Category Archives: Blockchain, Crypto, Digital Assets Regulations

China’s Draft Anti-Monopoly Guidelines on Platform Economy

Paul | Weiss | Nov 18, 2020

Antitrust - China’s Draft Anti-Monopoly Guidelines on Platform EconomyChina’s competition regulator, the State Administration for Market Regulation (“SAMR”), issued a consultation draft of the Anti-Monopoly Guidelines on the Sector of Platform Economies (the “Draft Guidelines”) on November 10, 2020. This marks China’s first major step in formulating a comprehensive regime to regulate competition among platform businesses operated on the Internet (the “Platform Economy”) and signals SAMR’s changed regulatory priorities with a focus on anti-competitive behavior in the Platform Economy.

The Draft Guidelines attempt to address perceived shortcomings in applying traditional antitrust analysis to the Platform Economy. SAMR has drawn upon the experience of regulators and academics in this emerging area and attempted to consolidate the lessons learnt in various jurisdictions. The Draft Guidelines set out in detail the considerations that may be taken into account and the defenses that may be available, providing some guidance to platform businesses on how to achieve compliance.

See: 

China Stops Jack Ma’s $35 Billion Ant IPO From Going Ahead

DOJ files antitrust lawesuit challenging Visa’s $5.3 billion acquisition of Plaid

While the Draft Guidelines are brief in length, only 23 provisions in total, they are wide‑ranging in their scope. Rather than an exhaustive review of the Draft Guidelines, this note examines selected provisions. If implemented in the current form, many more mergers and acquisitions may be subject to China’s merger control clearance and antitrust investigation and enforcement may become a much more realistic and serious prospect for Internet-based businesses participating in the China market.

The Draft Guidelines represent a comprehensive guide to how SAMR intends to regulate anti-competitive behavior in the Platform Economy and signal SAMR’s determination to make regulation of anti-competitive behavior in the Platform Economy a priority. If implemented in their current form, the Draft Guidelines may significantly increase the number of mergers and acquisitions in the Platform Economy that are subject to merger control review and increase the likelihood of findings of antitrust violations and enforcement, resulting in increased regulatory risks and costs for participants in the Platform Economy in China. This may have far-reaching effects, not only on the operators in the Platform Economy in China and their transaction counterparties, but also indirectly on private equity and venture capital investors who have been active in investing in this sector.

SAMR invites public comment on the Draft Guidelines before November 30, 2020.

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NCFA Jan 2018 resize - China’s Draft Anti-Monopoly Guidelines on Platform Economy The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Keynote speech OSC Dialogue Conference

Norton Rose Fulbright | Walied Soliman | Nov 23, 2020

Walied Soliman - Keynote speech OSC Dialogue ConferenceThe following is an abridged version of a keynote speech given by Walied Soliman, Canadian Chair of Norton Rose Fulbright Canada LLP and Chair of the Capital Markets Modernization Taskforce, at the OSC Dialogue Conference on November 4, 2020.

Whenever I speak about the capital markets, I like to reflect on the incredible privilege we have of being practitioners and stakeholders in this area. In just over 100 years, Ontario has developed what is widely regarded as one of the most sophisticated capital markets regulatory frameworks in the world. Ontario was five years ahead of the federal government in the United States in regulating the capital markets in an organized manner.

We were ahead. We cannot fall behind.

It was with this backdrop that Premier Doug Ford and Minister Rod Phillips had the vision to form the Capital Markets Modernization Taskforce, reporting to the Minister of Finance, to conduct a broad review of the state of our capital markets in Ontario and determine what we can do to modernize the regulatory framework and ensure that we continue to be global leaders.

See:  Big Changes In Financial Regulation: Dialogue With The OSC 2020

That vision was focused on ensuring that we are a safe and secure capital market for people saving for their retirement and equally a market that efficiently marries capital with opportunity. This latter objective is critical: it is how we create new head offices in Ontario, how we ensure that our capital markets contribute to wealth creation and, most importantly, how we create new jobs in this province.

