Fintech trends and updates

An update on the latest fintech trends, including blockchain, open banking, PSD2 and initial coin offerings.

05 June 2018
The fintech sector is driven by constantly evolving technology and a complex web of global regulation. Below you'll find our regular round-up of fintech news, trends and industry analysis.
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Fintech updates

Update posted: 15 June 2018

By Heather Musk

FCA releases ‘Dear CEO’ letter on Crypotassets and Financial Crime

In the letter addressed to UK banks issued on 11 June 2018, the Financial Conduct Authority (FCA) warns specifically on the use of cryptoassets being used for criminal purposes. The letter acknowledges how these assets are attractive to criminals because of their anonymity and ability to move money between countries.

The letter advises that reasonable and proportionate measures should be taken to lessen the risk of facilitating financial crimes, including: 

  • developing staff knowledge and expertise on cryptoassets to help them identify the clients or activities which pose a high risk of financial crime 
  • ensuring that existing financial crime frameworks adequately reflect the crypto-related activities which the firm is involved in, and that they are capable of keeping pace with fast-moving developments
    engaging with clients to understand the nature of their businesses and the risks they pose
  • carrying out due diligence on key individuals in the client business including consideration of any adverse intelligence
  • in relation to clients offering forms of crypto-exchange services, assessing the adequacy of those clients’ own due diligence arrangements
  • for clients which are involved in Initial Coin Offerings (ICOs), considering the issuance’s investor-base, organisers, the functionality of tokens (including intended use) and the jurisdiction.

High-risk areas where crypto-related activities might be carried out include:

  • offering services to cryptoasset exchanges
  • carrying out trading activities for clients or with counterparties whose source of wealth derives from cryptoassets 
  • arranging, advising or otherwise taking part in ICOs.

The FCA also elaborates that following a risk-based approach does not mean banks should approach all clients operating in these activities in the same way. Instead, because the risks associated with different business relationships in a single broad category can vary, the FCA thinks it appropriate to manage those risks appropriately.

If you are a bank and consider that your clients may be holding or trading cryptoassets (this may be discovered by enquiring about the source of a deposit), then existing requirements for checking the source of wealth and funds are still risk sensitive. Firms should assess the risks posed by a customer whose wealth or funds derive from the sale of cryptoassets. If a firm identifies a customer is using a ‘state-sponsored cryptoasset… designed to evade international financial sanctions’, then this should be seen as high risk.

 

Update posted: 05 June 2018

By Nathan Dudgeon

Google bans crypto advertising

Google announced in May that it was updating its ‘new restricted financial products policy’. The policy came into effect at the start of this month, and bans the adverts of ‘Cryptocurrencies and related content (including but not limited to initial coin offerings, cryptocurrency exchanges, cryptocurrency wallets, and cryptocurrency trading advice)’.

Facebook and Twitter made the same move earlier this year, with consumer protection as the clearly stated aim. Scott Spenser, Google’s director of sustainable ads, told CNBC in March:

We don’t have a crystal ball to know where the future is going to go with cryptocurrencies, but we’ve seen enough consumer harm or potential for consumer harm that it’s an area that we want to approach with extreme caution’.

Most people can agree that consumer protection is positive, so trying to prevent regular people from investing in extremely volatile products without being fully aware of the risks is also positive. On the other hand, this development is worrying because this action could be seen as going beyond Google's remit.

It may seem like regulatory language is not developing at the same pace as technological innovation or the commercial exploitation of recent interest in crypto and token offerings. It is clear though that regulators are not just sitting idle. In the USA, the U.S. Securities and Exchange Commission actively pursues potentially fraudulent initial coin offerings. In the UK, although there is no specific regulatory framework to catch crypto assets, the Financial Conduct Authority continues to keep a watchful eye over developments. It considers that the existing regulatory perimeter is currently enough to catch those activities that are likely to be troubling from a consumer protection standpoint.

This is why Google’s decision to act as a quasi-regulator in this context, is a potentially troubling development. Stepping in and blocking the crypto market may sound like consumer protection, but it is potentially overstepping its perceived role as gatekeeper to information.

 


 

Update posted: 29 May 2018

By Harry Tiara

Rewriting the insurance policy

Like much of the financial world, the insurance industry has been slow to recognise the growth of fintech (financial technology), regtech (regulatory technology), paytech (payment technology) and everything else ‘tech’. This is why those in the ‘insurtech’ area are making a seriously big impact.

For example, Lemonade (an American insurer aimed at individuals) automates pretty much everything that they do, such as using Chatbots and AI to run everything from the process of purchasing a policy, through to claims management, payouts and fraud prevention. The days of being stuck on the end of a telephone waiting to speak to customer service could soon be coming to an end. In late 2016 Lemonade paid out within 3 seconds of a claim for a stolen coat - an unofficial world record!

Lemonade is also literally rewriting the insurance policy.

A standard insurance policy is typically 40 pages of exceptions to exceptions and jargon from centuries long gone. Lemonade’s ‘Policy 2.0’ is open source and is a standard digital policy that can be altered by users to match their own bespoke requirements. For example, home contents insurance may be $10,000, but with Lemonade this amount can be modified simply by clicking on a sentence.

Lemonade’s aim is to be as transparent and legible as possible - and Policy 2.0 is about as transparent as an insurance policy can get. You can even read (and fully understand) it in 10 minutes without needing an actuarial degree.

There are questions for Lemonade to answer however: Will readability be prioritised over comprehensiveness? How enforceable is the policy?

In true fintech style, Lemonade has opened up the process for all stakeholders interested in insurance or tech to contribute their thoughts through GitHub.

If you’d like to learn more about insurtech, register for the event that we’re hosting with BILA on 21 June 2018 Register.

 


 

Update posted: 25 May 2018

By Nathan Dudgeon

FCA reviews the robo-advice sector

On Monday, the Financial Conduct Authority (FCA) published their review of firms in the automated investment sector. Unfortunately, it wasn’t a glowing report.

The FCA conducted two separate reviews.

The first review covered seven firms offering automated online discretionary investment management (i.e. on an ongoing basis). This covered most of that entire market at the time of the review. The second review contained three firms providing exclusively automated retail investment advice. Again, this covered most of the market at the time.

