvement proposals (BIPS)172

• Ethereum improvement proposals (EIPs)173

• zCash improvement proposals (ZIPs)174

• -XRP ledger amendments175

• Diem improvement proposals (DIPS)176

CASE STUDY #1:
ITU-T STANDARDIZATION SECTOR
STANDARDIZATION WORK ON
DLT UPDATE
BACKGROUND • research security and privacy aspects related to
e-services based on DLT;
The FG DLT was established in May 2017 and • examine means for extending online trust in
completed its work in 2019. It aimed to: the context of e-services using DLT;

• Identify and analyze DLT-based applications In addition, other study groups where
and services standardization work on DLT is happening
• Draw up best practices and guidance include:
• Propose a way forward for related
standardization work in ITU-T study groups. • ITU-T Study Group 3: Economic and Policy
Issues. The standardization work on DLT
STANDARDS here focuses on its application in accounting/
settlement process in telecoms
Several specifications and reports have been • ITU-T Study Group 13: Future networks, with
made available through the FG DLT, such as focus on IMT-2020, cloud computing and
DLT terms and definitions, DLT use cases and trusted network infrastructures
assessment criteria for DLT platforms. Next to the • ITU-T Study Group 17: Security
FG DLT, ITU-T consists of several study groups • ITU-T Study Group 20: Internet of things (IoT)
focusing on a specific topic together with DLT. and smart cities and communities (SC&C)
• ITU-T Focus Group on Environmental Efficiency
In particular, Question 22 of ITU-T Study Group for Artificial Intelligence and Other Emerging
16 focuses on multimedia aspects of DLT Technologies (FG-AI4EE)
related systems and their use in e-services
(e.g., healthcare, supply chain logistics, telecom, Following the completion of the work of the ITU-T
financial services, etc.). Study items in Question Focus Group on Digital Currency including Digital
22 include, but are not limited to: Fiat Currency in 2019, the ITU established the
Digital Currency Global Initiative in collaboration
• concepts, coverage, vision, and use cases of with Future of Digital Currency Initiative of
e-services based on DLT; Stanford University in 2020. The Digital Currency
• characteristics and requirements for e-services Global Initiative work is to investigate areas
based on DLT; where technical standards would be needed
• architectural framework and communication for integrating central bank digital currencies,
technologies of e- services based on DLT; stablecoins and cryptocurrencies to existing
• analysis and evaluation of the current status of payment system and also study the applications
DLT and its maturity to support e-services; of DLT in enabling this to happen. The Digital
• investigate the relations between DLT, digital Currency Global Initiative consists of three
fiat currencies and crypto tokens, including working groups:
management, exchange and transactions, etc.;
• define general requirements and framework for • Policy & Governance,
DLT; • Architecture, Interoperability Requirements and
use cases

37
 CASE STUDY #2:
MOBI UPDATE
The standards developed by MOBI serve as partners while complying with emerging
a foundation for the mobiNET network. The regulatory and industry best practices for
mobiNET will offer mobility stakeholders and preserving data privacy and property rights.
related businesses an open and inclusive The CMDM Standards provide a foundation
core services infrastructure for decentralized for a multitude of applications, including but
transactions at the edge. The goal is to unlock not limited to V2X data exchange, connected
monetization opportunities across mobility and vehicle commerce, and sharing/monetizing
transportation services by allowing application AV driving data for better driving algorithms
interoperability and multi-party data sharing. through machine learning.

• New standards from the Vehicle Identity The FSSC working group strives to improve
(VID), Electric Vehicle Grid Integration (EVGI), accuracy and transparency, create operational
Connected Mobility Data Marketplace (CMDM), efficiencies, minimize fraud risks, and save on
Finance, Securitization, and Smart Contracts costs and time in the execution of financings,
(FSSC), and Supply Chain (SC) working groups including securitizations, for all entities in
the financing lifecycle. The FSSC Standards
Updated description for the VID working group: leverage distributed ledger technologies to
create a trust layer for transactions and data
The VID working group aims to define a exchange within a shared digital ecosystem.
digital document that is a verifiable link to a
specific vehicle, a minimum representation of The SC working group assesses the value
that vehicle’s digital twin. VID can be used to proposition of blockchain in mobility supply
establish existence, manage access control, chain management for stakeholders of
confirm ownership history, and contain key the procurement, logistics, and finance
events in the life of a vehicle. or accounting divisions, including Original
Equipment Manufacturers, N-tier suppliers,
Descriptions for the other working groups: and further business partners. The group aims
to create interoperability standards to bring
The EVGI working group aims to aid the operational efficiencies and increased visibility
increasing adoption of electric vehicles through the N-tiers; enable provenance,
by creating interoperable systems for tracking, and authenticity of parts and vehicles;
governments, utilities, and the mobility and improve conflict resolution and settlement
industry alike. These systems will enable a with distributed ledger technology (DLT).
better way to manage the grid load, calculate
carbon offsets, and generate carbon credits, MOBI are also working on a layer above the
facilitating the implementation of peer-to-peer mobiNET, which is named Citopia. Citopia is a
services. The first standard defines the system, multimodal mobility payments platform built
and data requirements for three core use case on blockchain that allows for the monetization
areas: Vehicle to Grid (V2G), Peer to Peer (P2P), of infrastructure use (i.e., road usage) and
and Tokenized Carbon Credits (TCC). other new mobility services. The following
information was pulled from the MOBI website
The CMDM working group aims to on the specific MOBI Working Group standards:
enable a DLT-based data marketplace for MOBI has a number of working groups that are
all stakeholders of the mobility ecosystem creating different types of standards. Anyone
— including OEMs, insurance providers, can gain full access to their white papers
infrastructure operators, and others — to and use cases and business requirements
effectively share data with their business documents and partial access to the technical

38
 specifications and reference implementation architectures. MOBI members are provided full access
to the technical specifications and the reference implementation architectures.

0001 – Business MOBI Business White Papers are high-level business reviews that discuss
White Papers (WP) issues and propose solutions to the world’s most pressing transportation
challenges with consideration to ecosystem stakeholders, new strategies,
emerging technologies, and global policies.

0002 – Use Cases MOBI Use Cases and Business Requirements documents describe pain
and Business points, stakeholder responsibilities, and high-level business requirements
Requirements (UC) potential solutions must meet in order to resolve stakeholder needs.
UCs also detail workflows for particular applications and are technology-
agnostic.

0003 – Technical MOBI Technical Specifications define recommended minimum interfaces

Specifications (TS) between systems/modules and data specification exchanged in the
process leading up to a reference implementation. This process allows
independently developed systems to be interoperable.

0004 – Reference MOBI Reference Implementation Architectures prescribe and

Implementation recommend a solution architecture stakeholders can refer to when they
Architectures (RI) deploy solutions, ensuring that stakeholder requirements described in TS
and UC are met in the process. RIs are vendor-agnostic.

Standards in • MOBI VID0001/WP/2021 — VERSION 2.0 – VID Business White Paper

Vehicle Identity • MOBI VID0003/TS/2019 — VERSION 1.0 – VID I Technical Specifications
(3 new/updated
standards since GSMI 1.0) • MOBI VID0002/UC/2021 – VERSION 2.0 – VID II Use Cases and Business
Requirements
• MOBI VID0004/RI/2021 – VERSION 1.0 – VID II Reference
Implementation Architecture

Standards in • MOBI EVGI0001/WP/2020 – Version 1.1 – EVGI Business White Paper

Electric Vehicle Grid • MOBI EVGI0003/TS/2020 – Version 1.0 – EVGI Technical Specifications
Integration (EVGI)
(new since GSMI 1.0)

Standards in • MOBI CMDM0001/WP/2021 – Version 1.0 – CMDM Business White

Connected Mobility Paper
Data Marketplace
(CMDM) (new since • MOBI CMDM0003/TS/2021 – Version 1.0 – CMDM Technical
GSMI 1.0) Specifications

Standards in Finance, • MOBI FSSC0001/WP/2021 – Version 1.0 – FSSC Business White Paper
Securitization, and • MOBI FSSC0003/TS/2021 – Version 1.0 – FSSC Technical Specifications
Smart Contracts
(FSSC) (new since
GSMI 1.0)

Standards in Supply • MOBI SC0002/UC/2021 – Version 1.0 – SC Use Cases and Business
Chain (SC) (new since Requirements
GSMI 1.0)
• MOBI SC0004/RI/2021 – Version 1.0 – SC Reference Implementation
Architecture
 CASE STUDY #3:
TOKEN TAXONOMY FRAMEWORK
OVERVIEW, SPECIFICATIONS, AND
IMPLEMENTATIONS
Tokens will disrupt global economics and radically change how commerce will be transacted.
While various implementations exist today for tokens specific to numerous blockchain
platforms, the industry lacks a venue for all participants to collaborate on a shared description
and approach – resulting in a lack of interoperability, reuse, and common ground to address
regulatory issues. The IWA is a member-led non-profit with over 30 organizations mapping
requirements and artifacts into a variety of use cases. The IWA working groups are developing a
clear definition and scope of the token concept including use cases, taxonomy and terminology,
and a specification neutral to the underlying technology.

BACKGROUND • Clearly define common token concepts and

terms in non-technical and cross-industry
The Token Taxonomy Framework (TTF) is language using real world, everyday analogies
an open-source, extendable framework for so that business, technical, and regulatory
defining and tokenizing digital assets, and participants can understand them.
serves as one of the core technical frameworks
for the InterWork Alliance (IWA), a GBBC • Produce token definitions that have clear
initiative focused on creating standards around and well-understood requirements for
tokenization to promote interoperability and token properties and behaviors that are
cooperation. The goal of the TTF is to provide implementation neutral for developers to
a language by which tokens can be discussed, follow and standards organizations to validate.
architected, and standardized across industry
verticals. • Establish a base Token Classification
Hierarchy, driven by metadata, that is simple
The view of the TTF is that a token can be broken to understand and navigate for anyone
down into a core set of attributes: a token base interested in learning and discovering tokens
type (e.g., fungible or non-fungible), properties and underlying implementations.
(data contained in the token, e.g., manifest data),
and behaviors (e.g., transferable, burnable, etc.). • Deliver tooling meta-data that enables the
Using these artifacts, one can construct a whole generation of visual representations of
new token based on a repository of artifacts that classifications, and modelling tools to view
are contributed by the IWA membership. This and create token definitions mapped to the
open source, composable framework allows taxonomy.
for artifacts to be repurposed to meet the
requirements of new use cases. • Produce standard artifacts and control
message descriptions mapped to the
The Token Taxonomy Framework bridges taxonomy that are implementation neutral and
the gap between developers, line of business provide base components and controls that
executives, and regulators, allowing them to consortia, startups, platforms, or regulators
work together to model existing and define can use to work together.
new business models based on tokens. The
Framework’s purpose is to: • Encourage differentiation and vertical
specialization while maintaining an
interoperable base.

40
RESOURCES

REAL-WORLD TTF (7-STEP JOURNEY)

TOKEN TAXONOMY FRAMEWORK PUBLIC GITHUB

INTRODUCTION TO TOKEN TAXONOMY FRAMEWORK

TOKEN TAXONOMY SPECIFICATIONS

TOKEN TAXONOMY IMPLEMENTATIONS

TOKEN TAXONOMY AND CENTRAL BANK DIGITAL CURRENCY (CBDC)

TOKEN TAXONOMY AND VOLUNTARY ECOLOGICAL MARKETS WHITE PAPER

CARBON REMOVAL AND THE DIGITAL MEASUREMENT, REPORTING & VERIFICATION FRAME-
WORK BUILT WITH THE TOKEN TAXONOMY FRAMEWORK

HEDERA & THE HBAR FOUNDATION ANNOUNCE THE FIRST OPEN SOURCE TTF REFERENCE IM-
PLEMENTATION FOR PARTNER ECOSYSTEMS.

IWA OPEN-SOURCE TOKEN DESIGNER TOOL

GITHUB – INTERWORKALLIANCE/TOKEN-DESIGNER: VS CODE EXTENSION THAT FACILITATES
MANIPULATION OF ARTIFACTS IN THE TOKEN TAXONOMY FRAMEWORK

GSMI 1.0 WEF APPENDIX A

REFERENCE ARCHITECTURE COMPARISON: FUNCTIONS OF STANDARDS IN KNOWLEDGE-IN-
TENSIVE INDUSTRIES

NEXT STEPS
Blockchain and DLT standards, both formal and industry-led, continue to evolve and
remain at nascent stages. Areas of further technical mapping include interoperability,
Layer 2 protocols, DeFi protocols, Decentralized Autonomous Organizations (DAOs),
and other standards bodies which emerge as the industry evolves in 2022 for GSMI 3.0.
In addition to mapping technical standards, there is development work in the areas of
standards in blockchain / DLT audit, certification, security, and environmental impact
metrics which may be explored in the future. The GSMI Technical Working Group
welcomes suggestions for improvements and additions.

41
 SECTION VII

GREEN ECONOMY
The word “green” has been used for years as a vague placeholder for taking care of, and
improving, the world’s natural resources. Our working group’s goal is to make “green”
quantifiable. A significant number of organizations are using technology to tackle the world’s
environmental problems; this working group has examined their work, documented the most
relevant initiatives, and highlighted key topics to inform and recommend how those in the
market can address these challenges moving forward.

DEFINING THE
‘GREEN ECONOMY’ 1. The data available for buyers of carbon credit
offsets does not meet sufficient due diligence
The International Chamber of Commerce (ICC) standards for most global corporations; and
defines a green economy as “embedded in the
broader sustainability development concept” and 2. The supply of carbon credit offsets
“as an economy in which economic growth and associated with removing CO2 from the
environmental responsibility work together in atmosphere accounts for only around 5% of
a mutually reinforcing fashion while supporting the market.
progress on social development.”177 More simply,
a green economy is defined as an economy Many expect carbon credit offsets related to
that is low carbon, resource efficient, and removal of CO2 to become the most dominant
socially inclusive. The Organisation for Economic part of the market given the correct governance
Co-operation and Development (OECD) has framework.180 Where will these offsets be found?
identified six strategic pillars in its Green Growth According to Drawdown by Paul Hawken, the top
Strategy, including: solutions to global warming (with a total potential
carbon savings of 584 Gigatons of CO2e by
1. Climate change the year 2050)181 will be found in refrigeration,
wind turbines, reduced food waste, plant rich
2. Resource saving and management diet, tropical forest, women’s education, family
planning, solar farms, silvopasture, and rooftop
3. Circular economy solar.

4. Environmental protection Because CO2 emissions in these areas are

harmful, organizations are working together to
5. Ecosystem protection and recovery target net-zero carbon emissions. While carbon
credits are not the only solution, they have a
6. Water conservation and natural disaster quantifiable impact and identify core principles
prevention.178 that are critical to driving such an impact.

Regulatory changes across the developed world GREEN MARKETPLACE

are obliging institutions to be more honest
For this paper, “green” is defined as an aggregate
about carbon neutrality claims. Entities are now
of players from both the supply and demand
working to reduce carbon dioxide emissions
side who want low energy consumption and less
or other greenhouse gases to compensate
waste; they use sustainable materials, follow
for emissions made elsewhere. This is known
environmental laws and regulations, and want
as carbon offset. The demand for voluntary
to both quantify and verify their valuations in
carbon offsets is estimated to be at U.S.$50B
an auditable way. A “green” product, service
by 2030; this is still in a very early growth
or solution is one that contributes to the
phase.179 The success of carbon credit offsets
marketplace by reducing or offsetting carbon/
has been constantly hampered by two constant
pollution footprints. This can often be achieved
challenges:

42
by purchasing Renewable Energy Certificates
ROLES AND
(RECs), Carbon Credits, or using other
systems – such as 24-hour renewable power
RESPONSIBILITIES
procurement. To effectively impact communities and focus
recommendations, it is important to understand
The cost of offsetting corporate carbon participants in the global marketplace. Key
emissions is expected to surge over the players and their roles in the marketplace
next decade.182 As more organizations take include:
on “green” initiatives, the growth in demand
for carbon credits will outpace the supply • Supra-national organizations
of measurable and verifiable offsets. In Agenda setting and global initiatives and
addition to the demand for carbon credits, commitments
organizations are looking to offset energy
usage with RECs. Corporate giants like • Governments
Microsoft have recognized that “while we Regulations, task force investigations into
can’t control how our energy is made, we “green” systems and enhancement, as well
can influence the way that we purchase our as Voluntary Carbon Market Investment
energy.”183 Promotion Agencies (IPAs), branches of
existing investment agencies or as new
Electricity currently generates 25% of the institutions, helping countries attract private
world’s greenhouse gas emissions.184 A investment from the VCM and support
carbon-free electricity sector, is considered the national climate objectives.
foundation for decarbonizing other sectors of
the economy, establishing net-zero emissions, • Producers/Project Developers
and creating a green global economy.185 Carbon offsetting and renewable energy
procurement solutions, following market
Traditionally, matching energy supply and and technical standards organizations (IWA,
demand has been one of the largest problems TSVCM, ISO, EWF, RMI, AIR, CCA, VCS, “The
of the transition to renewable energy.186 Gold Standard”, CAR, ACR)
Today, technologies facilitate 24/7 carbon-
free energy,187 which focuses on matching • Financial
Institutions/
the temporal and spatial particulars of clean Exchanges
energy and an organization’s energy load Providing a way to easily trade carbon credits/
profile.188 The new trend of 24/7 energy tokens, creating tokens to trade.
procurement will pave the path to true net-
zero emissions for many. • Financiers
Providing energy projects finance (e.g.,
There are two major types of carbon markets: sequestration project funding, Rabo Carbon
voluntary and regulated. The voluntary markets Bank).
are not under any governmental agency or
regulatory control or sanction, which means • Standards Organizations
participants are active based on natural market Managing measurement standards,
forces or social responsibility to the consumers additionality, permanence, preventing leakage.
in the market. For example, environmental,
social and governance (ESG) criteria, defined by • Registries
socially conscious investors, are used to screen Institutions that can record and validate if an
potential investments based on company organization has followed specific protocols.
operations. Regulated markets, on the other
hand, require a governmental agency, either • Verifiers/Auditors
a nation-state or treaty, to enforce industry Individuals who have the authority to
compliance.189 determine if the claims of an organization are
correct.

43
 • Retailers
Using carbon offsets in their production and
other operations.

• Consumers
Purchasing from retailers who are following
green standards.

• Decarbonization consultants
Working with businesses on supply chain and
Scope 3 emissions (the result of activities from
assets not owned or controlled by the reporting
organization190), measurement, reduction, and
offset.

• Tech companies
Providing trackers (including trackers integrated
with bank account or spending data), as well as
bilateral offset solutions.

• HR/Employee solutions
Offsetting for businesses in terms of their
employee and operational footprint.

