链闻消息，路印钱包宣布推出「首次钱包发行」机制 IWO，Web3 孵化器 DAOSquare 将作为其 IWO 的首发项目，将于 5 月 19 日晚公布 IWO 具体规则。路印钱包的 IWO 与 IDO 相比，参与流程简单，只需注册一个路印钱包，就能参与优质项目的额度认购。此外，路印钱包是集成二层扩容技术的非托管钱包，后续将推出 IWO 项目的交易大赛以及流动性挖矿活动，用户可在路印钱包拥有交易秒成交、零 Gas 费的体验。
链闻消息，二层隐私协议 Suterusu 将于 5 月 23 日 20:00 启动 xSuter 拍卖活动，将交易服务费池中约 250 万美元价值的 BNB/BUSD 等代币一次性分红给 xSuter 的持有者，拍卖活动将持续 48 小时，结束时间为 5 月 25 日 20:00。xSuter 的的发行总量共计 32000 枚，其中参与本次创世卖拍的数量为 19000 枚，另有 1000 枚用于与 Suterusu 团队的合作伙伴举办大型空投活动。预留给未来拍卖的数量为 12000 枚。用户获得 xSuter 的方式有两种，其一是锁定自己所持的 Suter，通过创世拍卖活动换取 xSuter，其二是参与合作社区的空投抽奖。每一枚 xSuter 在本次活动中都会分得至少 120 美元的收益，并且还可以持续分享网络后续的交易手续费。
Firms with iconoclastic leaders, like Musk and Dorsey, “would be the most likely to take the plunge” and commit sizable cash balances to crypto.
It surely hasn’t escaped their notice, after all, that a number of public companies that “joined” Bitcoin (BTC) in a big way over the past year recently broadcast strong Q1 2021 earnings. Square, which holds $472 million worth of BTC, for instance, reported a quarterly gross profit increase of 79% year-over-year, doubling analysts’ expectations. While Tesla, which plunked down $1.5 billion — 8% of its cash — into BTC in February, posted record earnings with revenues surging 74%. MicroStrategy, which made Bitcoin its primary corporate reserve in 2020, notched a 10% gain in Q1 revenues.
“If inflation picks up, or even if it doesn’t, and more companies decide to diversify some small portion of their cash balances into bitcoin instead of cash, then the current relative trickle into bitcoin would become a torrent,” wrote storied investor Bill Miller in a market letter earlier this year. Already, “companies such as Square, MassMutual, and MicroStrategy have moved cash into bitcoin rather than have guaranteed losses on cash held on their balance sheet,” he added.
Elsewhere, Ark Investments commented in a company newsletter: “Microstrategy, Square, and now Tesla are showing public companies the way to add bitcoin as a legitimate alternative to cash on their balance sheets.”
But Bitcoin remains a volatile asset — as the most recent BTC price drop to $46,000 reminded users again — so maybe its embrace by corporate treasurers is really just a short-term happenstance? On the other hand, if the trend does have legs, is it really appropriate for all companies? If so, at what level of allocation is appropriate?
Overall, what does this say about the global economy if public firms now look to a 12-year-old digital currency to keep its cash stockpiles liquid and secure?
A longer-term trend or seasonal fashion?
“I do not view this as a fad,” Paul Cappelli, a portfolio manager at Galaxy Fund Management, told Cointelegraph. Bitcoin’s “inelastic supply curve and deflationary issuance schedule” make it a “compelling hedge against inflation and poor monetary policies that could lead to cash positions becoming devalued over time,” he told Cointelegraph, predicting:
“Corporations will continue to use Bitcoin as one of the tools available to preserve the value of their balance sheets.”
David Grider, lead digital asset strategist at Fundstrat, informed Cointelegraph that as crypto becomes more mainstream, he expects to see “more corporates holding crypto for legitimate business purposes.” Exchanges could hold it as inventory, tech companies might use it to stake tokens and participate in networks, while multinational corporations could accept it for payments.
“I expect two types of companies to consider early adoption of crypto — ones led by leaders who are strong believers in crypto, as well as companies that may have unique cross-border needs that are a good fit for Bitcoin transfers,” Gil Luria, director of research at D.A. Davidson & Co., told Cointelegraph.