The FCA’s report detailed several issues, but two of the biggest were:

  • not being clear on fees and service levels. Some firms compared their services to their competitors’ without explaining the difference
  • not understanding the individual client well enough. A lot of the advice was based on assumptions, or is ‘streamlined’ (narrowing the focus to just the most relevant factors). This is acceptable in principle, but the FCA explained that ‘this means taking a proportionate approach to information gathering while maintaining the appropriate level of client protection’

Automated investment services must meet the same regulatory standards as traditional discretionary or advisory services. The FCA’s findings include detailed references to the FCA handbook, as well as non-handbook sources like European Securities and Markets Authority Guidance. If you are a firm looking to operate in this area, do not forget the various ways the FCA can help such as Project Innovate, the Regulatory Sandbox and the Advice Unit, all of which are very successful.

Not all bad news

It may be tempting to see the results of the reviews as bad news. However, the FCA is actually very positive about robo-advice models. The Advice Unit in particular was specifically set up to help firms develop automated advice models. The FCA’s head of strategy and competition also spoke in November about robo-advice, saying that it promotes competition and is ‘a valuable vehicle to help tackle the issues faced by those consumers who are unserved or underserved by more traditional advice models’. One of the more interesting areas for robo-advice is pensions, where it has attracted both fierce criticism and ardent praise.

Considering the results of the review and the growth in the area, the FCA plans to do another review later this year.




Update posted: 21 May 2018

By Alex Gillespie

The SEC launches the Howey Coin

In what some might call an unconventional move, the US Securities and Exchange Commission (SEC) announced yesterday the launch of its own initial coin offering. The coins, called ‘Howey Coins’ (after the famous ‘Howey test’ for determining securities) are now available on the SEC’s own Howey Coin website. According to the website, the coins offer potential investors ‘guaranteed returns’ on their investment and can be traded either for cash or cryptocurrencies, or with participating businesses (such as airlines or hotels, etc). However, any investors that are sufficiently tempted by such a prospect and click on ‘Buy Coins Now!’ will be greeted with a page teaching investors how to spot scam Initial Coin Offerings (ICO).

The SEC’s fake cryptocurrency is the latest attempt by a regulator to teach investors about the risk of investing in ICOs (the Financial Conduct Authority issued a similar risk warning to investors in September last year). Both the UK and US have strict legislation around the issuance and sale of regulated securities which can include cryptocurrencies, as well as on their promotion (such as the whitepaper for ICOs) and there can be criminal penalties (including imprisonment in the UK) for anyone who contravenes them. The SEC’s ICO is an innovative approach to warning investors to be alert to scams and fraudsters operating outside the law. It also demonstrates the increasing regulatory scrutiny faced by ICOs worldwide and the prospect of further action from regulators either side of the Atlantic.

For further information on ICOs, their risks and benefits as well as the underlying UK regulatory regime, please see our article ‘A guide to initial coin offerings’.




Update posted: 10 May 2018

By Nathan Dudgeon

The winner of the global AI race is not as clear-cut as you think

Putin famously said that the leader in AI will 'rule the world'. True or not, the race between countries is in full swing. China and the USA are fighting for pole position but for some pundits on both sides, the outcome is already clear.

The case for the USA

For some, the USA is the clear choice. It has the best universities, the best engineers, and the most innovative private sector. One of the trends to look at when thinking about long-term technology growth is ‘patent filings’. Again, the USA is in the lead here. Do not forget that they have Google, Amazon, Microsoft and Facebook. Government support is rapidly gathering strength too – the White House is even hosting an AI summit on 10 May.

The case for China

For others, China will be the clear winner. It is explicit government policy that China will be the world leader in AI in both research and application by 2030. China has the knack of being able to ‘get things done’; its ‘One Belt, One Road’ policy among many others is proof of that. Not only does it have the willpower and government support, it also has the resources. AI is fuelled by data, and China has more data than any other country on the planet.

While China and the USA command the limelight however, dozens of other countries have announced their own AI strategies.

The case for Europe

There's also a case for Europe. Its three point strategy will help companies get access to data, boost development, and set up centres to connect research with entrepreneurs. The secret weapon in both the UK’s AI report and the EU’s AI strategy is ethics. They are not running the race the same way the USA and China are, as Europe wants to set ethical standards that could one day be used around the world. If consumers can trust the AI applications, it will help Europe catch up and overtake the USA and China.

So who will win the AI race?




Update posted: 8 May 2018

By Nathan Dudgeon

AI: how does machine learning work?

How do you teach an AI bot? What are decision trees and neural networks? How do machines learn? Read our article 'AI: how does machine learning work?'.


Update posted: 26 April 2018

By Alex Gillespie

RBS throws down the fintech gauntlet

The rumours were true.

Yesterday, RBS revealed its plans to launch a new mobile-only bank in direct competition to the growing popularity of challenger banks, such as Monzo and Atom. Details are sketchy and RBS is keeping its cards close to its chest for now - there is however, no doubting RBS’s ambition. The bank has revealed a target of switching 1 million of its existing Natwest customers to its new challenger bank. This is all the more surprising given the challenges faced by RBS from coming out of the recession, including recently suffering losses as a result of the unsuccessful sale of its Williams & Glyn division.

The announcement is a tacit recognition of the growing success of challenger banks within retail banking and other retail banks will monitor the success of RBS’s new bank with interest. The challenger bank is expected to help RBS customers make ‘significant’ cost saving and apparently will be targeted at ‘less financially literate’ customers who ‘struggle to make ends meet’. One option under consideration is for the platform to operate as an online marketplace in which customers can save by switching between financial products offered by RBS and smaller, fintech businesses. A beta version of the platform is expected to be released in Q3 of this year.

We shall see whether RBS is able to deliver on its ambitious plans and the high expectations it has raised. If it can, expect ‘traditional’ banks to follow quickly.




Update posted: 23 April 2018

By Sarah Kenshall and Nathan Dudgeon

An introduction to artificial intelligence

As technology expands into virtually every corner of human experience, it’s clear that computers with sophisticated artificial intelligence (AI) capabilities are more than simply a sum of their chips. Read our article 'An introduction to artificial intelligence'.




Update posted: 20 April 2018

By Rachel Mahoney and Nathan Dudgeon

Santander launches OnePay FX: blockchain app for retail banking

Santander has joined the ranks of other big banks offering a blockchain based international money transfer service.

What is the app?

Ripple’s OnePay FX app allows customers in the UK, Spain, Brazil, and Poland to send euros across most of Europe, or dollars to the US. The attraction for customers is that they can transfer funds within a day, and the fees are lower (and clearer).

