In October 2019 , Liechtenstein’s parliament unanimously passed the Blockchain Act, also known as Token & Trustworthy Technology Service Provider Act (TVTG), which was enacted into law on January 1st 2020. The Act seeks to provide a reliable framework for a new digital economy developed on “trustworthy technology,” which encompasses blockchain technology and DLT systems. Hence, Liechtenstein becomes one of the first European jurisdictions to acknowledge the importance of distributed ledger technology and marks another milestone in the digital transformation of the physical world economy.

The Blockchain Act

The Blockchain Act offers groundbreaking framework conditions and legal security for the creation of a true token economy. Its scope goes beyond specific use cases such as cryptocurrencies but aims to create the right incentives for existing companies and newcomers to create new business models based on DLT, especially within Liechtenstein’s thriving financial sector. In order to achieve the latter, the main contribution of the new legal framework is allowing rights and assets to become tokenized. 

According to the Token Container Model laid out in the Blockchain Act, any asset or right can essentially be represented by a token based on trustworthy technology. In this model, a token serves as a legal vehicle capable of holding rights of all kinds. Tokens can contain rights that represent real world assets such as gold, real estate, stocks & bonds and currencies. Tokens as containers can also be created “empty,” meaning they don’t represent real world assets but the digital code they are made of. Well known examples of tokens in this category are Bitcoin, Ethereum, EOS and Tezos, among other cryptocurrencies that derive their intrinsic value from the underlying technology of the blockchain protocol they are built on.

Liechtenstein’s soon to be enacted legal framework on DLT-based assets encompasses varied applications of the technology within the financial sector, from security tokens to genesis digital assets such as Bitcoin. Nonetheless, the main factor is the differentiation between technology and law. The “container” approach allows to separate the rights on real-world assets derived from the ownership of the token (which have been ‘loaded’ onto it) and the technology on which the token  runs.

The TVTG gives rise to a new subset of regulated service providers that interact with the blockchain, the tokens and the underlying rights contained in them. It introduces a new role for these entities, the “physical validator”, as they must ensure that the rights “loaded” onto the tokens are present. To operate between the digital and the physical world, validators need a license and registration with the Liechtenstein Financial Market Authority (FMA).

Physical validators have other roles to comply with according to the proposed framework. Firstly, they must ensure that the asset or underlying right exists. For example, if a token represents 1 troy ounce of gold, the validator must ensure the same amount of gold in the specified purity is held in storage. The entity will be responsible for any issues with the custody or storage of the asset represented in the token i.e. the gold. Secondly, the physical validator has the duty to identify the holder of the tokens and must legally enforce the represented rights and contractual obligations. In essence, the physical validator has the obligation, under risk of losing its license and subsequent legal proceedings, of ensuring a perfect coordination between the digital and the physical world.

Additional TT Service Providers are delineated by this new legal framework. The responsibilities and legal obligations of these entities are defined by their respective roles in the lifecycle of the token. We can separate these into four categories: Token Generators, Token Issuers, Trustworthy Technology Key Depositaries and Trustworthy Technology Token Depositaries.

Token Generators and Token Issuers, as their name reveals, are tasked with the creation of the smart contracts and the subsequent token issuing process. TT Key Depositaries and TT Token Depositaries, typically represented by digital asset wallets and exchanges, safeguard tokens or private keys for third parties. The former must securely store private keys ensuring the client still has access to the tokens at will. The latter assigns the safeguarded tokens to its own TT Identifier and can therefore dispose of the clients’ tokens itself while having rights and responsibilities over execution of transactions.

With the introduction of the TVTG, Lichtenstein positions itself as a contending leader in the cryptocurrencies race in Europe and worldwide by adopting an advanced regulatory framework for what it recognizes as the token economy. The country that despite its size has established itself as a financial powerhouse in the EU, is set in the path of encouraging broader adoption and paving the way for the complete digitization of its financial sector. 

Adapting to the act

At Scalable Solutions, a Crypto Valley based blockchain and digital asset services provider, we understand the opportunities for companies interested in adapting “trustworthy technologies” into their business model and business operations. 

Our technology can sustain high-load demand from highly regulated institutions and comply with various regulatory frameworks such as Lichtenstein’s TVTG. As a Technology provider, we can help your company offer a wide range of services to serve the token economy as a whole while accompanying you through the process of acquiring the required licenses and registration with the Liechtenstein FMA, together with our network of top tier legal partners.