HOW DO THESE ROLES

FUNCTION WITHIN
THE VOLUNTARY AND
MANDATORY MARKETS?
The Voluntary Carbon Market (VCM) offers tools
to estimate and measure GHG emissions and
removals, and - by utilizing a range of standards,
protocols, and greenhouse gas (GHG) crediting
programs - enables the creation of tradable
carbon credits. The VCM enables private actors
to drive climate benefits beyond their own
operations. The VCM typically complements the
United Nations Framework Convention on climate
change known as the Kyoto Protocol, and other
regulated carbon markets, with VCM project
developers filling gaps left by the mandatory
market.

Both the direct and indirect economic impacts of

the VCM and their subsequent contributions to
the Green Economy can be significant. A study
from the Imperial College and the International
Carbon Reduction & Offset Alliance (ICROA)
estimates that each ton of emission reduction
from a voluntary project creates value two orders
of magnitude greater than the average carbon
price.191 These benefits include local employment

44 44
in the projects, the use of local products and services when implementing and operating projects,
provision of services or products for the local economy, conservation of domestic ecosystems,
technology transfer, capacity building using new technologies, and empowerment of local
communities.

Entities engage in the VCM to identify cost-effective solutions to reduce their corporate carbon
footprint or to meet carbon neutrality or net-zero goals. While some companies prefer to purchase
carbon credits from small, locally owned mitigation projects, corporations typically look to purchase
credits from larger-scale (often “charismatic”) projects. These projects generate high volumes of
credits, thereby reducing buyers’ transaction costs, while providing social and environmental co-
benefits. Corporations also seek to avoid reputational damage by requiring robust environmental
integrity of the carbon credits they purchase.192 The surge in companies seeking to offset both direct
and indirect carbon generation has precipitated a supply and demand issue. Trends worth noting
include:

• Carbon pricing (sufficiently high) is considered part of the essential framework for creating real
value implications for high carbon activity, thereby changing business and consumer behavior

• Business, consumer, finance, and investment product development around carbon offsets and
markets is increasing

• Incentives include the ability to connect with consumers, maintain social responsibility, and
improve the effects of climate change

• Voluntary blockchain-based carbon projects include DOVU, puro.earth, REDD+, UPCO2,

Nori, CarbonX, Moss.earth, AIR Carbon, and Xpansiv; these projects are in the early stages of
development; many have secured significant financial backing to support their efforts – most are
contributing market requirements to develop correct mapping for standardization.

Carbon registries and standards vary in diligence and stringency. Requirements and obligations
between parties must be contractual to ensure the necessary standards are met. Carbon registries
have their own terms of use and explicit provisions limiting their liabilities. Arguably, a better
regulated market would provide for greater environmental integrity, transparency, and legal
certainty.

Mandatory Markets are used by entities required to show proof of offsetting carbon
emissions. The United Nations Framework Convention on Climate Change (UNFCCC), formed in
1992, established the foundation upon which the Kyoto Protocols of 1997 and the subsequent Paris
Agreements of 2016 were built. These internationally binding agreements created the Nationally
Determined Contributions (NDC) by which Countries party to the U.N.’s Framework Convention on
Climate Change (UNFCCC) may set up mandatory reporting programs to improve national inventory
estimates.
 NATIONAL, REGIONAL, AND SUBNATIONAL
JURISDICTIONS WITH MANDATORY AND PROPOSED
MANDATORY REPORTING REQUIREMENTS INCLUDE:
Australia National Greenhouse and Energy Reporting Scheme

California Mandatory GHG Reporting Program

Canada GHG Emissions Reporting Program

China Proposed national reporting program

European Union E.U. Emissions Trading System

France Bilan d’Emission de GES

Japan Mandatory GHG Accounting and Reporting System

Mexico National Emissions Registry

Norway Emissions Trading System

South Africa Proposed national GHG reporting program

Turkey GHG Reporting Scheme

United Kingdom GHG Reporting Program

United States GHG Reporting Program

In the U.S. in 2009, GHGs that represent the largest drivers of human-caused climate change
(carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur
hexafluoride) were ruled to endanger public health by the U.S. Environmental Protection Agency
(EPA). They are thereby subject to the Clean Air Act. Starting in 2010, large emitters of greenhouse
gases were required to begin collecting data under a new reporting system. In 2011, fossil fuel
and industrial GHG suppliers, motor vehicle and engine manufacturers, and facilities that emit
25,000 metric tons or more of CO2 equivalent per year began to report GHG emissions data to EPA
annually; these metrics have formed the basis of NDC reporting under the Paris Agreement in the
U.S.193

These NDCs help to develop economy-wide or sector-specific programs that address national and
subnational priorities and objectives. The Paris Agreement is one of the most prominent examples
of a mandatory market and is the basis for most demand metrics. Its goal is to limit global warming
to well below 2 (preferably 1.5) degrees Celsius, compared to pre-industrial levels. This is the basis
for most demand metrics. The Paris Agreement provides a framework for financial, technical, and
capacity building support for interested countries.
IT’S NOT EASY we are to avert potential tipping points

BEING GREEN • Scaled up action

The latest Intergovernmental Panel on Ambitions must be raised to make significant
Climate Change (IPCC) report stated that investments in climate mitigation outside of
climate change is “widespread, rapid, and immediate value chains
intensifying.”194
• Transparent action
Stabilizing the climate will require significant, The scope, boundary, use of carbon credits,
sustained reductions in greenhouse gas and terminologies used in commitments
emissions. must be transparent; progress and learnings
are publicly reported
If green or carbon markets are going to be
used as the primary vehicles for responding • NDC enabling action
to climate change, certain issues must be Companies contribute to the finance flows
addressed. Organizations including the Science needed to achieve climate ambition in
Based Targets Initiative, Science Based Targets Nationally Determined Contributions (NDCs)
Network, Natural Climate Solutions Alliance, under the Paris Agreement
Oxford Principles for Net-Zero Aligned Carbon
Offsetting, Greenhouse Gas Protocol, Climate • Consistent action
Disclosure Standards Board, and Task Force Companies require climate action plans
on Climate-Related Financial Disclosures agree that fully align their businesses with net
the following climate principles are critical to zero, including everything from investments,
aligning carbon markets with the ambitions of governance structures, lobbying efforts,
the Paris Agreement: and the advocacy of affiliated industry
associations
• Science-based action
Companies align with science-based • Collective and predictable
mitigation hierarchy – emission reductions action
should be first-order priority in value chains Companies align VCM engagement with host
country policies and work in partnership
• Comprehensive action with other corporations, NGOs, and local
Climate targets and action are built on stakeholders
accurate and complete greenhouse gas
inventories in-line with the requirements set THE CHALLENGES -
out in the GHG Protocol DIFFERENT, SILOED
STANDARDS AND
• Equity oriented METHODOLOGIES
Climate targets should be consistent
with achievement of broader sustainable Though reputable carbon standards seek
development goals and the concept of a “just to verify carbon credits, there is not yet a
transition” formalized standard for real and verified
carbon credits regarding common quality
• Nature-positive features: (i) robust baselines; (ii) additionality;
Efforts should prevent or mitigate nature (iii) permanence of emission reductions or
and biodiversity loss; move toward a nature- removals; (iv) addressing leakage; and (v)
positive state of recovery and renewal absence of double counting. VCM registries
enable the public to view some details about
• Rapid action projects and carbon credits, but differences
Goals should target immediate action on in methods used to collect and organize data
climate, recognizing this decade is critical if make comparison difficult. Data is not always

47
detailed enough to conduct independent assessments of carbon credit quality features, and the
price may not always be indicative of the quality of carbon credits.

VALIDATING CLAIMS - NET ZERO, CARBON NEUTRAL

CLAIMS OR ASPIRATIONS
It is critical to ensure claims are true, clear, and relevant to their target audience and substantiated
with objective, transparent, and up-to-date data. Additionally, they should not overstate their
beneficial environmental impacts and avoid creating a false impression or hiding trade-offs.

HOW DO WE SCALE UP HIGH QUALITY CARBON

PROJECTS TO ACCELERATE OUR TRANSITION TO NET-
ZERO, AND HOW CAN BLOCKCHAIN HELP ACHIEVE
THESE GOALS?
Some companies make environmental or ecological claims regarding environmentally friendly
practices they follow. To push companies in the right direction while making green practices easily
adoptable, organizations like the Taskforce for Scaling Voluntary Carbon Markets (TSVCM), Crypto
Climate Accord (CCA), and others have published standards to reduce carbon in our atmosphere.
Blockchain can help solve these problems. However, it is important to note that energy use is an
increasing problem for the climate. Although the Proof-of-Work (PoW) consensus, popularized by
Bitcoin, provides immense security and decentralization, it uses much more energy than other
consensus mechanisms like Proof-of-Stake (PoS). The Bitcoin blockchain has about the same carbon
footprint as the country of Chile.195 Several blockchain protocols are being developed that address
this problem; it is critical that blockchains are interoperable and allow for multi-party interaction so
that they do not contribute to this problem.

ALIGNMENT, SCALE, AND SOLUTIONS

The problems outlined above cannot be addressed if technology solutions are not aligned for
specific use cases. Many legacy technology solutions are not working because they are not scalable,
measurable, or results are not tangible, leading to incentives that are not aligned. But blockchain is
proving to be a powerful technology because it can facilitate an ecosystem of value exchange across
industries. On the demand side for removals via credits,
IWA mapped an open source, interoperable
Robert Opp, Chief Digital Officer for the United token that aligns with the TSVCM’s Core
Nations Digital Program, stated that blockchain Carbon Principles (CCP). The CCP defines a
can play a significant role in creating digital “token” as representing a specified volume
ecosystems by understanding the ecosystems, of metric tons of GHG emissions reduced
identifying their core use cases, and validating or removed by a project. The technique for
the areas they can impact by providing a reduction or removal of GHGs in a project, its
scorecard on impact toward the SDGs196. measurement, and verification methodology
are found in the Verification Contract and the
The results can be measured, promoted, issuing standard registry.
and funded. Blockchain technology is either
introducing or improving the following digital The CCP is a tradeable digital asset whose
ecosystems: digital identification, supply chain price is determined by the market using the
traceability, energy, remittances, financial associated information. The CCP has standard
inclusions, and land registries by: data elements that represent the shared
view required by the parties in the carbon
Allowing for efficient multi-party market from suppliers, buyers, validation
tracking, traceability, and proof of and verification bodies (VVBs), registries, and
green reporting, making it possible to exchanges. These standard data elements
track the journey of the carbon credits are based on the recommendations from the
and carbon in the atmosphere TSVCM.

Preventing “double-spending,” a vital Working together with TSVCM, IWA introduced

piece when it comes to offsetting its tokenization recommendations in May
carbon 2021. Every CCP must be unique to derive
value in a market. The following is an overview
Enhancing transparency, security, and of the artifacts of data that are unique and
creating a trustless environment. valuable. Public blockchains make these
features applicable and useful within a green
Green Standards Organizations are also market. The CCP Token has the following
defining and aligning basic taxonomy, behaviors and properties: ● It is a fungible
especially around tokenization, which token (think of this as a quantifiable asset for
is covered in depth in the technical and exchange) that represents one metric ton of
taxonomy sections of GSMI 2.0. CO2 (mtCO2) or 1 mtCO2e that validates either
a reduction, avoidance, or removal.
DEFINING AND TRADING
DIGITAL VERSIONS OF • It is divisible, transferable, encumbered,
TANGIBLE ASSETS revokable, delegable, offsetable, and
mintable with role support
An example of this is TSVCM’s Core Carbon
Principles for tokenization of digital assets. • It includes a Unique identifier (ID) that is
TSVCM published this blueprint to create a assigned when issued and sets this specific
large-scale, transparent carbon credit trading asset apart and gives it unique value;
market. A large-scale voluntary carbon market established and anchored on a public
is critical to reaching the goals of the Paris blockchain along with any relevant static data
Agreement as it enables companies to turn about the asset and any dynamic “events”
net-zero commitments into action through associated with the asset
investments in emissions abatement projects.
• Includes an Owner: The ID of the account
For a voluntary market to flourish, a standard that is the owner of the token
must be defined for the tokenization of assets.

49
• Includes an Issuer: The ID for the issuing standard registry or record of activity
It must also validate the following Core Carbon Attributes (CCA), or a set of properties where the
values can differ significantly between CCPs and allows comparisons and groupings of like CCPs
together. Core Carbon Principles will contain some or all of the following:

• AssetID
The serial number or unique identifier of the referenced credit on the standard registry that the
token represents, where this identifier is established and anchored on a public blockchain along
with any relevant static data about the asset and any dynamic “events” associated with this asset.

• Issuance Date
The date of creation.

• Verification Standard:
VCS, GS, etc.

• Reference to Project/MBP/Claim
• Reference to Contract/Verified Claims
• Date Range
The verified period of the benefit claim.

Only through public blockchains can the market confirm that the token is a unique representation of
the actual data and cannot be corrupted. Furthermore, it can be trusted because it is decentralized
and distributed with a consensus or agreement through the technology and not through extraneous
or onerous touchpoints. This in turn gives the token a unique value that is more secure and can
be quickly settled between parties. Several blockchain projects are already implementing this
token framework in their product specifications. Future work on these standards includes an
MRV (Management, Reporting, and Verification) framework based on international standards
for environmental management or ISO 14064-1:2018. This will improve and provide additional
implementations for tokenization certification.

This is just one example of how a business problem is identified, creating a large-scale, transparent
carbon credit trading market, in which blockchain technology is used to capture significant value
through tokenization. There are numerous use cases following a similar model - identify a problem,
map a blueprint solution, and use an open source, technology neutral standard that scales on any
platform.
RECOMMENDATIONS DIGEST - READ AND LEAD
Invest people and funds We recommend
into voluntary markets the following readings
Voluntary markets are not under governmental • COP26 Explained
control, which means participants engage
because of natural market forces or social • Paris Agreement Explained
responsibility. Regulated markets, on the other
hand, require a governmental agency to compel • Ceres Roadmap 2030 |
industry compliance.
• The InterWork Alliance’s Voluntary Ecological
• Identify a specific use case that can make a Markets Overview
tangible difference to solve a problem area.
• White & Case LLP
• Understand and Invest in ESG Standards
Working Groups to engage and align ESG • VCMI Synthesis Report
investments.

• Make a commitment to a working group

backed by a financial investment and man-
hours. By having a more robust voluntary
market we can go to the mandatory markets
with specific, detailed requests for alignment,
and help drive impactful ecosystem
development.

WHAT IS YOUR ESG STRATEGY

Review the Sustainable Development Goals (SDGs) and
communicate your accountability and alignment
• Do not assume understanding; take time to understand and educate constituents

• Measure your results and be accountable - communicate goals to constituents

• Invest in technology that offers impact; solutions should be quantifiable and interoperable

Organizations can remove or reduce harmful greenhouse gas emissions, improve data required
to measure and validate, reduce the cost of bringing solutions to markets, and increase the
speed of this work through these steps. By mapping this level of detail, the marketplace can
derive a value and focus investors’ minds on the sustainability strategies of the companies and
institutions in which they invest across the globe. The usefulness of carbon credits depends
on liquidity and consistent price generation in the markets on which they are traded, which in
turn depends on reliable and consistent data, taxonomies, and benchmarks. GSMI has set out
concrete steps to accelerate and scale up the development of these markets as the axis for
generating liquidity, pricing, data, taxonomies, and benchmarks — ultimately achieving real and
swift mitigation of climate change.

51
 SECTION VIII

GLOBAL TAXATION
In a report on Distributed Ledger Technology (DLT)197 published in January 2016, the United
Kingdom (UK) Government stated that DLT “has the potential to redefine the relationship
between government and the citizen in terms of data sharing, transparency and trust.”198
The report went on to identify a tax collection of incidences as a major use case for DLT that
governments should instigate and be actively involved with as the technology matures.

Historically, the fundamental redistributive role of the state has been based on centralized
and fiat-based systems. But with DLT, individuals, corporations, and states can exchange
identity, trust, data, and value without the need for the (inter-)mediation of a central authority.
DLT enables a move away from bilateral trust relationships. Now tax authorities can join
trust networks, be part of their governance arrangements and witness in real-time the tax
events that create obligations to the state. Tax authorities can make decisions about the tax
implications of those events as they happen. Simply put, tax can ‘just happen’. Such adoption
and synchronization of all DLT elements in tax will take time to develop. However, many early
benefits that DLT affords are already becoming visible and are outlined in this report.

This report examines the state of domestic and international applications of DLT in tax
administration, assesses where efforts to standardize and ensure interoperability of systems
can be concentrated, and recommends how tax authorities can generate significant value,
realized by governments and taxpayers alike. Many more fundamental matters that individual
states and their governments should consider as the world becomes more distributed are
beyond the scope of this report. You can view the full Global Taxation report here.

DIGITAL IDENTITY Additionally, this will ensure tax requirements are

aligned with other governmental service delivery
Digital identity (DID) assurance is critical to functions across tax, trade, social services,
fair, just, and efficient taxing systems. Costly justice, welfare distribution, government-
efforts have been initiated to ensure accurate supported utilities, etc. This framework should
and secure identities; however, as long as be supported by the selection of sufficient
confidential information is maintained in technical tools to ensure data security, integrity,
centralized repositories, future attacks and and availability expectations are met. Various
breaches are inevitable. state databases containing and collecting digital
identity information can be well managed and
KEY RECOMMENDATIONS diminish the incidence of actual data exchange
using DLT. As this approach matures, DLT-based
Tax as a prime use case systems will help to ensure the transparency,
Tax administrations can reuse and leverage cost-effectiveness, integrity, and high credibility
existing Know Your Customer (KYC) approaches of data management processes.
of private sector financial service providers.
A cross-government approach is desirable,
Interoperability
including all layers (national, sub-national, and
Organizations need to collaborate to ensure
municipal); the tax administration use-case for
tax data is accurate with proper security
such a system could be an effective exemplar
measures in place. This will help in appropriate
for this multi-layer approach. This includes a
tax risk analytics and reporting measures. In
standardized digital identity framework and
addition, this will reduce (but never eliminate)
roadmap for implementation that supports the
potential fraudulent tax-related activities in
necessary technical development and resource
which different identities are established and
management.
verification and validation can be challenged.