Santander’s aim is to roll it out as an app that can be used by customers with other banks too. They also plan to add more countries to the list – and customer types (e.g. SMEs).

How it works

Ripple’s xCurrent doesn’t use blockchain the same way most others do. The infrastructure is public so that anyone with the right app can access it. The mechanisms however are centrally controlled – just because you have a node doesn’t mean you can validate the transactions. The ability to validate requires permission from Ripple, and those with permission are big institutions, such as banks.

The advantage of using Ripple’s software over the legacy systems is trust and speed. The banks can pre-validate their end of the transaction (instead of having to go back and forth), trusting that it will not go ahead unless the other party also validates their end. Since Ripple only allows trustworthy institutions to be validators, everyone is happy.

Speed is gained through both real time validation and simultaneous settlement.

You can see a short explanatory video from Ripple themselves here.

Comment

Santander’s move is not a big surprise considering they invested in Ripple a few years back and have been developing this solution for a while.

Competition is also probably a big factor, like the National Bank of Abu Dhabi who offered a similar service to their customers last year. There is clear competition with non-bank providers too, like TransferWise (who triumphantly announced this week that they are the first non-bank with access to the Bank of England's real time gross settlement system). As always with blockchain, there are serious concerns about the ability to scale effectively so we’ll be watching progress with interest!




Update posted: 17 April 2018

By Gareth Malna

Spate of EU activity in blockchain and AI

Blockchain

Of the 28 EU member states, 22 (including the UK) have sought to flex the muscle of the single market by signing a declaration on establishing a European blockchain partnership.

The initiative hangs on to the coat-tails of the EU Blockchain Observatory and Forum; a project that is dedicated to investing €300 million in blockchain projects. The project intends to approach blockchain opportunities in a harmonised way by developing an EU-wide infrastructure that can enhance value-based, trusted, user-centric digital services.

The premise of the initiative is that ‘Europe is well placed to take a global leadership position in the development and application of blockchain and distributed ledger technologies which can change the way citizens and organisations collaborate, share information, execute transactions, organise and deliver services’. Each of the signatories have pledged to work together ‘towards realising the potential of blockchain-based services for the benefit of citizens, society and economy’.

On a practical level, this means the following:

  • By September 2018 the 22 will identify an initial set of existing cross-border digital public sector services that would gain added value from the support of a blockchain services infrastructure and starting to explore other use cases.
  • By the end of 2018, the 22 will assist the commission in preparing the technical specifications of this initiative, defining the appropriate governance model and identifying other framework conditions which are essential to its success (including regulatory compliance), and to consider possible co-operation between the public and private sectors.
  • The 22 will sharing experiences, best practice and key takeaways related to the implementation of blockchain applications.

Artificial intelligence (AI)

On the same day, 25 member states signed a declaration on co-operation on artificial intelligence. This represents one of numerous steps on the way to a comprehensive European approach to AI and robotics. The text of this integrated approach is due to be published in the first half of this year, while the declaration itself states that the signatories will 'work towards such integration on AI in order to increase the EU’s competitiveness, attractiveness and excellence in R&D in AI', including through the exchange of ideas and best practice.

These commitments are welcome in the ongoing development of a broader array of blockchain, distributed ledger technology (DLT) and AI applications. The hope is that with such high-level backing the outcomes will not end up being solutions looking for problems.

From a UK perspective, it will also be interesting to see whether the critical mass that has built up in the UK’s tech and fintech sectors, will continue to play any part in cross-border digital public services applications after the UK leaves the EU. This is particularly interesting considering that they intend to launch the first cross-border blockchain actions by the end of 2019.




Update posted: 4 April 2018

By Nathan Dudgeon

FCA confirms (again) that cryptocurrency derivatives are regulated

The Financial Conduct Authority confirmed on last Friday that it would regulate derivatives. The FCA does not currently regulate cryptocurrencies but this does not mean that they cannot be used, accidentally or otherwise, in or as part of regulated products or services. A prime example of this is trading in derivatives which is a very highly regulated activity.

'It is likely that dealing in, arranging transactions in, advising on or providing other services that amount to regulated activities in relation to derivatives that reference either cryptocurrencies or tokens issued through an initial coin offering (ICO), will require authorisation by the FCA.'

Last year, the FCA published a warning to cryptocurrency investors, followed by another warning the following month about investing in cryptocurrency (contracts for difference).

You can even scroll down to our 8th February blog entry to see another FCA confirmation that cryptocurrency may be regulated (and more detail on why).

Many have argued that the FCA has not said anything new in this latest statement. In essence, this is true but these warnings are becoming increasingly concrete – with more examples that are specific and fewer grey areas. You can expect more to come in the future.




Update posted: 26 March 2018

Fintech strategy: HMRC publishes sector report

By Nathan Dudgeon

The Fintech Sector Strategy (PDF) is ‘all about the action the government has taken to make the UK the best place to start and grow a fintech business’. If you do not have half an hour spare to read the report, this UK Tech News article is a good summary.

Interesting facts:

  • More people work in UK fintech than in New York fintech or in the combined fintech workforce of Singapore, Hong Kong and Japan.
  • Over 42% of digitally active adults now use the services of at least one fintech firm.
  • More than 20 million people in the UK make use of banking apps.

Most articles focus on the creation of a new ‘crypto asset task force’, which does sound a lot like another one of those viral games that might break the Ethereum network. The task force is actually part of a concerted effort to lessen regulatory headaches. Another part of the report focuses on regtech and how compliance obligations can be converted to a machine-readable format.

Fintech bridges

One of the more widely relevant (and eagerly anticipated) announcements is that the UK is building a ‘Fintech bridge’ with Australia.

This would be the fifth bridge, since the UK already has one with Hong Kong, South Korea, Singapore and China. The report says it will ‘minimise barriers to entry for fintech firms that wish to expand globally, and . . .] ensure that the growth potential of UK fintechs is showcased to international investors’.

What that means in practice:

  • The FCA and the Australian equivalent (ASIC) work together. They will share information about emerging trends or regulatory issues etc.
  • The governments will harmonise a range of policies relevant to fintech. A prime example is in their Open Banking regimes.
  • Streamlining the process for fintechs trying to expand internationally
  • There will be plenty of collaborations in the private sector too; events, conferences, networking and so on.

