CVA Regulatory WG responds to Federal Department of Finance on blockchain blanket ordinance
The Crypto Valley Association has submitted its consultation response to the Ordinance on the Adaptation of Federal Law to Developments in Distributed Electronic Register (DLT) Technology on February 2nd, 2021.
In this document, you will find a systematic analysis of the proposal highlighting the key questions and opinions discussed by the Regulatory Working Group during our meetings. In particular, we discussed the paradigm shift proposed in the AMLO with regards to its current criteria of the power of disposal. Further, we gave improvement proposal about the notion of bank deposit under the Banking Ordinance. Finally, the group underlined key remarks on the framework set in place under the FMIO, notably considering the restrictive approach towards privacy coins and the outsourcing of services via a blockchain by market infrastructures. We wish you a good reading.
A big thank you goes out to the contributors of this paper: Florian Duccomun, Gabriel Jaccard, Christine McAteer Gschwend, Lars Hodel and Ekaterina Anthony.