Our experienced team is prepared for the technological or regulatory challenges your company may face in this process by offering white-label platforms for the primary issuance and secondary trading of digital assets with a robust custody infrastructure. Scalable Solutions has also launched a digital and blockchain development engineering house for developments that need higher customisation and deeper specification.

If you are looking to get your company established in Lichtenstein under the newly approved TVTG legal framework, Scalable Solutions is the technology partner to help you achieve this, together with our legal partner ARBI. Get in touch with us here. 

 

 

Resources

“Blockchain Act Liechtenstein.” Impuls Liechtenstein, 15 Jan. 2020, impuls-liechtenstein.li/en/blockchain-act-liechtenstein/. 

“FMA Instruction 2020/1 – Registration as a Service Provider under the TVTG .” FMA Liechtenstein , 1 Jan. 2020, www.fma-li.li/files/list/fma-instruction-2020-1-registration-tvtg.pdf. 

“Liechtenstein Blockchain Act in Force since 1 January 2020.” Digital Assets Custody, 7 Feb. 2020, digital-assets-custody.com/liechtenstein-blockchain-act-in-force-since-1-january-2020/.

Sandner, Philipp. “Liechtenstein Blockchain Act: How Can Nearly Any Right and Therefore Any Asset Be Tokenized Based…” Medium, Medium, 14 Apr. 2020, philippsandner.medium.com/liechtenstein-blockchain-act-how-can-nearly-any-right-and-therefore-any-asset-be-tokenized-based-389fc9f039b1. 

Team, LCX, and Monty C. M. Metzger. “Liechtenstein Government Approves Blockchain Act.” LCX, 7 Aug. 2019, www.lcx.com/liechtenstein-government-approves-blockchain-act/. 

“The Regulatory Framework for a Tokenized Economy – TVTG Liechtenstein.” Bitcoin Suisse, 27 Oct. 2020, www.bitcoinsuisse.com/outlook/regulatory-framework-tokenized-economy-tvtg-liechtenstein.

“TVTG.” FMA, www.fma-li.li/en/fintech-and-tvtg/tvtg.html. 

Financial services are a rapidly evolving industry, with a fast-paced environment that often elicits the attention of financial regulators. Blockchain is no different; since an anonymous person or group by the name of ‘Satoshi Nakamoto’ revolutionized a thousands’ year-old way of recording transactions, this new technology came to redesign legacy financial services and develop new ways of utilizing financial concepts. In turn, such a technology has caused regulators to react by finding secure ways to manage adverse situations and diminish the spread of malicious actors. One such way is implementing KYC (Know Your Customer) measures. 

Know Your Customer

KYC or “Know Your Customer” is a risk-based approach that is mandated by regulatory bodies (such as SEC, FINRA) and is carried out by financial institutions to identify and authenticate the customers they do business with, based on their perceived risk profile. KYC policies help mitigate the risk of being exploited by bad actors (both intentionally and unintentionally), in order to conduct illicit behavior (such as money laundering, terrorism funding, etc). In the process, clients are required to provide identity credentials in order to use the company’s services. The requirements that must be fulfilled depend on the financial institutions’ activities, and can be divided into two main categories: Facts and Behaviors.

Facts: They serve to establish what the institution knows about the customer and includes personal information such as names, surnames, ID’s, phone numbers, email and physical address. This information can then be used to create behavior profiles and assign expected behavior parameters.

Behavior: Uses facts premises to verify that transactions adhere to corresponding laws and to report suspicious activities for further investigation to the necessary authorities.

Due Diligence

There are two main mitigation layers, where one builds on top of the other. Customer Due Diligence (CDD) includes background checks on potential clients prior to the onboarding stage, with its main objective being the understanding of the risk that the new client brings to the business. Enhanced Due Diligence (EDD), on the other hand, conducts a thorough investigation on higher-risk customers, occasionally identified by CDD. This sophisticated process falls outside of CDD and can usually be subjective by nature, depending on the risk tolerance profile of the company.