52
If an assured identity system works for the of blockchain (e.g., physically certifying
financial arrangements between government documents). Redundant rules should be
and citizen, then others (welfare, pensions, repealed and substituted with new rules
health data management, and broader relevant to blockchain infrastructure (see
governmental service access) can work in a below).
similar interoperable fashion.
• Rules that impose barriers but are necessary
LEGAL AND REGULATORY (e.g., protection of fundamental individual
rights, such as privacy). Appropriate actions
Most tax legislation predates the sort of may include leveraging innovative technology
distributed systems enabled by DLT. If the like Zero-Knowledge Proofs (ZKP), which
full benefits of the technology are to be can protect privacy within transactional tax
realized, not just in tax but with respect to any regimes, such as VAT and withholding taxes.
government program or process, there needs
to be a thorough analysis of existing legal and • Rules that include a significant element of
regulatory barriers. Any successful project subjectivity or ambiguity (e.g., anti-avoidance
depends not only on mapping the issues but rules) and therefore prevent binary
also on addressing the barriers. Governments outcomes based on quantifiable objective
and businesses must work together to factors. See below for appropriate actions.
ensure the legal and regulatory regime is
fair and relevant. Applying blockchain in an EXPLORE OPTIONS FOR
international context introduces a further layer
of complexity in this realm.
ADDRESSING LEGAL
AMBIGUITY
KEY RECOMMENDATIONS Technological Solution
Address the challenges Determine whether the current state of natural
stemming from the legal/ language processing (Artificial Intelligence)
regulatory framework capabilities can adequately analyze legal
provisions and case-law with sufficient
• Review the existing legal framework, and precision.
group rules by the following classifications,
execute the designated actions

• Rules that are redundant in the context

53
 Legal Solution Technological Solution
Consider introducing binary objective criteria Automatic exchange of information in real-time
that trigger rebuttable legal presumptions, between tax authorities, based on a blockchain
the outcomes of which can be revisited at the solution.
request of the authorities or the taxpayer.
ESTABLISH THE QUALITY
Review Outcomes OF DATA AND ITS
Provide for a possibility to review outcomes
in case of dispute resolution and embed such
IMPACT ON LEGAL
possibility in the blockchain system (e.g., by
RESPONSIBILITY;
having a trusted party that can implement the quality of the output of the
changes). blockchain system is entirely
dependent on the quality of the
IDENTIFY THE data input
CHALLENGES THAT
ARISE IN CROSS-BORDER Importance of standardized data, especially
SITUATIONS for cross-border data exchange; consider
alignment to a global standards organization,
Divergent legal frameworks across jurisdictions such as the National Institute of Standards
leading to different legal qualifications of and Technology (NIST) or the Organization for
similar fact patterns. the Advancement of Structured Information
Standards (Oasis).
Technological Solution
Explore the technical feasibility of smart Importance of intermediaries (e.g., banks,
contracts accounting for different legal telecommunication providers, other digital
frameworks across jurisdictions, depending on platforms) with robust KYC programs, for
a protocol that attributes jurisdiction to tax to providing the necessary data.
a given country or countries.
Determination of legal responsibility when the
Legal Solution data provided is dependent on a due-diligence
Coordination of the legal framework, thus standard (e.g., due diligence commensurate
ensuring greater consistency (especially with the activity in banking or financing
feasible within regional integrated blocks such activities).
as the European Union).
ENSURE THAT ANY
International Exchange of Information under TAX-DLT SYSTEM
Article 26 of the Organization for Economic
Co-operation and Development (OECD)
IS COMPLIANT
Model Tax Convention199 or the Directive
WITH GENERAL
on Administrative Cooperation (DAC) DATA PROTECTION
relies on communication only between tax REGULATION (GDPR) OR
authorities, excluding the possibility for direct SIMILAR GOVERNMENT
exchange between private parties and foreign DATA ACT
authorities.
Prohibition of decision-making by automatic
Legal Solution means (e.g., Article 22 of the GDPR); there
Amend the Exchange of Information rules, needs to be a possibility for human review and
allowing for direct data sharing between adjudication.
private parties and foreign authorities. This
may be achieved on a bilateral or multilateral ‘Right to be Forgotten’
basis. Possibility of erasure; determine whether such
principles may undermine the immutability of
the blockchain.

54
 decision on which mechanism to deploy
should involve a robust cost-benefit analysis.
Private Data
Explore the possibilities afforded by Zero- Coordination of
Knowledge Proof advanced cryptographic Data Ingestion
capabilities.200 Coordination is a key component while fulfilling
a data model; however, blockchain, by design,
ALIGN WITH is a decentralized system that brings trust-less
COMPETITION LAW nodes together. The technology itself facilitates
many stakeholders (nodes) in coordinating
Although this point is beyond the strict taxation and validating transactions. Pilot programs are
scope of this report, there is a need to monitor thus advised to stress-test the developed data
industry-commercialized blockchain-based infrastructure and ingestion processes.
taxing systems for the incidence of competition
amongst DLT systems. It will be important Associated Costs
to analyze the different means of validating to Consider
transactions and the possibility of systems Questions to address should include timing:
containing commercially sensitive data, which whether onboarding of the historical data from
could be used for illegal price setting and anti- previous years into the new form of a data
competitive behavior. model is required. If not, how would the old
data model be compatible with the new data
DATA MODEL FOR TAX model in case there is a need to access and
act upon older data? It is also important to
A decentralized solution may decrease the consider the costs associated with educating
amount of continuous effort currently needed taxpayers on how to use the system.
to monitor, administer, and police compliance
with tax obligations. A blockchain solution Security and Systematic
necessitates an upfront fixed investment with Risk Management
variable, but controllable, future maintenance A multi-phase process should be developed in
costs. A decentralized data model is also the unfortunate scenario of data leakage, data
conducive to preventing information hacking, or other form of systemic failure. The
from altering. Therefore, it could assist in first phase should be an immediate technical
addressing tax avoidance incidents and equip response to mitigate the risk. The second
policymakers with enhanced data transparency phase should consist of the following actions,
and traceability. Improved transparency will executed in parallel or series: communication
also support better policy design decisions. plan; compensation program aligned to the
Decentralized data infrastructure brings clarity data breach, and a legislative/regulatory
and simplicity to a confusing and challenging framework pre-developed to protect and
process. support those affected.
A decentralized data model does not
translate into higher taxes, but rather offers a GOVERNANCE DATA
more efficient means of taxation that, in turn,
yields advantages for tax authorities and
MODEL
taxpayers alike. Governance of the decentralized data model
could be divided into two general themes
KEY RECOMMENDATIONS (on-chain data governance and off-chain
Data Framework governance) with three associated layers
(off-chain community, off-chain development,
Consensus Protocol and on-chain protocol).201 To design an
The two most prominent consensus protocols efficient blockchain tax data infrastructure,
are: Proof-of-Work (PoW) and Proof-of-Stake it is important to recognize that off-chain
(PoS); they have their own benefits and costs. components do not exist in isolation from their
When designing a data infrastructure, the on-chain counterparts, since both elements

55
 are mutually dependent, and thus should be The protection of taxpayers’ rights is a
designed in unison. fundamental and critical element. This effort
should be focused on a robust dispute
INTERSECTION OF resolution mechanism, appropriate guidance
ARTIFICIAL INTELLIGENCE on burden-of proof, identity management, and
(AI) AND BLOCKCHAIN digital inclusiveness.

Providing an Integrated Value

AI brings sophisticated data analytics to tax to
Proposition
optimize compliance and effectively transform Distributed ledger technologies will also
tax into an innovation hub, while generally require clarity regarding when it is acceptable
empowering the tax function.202 Blockchain to use data for purposes other than those for
offers transparent, validated, and structured which the data was initially provided. Thus, it
data sources necessary for AI model building is important to: (i) avoid establishing siloed
and deployment. AI systems partnered systems when an integrated system is more
with blockchain can produce new insight to effective; (ii) consider including services of
substantially improve information security, value to the taxpayer, even if they are not tax
system scalability, fraud reduction, and related; (iii) embed information requirements
governance.203 from other government entities rather
than establishing parallel systems; (iv) avoid
GOVERNANCE replicating existing processes found in paper-
based or legacy IT systems; and (v) define the
A blockchain infrastructure for tax purposes
integrated value proposition for both private
will require special governance arrangements.
and public stakeholders when participating
The critical roles of each party should be
together in an ecosystem.
clearly defined and built into the Information
Technology (IT) infrastructure, along with
appropriate incentive mechanisms that will
Applying the Principle of
enhance the long-term viability of the DLT
‘Subsidiarity’ When Selecting
system by encouraging participation by a
a Platform
Taxation is incidental to economic transactions.
multitude of stakeholders. The tax ecosystem
Therefore, a blockchain-based tax platform
encompasses a wide variety of actors. Thus,
may not be the best general purpose
it is important at the outset to define a set of
technology option if there exist current
shared principles that reflect the aspirations of
solutions in the market where taxation can be
the members of the ecosystem and serve as
effectively incorporated. For example, it may be
guidelines in developing blockchain solutions.
more efficient to embed taxation into a digital
payment, commerce, or supply chain solution
KEY RECOMMENDATIONS rather than establishing an entirely new tax
Delivering Mutual system.
Tax Certainty
The overriding objective of a tax-based Ensuring the Resilience of the
blockchain infrastructure should be to deliver Blockchain
faster tax certainty for both the taxpayer and Tax-related blockchain systems will require:
the tax administration. This means that there (i) a very high degree of uptime; (ii) effective
should be certainty around: (i) the identity of authentication of the actors operating on
those operating on the ledger; (ii) the fact that the blockchain; (iii) a robust information
the taxable event has occurred as recorded security arrangement, including protection of
in the chain; and (iii) including all relevant commercial secrets; (iv) predictability in change
information to automatically assess tax management since the system interfaces
implications.204 with other systems within and outside the tax
administration; (v) capacity to train users and
Protecting Taxpayer Rights handle complaints and queries; (vi) monitoring

56
of the system; and (vii) a proper dispute resolution mechanism.

Promoting participation and inclusion of multiple stakeholder

classes in system design and development
Longer and more intensive, participatory processes are likely needed to effectively design blockchain
systems. Multi-stakeholder classes should be represented in the governance structure of the
DLT system (participation) and decision-making rights should be carefully considered to ensure
all relevant and material stakeholder classes are represented by a governance member with
a recognized, and valued, decision-making vote. The discourse should in any case address the
following seven governance dimensions: system development/maintenance roles; participation
incentives; membership; communication amongst stakeholders; decision-making; initial system
formation and launch; and context-specific rights and obligations of stakeholders.

Establishing a Governance Board/Framework

The aforementioned governance elements need to be included in an overarching governance
framework and associated board where all relevant stakeholders are properly represented. Special
governance arrangements will likely include: (i) earlier, longer, and more intensive consultations
processes to understand how the blockchain systems interact with existing processes in the public
and private sectors; (ii) a robust change management mechanism, as upgrades to the blockchain
system are likely to have ripple effects; (iii) a process for encouraging and processing unsolicited
proposals; and (iv) a program to foster a vibrant conversation across the ecosystem addressing
needs of the multi-stakeholders.

While there are few tax-related DLT systems with robust

and carefully constructed governance models from which to
leverage, there are several technology-laden systems impacting
a multitude of stakeholders with impressive governance models
Consider, for example, the Global Vaccine Alliance (GAVI)205 for a nuanced and precise governance
model, DHIS2,206 an open-source digital health information system for a streamlined governance
model uniquely tied to a university (University of Oslo), and Mojaloop,207 an open-source software
payment system employing a foundation model across an efficient mix of public and private sector
actors.

PRIVACY AND TRANSPARENCY

DLT has created an opportunity to rethink the traditional balance between privacy and transparency
across tax policy, law, and processes. While digital technology is enabling better tracking and
reporting of economic activity, the concept of taxation and the associated administrative burden
have remained largely unchanged. DLT can free institutions, the economy, and society to rethink
deeply embedded paradigms outside of the traditional constraints of data collection and
management.

Privacy and transparency should also be qualified by the subject (person or organization) at issue,
the entity bequeathed with the authority to enforce privacy and transparency, and the scope of
the tax-related data being made private or transparent (e.g., all DLT data or only cross-border
transaction data). Technologies such as Zero-Knowledge Proofs (ZKP) may also play a key role here.
Applying ZKP-technology, one party (the prover) can prove to another party (the verifier) that they
know a value x, without conveying any other information. Privacy-preserving technologies such
as this may enable compliance with required privacy standards and legislation, although further
development may be needed.

57
 KEY RECOMMENDATIONS Policymakers should consider
the introduction of an
Put citizens in control Immutable Notarization
For a balance between privacy and Blockchain for Taxation Data
transparency to evolve as technology evolves, One key challenge in the potential utilization
a social license to innovate is important and of blockchain and DLT technology for greater
should be maintained. It is recommended transparency in the digital taxation domain
that safe, secure, and easy to use custodial concerns the data privacy of relevant entities
solutions be provided so citizens can own who participate in the DLT network. Often
their identity keys, building a partnership transactions between parties are confidential
approach between responsible authorities to these parties, with the taxation authority,
and citizens, whereby a clear balance is possibly being the sole third party legally
considered between providing the relevant permitted to further query into the transaction
data and maintaining privacy and control from details. In these use cases, there is an
a taxpayer’s perspective. inherent tension between the benefits of DLT
technology for transacting parties and the
Policymakers should leverage danger of loss of privacy for the parties. Thus,
the power of smart contracts blockchains and DLT technology must continue
to mirror existing legal, to develop to address these privacy concerns.
regulatory, and contractual
restrictions on data usage One potential solution is to retain only a
and sharing minimal trace of the transaction, by way
There are opportunities for public and private of capturing on the blockchain only the
sector actors to launch proofs of concept cryptographic hash of the transaction records.
and pilots with DLT systems that adhere to This is known as a “hash-only blockchain,” a
current legislative, regulatory, and contractual digital notarization blockchain which functions
limitations. much in the same way as legal, human
notaries. In this system, when two transacting
Consider the use of Non- parties arrive at a taxable event, both parties
Fungible Tokens (NFTs) compute the cryptographic hash of their
NFTs provide the opportunity to establish relevant documents and evidence of the
that data is unique and immutable, its true payment. They then utilize the blockchain to
ownership, and its associated permissions. store only these hash/digest values together
The ability to locate meta-attributes around with the appropriate record-identifier. Each
the data, and verify the data as being unique, party retains their complete data records in
could be a way of balancing privacy and their respective private databases.
transparency in a way that is comfortable to
citizens and businesses and enables them to In this case, the blockchain acts as a
make decisions about the costs and benefits of decentralized, automated notary that keeps
sharing their data, while recipients of the data an immutable list of these hash values, thus
can be assured of its validity and ownership. preventing parties from modifying their data
records. Relevant government authorities
can later request these transaction data

58
records from the parties and recompute the not fit for purpose and cannot be implemented
cryptographic-hash values for these records at scale and in compliance with existing
and compare these hash values against frameworks, it will fade away and a lot of time
those found on the blockchain. This provides and trouble will have been saved.
assurance that none of the parties have
illegally modified these data records after the This working group holds that stakeholders
taxable event has occurred. should be directed to further develop
blockchain technologies, in general, across
Tokenized currency that certain key use-cases, including tax. For tax
can execute governance specifically, we suggest all involved in tax
requirements associated with administration, domestic and international,
transactions could enable public and private, engage with this
a broader range of taxable breakthrough technology and understand
events or could enable a more what it means for the tax systems that support
targeted approach to taxable the financial and societal stability of our nation-
events states.
This could be accomplished by programming
a tax office-approved corporate policy into
the transaction or by making the amount of
tax due so small as to be negligible on a per-
transaction basis. The central role of a taxation
authority could be reconfigured and risks
associated with the implementation of new
transaction and currency systems reduced.

CONCLUSION
There is no doubt that DLT will continue to
have significant effects on finance, tax, trade,
and other settings where many actors in a
system need access to assured real-time data
about a transaction. Governments have the
option, of course, of stepping back and letting
the market take its course. That way, if DLT is

59
SECTION IX

DERIVATIVES

CRYPTO-DERIVATIVES
The traditional derivatives market is said to be over $1 quadrillion dollars on the high end, but some
analysts say the market is grossly overestimated. The higher end of the estimates includes the
notional value of derivative contracts.208

The rise of cryptocurrency derivative products in the current financial market brought with it lots of
questions and concerns. The crypto-derivatives market has now overtaken the crypto spot market by
trading volume as it continuously expands with new products. Although crypto derivatives represent
a new set of tradeable products, they have many of the same characteristics as traditional crypto-
derivatives. You can access the full crypto-derivatives report here.

Crypto-derivatives are “secondary contracts or financial tools that derive their value from a primary
underlying asset. A primary underlying asset could be a cryptocurrency such as Bitcoin”.209

These derivatives can be traded OTC, over centralized exchanges, and even over decentralized
exchanges because of blockchain technology. There are many different types of crypto-derivative
and structured products on the market. We can categorize these products into three main
categories: crypto futures, crypto options, and perpetual contracts.

CRYPTO FUTURES
Crypto Futures are structured the same as traditional futures contracts but the underlying asset is a
cryptocurrency. Within the crypto space, there are two different types of futures, inverse futures and
non-inverse futures, also referred to as vanilla futures. Vanilla futures work in exactly the same way
as we are used to in traditional finance – the P&L is linear and paid out in the quote currency, such
as USD or a USD-based stablecoin when trading a pair like BTC/USD or ETH/USD.

Inverse futures were designed to eliminate the need to hold any fiat or stablecoin on a platform.
For those contracts the margining and P&L are calculated in the base currency of the contract, for
example in BTC when trading BTC/USD futures. As a result, the P&L calculation is non-linear.

CRYPTO OPTIONS
Crypto options share the same structure as its traditional counterpart but the underlying asset is
a cryptocurrency. Crypto options are relatively nascent and simple at this stage of development.
Over the coming years, exotic crypto options with more complex structures as well as embedded
option structures may emerge for multiple purposes including for hedging, synthetic exposure, and
speculation.
 with the spot market, the contracts have an
‘CRYPTO’ PERPETUAL exchange of payment between buyers and
CONTRACTS OR SWAPS sellers depending on where the future price
is trading relative to the underlying spot price.
Crypto Perpetual Contracts, which are The spread between spot and perpetual
sometimes referred to as Perpetual Swaps futures prices is commonly known as ‘basis’
and other times referred to as Perpetual in traditional finance, but in crypto is often
Futures, but generally referring to the same referred to as ‘funding’. The resulting payment
concept, were originally invented by BitMEX. that is exchanged between long and short
When cryptocurrencies grew in popularity holders of the contract is mostly referred to as
and started attracting more and more retail the funding payment.212
traders, these traders kept complaining that
their positions ‘disappeared’ when in reality The MTM (‘mark-to-market’) of perpetual
they were trading dated futures which had contracts is determined by the ‘Funding Rate’.
expired. To solve for this, BitMEX came up The funding rate is the mechanism that ties
with the Perpetual Contract. Unlike the other the perpetual contracts price to the underlying
futures and options, perpetual contracts are spot price. Depending on how often the
unique to cryptocurrencies. exchange processes the funding rate, the
spread between the perpetual contracts and
Perpetual contracts are the most popular spot prices is generally smaller than the spread
derivative in the current crypto market. A between the perpetual contracts and dated
perpetual contract can be thought of as a futures (exception being when approaching
futures contract that never expires. expiry date).
Traders are able to keep their positions
open for as long as they want under certain To date, perpetual contracts are the most
conditions. One of these is that the account popular product in the current crypto market.
must contain a minimum amount of BTC, or
other crypto, (margin). Another distinct factor CRYPTO ETFS
to consider is the funding rate. This is a unique
mechanism that helps tether the price of the Exchange Traded Funds (ETFs) are not
perpetual contract to that of Bitcoin, or other derivatives, rather it is synthetic exposure to an
crypto. Because of its dated expiry, the price underlying asset like stock shares.
of a futures contract will always converge with
the price of the underlying asset at expiration. A Bitcoin ETF tracks Bitcoin’s value and
Since perpetual contracts do not expire, its trades on regular exchanges (rather than on
price can start deviating significantly from dedicated crypto exchanges). Investments
the spot price. A solution to this problem is in them give investors the opportunity to
to have one side of traders pay the opposing get exposure to bitcoin’s price changes
side.210 without having to buy the underlying asset on
cryptocurrency exchanges, while also offering
Perpetual futures are futures contracts with price leverage.
no maturity, as opposed to dated futures,
which expire at a pre-set date and time such A Bitcoin ETF listed on major stock exchanges
as every month or every quarter. Any position decreases the barrier to entry, allowing a larger
in a perpetual futures stays open until the demography of investors to participate. Bitcoin
trader decides to close the trade by executing ETF proposals in the US have been circulating
an offsetting trade, or until the trade gets since 2013, and only recently, Bitcoin ETF
liquidated.211 on CME Futures have been approved. On
October 19, 2021, ProShares BTC ETF (ticker:
As perpetual futures have no set expiry BITO) launched and within days, broke ETF
they are, in a way, akin to spot exposure. To records for investment inflows (over $1bn in
ensure that perpetual prices are kept in line two days at the time of publication).213 Other
cryptocurrency ETFs trade on the Toronto

61
Stock Exchange (TSX), on Europe’s Euronext, XETRA, and B3 in Brazil. Currently, European regulated
markets only offer ETNs on digital assets or digital assets proxies.