Select parts of speech

  • An alarming and recurring theme in the comments we received was the belief that there has been a decline of new issuers, new initial public offerings and new reverse take-overs in Ontario.
  • We heard from numerous stakeholders that in order to incubate the next Canadian issuer success story, we need to increase the number of independent intermediaries whose focus is on marrying capital with junior opportunities. We heard that the number of active independent dealers has fallen – largely, in the view of many stakeholders, due to a business model where independent dealers were losing out to bank-owned dealers with commercial lending capabilities.
  • We heard from retail investor advocates on the importance of ensuring that wealth management distribution channels allow easy access to competitive and independent wealth management products. It is clear that the OSC’s Client Focused Reforms are going to have a significant impact on the contents of the retail shelf.
  • We have also recommended enhanced powers for the Ombudsman for Banking Services and Investments.
  • Every Taskforce member is in favour of a national regulator. Clearly, this must be the goal. Our national reality poses challenges to achieving that goal. Our federation is complex both geographically and culturally, with varying capital markets objectives across the country. The political will needed to accomplish the goal of a national regulator does not currently exist.
  • [Before] whether setting up a dealer or a registrant, there was a clear path in the market for a business plan to succeed. Today, there are structural barriers to the business plans of new entrants. When combined with high entry costs, these structural barriers have a significant impact.

See:  OSC unveils charter for office to promote innovation and reduce regulatory burden

What comes next?

We continue to actively engage with stakeholders and are working diligently with the Ministry of Finance and the OSC on developing our final recommendations. We anticipate delivering to the Minister a final report sometime in December. From there, the Minister of Finance and the government will review our final report and work to advance the recommendations that they choose to accept as government policy.

 

 


NCFA Jan 2018 resize - Keynote speech OSC Dialogue Conference The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Big Changes In Financial Regulation: Dialogue With The OSC 2020

Lenczner Slaght | Shara N. Roy and Isabel Dávila Pereira | Nov 12, 2020

OSC dialogue event - Big Changes In Financial Regulation: Dialogue With The OSC 2020On November 4, 2020, the Ontario Securities Commission (OSC) held its annual OSC Dialogue. Financial industry leaders, senior regulators and investors came together virtually to discuss changes in the industry and how they are working together.

This year, the current COVID-19 global pandemic informed both the virtual setting for and the theme of the OSC Dialogue. The main theme of the discussion was the link between the world's physical and financial health brought forth by the pandemic. The OSC Dialogue was divided into five sessions, and in spite of the different topics and perspectives, one key issue was at the forefront of the discussion: the role of the OSC in fostering economic growth, adapting to technological innovation, and incorporating principles of Environmental, Social and Corporate Governance (ESG).

The Capital Markets Modernization Taskforce and the Expansion of the OSC's Role

In February of this year, the Ontario government established the Capital Markets Modernization Taskforce, which is in charge of making recommendations to the Minister of Finance for the review and modernization of the province's capital markets regulations. Walied Soliman, Taskforce Chair and Canadian Chair of Norton Rose Fulbright, provided an update on the work of the Taskforce. He noted that the Taskforce's recommendations will focus on three pillars: (1) proper governance, (2) an expanded mandate for the OSC, and (3) harmonized regulation.

See: 

Ontario capital markets task force proposes big changes

Ontario’s Capital Markets Modernization Task force report draws criticism

One of the key discussions across the OSC Dialogue focused on the second of these pillars. In several panels, which included a conversation with former OSC chairs, a discussion about the role of regulation in rebuilding the economy, an update from the Ontario Capital Markets Modernization Taskforce and a discussion on fostering innovation, the participants discussed the proposed expansion of the OSC's mandate to include the fostering of capital formation and the protection of competition. This proposal, as pointed out by Soliman, is part of the Taskforce's recommendations and will be delivered to the provincial government in December in its final report.

The Taskforce's justification for this and other recommendations highlighted by Soliman is that, “Capital markets regulation is not an end to itself”; a phrase he repeated during his presentation, and a sentiment which aligns with the current Ontario government's view on regulation.

“Capital markets regulation is not an end to itself”

Walied Soliman, Taskforce Chair and Canadian Chair of Norton Rose Fulbright

Soliman stated that such regulation must respond to the social and public good it is meant to support and the economic well-being of the province. He pointed out that the inclusion and making of this recommendation was not a difficult decision to reach by the members and that it follows advances already occurring in other places, including changes made in the UK, Singapore and Australia, where regulators have mandates to promote economic growth and competition, allowing them to remove obstacles including fees and tackle anti-competitive behaviour.