KYC & AML

A common misconception regarding KYC is it being the same as Anti-Money Laundering (AML). Even though these principles and practices are often combined and usually go hand in hand, it’s inaccurate to categorize them as being ‘the same’. While KYC is a process that identifies and authenticates the clients of financial institutions, AML is a far more complex framework of strategies, rules and regulations with the specific purpose of combating money laundering. ‘KYC is but a small cog in the AML wheel’ [1]. Therefore, AML regulations require thorough risk reports, as well as reports of suspicious activities. AML non-compliant entities face severe penalties (up to criminal prosecution), whereas KYC compliance is more gentle in disposition.

KYC State of Affairs

As initially mentioned, the developments of new financial technology applications based on blockchain made it difficult for regulatory bodies to swiftly adapt and set new rules. The fact that asset classes differ among applications has only hardened the task. 

The case of KYC in the world of cryptocurrencies could be considered odd. Most cryptocurrency exchanges allow user registration without carrying out any KYC practices  when onboarding them (CypherTrace research found that 56% of virtual asset service providers have weak or porous KYC processes [2]). A self-regulation process governed these platforms for quite some time, and are only nowadays including KYC procedures as a standard. Centralized exchanges that provide cryptocurrency-fiat trading pairs are usually the ones that comply with the most regulatory requirements [3], while decentralized exchanges (those with no central authority, governed by smart contracts) usually don’t. The aforementioned report [2] also found that over 90% of DEX had deficient KYC scores, with 81% having little to no KYC measures [4].

Cryptocurrency exchanges’ KYC efforts can be grouped into three categories (no KYC, basic KYC and full KYC) [1] and sorted as a spectrum of KYC total information. As we move towards the far end of the range, capabilities and functionalities of accounts are unlocked, and limits on operations are taken out (no withdrawal limits for example).

As cryptocurrencies continue to evolve and new blockchain-based financial services continue to appear, the question of how regulatory bodies will choose to keep track of transaction information in order to control for malicious players will be essential. Will it be possible to slow down the revolutionary machine or will existing financial systems have to yield some control and swim with the current? Time will tell. 

 

How SCALABLE Can Help

In the meantime, Scalable Solutions can help you navigate through regulatory requirements by offering leading white label exchange technology with a myriad of flexible KYC integrations. The systems we have in place ensure that the required documents are checked in order to provide a secure transaction space for all parties involved. These also assure that where necessary, staff are informed and proceed to take measures to ensure compliance. Get in touch to discover more about our exchange technology here. 

 

References:

[1] “What Is AML/KYC in Crypto?” Sygna, 16 Sept. 2020, www.sygna.io/blog/what-is-aml-kyc-in-crypto/. 

[2] Barragan, Julio, and John Jefferies. “2020 Geographic Risk Report: VASP KYC by Jurisdiction.” CipherTrace, 1 Oct. 2020. 

[3] Exchanges in the USA are required to implement Banking Secrecy Act policies, for instance.  

Lansky, J. (2018). Possible state approaches to cryptocurrencies. Journal of Systems Integration, 9(1), 19-31.

[4] There is a note to be made at this point. Given the nature of decentralization embedded into these financial institutions (decentralized exchanges) it is but normal that there are no robust KYC mechanisms in place. Users’ of blockchain applications (DApps) main motivation is not having to transact in centralized venues and reporting to a centralized authority.

On 25 September 2020, the Swiss Parliament approved new regulations on Distributed Ledger Technology (DLT) and blockchain, amending the Swiss legal framework in order to specifically recognize securities based on these innovative technologies [1]. Along with the government, the Swiss Financial Market Supervisory Authority (FINMA) has recognized the high potential of blockchain technology and DLT in the financial field and the economy in general.

Switzerland positions itself as a leader in the cryptocurrencies revolution in Europe by adopting advanced regulatory amendments in key areas such as civil, insolvency and financial market law, as well as anti-money laundering regulation. The country continues to make great strides towards becoming the center of Europe’s blockchain technology developments, thus encouraging broader adoption and paving the way for the digitization of the Swiss economy as a whole.

With the unanimous approval of the parliament for new DLT regulations, the country is now experiencing the best conceivable environment for blockchain implementation within financial markets through: 

(i) the creation of a new financial market infrastructure by introducing DLT trading facilities; and

(ii) the introduction of legal specifications for the creation, transfer and custody of DLT-based assets.

DLT-trading facilities introduce a new permission for trading venues, allowing entities to offer DLT-based asset trading, clearing, settlement and custody. Prior to the new legal framework, only banks, securities firms and other authorized financial institutions qualified as entities permitted to operate these venues in the form of organized trading facilities.