EVOLUTION OF TRADING ACTIVITY OF DERIVATIVES ON

DIGITAL ASSETS
Over the past few years, the ever-growing volume, coverage, and diversity of contracts has
transformed the derivatives industry into a structurally critical force in cryptocurrency markets.

EXCHANGE MARKET SHARE

The vast majority of cryptocurrency derivatives trade volume occurs on unregulated exchanges.
The top unregulated exchanges are: Binance, Okex, Huobi, FTX, Bybit, Bitmex, and Deribit. Kraken,
Bitfinex, and Bitflyer also offer derivatives, but their volumes are lower than top-tier unregulated
markets. The Chicago Mercantile Exchange (CME) is one of the only regulated cryptocurrency
exchanges that offers futures on Bitcoin and Ethereum. There are several other smaller regulated
exchanges such as LedgerX, Bakkt, and ErisX, although volumes remain low.

All unregulated exchanges offer both perpetual futures and dated futures, but only a few exchanges–
Deribit, Okex, and Huobi – offer options on cryptocurrencies. For options, Deribit accounts for the
vast majority of market share.

TRADE VOLUME

62
Since the start of 2021, exchange market share of trade volume has changed drastically for dated
futures and perpetual futures. Since January, Binance went from accounting for just 2% of dated
futures volume and 37% of perpetual futures volume to 16% and 68% of volume, respectively. For
futures, Binance’s market share grew by more than 8x and for perpetual futures Binance’s market
share now accounts for a majority of all volume.

Okex still accounts for the majority of dated futures volume, although its market share fell 4% since
January.

FTX also slightly gained market share since the start of the year, growing from 1% to 3% of futures
volumes and 7% to 8% of perpetual market share. Huobi has lost the most market share since the
start of the year, losing more than half for both futures and perpetual futures.

EXCHANGE COVERAGE BY CONTRACT TYPE

Cryptocurrency derivatives markets have undergone massive growth over the past couple of years,
but nothing has been as impressive as the soaring popularity of perpetual futures. Almost every
cryptocurrency derivatives exchange offers perpetual futures, and most offer both USD and USDT
denominated contracts. Perpetual futures contracts cover the widest range of crypto assets, more so
than dated futures.

Only a handful of exchanges offer options contracts, and only on Bitcoin and Ethereum.

PERPETUAL FUTURES
The chart below shows the number of crypto assets covered by each exchange as of September
2021.

Today, FTX leads the market for perpetual futures with the largest number of contracts on crypto
assets. FTX is known for rapidly listing contracts on new crypto assets and offers the widest variety of
both blue-chip (BTC/ETH) and altcoin derivatives. FTX is a relative newcomer to the derivatives space–
launching their first contract in 2019–but has rapidly gained market share and relevance due to their
fast paced listing strategy.
We can observe that the quantity of perpetual futures has increased sharply since 2019. Today,
there are more than 600 total contracts. Around 400 are denominated in stablecoins (USDT-
margined) and 200 in USD (coin-margined).

DATED FUTURES
For standard dated futures contracts, most exchanges offer only a fraction of the coverage
compared with perpetual futures. Most exchanges offer futures contracts with expiries ranging from
weekly to quarterly, although the quantity of dated futures varies by exchange. For example, Binance
only offers a quarterly contract while FTX offers monthly, quarterly, and biannual contracts. Huobi
offers weekly, bi-weekly and quarterly contracts.
OPTIONS
Okex, Huobi and Deribit are the only unregulated exchanges to offer these contracts and all three
only offer options on Bitcoin and Ethereum. Options markets are far more complex than futures
which has prevented them from gaining widespread popularity, although volumes have increased
over the past couple of years. Today, Deribit accounts for 90+% of total market share of options
volume.

BTC VS. ALTCOINS

Derivatives are offered on 150+ altcoins, creating a highly varied trading environment. Bitcoin still
dominates derivatives trading volume, but the ever-increasing range of altcoin derivatives contracts
suggests growing trader interest. Bitcoin’s market share of futures volume vs. Ethereum is charted
below, and shows that Ethereum derivatives volume accounts for approximately 40% of total. This
share has increased since March of 2021 and suggests altcoin bull runs have a direct effect on the
breakdown of derivatives volumes.

Altcoin derivatives beyond Ethereum have also seen surging interest among traders. For example,
open interest for the altcoin Solana recently broke all-time highs at more than $800 million,
compared with just $200 million at the start of August 2021.
INITIAL CRYPTO-DERIVATIVES
LEGAL & REGULATORY
MAPPING
The GSMI 2.0 Derivatives Working Group also researched and mapped a subset of twelve
key jurisdictions: USA, Canada, United Kingdom, European Union – Germany, France, Italy,
Spain, Switzerland, Singapore, Japan, Hong Kong, South Korea which are paving the way for
the development and growth of crypto-derivatives. The European Union and Singapore are
highlighted here. Click here to access the full report for all twelve.

THE EUROPEAN UNION ESMA is the independent market supervisory

In the European Union, regulators have framed and enforcement authority within the E.U.
their approach to the regulation of crypto responsible for promoting “consistent
derivatives based upon the complexity of crypto- application of market rules”.218 ESMA has three
derivative products as well as investors’ lack of objectives; to protect investors, maintain orderly
understanding regarding the risks that come markets, and uphold financial stability within the
with these products. The E.U., through several of European financial markets.219
its regulatory bodies, has issued guidelines and
calls for evidence to better regulate this issue. B. ESMA’S VIEW OF
But individual E.U. member countries have also CRYPTOCURRENCY AND
developed their own approaches.214 CRYPTO-DERIVATIVES
A. ESMA & MARKET Most prominently as it pertains to
SUPERVISION IN THE cryptocurrency, crypto derivatives, virtual
EUROPEAN UNION currencies and new financial instruments, EMSA
has been granted specific product intervention
The European System of Financial Supervision powers to temporarily prohibit or restrict the
(ESFS), the framework for financial supervision in marketing, distribution or sale of a financial
the European Union, is made up of the European instrument or a type of financial activity or
Supervisory Authorities (ESAs), the European practice when certain conditions are met.220
Systemic Risk Board, the Joint Committee of
the European Supervisory Authorities, and the • MiFID and MiFir
national supervisory authorities of E.U. member On October 20, 2011, the European
states.215 Commission adopted a legislative proposal for
the revision of MiFID which took the form of a
Within the ESFS, there are three European revised Directive and a new Regulation.221 After
Supervisory Authorities, who are directly more than two years of debate, the Directive
responsible for supervision of the European on Markets in Financial Instruments repealed
Financial Markets: The European Banking Directive 2004/39/EC and the Regulation on
Authority (EBA); the European Securities and Markets in Financial Instruments, commonly
Markets Authority (ESMA); and The European referred to as MiFID II and MiFIR, were adopted
Insurance and Occupational Pensions Authority by the European Parliament and the Council of
(EIOPA).217 Each of the three ESAs has the power the European Union.222
to issue non-legally binding Guidelines as tools
to promote the consistent application of E.U. law MiFID stands for the Markets in Financial
across E.U. member states.217 Instruments Directive; It has been applicable
across the European Union since November conditions: (a) it must be settled in cash
2007.223 It is a cornerstone of the E.U.’s or may be settled in cash at the option of
regulation of financial markets seeking to one of the parties other than by reason of
improve their competitiveness by creating default or other terminational event; (b)
a single market for investment services it only provides for payment at its close-
and activities and to ensure a high degree out or expiry; (c) its payment is limited to:
of harmonized protection for investors in (i) a predetermined fixed amount if the
financial instruments.224 MiFID II/MiFIR entered underlying of the derivative meets one
into force on January 3, 2018.225 ESMA created or more predetermined conditions; and
this new legislative framework to strengthen (ii) zero or another predetermined fixed
investor protection and improve the amount if the underlying of the derivative
functioning of financial markets, making them does not meet one of more predetermined
more efficient, resilient and transparent. conditions.”

Within it, MiFID outlines the: (1) conduct of ESMA suggested that these derivatives
business and organizational requirements products are speculative and volatile, exposing
for investment firms; (2) authorization investors to potentially significant monetary
requirements for regulated markets; (4) loss.230 As a result of its findings, ESMA called
regulatory reporting to avoid market abuse; for responses from market participants
(5) trade transparency obligation for shares; regarding crypto-derivatives and adopted
and (6) rules on the admission of financial several restrictive product invention measures,
instruments to trading.226 stemming from its power under Art. 40 of
MiFIR.231
ESMA Regulation of
Cryptocurrency & Crypto- The intervention measures included (1) a
derivatives prohibition on the marketing, distribution,
or sale of BOs and (2) a restriction on the
ESMA first stepped into the world of marketing, distribution, or sale of CFDs to
cryptocurrency when it expressed its view on retail investors.232 In adopting these restrictive
token sales, also known as ICOs, in November measures, the ESMA is quoted as saying:233
2017.227 Although ESMA’s proclamation was
vague and did little more than acknowledge “CFDs are complex products. The pricing,
the existence of cryptocurrencies and ICO’s, trading terms, and settlement of such
later, in the Call for Evidence Report issued products is not standardized, impairing retail
in January 2018, the ESMA announced that investors’ ability to understand the terms
crypto-derivatives, in the form of CFDs of product…Retail investors find it difficult
and BOs, should be subject to strict legal to understand and assess the expected
scrutiny. ESMA defines CFDs or “Contracts for performance of a CFD… Furthermore,
Difference” as:228 the offer of CFDs to retail investors
has increasingly featured aggressive
“a derivative other than an option, future, marketing practices as well as misleading
swap, or forward rate agreement, the communications…”
purpose of which is to give the holder a long
or short exposure to fluctuations in the price, Separately, it also noted that cryptocurrency is
level or value of an underlying, irrespective of an immature asset class that poses “separate
whether it is traded on a trading venue, and and significant concerns.”234
that must be settled in cash at the option of
one of the parties other than by reason of
default or other terminational event.”

BO’s, or Binary options, are defined as:229

“a derivative that meets the following

67
 SINGAPORE definition of a “derivatives contract”, since
the SFA defines a “derivatives contract” as a
Introduction contract or arrangement under which:
In Singapore, the relevant regulator for
crypto-derivatives is the Monetary Authority of • one of the parties is required to discharge all
Singapore (“MAS”), which is Singapore’s central or any of its obligations at some future time;
bank and integrated financial regulator. and
The MAS is responsible for administering and • the value of the contract or arrangement
supervising the securities, financial advisory is determined by reference to the value or
services, and payments regimes in Singapore, amount of one or more “underlying things”.
under the Securities and Futures Act (“SFA”),
Financial Advisers Act (“FAA”) and Payment According to the MAS’ FAQs on product
Services Act 2019 (“PSA”), respectively. Entities definitions, the following would be considered
and individuals that intend to conduct activities “derivatives contracts”: (i) futures swaps (i.e.,
relating to crypto-derivatives, are required a swap on a futures contract), or any other
to comply with the MAS’ rules under the swaps; and (ii) contracts for differences
aforementioned regimes. referencing an “underlying thing”.2346

While crypto-derivatives are not prohibited in An “underlying thing” includes: a security, a

Singapore, the MAS has indicated that it does unit in a CIS, a currency or currency index, an
not consider crypto-derivative products to be interest rate, a commodity, or the credit of any
suitable for most retail investors.235 person. If the reference token of the product
is within the definition of an “underlying
ASSESSING WHETHER A thing”, the product is likely to be a “derivatives
CRYPTO-DERIVATIVE IS contract” and thus regulated as a “capital

REGULATED markets product”.

The primary factor determining the The next few sections summarize some of the
regulatory treatment of a crypto-derivative relevant licensing requirements that could
product is the nature of the token that the apply to a crypto-derivative product that is
product references. considered a “capital markets product” under
the legislation administered by the MAS.
Depending on the nature of the token, the
product will be regulated in Singapore if: (i) it CMS License
falls within the definition of a “capital markets An entity that carries on a business in any
product” under the SFA; or (ii) references a regulated activity under the SFA, will be
payment token (a “payment token derivative”), required to hold a capital markets services
and is offered or listed on an approved (“CMS”) license for such regulated activity.
exchange. Regulated activities under the SFA include: (a)
dealing in capital markets products; (b) advising
1. CAPITAL MARKETS on corporate finance; (c) fund management;

PRODUCTS (d) real estate investment trust management;

(e) product financing; (f) providing credit rating
Under the SFA, “capital markets products” services; and (g) providing custodial services.
include securities, units in a collective
investment scheme (“CIS”), derivatives Financial Advisers’ License
contracts, spot foreign exchange contracts for Any person that acts as a financial adviser in
the purposes of leveraged foreign exchange Singapore in respect of any financial advisory
trading, as well as any other products the MAS services, is required under the FAA to either
has prescribed as a capital markets product. hold a financial adviser’s license or be an
Of these categories, a crypto-derivative exempt financial advisor. A financial advisory
product is most likely to fall within the service includes advising others in respect

68
of any “investment products” (which includes comparable contract. This is subject to a floor of
capital markets products). 50% and a cap of 100% of the notional value of
the payment token derivatives contract. These
Markets where derivatives contracts are listed margin requirements must be supplemented
Entities and exchanges that provide a place with other measures such as tailored risk
or facility (whether electronic or otherwise) warnings and restrictions on advertising.
where, offers or invitations to exchange, sell
or purchase derivatives contracts are regularly NEXT STEPS
made on a centralized basis, may require
approval or recognition from the MAS as either We are witnessing the first steps of the
(i) an approved exchange or (ii) a recognized derivatives industry in the digital assets and we
market operator. believe this product area will significantly expand
and diversify its offering to adapt to the needs of
2. PAYMENT TOKEN the users. Firstly, the regulated market offering is
DERIVATIVES at its infancy with just a few traditional regulated
exchange offering products on digital assets.
Approved Exchanges
A crypto-derivative product will be regulated if it Those products are mostly on single tokens
references a payment token and is listed on an but the index industry is developing tools that
approved exchange. will offer a better representation of the overall
As of September 2021, there are only four digital asset offering. Then, as the trading activity
approved exchanges in Singapore: Asia Pacific and exposure of the actual underlying assets
Exchange Pte. Ltd.; ICE Futures Singapore Pte. grow and diversify, one can expect innovation
Ltd., Singapore Exchange Derivatives Trading from a product standpoint. 2021 seems to be
Limited; and Singapore Exchange Securities a milestone year for the entry of institutional
Trading Limited. investors in this asset class and further
development will most certainly bring new needs
Based on public media comments by the MAS, and consequently new products to the market in
the MAS considers Bitcoin and Ether to be the coming years.
payment tokens. Derivatives that reference
Bitcoin and Ether would therefore be payment
token derivatives and would be regulated if listed
on these approved exchanges.

If payment token custody services are provided

in relation to payment token derivatives offered
on an approved exchange, the MAS will require
the approved exchange to be responsible for the
appointment of the custodian. The custodian
will also be subject to similar regulation that a
custodian of securities or other capital markets
products is subject to.

ADDITIONAL MEASURES
FOR RETAIL INVESTORS
The MAS has also introduced additional
measures for retail investors who trade in
payment token derivatives with financial
institutions regulated by the MAS. Such financial
institutions are required to collect from retail
investors 1.5 times the standard amount of
margin required by approved exchanges for a

69
 SECTION X

COUNTRY HIGHLIGHT:
SOUTH KOREA
The linked report offers an overview of blockchain adoption through an analysis of policy and
business cases in South Korea.

Although South Korea leveraged information and communication technologies to advance its economy
in the 2000s (which has expanded its focus from manufacturing and exporting in the 1970s and 1980s),
its innovation in blockchain has been stagnant since the announcement of the emergency measure and
technology roadmap amid the Bitcoin shock in December 2017.

In this report, six use cases are introduced in three parts. The first part covers the policy and regulations
for blockchain as virtual assets. South Korea amended the Act on Reporting and Using Specific Financial
Transaction Information237, 238 to comply with the Financial Action Task Force’s recommendations
revised in 2018.239 As a result, on the enforcement due date, September 25th, 2021, out of forty-three
Virtual Asset Service Providers (VASPs) registering their virtual asset businesses at the Korea Financial
Intelligence Unit, only four companies provided fiat money services.240 Furthermore, they must abide by
the travel rule241 in six months and adapt to the emerging markets of NFTs and the metaverse.242

The second part looks at South Korea’s blockchain R&D. Seventeen ministries have funded 417 projects
to cultivate blockchain inventions since 2015.

Significantly, the Ministry of Science and ICT’s Blockchain Convergence Technology Development
Program supported fifty projects between 2018 and 2021.243 Their R&D focused on virtual assets at
the initial stage in 2015 and soon shifted its application to various domains, including identification and
logistics. In addition, the Busan Regulation-Free Special Zone244, 245 pilots seven blockchain projects on
financial services, public security, tourism, logistics, real-estate, and MyData.246, 247

The last part reviews two cases of government blockchain adoption. The Korea Customs Service was

70
one of the first agencies in the world to introduce blockchain into customs clearance.248

It stopped the project before commercialization due to the burden of transforming the public data
systems into blockchain-based systems and insufficient partnerships with counterpart governments.
In collaboration with private sectors, the government has now also provided the world’s first
blockchain-based vaccination certification services249, 250 and extended it to a globally integrated
Decentralized Identity (DID) system.251

These South Korean cases highlight three ambiguities in blockchain policies. First, blockchain involves
both financial and industrial features. As the government regulates the former252 and promotes
the latter, it needs a new regulatory framework253, 254 embracing the two features together. Second,
integrating services on a blockchain platform will bring forth seamless automation of industries
across manufacturing, financial services,254 and public services.256 South Korea, having accumulated
capacities in manufacturing, is in need of a comprehensive strategy to encompass all services on a
platform. Third, the two cases of the government’s adoption of blockchain suggest that innovations
in blockchain can be facilitated through effective cooperation among government ministries and
agencies regarding particular businesses of private sectors.

