While the Bank for International Settlement / Basel Committee on Banking Supervision continues to propose regulation, they also have developed a habit of not addressing legitimate concerns from the community. That is highly regrettable, but no reason to throw in the towel. So the Bitcoin Association Switzerland continues to provide constructive feedback and - so we think - well argued suggestions on how to improve on the longterm goals of the BIS to make the space safer and allow for more innovation. The letter we sent out this week is continuing this tradition. Zurich, 2022-08-07 To:  ..read more

The original response can be found here. Prudential Treatment of Cryptoasset Exposures Dear Basel Committee on Banking Supervision We welcome this opportunity to comment on your draft document "Prudential Treatment of Cryptoasset Exposure". At the same time, we are unsure whether our words will be heard as the concerns we raised the last time seem to have fallen on deaf ears. If you are interested in improving the dialog with the public, it might be helpful to shortly summarize and acknowledge received feedback in an according report. A good example is the Swiss government that publishes a sum ..read more

The Financial Action Task Force has recently published a revised raft for VASP guidance. Once finalised, this “guidance” will likely become de-facto law in numerous countries, so it is very important to get the guidance right. The Bitcoin Association Switzerland is hence providing constructive feedback and suggests seven simple principles, the FATF’s guidance could adhere to, benefitting society and innovation while keeping negative side effects to a minimum. The original response can be found here and is worth a read for its footnotes alone (which are not part of this blog post). Comments of ..read more

Today we sent the following letter to the Financial Stability Board of the G-20 commenting on their risk assessment for "global stablecoins": Dear Financial Stability Board We welcome this opportunity to comment on your thoughts regarding global stablecoins. In the following, we will outline our main concerns regarding the regulation of stablecoins. We are afraid that focusing on the posed questions would make us miss the forest for the trees. In fact, the main risk in this context does not stem from the idea of global stablecoins itself, but from the political response it has elicited. What ..read more

Roger Darin: Welcome everyone to the AMA (Ask Me Anything) with Finka from the Finka Token Project. We have two people joining, namely Carlos H. Fernandez Mazzi (@CHFernandezMazzi) and Pablo Diaz-Saubidet (@PDiazSaubidet). First of all, can I ask the particiapants of Finka to introduce themselves please Carlos Mazzi: Hello to all participants. It is noon time for us here in Bolivia Let me introduce myself first and then I will ask Pablo to introduce himself FIrst of all, I am the lead for the FInka Token project and I will take any and all questions from the group To start, a few lines about m ..read more

On the 8th of April 2020 we sent the following comment to FINMA regarding the new money laundering ordinance: On February 7th 2020, FINMA has published an ordinance project as well as several partial ordinance revision projects including the Geldwäschereiverordnung-FINMA (GWV-FINMA). We greatly appreciate this opportunity to take part in the public consultation and want to point out a specific detail that affects crypto currencies. The proposed article 51a GvW-FINMA would create a legal difference between virtual currencies and traditional currencies, imposing different limits to the exception ..read more

Broadly speaking, Bitcoin is two things: A decentralized blockchain and a censorship-resistant, digital currency. For Bitcoin to work, both are needed but it is possible to not only use Bitcoin (the currency) on the Bitcoin blockchain but also to use it with the Lightning network or the Liquid and RSK sidechains.  Today, the Bitcoin Association Switzerland (BAS), together with the involved companies, announces yet another way to use Bitcoin: tzBTC, a token on the Tezos blockchain backed 1-1 by Bitcoin. With Bitcoin being the de facto reserve-currency of cryptocurrencies, tzBTC is one of t ..read more

In December 2019 the Basel Committee on Banking Supervision published a discussion paper on the design of a prudential treatment for crypto-assets and welcomed comments on its analyses and ideas. The comment submitted by the Bitcoin Association Switzerland is as following: Dear Basel Committee Bitcoin Association Switzerland appreciates this opportunity to take part in your discussion of the prudential treatment of crypto assets. There is a worrying trend of our laws being increasingly shaped by international bodies without immediate democratic legitimacy. The invitation to take part in your ..read more

While the Crypto Valley Association’s paper on “Asset Tokenization” contains many insightful sections, there are other sections that get some fundamental legal considerations embarrassingly wrong. Further questionable is a piece of advice that could make an issued token incompatible with the law. In this blog post, we shed light on the three biggest blunders of the paper. First, the authors of the paper fail to recognize that there is a difference between the anti-money laundering laws applicable to cryptocurrencies and those applicable to asset tokens. Legally, crypto currencies are usually c ..read more

In March, the Federal Council presented a draft for a number of legal adjustments and invited Bitcoin Association Switzerland to take part in the public consultation. The consultation phase ends this month and we have filed an extensive comment, in which we support the position of the Swiss Blockchain Federation and lay out some of our common concerns in more detail. In this blog post, I will summarize the content of the proposed law as well as the comments of both Blockchain Federation and Bitcoin Association. In its December report, the Federal Council identified three main obstacles for the ..read more