The creation of DLT trading facilities results in lower barriers to entry and increased competition within the financial markets by ensuring that smaller infrastructures operating based on DLT have the ability to become licensed. Qualified participants will not be limited only to regulated financial market players, but also other legal entities and private customers.

Uncertificated Register Securities, a new type of digital securities, are also introduced within the approved DLT framework. They provide a legal basis for the use of DLT or other technologies on the digitization or tokenization of assets such as shares, bonds and uncertificated financial instruments. Its main advancement resides on that the underlying rights from these instruments cannot be transferred without the token. These rights, in turn, must be registered on a ledger that limits the transfer and assertion of these rights only within said ledger. Further requirements for this register are to prevent manipulation and provide functional safety, as well as having its operating principles and governing agreement recorded within.

The approval of the new regulations on Distributed Ledger Technology places Switzerland at the forefront of all legislation related to crypto/digital assets and financial technology by responding to the challenges of blockchain technology. The chosen regulatory methodology enables Switzerland to acknowledge the flexibility required to keep up with technological advances. 

It is imperative to comprehend that when investing, the FINMA license is a guarantee of confidence as it is the best indicator of trust representation. Switzerland’s support for blockchain companies and cryptocurrencies has resulted in many firms from all over the world establishing their headquarters in the country, with clear evidence seen in the exponential growth of the Crypto Valley in Zug. 

Acquiring the license

At Scalable Solutions, a Swiss blockchain and digital asset services provider, we understand the opportunities for companies interested in the development, acquisition and investment in the digital asset space. 

Our team is prepared for the technological or regulatory challenges that your company may face by offering white-label platforms for the launch of professional digital asset exchanges. Scalable also offers blockchain infrastructure to tokenize any asset and get everything running quickly, in a secure and regulated environment. 

Our technology can sustain high-load demand from highly regulated institutions and comply with various regulatory frameworks. As a Technology provider, we can also help companies with the process of acquiring the DLT license with our network of top tier legal partners.

If you are looking to get your company established in Switzerland under the newly approved DLT legal framework, Scalable Solutions is the technology partner to help you achieve this, together with our legal partner Lorez Legal. Get in touch with us here. 

 

 

 

 

 

Reference

[1] “Bundesgesetz Zur Anpassung Des Bundesrechts an Entwicklungen Der Technik Verteilter Elektronischer Register.” 25 Sept. 2020, www.admin.ch/opc/de/federal-gazette/2020/7801.pdf. 

General Source

“Parlament Setzt Bessere Rahmenbedingungen Für Blockchain.” Parlament.ch, 10 Sept. 2020, www.parlament.ch/de/services/news/Seiten/2020/20200910092808664194158159041_bsd039.aspx. 

With the upward trend in the use of cryptocurrencies and a rise in new blockchain leveraged technologies, it is important to not leave behind a go-along technology that is continuously updating: wallets.

At their most basic form, wallets were created to solve the need for storing, sending and receiving digital coins (originally Bitcoin). Since then, wallets have mutated into individual services that are provided by blockchain companies. They have evolved from simple software programs handling key management to sophisticated applications that offer a variety of technical features and additional services that go beyond the simple storage of cryptocurrency.

A wallet is a “software program that is used to securely store, send and receive cryptocurrencies through the management of private and public cryptographic keys. Wallets also provide a user interface to track the balance of cryptocurrency holdings and automate certain functions, such as estimating what fee to pay to achieve a desired transaction confirmation time” [1].

Wallets include three characteristic pieces of information: a public key, which lets one receive funds from any other wallet (like a bank account number); a private key used for creating digital signatures and verifying transactions; and an address, which is the location of the wallet in the blockchain network. The reason it is important to have the private key securely backed-up is that the public key and subsequently the address can be derived from it, not to mention that anyone with your personal private key has access to your funds, and can discretionally transfer them out of the wallet.

Who gets custody?

There are two kinds of wallets, custodial and non-custodial wallets. Custodial wallets are wallets where third-parties keep and maintain control over your cryptocurrencies on your behalf. Non-custodial wallets are wallets where you take full control and ownership of your cryptocurrencies.