With the history and legacy of remarkable industrialization, South Korea has the technological
foundation and the concrete capabilities (e.g., logistics, personal data) to advance and adopt
blockchain technology. Consequently, its policy is not simply to invest in virtual assets but also
to develop a virtual-physical world woven by blockchain. The new environment demands South
Korea transform its policy stances on blockchain, from specialization to comprehensiveness and
cooperation. These are the main lessons from South Korea for other countries adopting blockchain.

South Korea has achieved remarkable growth in the last 60 years, rising from the ashes of the war
into one of the most vibrant economies in the world. The country imports natural resources such as
oil and minerals to process them for export. Moreover, it exports cars, ships, semiconductor devices,
and smartphones. South Korea internally has an advanced value network and innovation system, and
externally made up 3.0% of world trade volume (9th largest) in 2020.

The tradition of its industrialization, accumulated through time, is its strength. Its culture is focused
on advancing blockchain technologies and developing business models for various domains, rather
than financial services and virtual assets. In other words, blockchain innovation in South Korea is likely
to be bound to real world assets such as logistics, real estate, personal data, and identification.255
Furthermore, it is in an excellent position to disseminate blockchain innovation through trading
partnerships.

However, these strengths can also resist blockchain adoption. Most of all, South Korea has specialized
its competence into a few parts (e.g., DRAM258 , smartphone devices) in compliance with global
platforms259 such as IBM’s framework and Google’s Android. Specialization in worldwide value chains
might be its best strategy to survive its lack of natural resources and insufficient domestic market
and lead the global economy. South Korea needs a well-designed strategy from a comprehensive
viewpoint and a cooperative stance to lead a specific part of the blockchain ecosystem.260
SECTION XI

NEXT STEPS/GSMI 3.0

Over the last decade, blockchain technology and digital assets have matured and expanded
across industries and across the globe. Much has changed, but a constant has been the industry’s
ability to move fast. GSMI aims to catalogue global activity in the industry, in part, to help address
counterproductive fragmentation. In the inaugural GSMI report, released in October 2020, areas ripe
for additional attention were highlighted. A year later, some of those challenges remain at the top of
our list.

COMMON REGULATORY APPROACH

The distributed nature of the technology supports agility, but the difference in regulatory approaches
across jurisdictions continues to lead to widespread fragmentation – both globally and within
countries. This is a perennial pain point for both regulators and innovators. A common strategy
would better serve all ends. Meaningful efforts to mitigate the incidence of information silos have
also increased, but there is still much room for improvement.

EDUCATION
Education remains paramount. The development of thoughtful, digestible, and nuanced educational
resources and efforts aimed at informing those crafting laws and regulations that touch blockchain
technology and digital assets is critical. Recent interest in NFTs and Web 3.0 has increased attention
in the industry, but the quality of understanding by stakeholders remains inadequate. Decision
makers must be better educated with thoughtful, accurate, digestible information.

MULTI-STAKEHOLDER ENGAGEMENT
Important things happen when stakeholders from myriad backgrounds communicate. Regulatory
frameworks based on input from actors in the public sector, private sector, and civil society have
a better chance of effectively addressing concerns while encouraging thoughtful innovation. In
their efforts to identify a rational path forward, regulators should prioritize engaging stakeholders
from varied backgrounds and jurisdictions. Cross-industry, multi-stakeholder, multi-jurisdiction
engagement is the way to build the robust frameworks needed for the future.

NIMBLE, PRINCIPLES-BASED GUIDANCE

Much existing regulation and standardization related to blockchain focuses on digital assets, as
opposed to the underlying technology. This is positive. The future benefits and risks of blockchain
cannot be completely or correctly anticipated at this juncture. As new uses for blockchain technology
emerge, nimble, platform-agnostic, principles-based regulation will continue to be more sustainable
and relevant.

TAX COMPLIANCE
Blockchain is an exceptional tool for compliance – particularly in tax. By integrating blockchain into
tax systems, governments can ensure the benefits of this technology reach an expansive swath of
society. Focusing on blockchain for tax will result in solutions with built-in smart regulations that
manage risks. Tax solutions should result in on-chain transactions recorded on a publicly viewable
blockchain ledger that are auditable by anyone at any time. This is a feature FinCEN and law
enforcement have already embraced, and something tax authorities should consider seriously.
TAXONOMY
When carefully conceived, shared language can create an invaluable foundation for understanding
and progress. Over the last decade, numerous blockchain taxonomies have emerged, but so far
none have been universally accepted or adopted, making consistent regulations across (or within)
jurisdictions difficult. Confused language remains a pain point within the industry. The taxonomy
presented by this working group spans industries – including terms related to digital ID and the
environment, which are often left out of blockchain taxonomies; it is a dynamic document and
recommendations are welcome.

ADDITIONAL MAPPING
Moving forward, as the digital and crypto assets markets continue to grow, additional areas of
research and mapping could include Web 3.0, specifically NFTs, DAOs, community tokens, virtual
reality, gamification, DeFi protocols, and the metaverse. As these areas become more developed
and complex, new legal and regulatory issues will arise. It is critical that stakeholders maintain an
understanding of new developments; additional mapping should continue.

GSMI is an ongoing effort to connect the constellation of satellites that

make up the blockchain technology and digital assets solar system. The
proliferation of activity in this space is stimulating a generation of solutions
fit to meet the challenges of our time. As global actors build novel solutions
to address society’s most intractable challenges, shared standards are
needed to facilitate responsible, sustainable innovation. We welcome your
support and participation in our crowdsourced efforts to bring additional
resource tools and understanding of our great and burgeoning industry.

Thank you to every volunteer author, editor, and supporter. We

appreciate all of you. See you in 2023 for GSMI 3.0.

73
 SECTION XII

ENDNOTES
1. E.U.R-Lex - 52020PC0593 - EN - E.U.R-Lex (euro- 28. Travel Rule Crypto Regulations in European Union
pa.eu) by EBA 🇪🇺 [2021] - Notabene
2. Documents - Financial Action Task Force (FATF) 29. Travel Rule Crypto Regulations in European Union
(fatf-gafi.org) by EBA 🇪🇺 [2021] - Notabene
3. UK regulatory approach to cryptoassets and sta- 30. p3 COM(2021) 241 final.
blecoins: consultation and call for evidence - GOV.UK (www. 31. https://notabene.id/world/germany
gov.uk)
32. https://www.lexology.com/library/detail.
4. Press release: Basel Committee discusses effects of aspx?g=29906858-4271-4604-a2ef-48d7c819e5a6
Covid-19 on banks, assesses post-crisis reforms and agrees
public consultation on cryptoassets (bis.org) 33. https://www.jdsupra.com/legalnews/
hong-kong-s-proposed-licensing-regime-9296071/
5. https://www.unlock-bc.com/news/2021-03-29/
dubai-financial-services-authority-publishes-consulta- 34. Documents - Financial Action Task Force (FATF)
tion-paper-for-security-tokens (fatf-gafi.org)

6. HM_Treasury_Cryptoasset_and_Stablecoin_con- 35. https://www.coindesk.com/markets/2021/04/01/

sultation.pdf (publishing.service.gov.uk) japan-to-adopt-fatf-travel-rule-for-crypto/

7. Qatar Bans All Cryptocurrency in QFC - Securities.io 36. https://www.legal500.com/developments/

thought-leadership/amended-act-on-reporting-and-us-
8. FCA bans the sale of crypto-derivatives to retail ing-specified-financial-transaction-information-now-gov-
consumers | FCA erns-virtual-assets/
9. https://www.bbc.com/news/technology-58678907 37. https://notabene.id/world/singapore
10. https://news.bitcoin.com/sec-chair-gensler-we- 38. https://www.fic.gov.za/Documents/CRYPTO%20
dont-have-enough-investor-protection-in-crypto-finance- ASSETS%20GETTING%20THE%20REGULATORY%20
issuance-trading-or-lending/ TREATMENT.pdf
11. https://www.wsj.com/articles/bitcoin-draws- 39. https://notabene.id/world/switzerland
more-scrutiny-from-regulators-worried-about-
fraud-11625576400 40. https://www.fatf-gafi.org/publications/mutualev-
aluations/documents/fur-thailand-2021.html
12. https://www.wsj.com/articles/sec-will-po-
lice-cryptocurrencies-to-maximum-possible-ex- 41. https://www.fatf-gafi.org/media/fatf/documents/
tent-chair-gary-gensler-says-11628007567 reports/mer4/Mutual-Evaluation-Report-Turkey-2019.pdf

13. Infrastructure Bill Passed. What Does it Mean for 42. https://www.adgm.com/media/announcements/
Crypto? - Token Metrics Blog fsra-updates-its-virtual-asset-regulatory-framework

14. DeFi Pulse - The Decentralized Finance 43. https://notabene.id/world/united-kingdom

Leaderboard 44. https://ciphertrace.com/the-complete-guide-to-
15. https://www.businessinsider.in/cryptocurrency/ the-fatf-travel-rule-for-cryptocurrency/
news/a-top-us-regulator-said-he-googled-defi-and-thinks- 45. https://www.regulationtomorrow.com/asia/
much-of-it-is-illegal/articleshow/83372633.cms hong-kong-consultation-conclusions-on-licensing-re-
16. https://coingape.com/breaking-sec-signs-625k- gime-for-virtual-assets-services-providers/
contract-with-analytic-firm-to-investigate-defi-market/ 46. Chambers & Partners
17. https://go.chainalysis.com/2021-Crypto-Crime-Re- 47. https://www.sygna.io/blog/japan-crypto-as-
port.html set-regulation-financial-services-agency-chang-
18. https://news.bitcoin.com/ es-psa-fiea-may-2020/
janet-yellen-bitcoin-cryptocurrencies-illicit-financing/ 48. The Legal Development of Crypto Asset in
19. http://www.fatf-gafi.org/publications/fatfrecom- Indonesia - Lexology
mendations/documents/guidance-rba-virtual-assets-2021. 49. https://digital-strategy.ec.europa.eu/en/policies/
html regulatory-framework-blockchain
20. Documents - Financial Action Task Force (FATF) 50. https://main.sci.gov.in/supremecou
(fatf-gafi.org) rt/2018/19230/19230_2018_4_1501_21151_ Judgement_04-
21. https://www.fatf-gafi.org/publications/fatfgener- Mar-2020.pdf
al/documents/outcomes-fatf-plenary-june-2021.html 51. https://cryptonews.com/news/crypto-illegal-in-
22. FATF Blacklists and Greylists: What You Need To the-kingdom-says-saudi-arabia-2433.htm
Know (complyadvantage.com) 52. https://www.fca.org.uk/news/press-releases/
23. 4th-Round-Ratings.pdf (fatf-gafi.org) fca-bans-sale-crypto-derivatives-retail-consumers

24. https://www.zdnet.com/article/home-affairs-be- 53. Australian Consumer Protection Body Issues

lieves-technological-capability-not-there-yet-for-cryptocur- Warning For Investors (forkast.news)
rency-travel-rule/ 54. https://insidebitcoins.com/news/irelands-central-
25. Central Bank of Bahrain issues final rules on bank-chief-warns-of-risky-cryptocurrencies-calls-for-reg-
Crypto-asset services and Crypto-asset exchanges | CBB ulation

26. https://www.fintrac-canafe.gc.ca/ 55. ESAs warn consumers of risks in buying virtual

guidance-directives/transaction-operation/ currencies (europa.eu)
travel-acheminement/1-eng 56. China’s makes all cryptocurrency transactions ille-
27. https://www.bbc.com/news/technology-58678907 gal in blow to Bitcoin and other tokens | Euronews

74
57. https://www.nasdaq.com/articles/bitcoin-ex- in 2021 - Cayman Compass
change-huobi-to-retire-existing-mainland-china-us- 87. Saudi Gazette https://saudigazette.com.sa/
ers-2021-09-27 article/559997
58. U.S.DT sell-off against yuan intensifies on crypto 88. https://www.blockchain.com/
OTCs after China’s crackdown (theblockcrypto.com) charts/n-transactions
59. https://rekt.news/leaderboard/ 89. https://ycharts.com/indicators/
60. https://www.sygna.io/blog/fatf-draft-guidance- ethereum_transactions_per_day
on-rba-to-virtual-assets-and-vasps-public-consultation- 90. See Bank for Int’l Settlements, Central bank digital
march-2021/ currencies for cross-border payments: Report to the G20
61. http://www.cryptoinvestor.news/news/bit- ( July 2021), at p. 1, https://www.bis.org/publ/othp38.pdf.
coin/2019/hong-kong-now-offers-opt-in-regulation-to- 91. See Bank for Int’l Settlements, Central bank digital
crypto-exchanges/ currencies for cross-border payments: Report to the G20
62. Bitcoin becomes legal tender in El Salvador (rte.ie) ( July 2021), at p. 1, https://www.bis.org/publ/othp38.pdf.
63. https://news.bitcoin.com/bitcoin-will-become-cur- 92. See generally Bank for Int’l Settlements, Central
rency-in-brazil-soon-according-to-federal-deputy-aureo-ri- bank digital currencies for cross-border payments: Report
beiro/ to the G20 ( July 2021), https://www.bis.org/publ/othp38.
64. https://news.bitcoin.com/argentin- pdf.
ean-tax-body-asks-domestic-cryptocurrency-exchang- 93. See Foreign Exchange Management Act, 1999, §
es-to-report-monthly-transactions-and-wallet-balances/ 2(h), https://legislative.gov.in/sites/default/files/A1999-
65. https://www.bloomberg.com/news/arti- 42_0.pdf
cles/2019-02-20/bahrain-offers-incubator-style-regulato- 94. Definition of “Currency,” Notification No. FEMA
ry-program-for-crypto 15 (R)/2015 – RB, Reserve Bank of India, Official Gov’t
66. https://www.haaretz.com/israel-news/business/. Gazette of India – Extraordinary, pt. II, § 3(i) (Dec. 29,
premium-israel-finally-readying-a-fintech-regulatory-sand- 2015), https://www.rbi.org.in/scripts/FS_Notification.
box-1.8960548 aspx?Id=10267&fn=5&Mode=0.

67. https://www.forbes.com/sites/japan/2019/06/26/ 95. Vaibhav Parikh et al., India, in THE VIRTUAL

japans-blockchain-sandbox-is-paving-the-way-for-the-fin- CURRENCY REGULATION REVIEW 154 (Michael S. Sackheim
tech-future/?sh=288618223279 et al., eds. 2018), available at http://www.nishithdesai.
com/fileadmin/user_upload/pdfs/NDA%20In%20The%20
68. http://www.koreaherald.com/view. Media/News%20Articles/181207_A_The-Virtual-Currency-
php?ud=20210707000845 Regulation-Review-India.pdf.
69. https://cointelegraph.com/news/crypto-custo- 96. Bank for Int’l Settlements, Central bank digital cur-
dy-firm-graduates-singapore-monetary-authority-s-regu- rencies for cross-border payments: Report to the G20 ( July
latory-sandbox 2021), at p. 1, https://www.bis.org/publ/othp38.pdf.
70. https://practiceguides.chambers. 97. Bank for Int’l Settlements, Central bank digital cur-
com/practice-guides/fintech-2021/thailand/ rencies for cross-border payments: Report to the G20 ( July
trends-and-developments 2021), at p. 1, https://www.bis.org/publ/othp38.pdf.
71. https://cointelegraph.com/news/sands-of-change- 98. https://www.mondaq.com/india/fin-
uae-enables-private-sector-to-adopt-blockchain-tech tech/1023148/cross-border-transactions-cryptocurren-
72. https://www.europarl.europa.eu/legislative-train/ cy-and-foreign-exchange-management-act-fema
theme-a-europe-fit-for-the-digital-age/file-crypto-assets-2 99. See, e.g., U.S. Financial Action Task Force
73. https://finance.swiss/en/innovation/ (“FATF”) Interpretive Note to FATF Recommendation 15,
74. https://www.securities-administrators.ca/indus- International Standards on Combating Money Laundering
try_resources.aspx?id=1588 and the Financing of Terrorism & Proliferation—The FATF
Recommendations ( June 2019), available at www.fatf-gafi.
75. https://www.bcb.gov.br/en/financialstability/ org/recommendations.html.
regulatorysandbox
100. See Ian Allison, Why FinCEN Wants Details on All
76. https://www.bartlettmorgan.com/2018/11/21/ Cross-Border Transactions Over $250, CoinDesk (Nov. 16,
fintech-barbados-launches-regulatory-sandbox/ 2020 at 12:46 p.m. EST), https://www.coindesk.com/poli-
77. https://www.mondaq.com/mexico/ cy/2020/11/16/why-fincen-wants-details-on-all-cross-bor-
fin-tech/891724/mexico39s-regulatory-sandbox-in-2020 der-transactions-over-250/ (quoting Carole House, cyber
78. PowerPoint Presentation (fidelitydigitalassets. and emerging tech policy specialist at FINCEN).
com) 101. See Michael L. Spafford et al., Blockchain and
79. MiCA Working Group Amendments to the Cryptocurrencies: A Cross-Border Conundrum, White
European Commission Proposal - GDF Paper – Paul Hastings, LLP, at p. 4 https://webstorage.
paulhastings.com/Documents/Default%20Library/block-
80. Cryptocurrency Taxation in India 2020 | Is chain-and-cryptocurrencies-cross-border-conundrum-(fi-
Cryptocurrency Taxable in India? (coinswitch.co) nal).pdf
81. South Korea Plans 20% Crypto-Tax From 2022, Will 102. https://www.theblockcrypto.com/post/110506/
Exclude NFTs as Taxable - BeInCrypto crypto-lobbyists-put-defi-proposals-to-fatf-in-open-letter
82. Bitcoin hits new all-time high above $63,000 103. https://www.atlanticcouncil.org/cbdctracker/
ahead of Coinbase debut (cnbc.com)
104. https://financialservices.house.gov/calendar/
83. Cryptocurrency Transfers and Data Collection eventsingle.aspx?EventID=408111
(congress.gov)
105. https://www.imf.org/en/Publications/Policy-
84. Infrastructure Bill Expands Reporting for Papers/Issues/2021/07/09/Central-bank-digital-currencies-
Cryptocurrency ‘Brokers’ (cohnreznick.com) for-cross-border-payments-461850
85. DAC-8: E.U. Directive Could Force Crypto 106. https://www.bis.org/publ/othp40.htm
Exchanges To Hand Over Data To Tax Authorities -
Technology - European Union (mondaq.com) 107. https://www.banque-france.fr/en/communi-
que-de-presse/banque-de-france-and-monetary-authori-
86. OECD to release crypto tax-reporting framework ty-singapore-break-new-ground-cbdc-experimentation-0