If so, doesn’t this represent a sea change for corporate finance officers? “When I did my treasury exams, the thing we were told as number one objective is to guarantee security and liquidity of the balance sheet,” Graham Robinson, a partner in international tax and treasury at PricewaterhouseCoopers and adviser to the United Kingdom’s Association for Corporate Treasurers, told Reuters. BTC with its volatility might simply not fit the bill.
If Bitcoin were to be used as a corporate treasury reserve, and its price plunged, that company might not be able to meet its working capital requirements, noted Robert Willens, adjunct professor of Columbia Business School, in January, when he described it as “a high-risk, high-reward strategy.”
Has Willens changed his views? “I still believe it is a high risk/high reward strategy,” he told Cointelegraph, acknowledging that “lately, the rewards have far outweighed the risks.” He does see more firms following the lead of Tesla and Square, “as crypto investments become more ‘respectable’ and emerge as a viable outlet for corporate cash balances.” Asked who might lead the way, Willens answered:
“I think companies with iconoclastic leaders — not necessarily confined to a particular industry — would be the most likely to take the plunge and commit a decent amount of the corporation’s cash balances in crypto.”
Fundstrat’s Grider, citing the OTC trading firm Genesis’ Capital trading data, told Cointelegraph that more corporations may be buying crypto than has been reported in earnings statements. The Genesis Q1 2021 “Market Observations Report,” for example, reported a striking jump in “corporates’” share of crypto trading volume to ~27% from ~0% in the quarters prior. “As corporate clients began buying bitcoin for their treasuries in Q1, our ratios shifted,” noted Genesis.
As corporate finance leaders prepare to set sail into the post-COVID-19 world amid inflation storm warnings, an increasing number of corporations are taking stock of their treasury reserve holdings. If the worst happens, and the dollar and other reserve currencies weaken, are they sure that all their balance-sheet cash is lashed down securely?
Tesla allocated 8% — Is it too much?
Assuming that a company believes that crypto should be part of its treasury reserves, how much should it actually allocate? Last year, Cappelli told Cointelegraph that an investment of 50 basis points to 2% of reserves was about right, given crypto’s volatility. But since then, crypto prices have skyrocketed, and Tesla allocated a whopping 8% — or $1.5 billion — to its corporate cash reserves. Is the recommended allocation growing?
“I don’t think there’s a bright-line rule that we can apply here across the board,” Willens told Cointelegraph, “but I think something well north of 2% would be appropriate — perhaps as much as 8%–10% might even be acceptable.”
“It will all depend on the company,” Cappelli said this past week. “Corporations manage their balance sheets to fund operations and maintain a certain amount of liquidity.” Bitcoin is still a very volatile asset, “so while it does provide a hedge against inflation, it does come with a certain amount of market risk. I’d be very surprised to see a company allocation much more than a ballpark of 5% currently, but that may change over time.”
Still, what about Robinson’s contention that a corporate treasurer’s job is to guarantee liquidity and security of the balance sheet — and could Bitcoin not do that?
“If you think about crypto purely as cash, it is still very volatile relative to the dollar,” Grider told Cointelegraph. “But some assets like Bitcoin are becoming less volatile lately, and we are seeing strong liquidity emerge in crypto, which is encouraging.”
One way a firm could think about holding crypto is as an alternative to cash, continued Grider, “but you can also think about it like inventory or a marketable securities investment or an intangible long-term asset. That means even if not an ideal treasury asset in all respects, corporates could still hold crypto for other reasons,” such as:
“Certain incumbent businesses could buy crypto as a hedge against tech disruption, just like doing M&A of a competing startup.”
“I think the liquidity concern is a valid one,” responded Willens, “but limiting the investment to 8%–10% of the investible funds ought to insulate treasurers from criticism since the balance of the funds would be deployed in cash and cash equivalents with a readily realizable value.”
There is a sizing exercise that occurs for every investment, added Capelli, and “taking all balance sheet investments into account” is part of any corporate treasurer’s or chief investment officer’s job. Meanwhile, Luria declared that “crypto assets are liquid enough that this should not be a constraint.”
A more significant disincentive to using crypto as a corporate treasury reserve, in Willens’ view, may be the accounting treatment to which it is subjected at present — i.e., “the odd way investments in crypto are accounted for — they are treated as ‘indefinite-lived intangible assets,’ and thus any declines in the value of the asset must be reflected in income from continuing operations, whereas price increases cannot be so reflected.” He described this “unfavorable accounting treatment […] as the most unattractive aspect of an investment therein.”