By using a custodial wallet, you trust an external party to store your coins safely. This may be convenient as you avoid worrying about private key security. Instead, you only worry about the security of your account credentials, just as you would have to protect your email account. However, by trusting a third party with your cryptocurrencies, you open yourself up to the risk of the custodian losing your cryptocurrencies through mismanagement or hacks. There have been numerous incidents [2] of custodial wallets losing their cryptocurrencies, with the most current ones including Cashaa, in 2020, and the most notorious ones being CoinCheck, Bitfinex and Mt Gox, amounting to over US$ 1.3 billion of stolen funds [3]. Similarly, the 2019 Binance hack proved that even fast-moving exchanges could have security risks because of the limited amount of time they have to test for weaknesses. Custodial wallets are the equivalent of banks or funds, where the money is yours but a third party has control over it. 

Non-custodial wallets, on the other hand, leave the responsibility of security to the user. Even though at first it sounds wearisome, it also means that almost nothing can happen to the funds as long as the wallet owner takes precautions and stores the private keys diligently. Writer’s choice and industry recommended Lumi-wallet is an example of a multi-currency non-custodial wallet that includes services such as integrated exchanges and credit/debit card acceptance. 

There are various platforms under which wallets can be created. Mobile wallet apps are the most widely offered format, followed by desktop and web wallets. There are also hardware and PM (paper and metal) wallets. Though hardware wallets used to be considered the most secure, they don’t provide ease of access and transaction of funds, and include the risk of losing the hardware piece [4]. 

Despite being thought of as a usability-security trade-off, new non-custodial wallets aim to attend custodial shortcomings and keep security at the forefront of their operations. The Multi-Party Computation (MPC) wallet developed by Curv seems to have taken the lead and is gaining popularity. The distinct attribute that characterizes MPC wallets is the removal of the ‘single point of failure’ [5] by providing a secure, distributed way to sign transactions and manage digital assets.

Key differences

As with most things, wallets have distinct advantages and disadvantages. Some of the main trade-offs can be classified as follows:

Factors	Custodial	Non-custodial
Security	Trust third parties with storing funds (making them susceptible to hacks); diminishing risk of losing your private key which gives access to your money.	No trust in an external party, with sovereign control over private keys and funds. Cryptocurrencies are ‘safe,’ but with the risk of losing/forgetting private keys [4].
Auditing	Custodial wallets are -usually – closed source (this means its code can’t be inspected by outside developers to check for robustness). [6]	Usually auditable, open source code.
Anonymity	Need for KYC/AML information provision.	No need to provide personal information.
Practicality	You can manage your funds very quickly and at any time when there is an Internet connection.	Although it’s been historically challenging to carry out transactions, this problem is nowadays almost unique to hardware and paper wallets.
Additional Controls	Besides the inherent security characteristics of custodial/non-custodial and hot/cold wallets, there are newly developed options to strengthen security: Internal controls such as daily transaction limits, 2FA, backup wallets and Cold layers are some security complements that can be added. Multi-signature wallets present the possibility of several private keys with different access rules, and are used as a way of creating an additional layer of security. They are also used for managing joint crypto accounts.

While the decision on whether to opt for a custodial or non-custodial wallet will depend on the various factors outlined above and more, it acts as a guide to making the better decision for a user’s needs. 

 

SCALABLE Wallets

In September, Scalable Solutions and multi-currency crypto wallet LUMI Wallet formed a partnership. Leveraging on decades of industry knowledge, providing an ample and versatile spectrum of products, and with security as a core value, this relationship aims to build functional non-custodial white label wallets for cryptocurrency users that will provide fulfilling and versatile experiences in the world of rapidly developing global financial systems. You can read more about the white label features here. 

If you’re after dedicated custodial wallets for 130+ popular cryptocurrencies, high security layers including cold storage, and easy purchases even with credit cards, our partnership with Freewallet allows you to access all these features and more. For both custodial and non-custodial wallets, you can get in touch with us here.

 

 

 

References

[1] Hileman, G., & Rauchs, M. (2017). Global cryptocurrency benchmarking study. Cambridge Centre for Alternative Finance, 33, 33-113.

[2] Ton, Ngan. “A Complete List of Cryptocurrency Exchange Hacks [Updated].” IDEX Blog, IDEX Blog, 27 Mar. 2020, blog.idex.io/all-posts/a-complete-list-of-cryptocurrency-exchange-hacks-updated. 