75
 108. https://www.reuters.com/business/finance/aus- 141. https://www.reuters.com/business/finance/what-
tralia-singapore-south-africa-test-cross-border-cbank-digi- is-global-minimum-tax-deal-what-will-it-mean-2021-10-08/
tal-payments-2021-09-02/ 142. https://docs.baseline-protocol.org/
109. http://www.pbc.gov.cn/en/3688110/3688172/4157 143. https://www.bsigroup.com/en-GB/standards/
443/4293696/2021071614584691871.pdf
144. https://www.cen.eu/Pages/default.aspx
110. https://www.fmprc.gov.cn/mfa_eng/
zxxx_662805/t1834379.shtml 145. https://www.cenelec.eu/

111. https://www.enaira.com/ 146. http://www.cc.cesi.cn/english.aspx

112. Phillips, T., “The SEC’s Regulatory Role in the Digital 147. https://dcsa.org/
Asset Markets,” Center for American Progress, October 4, 148. https://www.etsi.org/standards
2021 149. https://www.gs1.org/standards
113. Jackson, T., “How Influential People Manipulate 150. https://www.iec.ch/
the Price of Cryptocurrency,” Thomas, The World Finance
Review, June 7, 2021 151. https://standards.ieee.org/

114. Alonso, E., Bodor, N., Jagannathan, S., Chaturvedi, 152. https://www.ietf.org/standards/
P., Ben-Hur, R., Kabra, K., Anand, A., “Market Manipulation in 153. https://iccwbo.org/
Digital Assets,” Deloitte, March, 2021 154. https://irtf.org/
115. Michaels, D., Ostroff, K., Yu, E., “Cryptocurrency’s 155. https://www.iso.org/standards.html
Surge Leaves Global Watchdogs Trying to Catch Up,” The
Wall Street Journal, August 23, 2021 156. https://www.itu.int/en/ITU-T/publications/Pages/
default.aspx
116. See Alonso, T., et al
157. http://www.sac.gov.cn/sacen/
117. See Gazi, S.
158. https://www.standards.org.au/
118. https://www.fatf-gafi.org/media/fatf/documents/
reports/money-laundering-through-transportation-cash. 159. www.wipo.int
pdf 160. https://www.w3.org/standards/
119. https://blog.chainalysis.com/reports/2021-cryp- 161. https://bialliance.io/
to-crime-report-intro-ransomware-scams-darknet-markets 162. https://blockchainindustrygroup.org/
120. https://www.mckinsey. 163. https://www.bita.studio/
com/mgi/overview/in-the-news/
nearly-one-billion-people-have-no-form-of-legal-id 164. https://entethalliance.org/

121. https://www.r3.com/blog/ 165. https://www.gdf.io/

the-evolution-of-digital-identity/ 166. https://www.hyperledger.org/
122. http://www.projectliberty.org/liberty/content/ 167. https://www.iif.com/tsvcm
download/387/2720/file/Liberty_Federated_Social_Identity. 168. https://interwork.org/
pdf
169. https://intervasp.org/
123. https://www.w3.org/TR/did-core/#:~:-
text=Abstract,the%20controller%20of%20the%20 170. https://dlt.mobi/
DID. 171. https://tech.sina.com.cn/it/2018-05-10/doc-ihaich-
124. https://www.gsma.com/identity/ qz3607998.shtml (Chinese)
decentralised-identity 172. https://github.com/bitcoin/bips
125. https://sovrin.org/wp-content/uploads/Sovrin- 173. https://github.com/ethereum/EIPs
Glossary-V3.pdf 174. https://github.com/zcash/zips
126. https://www.the-next- 175. https://xrpl.org/amendments.html
tech.com/blockchain-technology/
how-much-data-is-produced-every-day-2019/ 176. https://dip.diem.com/all-dips/

127. https://www.commontrustnetwork.org/ 177. International Chamber of Commerce, “Green

Economy Roadmap” (2012).
128. https://www.iata.org/en/programs/passenger/
travel-pass/ 178. OECD, “Towards green growth - A summary for
policymakers” (May 2011).
129. https://www.who.int/groups/
smart-vaccination-certificate-working-group 179. “Regulatory changes across the developed world
are obliging institutions to be more honest about carbon
130. https://www.aokpass.com/ neutrality claims. The demand for voluntary carbon off-
131. https://vci.org/ sets is estimated at U.S.$50bln by 2030 and this is still in
132. https://www.goodhealthpass.org/ a very early growth phase. The availability of carbon cred-
it offsets has been mixed with 2 constant challenges. 1.
133. https://www.goodhealthpass.org/blueprint The data available for buyers of carbon credit offsets does
134. https://kantarainitiative.org/about/ not meet sufficient due diligence standards for most glob-
135. https://aries-interop.info al corporations. 2. The supply of carbon credit offsets relat-
ed to actually removing CO2 from the atmosphere accounts
136. https://identity.foundation/arewewaciyet/ for around 5% of the voluntary carbon market. We expect
137. https://indicio.tech/the-decentralized-identity-rev- Carbon Credit Offsets related to removal of CO2 to become
olution-is-powered-by-machine-readable-governance/ the most dominant part of the market given the correct
138. https://www.hindawi.com/journals/ governance framework.” - Adam Linton, CFO & Founder at
scn/2021/8873429/#introduction Xange.com (securities exchange in partnership with UNODC
and UNEP)
139. https://www.iif.com/Publications/ID/4573/
Global-Assured-Identity-Network-White-Paper 180. Id.

140. https://www.fincen.gov/news/news-releases/ 181. https://www.greenameri-

fincen-host-innovation-hours-program-workshop-digi- ca.org/climate-change-100-reasons-hope/
tal-identity-services-and top-10-solutions-reverse-climate-change

76
182. https://www.greenbiz.com/article/ 202. “How Artificial Intelligence will Empower the Tax
carbon-offset-prices-set-increase-tenfold-2030 Function” (Ernst & Young November 2020) https://www.
183. ‘Lucas Joppa, Noelle Walsh, ‘Made to measure: ey.com/en_us/tax/how-artificial-intelligence-will-empow-
Sustainability commitment progress and updates’ (14 er-the-tax-function accessed October 7, 2021
July 2021) <https://blogs.microsoft.com/blog/2021/07/14/ 203. T. N. Dinh and M. T. Thai, “AI and Blockchain: A
made-to-measure-sustainability-commitment-prog- Disruptive Integration,” in Computer, vol. 51, no. 9, pp. 48-
ress-and-updates/> [emphasis original]. 53, September 2018, doi: 10.1109/MC.2018.3620971.
184. Sustainable Energy for All, ‘Call to Action: 204. It is recognised that there are some complex
24/7 Carbon-free Energy Compact to Accelerate the transactions for which this may not be possible, but these
Decarbonization of Electricity Grids’ (24 September will be an exception to the general rule.
2021) <https://www.seforall.org/press-releases/ 205. https://www.gavi.org/our-alliance/governance
energy-leaders-launch-247-carbon-free-energy-compact>.
206. https://dhis2.org/
185. Sustainable Energy for All, ‘Call to Action:
24/7 Carbon-free Energy Compact to Accelerate the 207. https://mojaloop.io/
Decarbonization of Electricity Grids’ (24 September 208. https://www.bis.org/statistics/rpfx19.htm
2021) <https://www.seforall.org/press-releases/ 209. Crypto Derivatives so defined by Phemex.
energy-leaders-launch-247-carbon-free-energy-compact>.
210. https://phemex.com/cryptoacademy/
186. Jemma Green, ‘The Rise of Renewable Energy crypto-derivatives
Certificates’ (7 October 2020) <https://www.forbes.com/
sites/jemmagreen/2020/10/07/the-rise-of-renewable-ener- 211. Liquidation in the cryptocurrency industry refers
gy-certificates/?sh=218eb9203710>. to the automatic unwinding of a position by the exchange
when the trader does no longer meet the minimum margin
187. Google defines carbon-free energy as any type of requirements for their position.
electricity generation that does not directly emit carbon di-
oxide. (See Google, ‘The Internet is 24x7 - carbon-free ener- 212. https://learn.eqonex.com/news/
gy should be too’ (September 2019) <https://sustainability. perpetual-futures-trading-guide
google/progress/projects/24x7/>. 213. https://www.proshares.com/funds/bito.html
188. Jemma Green, ‘The Rise of Renewable Energy 214. https://financefeeds.com/esma-clari-
Certificates’ (7 October 2020) <https://www.forbes.com/ fies-scope-cfd-restrictions-relation-rolling-spot-forex/
sites/jemmagreen/2020/10/07/the-rise-of-renewable-ener- 215. “Glossary: European System of Financial
gy-certificates/?sh=218eb9203710>. Supervision (ESFS)”. Deutsche Bundesbank.
189. InterWork Alliance, “IWA Voluntary Ecological 216. Id.
Markets Overview White Paper.” (2021).
217. https://europa.eu/european-union/about-eu/
190. https://www.epa.gov/climateleadership/ agencies/esma_en
scope-3-inventory-guidance
218. Id.
191. ICROA and Imperial College London, “Unlocking
the Hidden Value of Carbon Offsetting”. (2014). 219. Id.

192. Sandra Garavito and Pedro Moura Costa, 220. https://www.esma.europa.eu/policy-rules/

“Harnessing Corporate Climate Action for Sustainable mifid-ii-and-mifir
Development”. (September 2021). 221. Id.
193. https://www.epa.gov/clean-air-act-overview/ 222. Id.
progress-cleaning-air-and-improving-peoples-health 223. Id.
194. https://www.ipcc.ch/report/ar6/wg1/ 224. Id.
195. Gemini, “Types of Blockchain: PoW, PoS, and 225. Id.
Private”. ( July 2021). https://www.gemini.com/cryptopedia/
blockchain-types-pow-pos-private#section-proof-of-stake- 226. Id.
blockchains 227. https://perma.cc/A4BP-9QS4
196. Global Blockchain Business Council UNGA 2021 228. https://www.esma.europa.eu/press-news/es-
Event, New York ma-news/esma-consults-potential-cfd-and-binary-op-
197. Generally, all blockchains are distributed ledgers, tions-measures-protect-retail
but not all distributed ledger systems are blockchains. For 229. Id.
the purpose of this report the terms ‘DLT’ and ‘Blockchain’ 230. https://www.esma.europa.eu/sites/default/files/
are used interchangeably. library/esma35-43-1000_additional_information_on_the_
198. Science, Government Office for. “Distributed agreed_product_intervention_measures_relating_to_con-
Ledger Technology: Beyond Block Chain.” GOV.UK, tracts_for_differences_and_binary_options.pdf
GOV.UK, 19 Jan. 2016, www.gov.uk/government/news/ 231. 38 Art. 40 of MiFIR permits the ESMA to temporar-
distributed-ledger-technology-beyond-block-chain. ily prohibit, restrict marketing, distribution, or sale of cer-
199. “Article 26 of the OECD Model Tax Convention tain financial instruments on grounds of investor protec-
on Income and on Capital and Its Commentary: Read tion and market integrity.
Online.” Oecd, read.oecd-ilibrary.org/taxation/implement- 232. Id.
ing-the-tax-transparency-standards/article-26-of-the-oecd-
model-tax-convention-on-income-and-on-capital-and-its- 233. https://www.esma.europa.eu/sites/default/files/
commentary_9789264088016-6-en library/esma35-43-1000_additional_information_on_the_
agreed_product_intervention_measures_relating_to_con-
200. This form of proof allows for blockchain-based tracts_for_differences_and_binary_options.pdf
transactions to be verified whilst maintaining user
anonymity. 234. Id.

201. Rowan van Pelt., Slinger Jansen, Djuri Baars, 235. https://www.mas.gov.sg/news/parliamentary-re-
and Sietse Overbeek (2021) Defining Blockchain plies/2020/reply-to-parliamentary-question-on-regula-
Governance: A Framework for Analysis and Comparison, tion-of-crypto-derivatives-on-approved-exchanges
Information Systems Management, 38:1, 21-41, DOI: 236. https://www.mas.gov.sg/regulation/faqs/
10.1080/10580530.2020.1720046 faqs-on-product-definitions

77
 237. National Assembly of Korea. “Act on Reporting and 253. WEF. Bridging the Governance Gap:
Using Specific Financial Transaction Information,” No.17299, Interoperability for Blockchain and Legacy Systems. White
Amended on 2020.05.19., Enforced on 2020.05.20. Paper of World Economic Forum, 2020.12.09.
238. Lee, S. “The core summary of the act on report- 254. WEF. Inclusive Deployment of Blockchain for
ing and using specified financial transaction information Supply Chains: Part 6 – A Framework for Blockchain
that shook the coin market,” Nate News, 2021.08.11 (https:// Interoperability. White Paper of World Economic Forum,
news.nate.com/view/20210810n38625) 2020.04.09.
239. Kim, T. “The act on reporting and using specified 255. ADB. Blockchain Technology for Paperless Trade
financial transaction information specializes only in ‘ex- Facilitation in Maldives. October 2020 (https://www.
change regulations’… Imparis the virtual asset industry,” I adb.org/publications/blockchain-technology-paper-
News, 2021.08.12 (http://www.inews24.com/view/1395891) less-trade-facilitation-maldives).
240. FSC. “[Public Relase] As a result of a full investi- 256. MSIT. “Blockchain Tehnology Development
gation of the collection account of VASPs, 14 disguised ac- Strategy Implementing a Reliable Fourth Industrial
counts were found” Press Release of the FSC, 2021.07.28 Revolution,” Policy Information of the Ministry of Science
(https://www.fsc.go.kr/no010101/76312?). and ICT, 2018.06. (http://www.msip.go.kr/web/msipCon-
241. Lee, G. “What is Travel Rule? … Another hand tents/contents.do?mId=NzM=)
that holds back the exchanges,” Bloter News, 2021.08.23 257. Kim, D. “The next generation of rising star,
(https://www.bloter.net/newsView/blt202108200013) blockchain for the game companies… According to gov-
242. Kwon, D. “[Special Article] DeFi and NFT’s innoca- ernment regulations, they sigh,” Newdaily News,
tion and regulation,” Decenter News, 2021.07.06 (https://de- 2021.04.19 (http://biz.newdaily.co.kr/site/data/ht-
center.kr/NewsView/22OT2TCZ4V) ml/2021/04/19/2021041900101.html)

243. MSIT. “Incorporating blockchain into our lives: 258. Alsop, T. “DRAM manufacturers revenue share
Ministry of Science and ICT planning in full-scale promo- worldwide from 2011 to 2021, by quarter,” STATISTA
tion of 15 blockchain pilot projects in 2021,” Press Release 2021.05.12. (https://www.statista.com/statistics/271726/
of the Ministry of Science and ICT, 2021.05.27 (https://www. global-market-share-held-by-dram-chip-vendors-
msit.go.kr/bbs/view.do?%20sCode=user&mId=113&m- since-2010/).
Pid=112&pageIndex=&bbsSeqNo=94&nttSe- 259. Cusumano, M.A., Yoffie, D.B., and Gawer, A. “The
qNo=3180285&searchOpt=ALL&searchTxt=). future of platforms,” MIT Sloan Management Review 61 (3):
244. Chairman of the Trade, Industry, Energy, SMEs, 46-54, 2020.
and Startups Committee. 2018. “Bill on the Wholly 260. Lee, J.D., et al. Time of Accumulation: Made in
Amendment of the Act on Special Cases Concerning Korea, Suggestions for the Future of Korea. Knowledge
the Special Economic Zones for Specialized Regional Nomad, Seoul, South Korea, 2015.
Development,” National Assembly, Act No. 15705,
September 20th, 2018.
245. Han, M.-J. 2020. “Current Status of the Designating
the Third Round of Regulation-Free Special Zones,” Press
Release of Busan Metropolitan City Hall, 2020.07.06.
(Accessed on August 28th, 2020: http://www.busan.go.kr/
nbtnewsBU/1443413?curPage=&srchBeginDt=&srchEnd-
Dt=&srchKey=sj&srchText=).
246. MSS. Nodate. Regulation-Free Special Zone
(Written in Korean, Accessed on August 28th, 2020: https://
rfz.go.kr).
247. Moon, J. “Four major virtual asset exchanges sur-
vive: Small and medium-sized exchanges such as Gdac,
Huobi Korea, and Gopax are struggling,” Consumer News,
2019.09.17 (https://consumernews.co.kr/news/articleView.
html?idxno=635642).
248. KCS. Korea Customs Completed the World’s
First Blockchain-based Export Customs Clearance Service
Technology Verification. 2017.12.21 (https://eiec.kdi.re.kr/
policy/materialView.do?num=172512)
249. Blockchain Labs. “PASS INFRA: Blockchain-
Based COVID-19 Vaccination Verification & Management
System,” 2021.02.28.(https://ncv.kdca.go.kr/menu.
es?mid=a12509000000).
250. Lee, G., et al. “Blockchain-bassed vaccine pass-
port is made by SKT… It is scheduled to be issued by Jupy,”
Bizchosun News, 2021.03.31 (https://biz.chosun.com/site/
data/html_dir/2021/03/31/2021033102140.html)
251. Lim, M. “Starting to standardize digital vac-
cine passports… Does it become DID killer app?,”
Ajunews, 2021.08.14 (https://www.ajunews.com/
view/20210814022626597)Ministry of SMEs and Startups.
2019_03. “Designating as Regulation-Free Special Zones,”
Public Notice of the Ministry of SMEs and Startups, No.
2019-41, 2019.08.09 (Written in Korean).
252. Cheng, E. and Ming, C. “Bitcoin briefly falls 11%
after South Korea moves to ban new cryptocurrency
trading accounts,” CNBC 2027.12.28 (https://www.cnbc.
com/2017/12/28/bitcoin-drops-11-percent-as-south-korea-
moves-to-regulate-cryptocurrency-trading.html).