Update posted: 21 March 2018

Storing (illegal) data on blockchain

By Nathan Dudgeon

You may have seen in the news over the last couple days how researchers have found that the Bitcoin blockchain is being used to store illegal content, like images of child abuse or hacker code you can use to break encryption on DVDs. Using a blockchain to store files other than transactions is entirely possible; in fact some tokens deliberately exist to be an alternative file storage system (like Filecoin), despite the Bitcoin blockchain not being created for this.

How to store data on the blockchain

When you send money using your bank, there is often a little section for you to put a description of the transaction – as long as it is just a few characters. There is a function called ‘OP_RETURN’ that does the same thing with Bitcoin, which means that people can use it to post short messages. This is a deliberate function of the network. In fact, the first ever transaction has a message that reads "The Times 03/Jan/2009 Chancellor on brink of second bailout for banks". It is almost like a cryptic clue to blockchain’s mission statement.

Storing much larger amounts of data was not part of the design however, and it most often involves fragmenting. This is where you have to make many transactions, each with a different piece of the data, before some clever software stitches it all together at the end.

There is another way to store larger amounts of data where you essentially send your Bitcoin to a made up recipient (in Bitcoin language this means replacing the valid receiver keys with arbitrary data). This comes at a cost however, as there is no bank to ask for your money back. This is why it is called ‘burning your Bitcoin’.

A 21 KB image of Nelson Mandela (which is already on the chain, by the way) would burn about $380 of Bitcoin at the current price of $8,400.

Why you would want to store data

While there are valuable uses for blockchain data storage, people would usually choose a chain specifically designed for that purpose. For example, there is a notarisation industry that will certify that a document exists. For larger pieces of data, you could post content free from censorship (e.g. whistleblowers) or archive memorable/historical data (e.g., there are at least six wedding-related photos currently on the Bitcoin chain).

On the other hand, people can spread copyright infringements or commit blackmail with threats of posting private information. Interpol and Kaspersky Labs started warning years ago that you could use similar methods to embed malware into the blockchain. This has not happened yet with Bitcoin, but it only seems a matter of time.

What has already happened however (and is all over the news), is the appearance images (and links to more) of child abuse on the chain. The consequences of this is that possession of the Bitcoin blockchain could be a very serious criminal offence, although we will have to see how the police or courts respond to this.


Update posted: 14 March 2018

Google bans cryptocurrency ads

By Alex Gillespie

At 4am this morning, Google announced that, as of June 2018, it would no longer permit advertisements which service cryptocurrencies and related content (including initial coin offerings, cryptocurrency exchanges, cryptocurrency wallets and cryptocurrency trading advice). The ban will cover both Google’s AdWords as well as Youtube.

No reasons were given in Google’s announcement, however, the ban follows a similar ban from Google’s rival Facebook in January. At the time, Facebook explained that this was due to the fact that many companies that advertised ICOs and cryptocurrencies were not “operating in good faith”.

It also follows the IMF’s announcement on Tuesday about the ‘peril’ of crypto-assets and calling for greater consumer protection internationally. The value of bitcoin fell 4.1% to below $9,000 following the announcement.

This is the latest example of an established firm distancing itself from cryptocurrencies (another recent example being Lloyd’s ban on the use of its credit cards to buy cryptocurrencies) to protect themselves against commercial or reputational damage by association with the technology. It is unlikely that Google will be the last firm to do so.




Update posted: 9 March 2018

Cryptocurrencies and the future of money

By Alex Gillespie

In a speech (PDF) last week, Mark Carney set out his views on the future of money and how, in his view, this will change with the development of cryptocurrencies. Here are some key high-level takeaways from Mr Carneys speech:

  1. The role of cryptocurrencies as money: Mr Carney was upfront about the fact that in his view cryptocurrencies are “failing” as a currency and explored three key problems with the technology, namely that cryptocurrencies: (a) are poor stores of value due to the extreme volatility caused by their lack of intrinsic value or external backing, (b) are inefficient media of exchange due to their generally being slower and more expensive than payments in sterling and (c) because of these problems are virtually unused as units of account.
  2. The Bank of England’s policy towards cryptocurrencies: In addition to cryptocurrencies’ shortcomings as money, the Bank of England has wider concerns around consumer and investor protection, market integrity, money laundering, terrorism financing, tax evasion and the circumvention of capital controls and sanctions. However, the Bank of England does not wish to avoid stifling innovation or preventing the implementation of technologies that will bring future benefits to the financial system.
  3. The regulation of cryptocurrencies: In view of the potential technological benefits, Mr Carney was against general bans on the use of cryptocurrencies but instead targeted regulation so that cryptocurrencies are held to the same standards as the rest of the financial system. Mr Carney gave the following examples that the Bank of England are looking into: (a) regulating crypto-asset exchanges according to the same standards as security exchanges, (b) introducing regulations to prevent ICO’s being allowed to “use semantics” to avoid regulations and (c) clarifications to the regulatory requirements, such as for capital, of institutions which engage with or have exposure to cryptocurrencies.
  4. The future of money: Perhaps most interestingly, Mr Carney shared his thoughts on how, if cryptocurrencies as we know them are not the future, money and payment systems will change in the future as a result of the technology such as: (a) the diminished role of financial institutions as society’s preference changes towards decentralised peer to peer interactions (b) the role of distributed ledger technology and the benefits this will have on the efficiency, reliability and flexibility of payments and (c) the adoption by central banks of their own digital currencies (however, Mr Carney was of the view that this was unlikely to take place in the short term due to the technology’s existing shortcomings).

It is interesting to hear the views of such a senior policymaker on how a not-so-distant financial system might look based on market conduct to date. It also raises an important debate about how our financial system may need to change for the benefit of society and how traditional financial institutions will fit into that given the recent advances in cryptocurrency technology. Mr Carney’s speech will interest anyone engaged with this technology or financial services as a whole.




Update posted: 16 February 2018

Will artificial intelligence take our jobs?

By Nathan Dudgeon

We looked at a PwC report on the impact of AI over the next 15 years. The results were a bit more nuanced than most – discussing which industries, which job types, and which demographics are at risk to artificial intelligence, why, and when.

Read the full article here.




Update posted: 8 February 2018

FCA confirms (again) that cryptocurrencies may be regulated

By Nathan Dudgeon

In October last year, the Treasury Select Committee asked the FCA’s Chief, Andrew Bailey, to explain the limits of the FCA’s powers. This week they published a letter with the FCA’s detailed response (PDF).