However, not every panelist agreed with the Taskforce's easy adoption of this recommendation. On an earlier panel where several former OSC chairs discussed perspectives, Maureen Jensen, the previous OSC Chair until April of this year, had a word of caution for this proposed mandate expansion. Jensen warned that it can be very difficult to be both the regulator and a partner in fostering businesses, as it can affect the OSC's independence in subsequent regulatory and enforcement actions. She added that the OSC's current mandate already allows it to promote a fair and efficient market which allows the regulator to encourage innovation but without standing in the way by partnering in the innovation. Howard Wetston, Senator and former Chair of the OSC, agreed with Jensen's caution but noted that capital formation has always been a key role of the OSC and that what is needed in any case is more transparency in the OSC role.

See:  NCFA Response to the Modernizing Ontario’s Capital Markets Consultation Taskforce

Other recommendations that the Taskforce update revealed include an increase of OSC oversight over self-regulatory organizations (SROs). While Soliman recognized the importance of SROs in filling the gap left by the lack of a national securities regulator, he noted that their recommendation would be for the OSC and Minister of Finance to collaborate to ensure business plans and regulations align with public policy, avoid duplication of regulation, and ensure that all capital markets are rowing in the same direction. This recommendation follows policy discussion around the combination of the Investment Industry Regulatory Organization of Canada and the Mutual Fund Dealers Association

Finally, Soliman made a call to the public to continue to engage with the Taskforce. In spite of the Taskforce's public consultation period ending in September of this year, he pointed out that stakeholders can still reach out to the Committee.

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NCFA Jan 2018 resize - Big Changes In Financial Regulation: Dialogue With The OSC 2020 The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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SEC Chair Clayton to exit, giving Biden early chance to name key regulator

Politico | Kellie Mejdrich | Nov 16, 2020

Jay clayton stepping down from SEC chair - SEC Chair Clayton to exit, giving Biden early chance to name key regulatorUnder the SEC’s rules, it is up to the president to appoint an interim chair when the commission chair leaves

SEC Chair Jay Clayton plans to leave the commission at the end of the year, departing from the market regulator about six months before his term is up, the agency announced Monday morning.

Clayton's departure will be among the first of what will be a wave of exits from the Trump administration as Joe Biden is sworn in as the new president. Under the SEC’s rules, it is up to the president to appoint an interim leader when the commission chair leaves.

“Working alongside the incredibly talented and driven women and men of the SEC has been the highlight of my career,” Clayton, an independent who was sworn in on May 4, 2017, for a five-year term, said in a statement.

See:

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Statement on Modernization of the Accredited Investor Definition

SEC Votes to Approve Changes to Regulation Crowdfunding Increasing the Maximum Raise to $5 Million


The announcement did not say where Clayton is headed next. But his departure was expected after he told the House Financial Services Committee this summer that he wanted to return to New York. That was shortly after President Donald Trump announced his intention to nominate him to be U.S. Attorney for the Southern District of New York.

That appointment never happened, as Geoffrey Berman, then-U.S. attorney for the Southern District, refused to step down. The political flap was resolved when Berman was replaced by his deputy.

Clayton came to the SEC after more than two decades working at the Wall Street powerhouse firm Sullivan & Cromwell, representing banks such as Goldman Sachs. During his tenure at the regulator, he was criticized by Democrats for taking a light touch on enforcement and for expanding U.S. capital markets to include broader allowances for private offerings and proposing to dramatically cut down disclosures for many hedge funds.

Clayton also drew fire from Democrats for his approach to implementing a call in the landmark Dodd-Frank law to heighten an investment advice standard to avoid conflicts of interest among broker-dealers. Detractors said it did not apply the highest fiduciary standard of care that is followed by registered investment advisers.

See:  Why a Biden win could be good for fintech

Despite the criticism of his time at the market regulator, the total of 3,152 enforcement cases brought under Clayton's chairmanship was actually higher than that of former SEC Chair Mary Jo White — a onetime federal prosecutor and appointee of President Barack Obama — during her tenure from 2013 to 2017.