78
SECTION XIII

APPENDIX

CONTENTS

Taxonomy 80

Supranationals Chart 90

University Listing 90

Industry Consortia List 90

79
 APPENDIX A

TAXONOMY
TECHNOLOGY TERMS
Term Definition Category Source
An airdrop is the distribution of tokens without
OECD - Taxing Virtual
Airdrop compensation (i.e. for free), generally undertaken with a view Financial
Currencies
to increasing awareness of a new token.
Application An API is a particular set of rules and specifications that
Programming software programs can follow to communicate with each Technical LiMSwiki
Interface (API) other.
Banking Industry Architecture network (BIAN) is a
Red Hat - Modernizing
Banking Industry common architectural framework for enabling banking
Financial Retail Banking with
Architecture Network interoperability. It helps create standardized capabilities in
Blockchain
banking to lower costs and increase innovation.
ISO 22739:2020 -
Block Structured data composed of block data and a block header. Technical
Blockchain Vocabulary
Structured data composed of zero or more transaction ISO 22739:2020 -
Block data Technical
records or references to transaction records. Blockchain Vocabulary
Structured data that includes a cryptographic link to the ISO 22739:2020 -
Block header Technical
previous block unless there is no previous block. Blockchain Vocabulary
The reward given to miners or validators after a block is ISO 22739:2020 -
Block reward Technical
confirmed in a blockchain system Blockchain Vocabulary
A database that places records of transactions in blocks
on a DLT network. Each block is linked (or “chained”) to the
Blockchain Technical GBBC - GSMI 1.0
previous block, using cryptographic signatures that make the
transactions they contain immutable.
Burning is the act of sending cryptocurrency tokens to a
Burning Technical Economic Times
wallet that has no access key.
Centralized finance (CeFi) allows people to earn interest or
CeFi get loans on their cryptocurrency by lending or borrowing it Technical CryptoBriefing
through a centralized corporation.
The on-demand availability of computer system resources,
especially data storage and computing power through the IMF - Digital Money Across
Cloud Computing Technical
internet, typically made available by third-party service Borders
providers.
ISO 22739:2020 -
Confirmed Accepted by consensus for inclusion in a distributed ledger. Technical
Blockchain Vocabulary
ISO 22739:2020 -
Confirmed block Block that has been confirmed Technical
Blockchain Vocabulary
Confirmed ISO 22739:2020 -
A transaction that has been confirmed. Technical
transaction Blockchain Vocabulary
An agreement between Distributed Ledger Technology
(DLT) nodes that a transaction is validated, and that the
ISO 22739:2020 -
Consensus ledger contains a consistent set and ordering of validated Technical
Blockchain Vocabulary
transactions. Different DLTs use different consensus
mechanisms.
Consensus ISO 22739:2020 -
Rules and procedures by which consensus is reached. Technical
mechanism Blockchain Vocabulary
 A link used in the block header to reference the previous
ISO 22739:2020 -
Cryptographic link block in order to create the append-only, sequential chain Technical
Blockchain Vocabulary
that forms a blockchain.
Trust bestowed in a set of machines that are operating a
set of cryptographic algorithms to behave as expected.
Cryptographic Trust Regulatory Sovrin Glossary V3
This form of trust is based on mathematics and computer
hardware/software engineering.
Holding, directly or indirectly, client funds or securities,
SEC - Investor Bulletin:
or having any authority to obtain possession of them. As
Custody Financial Custody of Your Investment
it relates to cryptocurrency, custody commonly refers to
Assets
holding a client’s private keys.
Discipline that embodies the principles, means and
methods for the transformation of data in order to hide ISO 22739:2020 -
Cryptography Technical
their semantic content, prevent their unauthorized use, or Blockchain Vocabulary
prevent their undetected modification.
Decentralized ISO 22739:2020 -
An application that runs on a decentralized system. Technical
application Blockchain Vocabulary
Decentralized A Decentralized Autonomous Organization (DAO) is an
Autonomous organization where the rules of operation and organizational Financial Static1
Organization (DAO) logic are encoded as a smart contract on a blockchain.
Distributed system wherein control of the system is ISO 22739:2020 -
Decentralized system Technical
distributed among the participating entities. Blockchain Vocabulary
Decentralized finance (“DeFi”) is a broad term for financial
DeFi services that build on top of the decentralized foundations Financial WEF
of blockchain technology.
Data which, when appended to a digital object, enables
ISO 22739:2020 -
Digital Signature the user of the digital object to authenticate its origin and Technical
Blockchain Vocabulary
integrity.
A system of electronic records that enables independent
entities to establish a consensus around a shared ledger
without relying on a central authority to provide or
authenticate the authoritative version of the records. The
Distributed Ledger consensus is established by the authoritative ordering of
Technical GBBC - GSMI 1.0
Technology (DLT) cryptographically validated (“signed”) transactions made
persistent by replicating the data across multiple nodes
and tamper-free by linking them via cryptographic hashes.
The shared result of the consensus process serves as the
authoritative version of the records.
Representation of an entity participating in a transaction.
Distributed Ledger ISO 22739:2020 -
Smart contracts, digital assets, and private keys can be Technical
Technology Account Blockchain Vocabulary
associated with Distributed Ledger Technology Accounts.
Distributed Ledger Value that identifies a DLT account participating in a ISO 22739:2020 -
Technical
Technology Address transaction. Blockchain Vocabulary
Distributed Ledger ISO 22739:2020 -
Network of DLT nodes that make up a DLT system. Technical
Technology Network Blockchain Vocabulary
Distributed ledger technology device or process that
Distributed Ledger ISO 22739:2020 -
participates in a network and stores a complete or partial Technical
Technology Node Blockchain Vocabulary
replica of the ledger records.
A service that provides a distributed ledger with external
Distributed Ledger information. DLT Oracles are primarily used to provide ISO 22739:2020 -
Technical
Technology Oracle smart contracts with information that is not available on the Blockchain Vocabulary
DLT system.
System in which components located on networked
ISO 22739:2020 -
Distributed System computers communicate and coordinate their actions by Technical
Blockchain Vocabulary
interacting with each other.
Failure of a DLT platform where the control of a token or
ISO 22739:2020 -
Double spending crypto-asset is incorrectly transferred more than once, Technical
Blockchain Vocabulary
creating a situation of ambiguous ownership of the asset.
 An electronic health record (EHR) is a digital version of a
Electronic Health patient’s paper chart. EHRs are real-time, patient-centered
Healthcare HealthIT
Record records that make information available instantly and
securely to authorized users.
Encoding message or data in such a way that only
Encryption Technical -1
authorized parties can access it.
Having data available across the supply chain in real
Supply
End-to-end visibility time to enable better decisions on risk management and EY
Chain
performance improvement
Item inside or outside an information and communication
technology system, such as a person, an organization, a ISO 22739:2020 -
Entity Technical
device, a subsystem, or a group of such items that has Blockchain Vocabulary
recognizably distinct existence.
The standard allows for the implementation of a standard
API for tokens within smart contracts. This standard provides
ERC-20 basic functionality to transfer tokens, as well as allowing Technical GBBC - GSMI 1.0
tokens to be approved so they can be spent by another on-
chain third party.
The standard allows for the implementation of a standard
application programming interface (API) for non-fungible
ERC-721 Technical GBBC - GSMI 1.0
tokens (NFT) within smart contracts. This standard provides
basic functionality to track and transfer NFTs.
Ethereum is an open-ended, decentralized, blockchain-
based, public software platform that facilitates peer-to-
Ethereum Technical CME
peer contracts, known as Smart Contracts, as well as
Decentralized Applications, known as DApps.
Ability of a functional unit to continue to perform required ISO 22739:2020 -
Fault Tolerance Technical
function in the presence of faults or errors. Blockchain Vocabulary
This is often called staking and refers to the process through
OECD - Taxing Virtual
Forging which transactions are verified when a DLT uses a ‘proof of Financial
Currencies
stake’ mechanism
A token that is interchangeable with an identical token and ISSA Global Corporate
Fungible Token Technical
divisible into smaller units. Action Principles
A genesis block has no previous block and serves to initialize ISO 22739:2020 -
Genesis Block Technical
the blockchain. Blockchain Vocabulary
Governance refers to how a blockchain is initiated and
managed. It defines the rules and procedures about OECD Ilibrary - The
network membership, management of permissions, Potential for Blockchain
Governance Technical
transaction validity, issuance of new assets and their Technology in Corporate
tokenization, dispute resolution, software updates, Governance
regulatory reporting, and protection against cyber risks.
A hard fork is a software change to a DLT protocol that
ISSA - Crypto Assets:
introduces a permanent split between the new protocol
Hard Fork Technical Moving from Theory to
and the old protocol, making them incompatible (“backward
Practice
incompatible”).
Hash Time-Locked A smart contract that enables the implementation of time- World Bank Group -
Technical
Contract bound transactions. Blockchain Interoperability
String of bits which is the output of a cryptographic hash ISO 22739:2020 -
Hash Value Technical
function. Blockchain Vocabulary
The health record is the principal repository for data and American Health
Health record information about healthcare services provided to an Healthcare Information Management
individual patient. Association
Healthtech is the application of organized knowledge and
skills in the form of medicines, medical devices, vaccines, WHO - Health Technologies
Healthtech Healthcare
procedures and systems developed to solve a health and Medicines
problem and improve quality of life.
Hyperledger Fabric, an open-source project from the Linux
Foundation, is a modular blockchain framework, which
Hyperledger Fabric Technical Circulor
is used as a foundation for developing enterprise-grade
applications and industry solutions.
 Hyperledger Sawtooth is an enterprise solution for building,
deploying, and running distributed ledgers. It provides a
Hyperledger
modular and flexible platform for implementing transaction- Technical Hyperledger Sawtooth
Sawtooth
based updates to shared state between untrusted parties
coordinated by consensus algorithms.
A property wherein ledger records cannot be modified or ISO 22739:2020 -
Immutability Technical
removed once added to a distributed ledger. Blockchain Vocabulary
The cryptocurrency industry’s equivalent to an initial public
Initial Coin Offering offering (IPO). A company looking to raise money to create a Investopedia - What is an
Financial
(ICO) new coin, app, or service launches an ICO as a way to raise ICO?
funds.
The Internet of things refers to a type of network to connect
anything with the Internet based on stipulated protocols
Internet of Things through information sensing equipment to conduct IJESC - Volume 6 Issue No.
Technical
(IoT) information exchange and communications in order to 5
achieve smart recognitions, positioning, tracing, monitoring,
and administration.
Ability of two or more systems or applications to exchange
ISO 22739:2020 -
Interoperability information and to mutually use the information that has Technical
Blockchain Vocabulary
been exchanged.
A method of using automation software to extract invoice
Supply
Invoice Automation data, populate the information in an accounts payable Tipalti
Chain
system, and process invoice data for the accounts payable.
Layer 1 is the underlying main architecture of a blockchain
Layer 1 such as the already existing and functioning Bitcoin or Technical Cryptoeq
Ethereum network.
Layer 2 refers to an overlaying network that is built on top of
Layer 2 Technical Cryptoeq
the underlying blockchain.
Information store that keeps records of transactions that ISO 22739:2020 -
Ledger Technical
are intended to be final, definitive, and immutable. Blockchain Vocabulary
Containing transaction records, hash values of transaction
ISO 22739:2020 -
Ledger record records, or references to transaction records recorded on a Technical
Blockchain Vocabulary
distributed ledger.
Liquidity mining is a DeFi mechanism in which participants
supply cryptocurrencies into liquidity pools, and are
Liquidity Mining Financial Defichain
rewarded with fees and tokens based on their share of the
total pool liquidity.
Local payment refers to a payment denominated in a single,
UNECE - Blockchain in
Local payment specific currency exchanged by two banks/Payment Service Financial
Trade Facilitation V2
Providers located within the same country.
Independent blockchain running its own network with its
Mainnet Technical Coinmarketcap
own technology and protocol.
The Master Patient Index identifies patients across separate
clinical, financial and administrative systems and is needed
Master Patient Index Healthcare Indian Health Service
for information exchange to consolidate the patient list from
the various RPMS databases.
Medicalchain is a decentralized platform that enables
Medicalchain secure, fast and transparent exchange and usage of medical Healthcare Medicalchain - Whitepaper
data.
Miners are nodes in the network that ensure the
Miner Technical OECD - Blockchain Primer
transactions in the block are valid.
Activity, in some consensus mechanisms, that creates and
validates blocks or validates ledger records. Participation ISO 22739:2020 -
Mining Technical
in mining is often incentivized by block rewards and Blockchain Vocabulary
transaction fees
Related to a blockchain system but located, performed, or ISO 22739:2020 -
Off-chain Technical
run outside the blockchain system. Blockchain Vocabulary
Related to a DLT system, but located, performed or run ISO 22739:2020 -
Off-ledger Technical
outside the DLT system. Blockchain Vocabulary
 ISO 22739:2020 -
On-chain Located, performed, or run inside a blockchain system. Technical
Blockchain Vocabulary
On-chain governance is a mechanism that enables a
Gemini - An Overview of
On-chain Governance decentralized community to update a blockchain by voting Technical
Blockchain Governance
directly on-chain.
ISO 22739:2020 -
On-ledger Located, performed, or run inside a DLT system. Technical
Blockchain Vocabulary
Having the source code freely available for possible
Open-source Technical Merriam-Webster
modification and redistribution.
Valid and verified blocks which have not been accepted
into the blockchain network due to a time delay in the
Orphan Blocks Technical Cryptoeq
acceptance of the orphan block as opposed to another
qualifying block.
A method of storing cryptocurrency where one writes or
Paper Wallet prints their wallet’s private key and address on paper, which Financial Cryptoeq
is its final security backup method.
Payment transaction means an act of placing, transferring
or withdrawing funds, initiated by the payer, or on his/ UNECE - Blockchain in
Payment transaction Financial
her behalf, or by the payee, irrespective of any underlying Trade Facilitation V2
obligations between the payer and the payee.
Requiring authorization to perform a particular activity or ISO 22739:2020 -
Permissioned Technical
activities. Blockchain Vocabulary
Not requiring authorization to perform any particular ISO 22739:2020 -
Permissionless Technical
activity. Blockchain Vocabulary
Pooled mining pools all the resources of the clients to
generate the solution to a given block. Therefore, rewards
Pooled mining Financial IMF
generated by that block’s solution are split and distributed
between the pool participants.
Private Distributed DLT system that is accessible for use only to a limited group ISO 22739:2020 -
Technical
Ledger System of DLT users. Blockchain Vocabulary
Part of an entity’s asymmetric key pair, used for public key
cryptography. A private key is used to generate a public key
Private key as well as sign off on blockchain transactions. Private keys Technical Original
are used in order to allow an entity to access their crypto
assets, and should not be shared.
A type of consensus mechanism that gives certain nodes
Proof-of-Authority the exclusive right to create new blocks and secure the Taxonomy of Blockchain
Technical
(PoA) blockchain. The Proof-of-Authority mechanism is most Technologies
commonly used for private blockchains.
A type of consensus mechanism in which miners must prove
that they have ‘burned’ a digital asset through sending it to Taxonomy of Blockchain
Proof-of-Burn (PoB) Technical
a verifiable and unspendable address. The Proof-of-Burn Technologies
mechanism is commonly used to bootstrap a network.
A consensus mechanism that focuses on the amount of
Proof-of-Capacity memory the prover can employ to compute the proof. Taxonomy of Blockchain
Technical
(PoC) Miners who dedicate more disk space have a proportionally Technologies
higher likelihood of mining a block and gaining the reward.
A consensus mechanism that selects ‘provers’ based on
the amount of tokens that they own. The more tokens a
‘prover’ owns, the more likely they are to be chosen to verify Taxonomy of Blockchain
Proof-of-Stake (PoS) Technical
the next block. Proof of stake assumes that users with a Technologies
large share of the system wealth are more likely to provide
accurate information.
A consensus mechanism in which miners validate
transactions through solving the inversion of a cryptographic
Taxonomy of Blockchain
Proof-of-Work (PoW) function. The likelihood that a miner mines a new block is Technical
Technologies
proportional to their contribution of computing power to
that of the system’s total computing power.
Key of an entity’s asymmetric key pair which can be made ISO 22739:2020 -
Public key Technical
public. Blockchain Vocabulary
 Cryptography in which a public key and a corresponding
Public-key private key are used for encryption and decryption, or are ISO 22739:2020 -
Technical
Cryptography used for verifying digital signatures and digitally signing, Blockchain Vocabulary
respectively.
Information created, received, and maintained as evidence
ISO 22739:2020 -
Record and as an asset by an organization or person, in pursuit of Technical
Blockchain Vocabulary
legal obligations or in the transaction of business.
Regional payment is a payment denominated in a single,
specific currency exchanged by two banks/Payment Service UNECE - Blockchain in
Regional payment Financial
Providers located within a specific geographical area which Trade Facilitation V2
includes different countries
The use of technology to manage regulatory processes
within the financial industry through technology. The main IMF - Digital Money Across
RegTech Regulatory
functions include regulatory monitoring, reporting, and Borders
compliance.
Reward System Method of offering reward for some activities concerned
ISO 22739:2020 -
(Incentive with the operation of a DLT system. An example of a reward Technical
Blockchain Vocabulary
Mechanism) is a block reward.
Scalability in regards to a blockchain protocol refers to its
Gemini - The Blockchain
Scalability ability to support high transactional throughput and future Financial
Trilemma
growth.
Segregated Witnesses The process to increase Bitcoin blockchain block size limit by
Technical Cryptoeq
(SeqWit) removing signature date from transactions.
Settlement finality is defined as the point when the
BIS - Payments without
Settlement Finality irrevocable and unconditional transfer of an asset occurs. Financial
Borders
Final settlement is a legally defined moment.
A technique in distributed systems that horizontally
partitions databases into rows, called shards. This is done
to reduce the load on the blockchain network’s participating
Sharding Technical Cryptoeq
nodes by eliminating the need for nodes to store every state
or transaction, and instead only store a subset of every
transaction.
Blockchain system that interoperates with a separate
ISO 22739:2020 -
Sidechain associated blockchain system to perform a specific function Technical
Blockchain Vocabulary
in relation to the associated blockchain system.
A computer program that is stored on a DLT) system, used
to define and enforce a set of conditions. Smart contracts
ISSA - Crypto Assets:
are typically used to execute agreements between two
Smart Contract Technical Moving from Theory to
parties, without the involvement of an intermediary. Smart
Practice
contracts sometimes use Oracles to utilize off-chain
information.
A soft fork can be defined as a change to the DLT software
ISSA Global Corporate
Soft Fork that is backward compatible, which means that, unlike hard Technical
Action Principles
forks, there is no splitting or branching out of the blockchain
Solo mining is when a miner performs the mining operations IMF - Treatment of Crypto
Solo Mining individually. All mined blocks are generated to the miner’s Financial Assets in Macroeconomic
credit. Statistics
Crypto staking is the process of locking up crypto holdings in
Staking Technical Sofi
order to obtain rewards or earn interest.
Logically separate chain that can form part of a blockchain ISO 22739:2020 -
Subchain Technical
system. Blockchain Vocabulary
Supervisory technology (suptech) is the use of innovative
technology by supervisory agencies to support supervision.
It helps supervisory agencies to digitize reporting and BIS - FIS Insights onPolicy
SupTech Financial
regulatory processes, resulting in more efficient and Implementation No. 9
proactive monitoring of risk and compliance at financial
institutions.
Telehealth is the use of telecommunications and information
technology to provide access to health assessment, Medicaid.gov -
Telehealth Healthcare
diagnosis, intervention, consultation, supervision and Telemedicine
information across distance.
 Value-less networks used by protocol and smart contract
developers to test their code in a production-like
Testnet environment before deployment to the mainnet. Most Technical Ethereum.org - Docs
testnets use a proof-of-authority consensus mechanism due
to difficulty in incentivizing proof-of-work miners.
Time variant parameter which denotes a point in time with ISO 22739:2020 -
Timestamp Technical
respect to a common time reference. Blockchain Vocabulary
Function by which a transaction, ledger record or block is ISO 22739:2020 -
Validation Technical
validated. Blockchain Vocabulary
Validators are the participants on the network who run
Consensys - What is Proof
Validator nodes (called validator nodes) to propose and attest blocks Technical
of Stake?
on a PoS blockchain.
The virtual file system is the software layer in the kernel that Kernel - Overview of the
Virtual file System Technical
provides the filesystem interface to userspace programs. Linux Virtual File System
A virtual node represents access to an object within a virtual IBM - Understanding Virtual
Virtual Nodes Technical
file system. Nodes
Application used to generate, manage, store or use private ISO 22739:2020 -
Wallet Technical
and public keys. Blockchain Vocabulary