In it, Mr. Bailey explains a number of areas that fall on the border of the FCA’s powers, one of which is cryptocurrencies.

The summary is that nothing has changed – crypto is still borderline.

Why? At a very high level, the existing regulated activities and financial promotions regimes were not originally drafted with ICOs in mind. The laws point to exhaustive lists to determine whether something is regulated or not, and digital tokens are not expressly referred to in the lists. We think this is partly why so many people (mistakenly) believe that all ICOs are not regulated in the UK.

Remember, however, that tokens’ functions vary widely. Many digital tokens perform the same or similar functions to financial instruments which do fall within the list of regulated investments.

The FCA has previously warned that “depending on how they are structured, some ICOs may involve regulated investments and firms involved in an ICO may be conducting regulated activities”. They noted that some ICOs show parallels with IPOs, private placement securities, crowdfunding, futures, options, or collective investment schemes. All of which are very much regulated.

This latest letter from the FCA merely confirms the status quo, for now.




Update posted: 2 February 2018

Lessons on building cyber resilience from the FCA

By Alex Gillespie

Cyber security has become an increasing concern both for individuals and businesses over the years. We have already seen one large cyber security scare in 2018 with the threat posed by ‘Meltdown’ and ‘Spectre’ both being widely reported in the media. With Open Banking coming into effect it is unsurprising that cyber security is very much in the FCA’s focus.

On Friday, Robin Jones, Head of Technology, Resilience and Cyber at the FCA, gave a speech setting out some salutary lessons the FCA has drawn from previous cyber attacks over the years and offering guidance to firms around improving their cyber resilience. By way of illustration of the dangers, according to the National Cyber Security Centre there were over 1,100 reported attacks in the last 12 months alone (590 of which were regarded as ‘significant’) and there are more than 10 cyber attacks in the UK every week.

Consequently firms should understand the dangers and make efforts to build their resilience against such a threat. The FCA expects firms to follow the basic principles of ‘resilience’ – being not only that firms can protect themselves against attacks and identify potential threats and their own vulnerabilities, but also that they can detect attacks that have been successful and know how to respond and recover from them.

According to Mr Jones, there are three key lessons that firms can take away from some of the last year’s high profile cyber attacks. These are:

  1. Address the basics: Cyber attacks typically exploit well-known vulnerabilities in systems. Wannacry is one example of where the attack could, for the most part, have been prevented if the NHS had carried out some basic security practice.
  2. Detect attacks, stop them spreading and have robust contingency plans: The best way to mitigate an attack is to have a back-up. Firms should consider and identify their tolerance for the systems or data being made unavailable due to a cyber attack.
  3. Ensure any contingency plan includes a communications plan: Know how to get hold of key people and contact staff, consumers, suppliers and authorities. Firms should ensure that they have plans in place prior to any attack, rather than trying to create plans at the same time as reacting to an attack.

Ultimately, the FCA expects firms to have strong governance procedures in place and show visible leadership in the event of an attack. According to the FCA, firms should understand their key assets and their back-up arrangements. They should be in a position to know what is important and the means for protecting their customers from any theft (most attacks exploit the simplest vulnerabilities and therefore following basic cyber-security practices will go some way to addressing this).

Firms should exhibit a good security culture whereby senior leaders and staff alike are alert to potential threats and trained to follow good security practices. Systems should also be put in place whereby passwords are regularly changed, systems access limited to only those that require it, etc.

Of course, this speech will be helpful both on a practical level and, for authorised firms, to help better understand the FCA rules pertinent to cyber-security. Read the full speech.




Update posted: 19 January 2018

Baidu releases blockchain as a service platform

By Nathan Dudgeon

Baidu aren’t the first huge company in China to launch blockchain as a service. In fact, both Tencent and Ant Financial (part of Alibaba) already have blockchain services in the market.

What is blockchain as a service? Firstly, you’ll need to understand blockchain – start with our article, or this YouTube video.

Blockchain as a service is, generally speaking, where a company (like Baidu) creates its own blockchain system and hosts it on the cloud. This blockchain is a foundation, or a template – and you can build stuff on top of it.

So instead of setting up your own blockchain, which costs a lot of time and resources, you might go to a blockchain service provider, like Baidu, and use theirs for a subscription fee. Companies will come in, use Baidu’s technology, and shape it into whatever specific purpose they choose. Baidu will no doubt have plenty of their own pre-made models to allow you to start immediately.

It’s the same idea as Dropbox – for many companies this is far cheaper, better-made, secure, and easy-to use than creating their own in-house file sharing system.

So what is Baidu actually offering? “Efficient and low cost traceability and trading, ideal for digital currency, payment and settlement, digital ticketing, bank credit management, equity proof and exchange-traded securities, insurance management, financial auditing and more.” Elsewhere, Baidu have said they want to use blockchain in AI, driverless cars and distributed computing.

People have noted that this is fairly generic, but that’s a common practice in the market at the minute. Apparently the whole platform has been built in-house, which is different to most other providers – commentators wonder whether this means it’s a private ledger (i.e. it is invitation-only, but probably also takes less of your computer power to run).




Update posted: 17 January 2018

PSD2 and Open Banking: finally here

By Nathan Dudgeon

The Payment Services Directive (PSD2) came into force this week. You might have noticed news stories about how credit card surcharges are ending, or an increase in ‘strong customer authentication’.

Open banking is probably the biggest change brought by this new law. Banks can now share your data with third parties (on receipt of your permission), and these can ‘plug in’ to your bank via an API to bring extra value. Interesting times are ahead; will the banks adapt or just become ‘dumb pipes’? (See this article in The Times. Please note, you will need to register/login to view.)

You can also read our Guide to Open Banking or Understanding the new Payment Services Regulations




Update posted: 15 January 2018

Lessons from the KodakCoin

By Alex Gillespie

On Tuesday 9 January 2018, Kodak became the latest firm to seek to raise capital from an initial coin offering (ICO). At the CES2018 convention, Kodak announced plans to use the Ethereum blockchain to create a digital platform for photographers to monitor and protect their photographs from IP infringement. Once launched, customers will be able to purchase photographs over the platform using its own digital currency, the ‘KodakCoin’. According to Kodak, the platform will record a cryptographic record of all photographs purchased through it.