Clayton also guided the SEC as it stepped into major legal fights during an unprecedented era of celebrity venture capitalist activity. The agency sued Elon Musk over tweets about taking his electric car maker Tesla private, and went after Elizabeth Holmes's blood testing company, Theranos. Both cases resulted in tough consequences for the executives, though some critics said the penalties involved were not harsh enough.

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NCFA Jan 2018 resize - SEC Chair Clayton to exit, giving Biden early chance to name key regulator The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Should the U.S. Government Create a Token-Based Digital Dollar?

Alt-M | Larry White |

Digital US Dollar - Should the U.S. Government Create a Token-Based Digital Dollar?Proposals for "central bank digital currency" (CBDC) come in two basic types: account-based and token-based. I have been critical of proposals for an account-based system. Until recently, there didn't seem to be much active interest in a token-based system. But now comes a significant token-based proposal in a new white paper by the Digital Dollar Project. Would a token-based system be any better than an account-based system? It might, but it all depends on the design details. Let me explain.

An account-based CBDC would mean that households and businesses have retail checking accounts directly on the Federal Reserve System's balance sheet. A detailed proposal for such a "FedAccounts" system by three legal scholars (Morgan Ricks, John Crawford, and Lev Menand) is available here. (I recently exchanged views with Ricks in an online event hosted by the Cato Center for Monetary and Financial Alternatives.) It is implausible that a FedAccounts system, run by a bureaucracy with no experience in retail payments, unguided by profit and loss, will provide better or more efficient service than systems offered by banks and other competitive private firms. But it isn't implausible that threats to privacy would arise from a system that gives a government agency real-time access to all deposit transfers.

See:  Why a digital dollar isn’t coming anytime soon (or so the Fed says)

A token-based CBDC would mean that households and businesses hold circulating digital Fed liabilities in digital wallets (think mobile phone apps), the way they hold Bitcoin or Tether[1], or the way they hold Federal Reserve Notes in analog wallets. This model has been labeled "FedCoin." The Federal Reserve System would know the dollar quantity of FedCoin in circulation, but in principle, as with physical notes and coins, it needn't know which users hold how many of these digital dollars. One prominent supporter of the FedCoin concept since 2015 has been Federal Reserve economist David Andolfatto. An early sketch of the concept was provided in 2014 by blogger J. P. Koning.

In May 2020 a group calling itself "The Digital Dollar Project" released a report entitled "Exploring a US CBDC." Although it deliberately leaves many important details to be determined later, the report deserves our scrutiny as an updated and prominent proposal for a token-based system. The report expands on an earlier WSJ op-ed by two of the Project's principals, J. Christopher Giancarlo and Daniel Gorfine. Giancarlo once headed the Commodity Futures Trading Commission while Gorfine was the CFTC's chief innovation officer. The named authors of the report include Giancarlo and Gorfine, plus Charles H. Giancarlo (CEO, Pure Storage) and David B. Treat (Accenture) as additional Project directors, together with eight more contributors from Accenture.

From the user's point of view, the Digital Dollar Project's "champion model" is akin to a well-backed dollar stablecoin, that is, a transferable digital token pegged to $1.00 per unit by its issuing entity. (Tether is by far the leading US-dollar-linked stablecoin with more than $9 billion currently in circulation. Here is a list of the many other available stablecoins.) But there are some differences between the Project's model and the typical stablecoin: the model's coin issuer is not a private entity, the fix to the dollar is free of default risk, and the exchange-rate variation around the $1.00 peg is zero. The issuer is to be the same US government agency currently responsible for supplying fiat US dollars in paper and ledger-entry form: the Federal Reserve System.

See:  US Federal Reserve Actively Working on Digital Dollar

Rather than buy FedCoins on an exchange, a user would get them from banks the way she gets fresh Federal Reserve Notes, redeeming her deposit dollars for them. She would hold FedCoin balances in a digital wallet, perhaps an app on her cell phone, and spend them online or in person, or transfer them to her friend, using the phone app.

The Fed would stand ready to interchange FedCoins (which the report calls "Digital Dollars," but FedCoins is less ambiguous) 1:1 with existing types of base money, Federal Reserve Notes (which are not to be abolished), and commercial banks' reserve balances on the books of the Fed. In this way FedCoins are to be a form of fiat money, part of the US dollar monetary base. They are to have "the same legal status as physical bank notes," which I interpret to mean that they are to be legal tender like Federal Reserve Notes. That is, they cannot be refused in the discharge of any dollar-denominated debts. Commercial banks will be as happy to accept them on deposit, and to pay them back out, as they are to accept and pay out Federal Reserve Notes.