[3] FortKnoxster. “THE TOP 10 CRYPTO EXCHANGE BIGGEST HACKS EVER.” FortKnoxster, 11 Sept. 2019, fortknoxster.com/blog/the-top-10-crypto-exchange-biggest-hacks-ever/. 

Similarly, Quadriga in Canada or Cryptopia in New Zealand are other examples that might fit into the list.

[4] Nowadays, lost private keys or mnemonic phrases doesn’t mean lost funds. The risk of social engineering (misleadingly obtaining user’s private keys) is still one of the most troublesome in this category. There’s a note to be made between retail and institutional wallet security, given that as storage space is defined for each one, further controls can be made regarding who has access to the wallet and under what circumstances.

[5] Up until recently and despite the type of wallet, single points of failure could be found. Having the private keys controlled by one individual (user in case of non-custodial wallet, protected server in case of custodial exchange) means that in the event of loss, stealing, or even death (see QuadrigaCX), the funds are lost and irretrievable.

[6] Cases where open source code is used to run a service while keeping private keys also exist.

[7] There is a note to be made when discussing the uses of wallets. Ethereum and Bitcoin wallets work differently. Ethereum wallets are more similar to a digital identity. You need your Ethereum wallet if you want to connect to a vast array of Ethereum-based DeFi or Gaming applications. Bitcoin, on the other hand, doesn’t have any Dapps (Decentralized applications). As such, Bitcoin wallets focus on storing, sending and receiving users’ funds. 

[8] “Uniswap Protocol Analytics.” Uniswap Info, info.uniswap.org/home. 

Hong Kong is changing its laws in relation to crypto-assets regulation in the region. 

 

Ashley Alder, chief executive of HK’s Securities and Futures Commissions (SFC), commented that “under the current legislative framework, if a platform operator is really determined to operate completely off the regulatory radar it can do so simply by ensuring that its traded crypto assets are not within the legal definition of a security” [1]. This approach was largely regarded as an “opt-out” or “opt-in” decision for digital asset trading firms on whether to be regulated or not. The legislation to opt in to be regulated and licensed was passed in November 2019, with the SFC’s Position Paper outlining the requirements needed for a firm to apply for a license, including regulatory concerns such as the security of assets, KYC requirements, AML and more [2].  

A year later (November 2020), the Hong Kong government is seeking to change this by requesting that under the new anti-money laundering legislation, all cryptocurrency trading firms in the region become regulated. An SFC license will become a prerequisite for the dozens of cryptocurrency exchanges already operating in that market, not to mention the ones looking to set up digital asset trading companies there. Hong Kong will thus join other financial centers in Asia, such as Japan and Singapore, that also require digital asset trading firms to be regulated [1]. 

Scalable Solutions, a leading technology provider of white label digital asset exchanges and tokenization services has extensive experience in helping companies launch new trading platforms or scale existing ones. As a global provider, we have dealt with regulatory requirements across a multitude of jurisdictions. Our team has the knowledge to guide cryptocurrency trading platforms, including the ones in Hong Kong, to fulfilling the necessary conditions to operate in a regulated manner. Get in touch to find out more here. 

 

 

 

 

References

[1] “Hong Kong Wants Cryptocurrency Trading Platforms to Be Regulated – SFC.” Reuters, Thomson Reuters, 3 Nov. 2020, www.reuters.com/article/us-crypto-currencies-hongkong-reulator/hong-kong-will-require-all-cryptocurrency-trading-platforms-to-be-regulated-sfc-idUSKBN27J07N. 

[2] “Position Paper: Regulation of Virtual Asset Trading Platforms.” Securities and Futures Commission Hong Kong, 6 Nov. 2019, sfc.hk/web/files/ER/PDF/20191106%20Position%20Paper%20and%20Appendix%201%20to%20Position%20Paper%20(Eng).pdf. 

General sources: 

“Hong Kong Now Offers Opt-In Regulation for Crypto Exchanges: Regulation Bitcoin News.” Bitcoin News, 24 Dec. 2019, news.bitcoin.com/hong-kong-now-offers-opt-in-regulation-to-crypto-exchanges/. 

Sinclair, Sebastian. “Hong Kong’s Securities Watchdog May Soon Regulate All Crypto Trading Platforms.” CoinDesk, CoinDesk, 3 Nov. 2020, www.coindesk.com/hong-kongs-securities-watchdog-may-soon-regulate-all-crypto-trading-platforms.