On the day it was announced Kodak’s share price rose by 119% but it has also faced criticism from many commentators on the proposal, particularly because KodakCoin and Global Blockchain Technologies Corp made an immediate $2 million investment into the cryptocurrency (subscribing for all 8 million KodakCoins available at the first stage of the pre-initial coin offering).

Many commentators have expressed concern at the considerable interest shown by investors in a platform that has not even been launched yet, akin perhaps to the frenzy shown by investors during the 17th century TulipMania, and an aspect of ICOs that the FCA has already expressed concern about in the UK. We have previously noted the FCA’s concerns about ICOs after it publically voiced concerns about a general lack of investor understanding in the products and a lack of substance behind many ICOs.  

Commentators have criticised the proposal for being vague and even flawed. For example, the ICO will only be available to ‘accredited investors’ earning more than $200,000 in income or with a net worth of £1 million (to avoid the ICO being registered with the SEC) creating considerable problems for a platform allegedly intended to be used by the mass market. Other commentators have argued that there is no need at all for the use of cryptocurrencies and blockchain for what is, after all, a proposal for a central database to record ownership supported by a web-trawler to identify cases of IP infringement.

The industry criticism should also be viewed in the general context that Kodak was only recently saved from bankruptcy and since the announcement had an ever falling share price. Kodak’s business and the problems that led to its falling share price (principally its failure to keep up with digital technology) do not appear to have changed beyond speculative proposals for the KodakCoin.

Of course, time will tell and the resurgence of a fading household branch is a great thing. However, it is clear that Kodak has a long way to go to convince its detractors (and perhaps the regulators) as to the viability of this project. We wait to see whether this could be the next KodakMoment.




Update posted: 27 December 2017

Tandem gets a banking licence, again

By Nathan Dudgeon

Earlier this week, the PRA gave Tandem permission to acquire 100% of Harrods Bank Limited.

This is big news. Tandem will finally have a banking licence, again – they did have one at the start of 2017, but lost it after failing to secure funding from a Chinese conglomerate in March (as reported in the Financial Times).

The deal is due to complete sometime in the new year, and Tandem will get £80 million of capital, access to a full banking licence and 10,000 savings and mortgage customers (plus tens of thousands of Tandem co-founders are already on the waiting list). The licence means Tandem will be able to offer their current accounts and finance other business activities with the deposits (such as offering loans).

Buying a banking licence is a fairly unusual way to get one – banks are rarely put up for sale and there are still regulatory hurdles to jump before you can buy one, which is why this news comes months after Tandem’s announcement of the deal. Another alternative is to become an ‘appointed representative’ – where someone who is already authorised agrees to take responsibility for your performance of that regulated activity, usually for a considerable fee.

To find out more about setting up a bank, have a look at the Bank of England’s new bank start-up unit, or you can always reach out to us.




Update posted: 18 December 2017

The FCA gives feedback on DLT

By Alex Gillespie

There was, I think, little to surprise in the FCA’s feedback statement (PDF) to its discussion paper on distributed ledger technology (DLT) which, in the rapidly changing world of fintech is arguably a surprise itself! There were no radical new policies or initiatives or proposed changes to the FCA Handbook just a confirmation that “our current regulatory requirements appropriately reflect our strategic objectives” and a commitment for further engagement with fintech, both domestically and internationally.

Despite the lack of any headline changes, the statement itself had the quiet confidence of a Regulator that is slowly getting to grips with the rapid changes to financial services brought about by fintech and DLT. The FCA engaged with participant feedback on topics ranging from digital currencies, smart contracts, regulatory reporting and financial crime (among others). Most of all, the statement primary reaffirmed the FCA’s ongoing commitment to engage with UK fintech as a ‘technology-neutral’ observer and highlighted the benefits which DLT offers to financial services as well as the shortcomings that need to be resolved.

My main take away from the statement, is that the FCA has rightly identified initial coin offerings (ICOs) as requiring closer scrutiny. The FCA mostly reiterated the concerns it gave in its consumer warning from September 2017 – that these are high risk investments little understood by the average investor – but also included a ‘regulatory considerations on ICOs’ annex to address widespread confusion as to the regulatory requirements behind an ICO (including when they are ‘regulated’). This should be compulsory reading for anyone considering launching an ICO.




Update posted: 12 December 2017

Madrec, MiFID II, and Ethereum: both complicated and excellent

By Gareth Malna

There is only a matter of weeks until the date that MiFID II takes effect, bringing with it the swingeing changes to the regulatory landscape that many compliance officers in the financial services sector have been working towards (and, perhaps, dreading) for the better part of two years. But, with a sense of inevitability, the world continues to turn and the big winners from the changes are likely to be those institutions that provide the tools to ensure compliance.

Step forward UBS, which with help from Barclays, Credit Suisse, KBC, SIX and Thomson Reuters has launched the Massive Autonomous Distributed Reconciliation platform (Madrec); an initiative based on the Ethereum platform to make the reconciliation of counterparty data a much simpler, automated, process. 

From a brief review of articles and blog posts reporting on the launch of Madrec it is clear that media commentators are struggling to understand exactly what the project does and why it is important, so we have set out our take on it below.

Without Madrec, banks (such as UBS) which make transactions in financial instruments for their clients are required to clear transactions on trading venues. This is done on a transaction-by-transaction basis and requires a physical review of the trading contracts in order to check the veracity of data being reported by the counterparties before the transaction can be cleared and regulatory reports filed. In order to effect that checking process banks rely on their own processes and data sources, taking external reference data from a number of sources without any agreed standard. 

As of 3 January 2018, MiFID II will require all parties to the majority of financial transactions to obtain and maintain a unique identification code for the purposes of increasing transparency about exactly who is actively participating in transactions in the market. That unique code is a Legal Entity Identifier (LEI), which has to date only been required of trading venues under certain European regulations – notably the European Market Infrastructure Regulation (EMIR – which imposes requirements on derivatives transactions) and the Market Abuse Regulation (MAR – dealing with illegal trading behaviours).

Pre-Madrec, banks acting for counterparties will be able to use the LEIs of the counterparties to identify and carry out checks on those counterparties using the bank’s standard data sources – a manual and potentially time-consuming process.

In a post-Madrec world, banks will be able to use the permissioned platform (which is based on smart contract technology) to automatically reconcile in real-time the information pertaining to each LEI against consensus baseline information. Any deviations in the reported information from the consensus could then be highlighted and resolved where necessary.