TYPES OF ASSETS/FINANCIAL TERMS

Term Definition Category Source
A type of CBDC tied to an identification scheme, such that all BIS Annual Economic
Account-based CBDC Financial
users need to identify themselves to access it. Report 2021 III. CBDCs
A crypto asset that can be pegged to a price level or a unit GFMA - Designing a
Algorithmic Crypto
maintained through buying, selling, or exchange among Financial Prudential Treatment for
Asset
assets, or some other predetermined mechanism. Crypto-Assets
ISSA Global Corporate
Asset-backed tokens Assets represented digitally on a distributed ledger Technical
Action Principles
A contract or an agreement between two parties to
Bitcoin Futures purchase and sell BTC at a given price at a specific future Financial Phemex Academy
date.
Bitcoin options are the right, but not the obligation, to buy
Bitcoin Options Financial GBBC - GSMI 2.0
bitcoin at a future date at a predetermined price.
Bitcoin perpetual contracts are derivatives that, unlike
futures or options, do not have an expiration or settlement
date. It is a swap contract that is closely pegged to the
Bitcoin perpetual
underlying instrument and is marked-to-market via a Financial Phemex Academy
contracts
“funding rate mechanism” (the relationship between
the swap price, the underlying price, and funding rate is
generally between -0.025% and 0.025%)
A digital payment instrument and store of value issued by
Central Bank Digital and as a liability of a jurisdiction’s central bank or other r3 - CBDC Taxonomy and
Financial
Currency (CBDC) monetary authority, and denominated in that jurisdiction’s Design Choices
national unit of account.
A currency that has an equivalent value in real currency
Convertible (or open)
and can be exchanged back-and-forth for real currency (ex: Financial FATF- Virtual Currencies
virtual currency
Bitcoin).
Crypto assets are a type of private asset that depend
European Banking
Crypto Asset primarily on cryptography and distributed ledger technology Financial
Authority
as part of their perceived or inherent value.
 A crypto asset that is a digital representation of value
with no redeeming rights against a central party.
Cryptocurrencies may function within the community
(enabled through peer-to-peer networks) of its users as
Cryptocurrencies a medium of exchange, unit of account or store of value. Financial GBBC - GSMI 1.0
Cryptocurrencies may also act as an incentive mechanism
and/or facilitate functions performed on the network they
are created in; their value is driven by market supply/
demand therein.
Cryptocurrency A derivative for which the underlying asset or reference is a
Financial GBBC - GSMI 2.0
derivatives cryptocurrency.
An asset in binary form that comes with a right to use,
that has clearly defined notions of issuance, termination,
ownership, and transfer of ownership, a definable monetary
Digital Asset value, which may be between specific counterparties, and Financial GBBC - GSMI 1.0
which may be based on a right to use, or may be based
on the principle of limited supply. A digital asset is not
necessarily analogous to a security.
A term used to distinguish financial assets in digital form
ISSA Global Corporate
Digital Financial Asset from other assets, such as images, videos and texts that are Financial
Action Principles
also rendered in digital form.
A digital asset that is generated and governed by the
Digital Native Tokens Technical World Bank Document
protocol of a DLT system.
KYC is the practice carried out by companies to verify the
Know Your Customer Electronic Identification -
identity of their clients in compliance with legal requirements Financial
(KYC) What is KYC
and current laws and regulations.
Borrowing money from a broker to buy a stock/crypto and
using your investment as collateral. Investors generally use SEC - Margin: Borrowing
Margin Trading Financial
margin to increase their purchasing power so that they can Money to Pay for Stocks
own more stock/crypto without fully paying for it.
A currency that is intended to be specific to a particular
Non-convertible virtual domain or world, such as a Massively Multiplayer
(or closed) virtual Online Role-Playing Game (MMORPG) or Amazon.com, and Financial FATF- Virtual Currencies
currency under the rules governing its use, cannot be exchanged for
fiat currency.
A cryptographic asset on a blockchain with unique
identification codes and metadata that distinguish it from
Non-fungible Token
others. Unlike cryptocurrencies, NFTs cannot be traded Technical Investopedia
(NFT)
or exchanged at equivalency. NFTs are commonly used to
record original work and ownership rights.
A token predicated on protecting user anonymity and
Privacy Coin Technical Cryptoeq
limiting traceability of transactions.
A “satoshi” or “ sat” refers to a single monetary unit of
Satoshi account on the Bitcoin blockchain (100,000, 000 satoshi =1 Financial Cryptoeq
Bitcoin)
Token issued solely on DLT that satisfies the applicable GFMA - Designing a
Security Token regulatory definition of a security or financial instrument Technical Prudential Treatment for
under local law (e.g., World Bank’s “Blockchain Bond”). Crypto-Assets
Representation on DLT of underlying traditional securities/
financial instruments issued on a different platform (e.g., a
traditional CSD, registrar, etc.) where such representation GFMA - Designing a
Settlement Token itself does not satisfy the definition of a security or financial Financial Prudential Treatment for
instrument under local law and is used solely to transfer Crypto-Assets
or record ownership or perform other mid/back-office
functions (e.g. collateral transfer, recording of ownership)
BCBS - Prudential
A crypto asset that aims to maintain a stable value relative to
Stablecoins Financial treatment of
a specified asset, or a pool or basket of assets.
cryptoasset exposures
Store of value An asset, commodity, or currency that maintains its value. Financial Investopedia
 A digital form of money that represents a single fiat currency
Tokenized GFMA - Designing a
and is issued by/structured as a claim on a bank, credit
Commercial Bank Financial Prudential Treatment for
institution or other similarly highly regulated depository
Money Crypto-Assets
institution.
A means of accessing aDLT platform and/or a medium of
exchange which participants on that platform may use
for the provision of goods and services provided on that GFMA - Designing a
Utility Token platform (e.g. loyalty rewards programs/systems, gift card Financial Prudential Treatment for
rewards, credit points that are only usable within the DLT Crypto-Assets
platform, memory and network server space, and other
utilities based value)
Virtual currencies are “a digital representation of value that
Virtual Currencies functions as a medium of exchange, a unit of account, and/ Financial GBBC - GSMI 1.0
or a store of value.”
A CBDC for use by financial institutions (wholesale
BIS Annual Economic
Wholesale CBDC transactions) that is different from balances in traditional Financial
Report 2021 III. CBDCs
bank reserves or settlement accounts.

ENVIRONMENTAL TERMS
Term Definition Category Source
A carbon tax implemented on imported products in order to European Commission -
Carbon Border Supply
prevent “carbon leakage” as a result of climate action in the Carbon Border Adjustment
Adjustment Taxes Chain
host country. Mechanism
One credit is equal to one ton of carbon emissions. The
goal of carbon credits is to decrease carbon emissions
Carbon Credit from companies, by granting them a tradable credit. This Sustainability Investopedia
incentivizes companies to cut down on emissions because
they can gain monetary value from the credits they receive.
A token representing a specified volume of metric tons of
Carbon Emissions
greenhouse gas emissions; distinguishes between the scope Sustainability VEM - Interwork Alliance
Token (CET)
and category of emissions being reported.
A quantifiable amount of carbon that can be traded, Carbon Offset Guide -
Carbon Offsetting bought, or sold in order to reduce carbon emissions in the Regulatory Understanding Carbon
atmosphere. Offsets
A non-fungible Token representing 1 mtCO2e removed from
Carbon Removal Unit the atmosphere and stored. Shares the same Core Carbon
Sustainability VEM - Interwork Alliance
Token Principles with attributes focusing on additionality, durability
and reversal/replacements.
A carbon token is an asset-backed stable token with Veridium - Unlocking the
Supply
Carbon Token underlying carbon assets that have low price volatility and World’s Environmental
Chain
can be independently verified on international registries. Asset Markets
Enables organizations to dynamically track and calculate the
GHG emissions footprint of their operations (scope 1 and
Carbon Tracking Sustainability Circulor
scope 2) and supply chains (scope 3), providing accurate
emissions insights based on the actual flow of materials.
Minerals trade used to finance armed groups, fuel forced
Conflict Minerals labor and other human rights abuses, and support Sustainability European Commission
corruption and money laundering.
A blueprint published by the Institute of International
Core Carbon IIF - TSCVM Phase 2 Report,
Finance that outlines criteria for utilizing and scaling Regulatory
Principles Page 13
voluntary carbon markets.
A fungible token representing a specified volume of metric
Core Carbon tons of greenhouse gas emissions reduced or removed
Sustainability VEM - Interwork Alliance
Principles Token by a project with standard data elements aligning with the
TSVCM’s Core Carbon Principles.
As relates to ecological markets, an individual or
Credit Buyer organization that purchases verified credits issued by a Regulatory VEM - Interwork Alliance
Standard Registry.
 A token issued by a Modular Benefit Project containing
Ecological Claim co-benefits of the project (e.g. water conservation) and
Regulatory VEM - Interwork Alliance
Token checkpoints, representing potions of a claim that build over
time.
A single source of truth to all participants regarding the
identity of a project or program and its ecological benefit
Ecological Project/ claims; contains key details that are important for the
Sustainability VEM - Interwork Alliance
Program (EP) supplier, validation and verification body, standard registry,
and buyer in the market. An EP can contain multiple
Modular Benefit Projects.
A simple scorecard for a participant to record their
Environmental, Social,
established pledge (net zero, net negative, etc.) and track
Governance (ESG) Sustainability VEM - Interwork Alliance
progress (goals, forecast, actuals, effective). Commonly a
Scorecard
report issued through an external auditor.
Performance evaluation based on ESG criteria and
ESG Certification certifications under environmental, social and governance Sustainability SGS ESG Certification
categories, leading to the issuance of an ESG certificate.
Enables a supplier to provide their customers with
ESG Token Environmental, Social and Corporate Governance data Sustainability SGS ESG Certification
regarding individual products
The process of conveying a false impression or providing
Green Washing misleading information about how a company’s products or Sustainability Investopedia
operations are more environmentally sound.
A data element contained in an Ecological Project/Program
(EP); an EP can have multiple MBPs depending on what type
Modular Benefit
of claim the project will be making (e.g. carbon removal, Sustainability VEM - Interwork Alliance
Project (MBP)
carbon reduction, etc.); used to issue specific types of Claim
Tokens.
Once validated and verified it is a credible claim that has
Processed Claim
an associate credit and is returned or burned, requires Regulatory VEM - Interwork Alliance
Control
Processed Id. Mint, Roles and Credible behaviors.
An organization that establishes science-based standards
for measuring, reporting, and verifying (MRV) ecological
benefit claims and issues value in the form of credit for
Standard Registry Regulatory VEM - Interwork Alliance
claims that meet the standard set. A standard registry also
certifies verifiers to collect and process claims based on the
established standard.
A supplier performs the actions, in either an Ecological
Project or Program (EP), for creating the asset value for use
Supply
Supplier in the voluntary market and becomes the initial owner of VEM - Interwork Alliance
Chain
the ecological benefit value generated. Includes owners,
sponsors, and developers.
Taskforce on Scaling
An initiative that is focused on creating a voluntary carbon
Voluntary Carbon Regulatory TSVCM
market that is consistent with the Paris Agreement.
Markets
Validation and
An organization that is certified by a Standard Registry to
Verification Body Regulatory VEM - Interwork Alliance
verify MRV claims issued by an EP.
(VVB)
A multi-party contract between an Ecological Project (EP)
and a Validation and Verification Body specifying the type of
Verification Contract VEM - Interwork Alliance
benefit being created; each Modular Benefit Project within
an EP would have a separate Verification Contract.

DIGITAL ID TERMS
Term Definition Category Source
A Credential issued by an Auditor Accreditor or
Accreditation Governance Authority asserting that a Trust Community
Regulatory Sovrin Glossary V3
Credential Member conforms to the Accreditation requirements of a
Governance Framework.
 An Agent that is hosted in the cloud. It typically operates
on a computing device over which the Identity Owner
does not have direct physical control or access. Mutually
Cloud Agent Regulatory Sovrin Glossary V3
exclusive with Edge Agent. A Cloud Agent requires a Wallet
and typically has a Service Endpoint. Cloud agents may be
hosted by an Agency.
An Entity that serves as a Holder of Credentials issued
by Trust Community Members in order to provide a
cryptographically verifiable directory service to the Trust
Community or to the public. The term also refers to the
Credential Registry Regulatory Sovrin Glossary V3
actual repository of Credentials maintained by this Entity.
An informal Credential Registry may accept Credentials from
participants whose purpose is to cross-certify each other’s
roles in the Trust Community.
A Credential issued by a Governance Authority asserting
Credential Registry
that a Credential Registry is authorized under a particular Regulatory Sovrin Glossary V3
Credential
Governance Framework
A globally unique identifier developed specifically for
decentralized systems as defined by the W3C DID
Decentralized
specification. DIDs enable interoperable decentralized Self- Regulatory Sovrin Glossary V3
Identifier (DID)
Sovereign Identity management. A DID is associated with
exactly one DID Document.
An Agent that operates at the edge of the network on a local
device, such as a smartphone, tablet, laptop, automotive
Edge Agent computer, etc. The device owner usually has local access Regulatory Sovrin Glossary V3
to the device and can exert control over its use and
authorization. Mutually exclusive with Cloud Agent.
Edge-to-Edge A Connection that forms and/or communicates directly
Regulatory Sovrin Glossary V3
Connection between two Edge Agents
Governance Authority The Entity (typically an Organization) governing a particular
Regulatory Sovrin Glossary V3
(GA) Governance Framework.
Governance Authority A Credential issued by one Governance Authority asserting
Regulatory Sovrin Glossary V3
Credential the recognition of another Governance Authority.
Information that enables a specific Entity to be distinguished
from all others in a specific context. Identity may apply to
Identity Regulatory Sovrin Glossary V3
any type of Entity, including Individuals, Organizations, and
Things.
The set of data associated with an Identity that permits
Identity Data Regulatory Sovrin Glossary V3
identification of the underlying Entity.
A set of Attributes sufficient to identify an Identity Owner
for the purpose of legal accountability in at least one
Legal Identity Jurisdiction. A Legal Identity may be established by one Regulatory Sovrin Glossary V3
or more valid Credentials from Issuers that are trusted to
provide the necessary Attributes.
A measure—usually numeric—of the Trust Assurance that
one Entity has in another Entity based on a defined set of
Level of Assurance criteria that establish the amount of reliance the first Entity
Regulatory Sovrin Glossary V3
(LOA) may accept from the second Entity in the performance of
the criteria. LOAs are often defined in or referenced by
Governance Frameworks.
A cryptographic data structure maintained over a single
Connection that enables two or more Agents to securely Supply
Microledger Sovrin Glossary V3
share Pairwise Digital IDs, Public Keys, Service Endpoints, Chain
and other Identity Data.
A role played by an Entity when it generates a Zero
Prover Knowledge Proof from a Credential. The Prover is also the Regulatory Sovrin Glossary V3
Holder of the Credential.
An identity system architecture based on the core principle
Self-sovereign that identify owners have the right to permanently control
Healthcare Sovrin Glossary V3
Identity one or more identifiers together with the usage of the
associated identity data.
 A set of Entities cooperating to achieve their mutual trust
objectives. An informal Trust Community may not have an
Trust Community official structure or a Governance Framework. A formal Trust Regulatory Sovrin Glossary V3
Community consists of the set of all Entities participating in a
Governance Framework

SUPPLY CHAIN TERMS

Term Definition Category Source
A discrepancy highlighted in the supply chain that could
potentially highlight an issue (e.g. an event that has Supply
Anomalies Circulor
happened in an unknown location, a mass balance ratio Chain
discrepancy between points in a supply chain).
An asset is a physical item that is being tracked through
Supply
Asset the chain of custody. An asset is identified by a QR Code, Circulor
Chain
barcode, NFC tag, etc.
A process that tracks the movement of evidence through
its collection, safeguarding, and analysis lifecycle by
Supply NIST - Computer Security
Chain-of-custody documenting each person who handled the evidence, the
Chain Resource Center
date/time it was collected or transferred, the GPS location
the action occurred, and the purpose for the transfer.
Used in the Circulor platform, with permission, to allow
Supply
Circulor Lockbox™ Organisations access to records within their supply chain Circulor
Chain
that they do not own.
The proprietary Circulor Protocol, embedded within the
Supply
Circulor Protocol™ Circulor platform, verifies data entered onto the system and Circulor
Chain
enforces common rules on all ecosystem participants.
An event is an action that occurs on an Asset being tracked
Supply
Events in the supply chain, and forms the chain of custody of a Circulor
Chain
given Asset.
Supply
First Mile The starting point in a supply chain Circulor
Chain
The amount of emissions that are inherited by downstream Supply
Inherited Emissions Circulor
suppliers in the supply chain. Chain
A statement or legal document that discloses some or all
Privacy Protection Supply
of the ways a party gathers, uses, discloses, and manages a Circulor
Policy Chain
customer or client’s data.
The proof of traceability and provenance of an Asset that is Supply
Traceability Circulor
being tracked through a Supply Chain. Chain
 APPENDIX B

SUPRANATIONALS CHART
The GSMI subteam focused on a subset of supranational organizations with the following
highlights. Access the full suprationals chart here.

10 Supranationals
187 Jurisdictions

APPENDIX C

BLOCKCHAIN UNIVERSITIES
The GBBC team mapped universities across the globe actively training the next generation of
blockchain professionals. Read the results here.

389
courses and degrees mapped
68
Jurisdictions

APPENDIX D

INDUSTRY CONSORTIA LIST

We are grateful to our research partners for this portion of the report, who include Accenture,
ESG Intelligence, and GDF. Access the full consortia list here.

479
industry consortia mapped
GLOBAL BLOCKCHAIN
BUSINESS COUNCIL

DC Location:
1629 K St. NW, Suite 300
Washington, DC 20006

Geneva Location:
20 Rue de-Candolle
1205 Geneva