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NCFA Jan 2018 resize - Should the U.S. Government Create a Token-Based Digital Dollar? The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Lagarde Says Her ‘Hunch’ Is That ECB Will Adopt Digital Currency

Bloomberg | Alexander Weber | Nov 13, 2020

European Central BankChristine Lagarde - Lagarde Says Her ‘Hunch’ Is That ECB Will Adopt Digital Currency President Christine Lagarde signaled that her institution could create a digital currency within years in what would be a dramatic change to the euro zone’s financial sector.

“My hunch is that it will come,” Lagarde said Thursday during a virtual panel discussion hosted by the ECB. “If it’s cheaper, faster, more secure for the users then we should explore it. If it’s going to contribute to a better monetary sovereignty, a better autonomy for the euro area, I think we should explore it.”

The president said it might be two to four years before the project could be launched as it addresses concerns over money laundering, privacy, and the technology involved.

See:  China’s digital currency app looks like Alipay and WeChat Pay

That’s still fast compared to its peers. On the same panel, Federal Reserve Chair Jerome Powell and Bank of England Governor Andrew Bailey reiterated their caution. Powell said the Fed will “carefully and thoughtfully” review the issue, and Bailey said there’s a “lot of hard work to think through the implications.”

China is also advance with plans for a central-bank digital currency.

“We’re not racing to be first,” Lagarde said. “We are moving ahead diligently, not incautiously. We will be prudent.”

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NCFA Jan 2018 resize - Lagarde Says Her ‘Hunch’ Is That ECB Will Adopt Digital Currency The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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Binance has begun to block U.S. users from accessing its exchange platform

The Block Crypto| Yogita Khatri | Nov 9, 2020

binance - Binance has begun to block U.S. users from accessing its exchange platformQuick Take

  • Binance has started blocking U.S. users from accessing its platform, The Block has learned.
  • An email obtained by The Block directed a user to withdraw their funds within 90 days if they were based in the U.S.
  • The move comes more than a year after Binance first announced that it would stop serving U.S. residents from September 2019.

Crypto exchange Binance has begun blocking U.S. users from accessing its exchange platform, The Block has learned.

The move comes more than a year after Binance first announced in July 2019 that it would stop serving U.S. residents from September of that year.

Until now, the exchange was still effectively allowing U.S. users to access its platform. As The Block reported recently, a U.S. resident just had to click "I'm not [American]" to set up an account on Binance.com. It remains possible to create an account in this fashion.

See:  5 Trends to Watch in Fintech Regulation

Binance is now sending emails to U.S. residents based on their IP addresses in what appears to be a significant step toward enforcing its previously announced blockade of such users. One such email, sent Sunday and obtained by The Block, reads:

"We noted your account may be associated with the U.S. due to an IP address you connected from in the past. In-line with regulatory requirements, we are unable to provide services to U.S. citizens or residents."

"If you are a U.S. citizen or resident, please transfer your assets out of your account within 90 days. You may consider using Binance U.S. or other U.S. platforms," the email continues.

A member of Binance's customer support team told The Block that "once our system detects the access of account or the factors mentioned in the email are detected within the account then the following email notification will be sent out to users."

See:  The case against BitMEX is a compass pointing towards the future of crypto regulation

Recent issues

Binance's move comes soon after the U.S. government launched twin legal cases against crypto derivatives exchange BitMEX.

The U.S. Department of Justice and the Commodity Futures Trading Commission recently charged BitMEX and its founders for violating know-your-customer (KYC) and anti-money laundering regulations, among other allegations. In light of this case, BitMEX accelerated its KYC program, requiring all customers to be verified by November 5 — three months earlier than its original deadline of February 2021.

BitMEX rival Deribit will also require all users to become verified before the end of this year, as The Block reported last month. (Deribit already blocks U.S. residents based on IP addresses).

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NCFA Jan 2018 resize - Binance has begun to block U.S. users from accessing its exchange platform The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org

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