Suddenly the compliance burden is reduced and firms are free to use their resources to focus on the business of running their business rather than relying on inefficient processes to meet their regulatory obligations.

This is clearly what the times should look like – use of available technologies in a manner that facilitates regulatory compliance and transparency at a reduced time and cost burden. The only question is, who else will step up to the plate to benefit from the regulatory changes that are afoot?




Update posted 8 December 2017

Bitcoin benefits: save hay while the sun shines?

By Nathan Dudgeon

Every news agency on the planet is talking about how bitcoin passed the $16,000 mark last week. The articles are full of people lamenting the fact that they deleted their bitcoin, or spent it all years ago and didn’t become millionaires. The pages are also full of dire warnings against bubbles.

Something from CoinDesk caught our attention this week, because it argues for bitcoin benefits beyond simple profit.

Marc Hochstein says:

“Off the top of my head, I can name three social useful functions of bitcoin: its censorship-resistance; its judgment-resistance; and the topic of this essay, its deflationary quality, which rewards saving for tomorrow rather than splurging today.”

In short, he argues:

"Bitcoin encourages people to be wiser with their money, to think before they spend, to plan ahead and not act so much on impulse."

Why? Because there are a finite number of bitcoins – once we’ve finished mining them all there will be no more. As bitcoin becomes more popular/widespread, the price rises, and a government can’t ‘print’ more money to water down value. If the value of your money increases as you hold it, you’re going to think a lot more carefully before spending it, and are incentivised to think long-term. The article argues that this will cause a shift away from “the culture of conspicuous consumption, of shopping as therapy”.

This is especially so for young people, whereas in contrast:

“More typical is the short-termism that, at its most destructive, led Wells Fargo to set impossible sales quotas for its retail bankers, motivating them to create millions of unauthorized accounts and ultimately resulting in massive fines and brand damage.”

We enjoy a good debate here at Burges Salmon so we think it’s important to highlight ‘a reasoned response from the other side’, regardless of whether we agree or not. If you’re interested in reasoned arguments against what some call ‘ICO mania’, take a look at Preston Byrne’s content.

For me, it is easy to say that you are patiently waiting for long term gains when your investment’s value rises meteorically every week. A more worrying thought is if bitcoin is a bubble, then when it bursts and those who bought high lose out, you’ve instead taught the exact opposite – they should have made the most of the short term gains while the sun was shining. That’s a point we can definitely agree on; short termism is rarely a good thing.




Update posted: 8 December 2017

FCA regulatory sandbox: Cohort 3 announced

By Nathan Dudgeon

The FCA have published an update on the third and fourth cohorts of their very successful regulatory sandbox.

There were 61 applications for cohort 3, and 18 made it through the selection process. They’re all listed on the website for you to have a look, but big players include Nationwide (robo-advice) and Barclays (regtech), and the rest cover everything from cybersecurity and insurance to investment management and AML.

In particular, the FCA has given some encouraging news regarding the location of the latest cohort:

In the sandbox’s first phase, a majority of the firms were London-based with only a few from other parts of the UK. As the FCA continues to increase its regional engagement in emerging FinTech hubs, encouragingly, the proportion of regional firms has increased in each subsequent cohort. Over 40% of firms invited to test in cohort 3 are based outside London, compared to 35% in cohort 2 and 25% in cohort 1.” 

Cohort 2 includes Bristol-based Moneyhub.

The sandbox is very popular and applications are being accepted for the fourth cohort now. Deadline is 31 January.




23 November 2017

The Autumn Budget and fintech

By Alex Gillespie

For those of us engaged with the UK’s burgeoning fintech scene, there was much to be pleased by in the Autumn Statement. Fintech and new technologies as a whole are increasingly seen by the government as part of the answer to the UK’s future and the uncertainties of Brexit. If you didn’t manage to catch the budget itself, one of the key policies (for fintech at least) was the government’s plan to unlock over £20 billion of investment to support the growth of innovative firms over the next 10 years. This, the Chancellor said, will be achieved by:

  1. Establishing a new £2.5 billion investment fund incubated in the British Business Bank and designed to co-invest with the private sector to generate £7.5 billion of investment.
  2. Doubling the annual allowance for those investing in knowledge-intensive companies through the Enterprise Investment Scheme (EIS) and the annual investment those companies can receive through the EIS and the Venture Capital Trust scheme. The government expects this will unlock £7 billion of investment.
  3. Investing in fund of funds in the private sector, with the initial wave of investment seeded by the British Business Bank. There will be up to three waves of investment to support up to £4 billion investment.
  4. Backing new and emerging fund managers through the Enterprise Capital Fund programme established by the British Business Bank, expected to unlock £1.5 billion.
  5. Backing overseas investment in UK venture capital through the Department of International Trade, which is expected to unlock £1 billion of investment.

On top of this, the government has announced several other policies to support UK fintech, such as to invest £21 million of the next four years for the expansion of Tech City UK and to support regional tech companies. Other benefits include supporting challenger banks by making PRA capital requirements more proportionate for eligible smaller banks as well as the creation of a new £10 million Regulator’s Pioneer Fund to help regulators develop innovative approaches to help get new products and services to the market.

Of course (as with any Budget), the devil will be in the detail and execution of the proposals – we look forward to seeing them in action.




20 November 2017

Artificial Intelligence and ethics: just because we can, should we?

By Nathan Dudgeon

Just a couple weeks ago, a panel at Bristol TechFin 2017 led a discussion on the ethics of creating AI which might evolve into something you can’t understand. Just a few days ago, New York University officially launches ‘AI Now’ an institute dedicated to understanding the social implications of artificial intelligence. Creepy coincidence or a sign of the times?

We think it’s a sign of the times, and one of the biggest for us was that the keynote was from a lawyer (a Supreme Court Justice, no less) – someone whose job is to be risk-averse.

“At its most ambitious, AI’s promise is to serve as a framework for improving human welfare to make the world more educated, more interesting and full of possibility, more meaningful, and more safe. But once we overcome some technical problems that are more likely than not to get easier to deal with every day, we’re in for more than just a world of change and evolution. We’re in for some discussion of what it means to be human.”

“Tonight we gather not because we know how to answer that question, but because we realize – using different words, perhaps – that change is coming.”

An adaptation of the keynote was can be found on Quartzy.

