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14 · Digital currency and blockchain technology · MiCA · AMF · SEC

Digital currency and blockchain technology

What assistance changes in this practice, what it does not change, and the time reduction actually observed.

Where the gain is real

Characterisation of tokens under the applicable regimes, review of white papers and published code, tracing of on-chain flows.

Where it is slight or nil

The decision to issue, dialogue with the regulator, the economic design of the protocol.

Observed time

−53% at constant case scope, on cases closed over the last three financial years. This measure says nothing about the quality of the outcome.

What the practice covers

  • Characterisation of tokens and of digital asset services
  • Service provider authorisation, regulatory filings and ongoing compliance
  • Review of white papers, terms of service and marketing materials
  • Tracing of on-chain flows and reconciliation with the accounting records
  • Anti-money laundering arrangements applied to digital asset transfers
  • Custody, staking and protocol access agreements
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