A “tectonic shift” in global finance?
All in all, the current monetary environment has raised serious corporate concerns about inflation and the continued strength of the United States dollar. It should not be surprising, as Grider said, “that corporations would become more open to alternatives like crypto.”
But something even larger may be going on. As Perianne Boring noted recently in the New York Times, a “tectonic shift” may be underway in global finance thanks to cryptocurrency. “Digital assets have brought forth a new paradigm in global finance,” concurred Cappelli, though we are still in the very early stages:
“With every cycle, there are always pockets of froth, but structurally, what we have seen built over the last few years certainly provides a strong foundation for this new asset class.”
The final guidance expected to be issued by the FATF this summer might determine the next chapter for the decentralized finance space.
The decentralized finance, or DeFi, space exploded over the last year, with a total value locked in DeFi of around $90 billion, according to DeBank. The DeFi ecosystem includes projects like Maker, Aave, Compound, Uniswap and more, with new ones rapidly emerging. DeFi is a broad concept to describe an emerging area of finance built using decentralized technological tools and characterized by being open, permissionless, disintermediated and with no single point of failure.
The spectrum of DeFi is broad, and the exact degree and mixture of various technological and governance features determine how decentralized a particular DeFi project is, or whether it is a DeFi at all. DeFi currently includes services like lending and borrowing, derivatives, margin trading, payments, asset management and nonfungible tokens, and it will expand and diversify in the future.
Rapidly expanding, the DeFi market has not escaped the attention of authorities — the Financial Action Task Force, or FATF, being one of them. The FATF is the intergovernmental policy-making body that monitors and sets international standards for Anti-Money Laundering and Counter-Terrorism Financing rules through its recommendations to governments. In March, the FATF issued a draft of revised guidance for a risk-based approach to virtual assets and virtual assets service providers, or VASPs, on which it was seeking comments from stakeholders until late April. The final revised guidance is due to be published in June.
The FATF first introduced a virtual asset and a VASP to its glossary in 2018 and explicitly clarified that FATF standards and recommendations apply to them. In June 2019, the FATF issued further guidance for a risk-based approach to virtual assets and VASPs, helping authorities respond to virtual asset activities and VASPs. Furthermore, it also helped private actors engaging in virtual asset activities understand their AML/CTF compliance obligations.
The forthcoming guidance focuses on six areas: 1) clarification of virtual asset and VASP definitions; 2) stablecoins; 3) the risks and potential risk mitigants for peer-to-peer transactions; 4) licensing and registration of VASPs; 5) implementation of the Travel Rule; and 6) principles of information-sharing and cooperation among VASP supervisors.
Some of the more intensely debated issues concern an expansive approach to the definition of a VASP, as FATF recommendations require that all VASPs are regulated for AML/CTF purposes, licensed or registered, and subject to monitoring or supervision. They will also be subject to the Travel Rule. It is therefore crucial for all participants in virtual asset-related activities to have clarity on whether they fall within the scope of a VASP definition.
DApps and VASPs
A VASP is defined as any natural or legal person who conducts, for or on behalf of another person (i.e., as an intermediary), certain activities or operations, including exchange — either between virtual assets and fiat currencies or between virtual assets — or transfer of virtual assets.
The FATF recognizes that VASP activities, the exchange or transfer of virtual assets, may also take place through decentralized exchanges. These are software programs that are decentralized or distributed applications, or DApps, that operate on a peer-to-peer network of computers running a blockchain protocol. A DApp itself is not considered a VASP since the FATF maintains that it does not seek to regulate the technology and its standards are meant to be technologically neutral.
However, the FATF makes it clear that it takes an expansive view on virtual asset and VASP definitions, and that most existing arrangements have some party involved that would qualify as a VASP, either at the development or launch stage of the project. Draft guidance specifies that DApps usually have a “central party” involved in creating and launching an asset, setting parameters, holding an administrative key or collecting fees, and such entities involved with the DApp may qualify as VASPs.
Which DeFi participants could be the potential new VASPs?
Similarly as stated in its 2019 FATF guidance, owner/operator(s) are mentioned, but this time, they not only may fall under a VASP definition but they likely fall within it since they are conducting VASP activities as a business on behalf of their customers. This would apply even if other parties have a role to play or the process is automated. In addition, any person involved in business development activities for DApps could qualify as a VASP, provided they engage in VASP activities as a business and on behalf of others (i.e., as intermediaries).