It will be interesting to see what, if anything, the Institute covers on the financial services industry specifically. We definitely think that more discussion and more awareness is good – after all, collaboration and transparency are (often) hallmarks of the fintech world.

It may also provide useful assistance for politicians and regulators when making proactive and proportionate laws or regulations for the future. Here in the UK, the FCA are especially innovative and proactive when it comes to working with industry and understanding new technologies and industries – for example, the FCA’s foray into Model Driven Machine Readable regulation (yes, based on R3’s Corda distributed ledger tech) that Burges Salmon is taking part in as a legal Subject Matter Expert.




15 November 2017

UK Financial Services after Brexit – ECB criticises bank relocation plans

By Alex Gillespie

The European Central Bank (ECB) released an article on the Brexit-related relocation plans of UK banks. The article criticised the relocation plans of banks to EU member states as setting up ‘empty shells’ or ‘letter box banks’ and stressed that banks within the EU needed to have sufficient substance locally. The ECB warned that:

  1. Banks should not seek to transfer all market risk to a third-country group entity. Some risk should be managed by the EU bank locally, with local trading capabilities and risk committees. The EU bank should also trade and hedge risks with diversified counterparties not just with their own group.
  2. It was concerned by banks’ plans for ‘dual hatting’ whereby employees carry out roles for multiple group entities, particularly where the employees would be primarily located outside the EU. This would have the effect of diluting the local governance and autonomy of the EU bank.
  3. In the event of a transitional period being agreed, banks must nevertheless set out clearly what their plans will be, commit to them and explain how and when they will be carried out.

Comment: Almost immediately following David Davis’ call the day before for greater collaboration and a new partnership between the UK and EU, the EU has announced plans to exert greater authority over UK banks operating in Europe than had initially been expected. The most immediate issue for UK banks will be committing to contingency plans before the outcome of the Brexit negotiations have been determined.




14 November 2017

UK Financial Services after Brexit – David Davis makes a speech

By Alex Gillespie

The travails of the UK financial services industry continued this week as the UK and EU jostled over the industry’s future relationship with Europe after Brexit. On Tuesday, David Davis, the embattled Secretary of State for Exiting the European Union gave a speech on the financial services sector post-Brexit relationship with the EU. The speech was positive and optimistic for the future of the industry as Mr Davis reminded the audience of London’s historic strengths and that it was the world’s leading financial centre.

Mr Davis warned of the potential risk to Europe of the Brexit negotiations leading to the fragmentation of its financial services sector. To avoid this the UK and EU should look for a ‘new balance’ between both sides, which should achieve three things:

  1. protecting financial stability
  2. ensuring consumer protection
  3. supporting the existing co-operative system for cross-border financial services.

These objectives were in the interests of both sides and would give clarity and certainty to businesses across Europe.

Mr Davis also disclosed that the government sought to include UK financial services in its two year transition period, during which UK firms would remain subject to EU regulators and agencies. A ‘carrot’, widely publicised by the media, was the government’s plans to introduce an Immigration Bill intended to give UK businesses greater flexibility over the mobility of their workers across the continent.




14 November 2017

FCA warns consumers of risks of cryptocurrency CFDs

By Guinevere Wentworth

The FCA has released a consumer warning on contracts for differences (CFDs) with cryptocurrencies, which are being heavily marketed at consumers. CFDs allow a consumer to speculate on the price of an asset by investing only a portion of its value. Both the potential profit and the risk are large and money can be lost very quickly so that money may end up being owed.

Cryptocurrency CFDs are extremely high-risk, speculative investments and the FCA highlights four main concerns:

  1. the price volatility of cryptocurrencies
  2. the large levels of leverage
  3. the high charges and funding costs
  4. the likelihood of pricing not being transparent.

It warns that only experienced and sophisticated investors with knowledge of the risks should invest. 

Comment: CFDs are regulated and investors should check that the firm is authorised if offered the opportunity to invest in a CFD or are considering one. This does not mean that losses from trading, however, are protected. Firms offering CFDs should make sure that they are authorised and prepared for MiFID II while also making sure that they only promote CFDs to appropriate investors.




13 November 2017

Concerns over ICOs raised by ESMA

By Guinevere Wentworth

The European Securities and Markets Authority (ESMA) has released two statements on the risks of initial coin offerings (ICOs). Read our introduction to ICOs.

The first statement (PDF) reminds firms involved with ICOs that they need to assess if their activities are regulated. If they are then they need to ensure that they comply with relevant EU legislation, such as the Prospectus Directive, the Markets in Financial Instruments Directive, the Fourth Money Laundering Directive and the Alternative Investment Fund Managers Directive, and any relevant UK law.

The second statement (PDF) is aimed at investors. It flags the key risks associated with ICOs, such as the risk of losing the whole of an investment, that there may be flaws in the technology, the lack of information provided to investors, that there may be no exit option and that there is no protection offered to the investor if the ICO is unregulated.

Next steps: Firms involved with ICOs should make sure that they are aware of the regimes in place and what their obligations are, while investors should carefully consider where they invest. If you have any questions on this area, please contact our fintech team or your usual Burges Salmon lawyer.




30 October 2017

CCC launches Image Clearing System

By Guinevere Wentworth

The Cheque & Credit Clearing Company issued a press release on 30 October 2017 launching the Image Clearing System. The Image Clearing System will mean that cheques processed under this system will be cleared much more quickly than the old, paper based system.

Funds will be available for withdrawal after being paid in by 23.59 on the following weekday (excluding bank holidays) rather being available six weekdays later, as is currently the case. Some banks are also likely to offer their customers the option of using a mobile app to pay in a cheque by taking an image of it, rather than having to physically pay it in.

The two processing systems will continue to be run in parallel while the Image Clearing System is phased in slowly.  Initially only very few cheques will be processed under the new system but the numbers will rise until no cheques will be processed under the old system. This is expected to happen in the summer of 2018. Consumers will not be able to ask for a particular system and will need to ask their bank for information on how quickly their cheques will clear in the cross-over period.

Comment: It may seem that cheques are unnecessary in the days of mobile phone transactions and Apple Pay, but 477 million cheques were used in 2016. This process will allow people to continue to bank in a way that they feel comfortable with (and in some cases is a still a necessity), but with the advantage of 21st Century technology eking out the lifespan of a paper-based payment that has apparently been around since the 9th century for a little while longer.

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