📍Yesterday, BBA submitted its formal response to the Financial Conduct Authority's Consultation Paper CP26/13: Cryptoasset Perimeter Guidance.
While we welcome the FCA’s efforts to provide greater regulatory clarity, we disagree with several aspects of the proposed guidance, and have invited the FCA to revisit six key areas:
➡️ The “identifiable person” doctrine is too elastic
➡️ The qualifying stablecoin definition leaves perimeter gap
➡️ The safeguarding “control” test is broader than the harm justified
➡️ The categorical treatment of crypto lending as “dealing"
➡️ The complete disapplication of the overseas persons exclusion
➡️ The dual MLR/FSMA architecture is duplicative
🌐 We would like to thank our members, advisors, partners, and researchers at CEBB for drafting this comprehensive, evidence-based response.
#Blockchain #FCA #Cryptoasset #UKRegulation #DigitalAssets #BBA
While we welcome the FCA’s efforts to provide greater regulatory clarity, we disagree with several aspects of the proposed guidance, and have invited the FCA to revisit six key areas:
➡️ The “identifiable person” doctrine is too elastic
➡️ The qualifying stablecoin definition leaves perimeter gap
➡️ The safeguarding “control” test is broader than the harm justified
➡️ The categorical treatment of crypto lending as “dealing"
➡️ The complete disapplication of the overseas persons exclusion
➡️ The dual MLR/FSMA architecture is duplicative
🌐 We would like to thank our members, advisors, partners, and researchers at CEBB for drafting this comprehensive, evidence-based response.
#Blockchain #FCA #Cryptoasset #UKRegulation #DigitalAssets #BBA