In addition, draft guidance specifies that anyone directing the creation, development or launching of the software to provide VASP services for profit is likely to be a VASP as well. A provider that launches a service would remain subject to VASP regulations in the future, even if the platform becomes fully automated and the provider is no longer involved. This is specifically the case when the provider could continue to benefit either directly, or indirectly, through fee collection or realizing a profit in some other ways. This could potentially apply to those developers that could benefit from an increase in the price of tokens, and the FATF specifically indicates that a party that profits from the use of a virtual asset could be a VASP. It is also not clear how holders of governance tokens would be treated, as the FATF explains that a decision-making entity that controls the terms of the financial service provided is likely to be a VASP as well.
The FATF is clear that launching an infrastructure is equivalent to offering its services, and commissioning others to build it is equivalent to actually building it. The whole lifecycle of a product or a service is relevant, and the decentralization of any individual element of operations does not affect qualification as a VASP and does not relieve such VASP of its obligations. The FATF also vaguely says that some kinds of matching or finding services could also qualify as VASPs even if not interposed in the transaction, despite stating that a pure-matching service platform that does not undertake VASP services would not be a VASP.
One of the implications of being caught within VASP definition would be an application of the Travel Rule, when VASPs will be required to perform extensive Know Your Customer and Anti-Money Laundering checks for the originator and beneficiary of transactions. Such requirements imposed on DeFi participants raise many concerns, not least of which are privacy and data protection issues.
DeFi is currently operating with no or minimal regulation, compared with traditional, centralized finance. It is becoming clear that some form of regulatory compliance for DeFi is inevitable. However, FATF draft guidance raises some questions. Under the current proposal, all kinds of parties considered central parties, entities involved or providers could face a high compliance burden of a VASP, even if their role in a DeFi project is limited, either in time or on merits.
Lacking further clarity as to exactly who and when would be caught within a VASP definition could prompt individual countries to adopt a broad regulatory scope and overregulate. It is also not clear how VASP obligations could even be applied in practice to DeFi or fulfilled across DeFi protocols, autonomous software and unhosted wallets.
DeFi is a new paradigm of finance, characterized by being open, permissionless and disintermediated. This multidimensional and dynamically evolving phenomenon is going through an experimental phase. It might be considered premature to impose stringent regulatory compliance obligations that were originally designed for centralized organizational structures, to an emerging DeFi ecosystem. It is as important to mitigate the risks as it is to not drive DeFi innovation underground, since this would achieve the opposite effect and could bring obscurity instead of transparency, and uncertainty instead of clarity.
Although the FATF’s guidance is not legally binding, it is expected to be followed. Countries that fail to do so risk being added to the so-called FATF “grey list” of jurisdictions under increased monitoring or “black list” of high-risk jurisdictions subject to a call for action. The stakeholders have provided their feedback, and now it is the FATF’s turn to issue the final guidance, which might determine the next chapter for DeFi.
The views, thoughts and opinions expressed here are the author’s alone and do not necessarily reflect or represent the views and opinions of Cointelegraph, nor the Warsaw University of Technology or its affiliates.
This article is for general information purposes and is not intended to be and should not be taken as legal advice.
链闻消息，据 Bitcoin.com 报道，伊朗立法机构伊朗伊斯兰议会（Islamic Consultative Assembly）发言人 Mohammad Baqer Qalibaf 在如何监管比特币等去中心化金融资产的辩论中表示伊朗央行应针对加密货币交易所制定更明确的法规。在过去一年里，随着加密货币价格的上涨和伊朗股市的暴跌，加密货币在伊朗民众中越来越受欢迎。Mohammad Baqer Qalibaf 表示，「仅仅禁止加密货币交易本身是不够的。伊朗央行（CBI）负责授权交易平台。CBI 需要针对加密交易所的功能制定精确的法规，并在规则最终确定之前阻止它们访问支付网关。」
另外，Qalibaf 在写给包括 CBI 和经济事务和财政部在内的金融监管机构的一封信中，呼吁伊朗国家税务总局（INTA）描述加密货币交易平台的所有者。议会议长强调说，税务机关预计将尽快向议会提交一份报告。据《金融论坛报》商业日报报道，议会还下令伊朗伊斯兰共和国广播公司（IRIB）和文化部采取必要措施，向公众传达对加密货币和数字资产交易所运营细节的认识。