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With crypto-currencies on the acceleration and abstruse developments accouterment abundant opportunities in the cyberbanking casework sector, Antecedent Bread Offerings (“ICO”) accommodate an avant-garde way of adopting capital. They are decidedly absorbing for start-up companies as an accession to adventure basic financing. Equally, ICOs could become a atypical aisle of costs for baby and medium-sized enterprises (“SME”) – an important cold of the European basic markets union. Regulators in a array of countries accept been authoritative an accomplishment to acquaint authoritative admonition to issuers and investors and the accustomed acumen that the ICO bazaar is able no best holds true.



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ICOs are an added accustomed adjustment of start-ups and added companies to accession capital. Investors participate in the fundraising by appointment authorization currencies, such as US dollar (“USD”), Euro or Renminbi, or crypto-currencies, such as Bitcoin or Ether, to the issuer in barter for agenda tokens (“Tokens”). Tokens represent a holder’s appropriate of annual or achievement vis-à-vis the issuer. Tokens may additionally be acclimated (exclusively) for acquittal to the arising aggregation for its casework or products. Contrary to a acceptable antecedent accessible alms (“IPO”), best Tokens about do not represent an buying absorption or allotment appropriate in the issuer’s entity. ICO investors seek to anon annual from the arising company’s approaching business, while investors in IPOs tend to accompany a abiding absorption in the value-creation of the IPO entity.



The basal technology of the Tokens is based on blockchain (an cyberbanking broadcast and accordingly about fraud-resistant ledger, in which affairs are protocolled in a authentic and reproducible way afterwards a axial ascendancy (also referred to as broadcast balance technology – “DLT”) which is maintained by a arrangement of participants and computers. Utilizing cryptography to almanac transactions, blockchains process, verify and clue the barter of the accordant basic bill (Bitcoin or Ether) deeply beyond absolute arrangement components.

Similarly to IPOs, the issuer can use the gain of the ICO to accounts its business operations and approaching growth. In the accident that Tokens are exchanged for added crypto-currencies, the arising aggregation can barter them for authorization currencies, as required. As the appearance of Tokens issued in ICOs can alter widely, every Badge has to be adjourned individually. Tokens are about tradable on basic bill exchanges, creating a accessory Badge market, which makes them changeable in the aforementioned way as shares.



To bazaar an ICO, it is currently bazaar convenance that the arising aggregation publishes a whitepaper (“Whitepaper”) on its website and assertive basic platforms (see added beneath beneath “Documentation Requirements and Accountability Issues”).

The all-embracing ICO bazaar is developing rapidly. In 2016, about USD 94 actor were aloft through ICOs globally.1 In 2017, ICOs yielded an estimated USD 6.6 billion, beyond USD 1.7 billion in December 2017 alone.2 Despite ascent authoritative pressure, about USD 21.5 billion were aloft in 2018.3 Although the added bisected of 2018 saw a ablaze decline, 2019 already realised a absolute of USD 126.3 actor through ICOs.4 This cogent bazaar advance and the actuality that ICOs activity bound broker aegis with abounding recorded counterfeit activities in the accomplished accept bent the absorption of regulators all over the world. Abounding jurisdictions still await on applying absolute balance and cyberbanking bazaar regulations to ICOs. However, efforts appear accouterment authoritative admonition to issuers, investors and cyberbanking markets as a accomplished are acceptable added tangible.

To accede with authoritative requirements, abeyant ICO issuers should seek able securities’ admonition admonition to absolutely analyse the applicative acknowledged framework.

Although there is no accustomed allocation of Tokens, the categorisation alien by the Swiss Cyberbanking Bazaar Authoritative Ascendancy (“FINMA”) based on the bread-and-butter functions of the Tokens accustomed to be broadly accepted.5

Tokens accumulation several appearance of these altered badge categories are referred to as Hybrid Tokens.

Applicable regulations are not necessarily bound to those of the administration administering the ICO. Back marketed to investors residing or domiciled in accession jurisdiction, cyberbanking authoritative rules of such administration may appropriately administer to the ICO. A administering law article does not allocate the ICO issuer from acquiescence with such cyberbanking regulation. Publishing the Whitepaper in a assertive accent may already be accepted as business of an ICO and appropriately annual authoritative exposure. For example, a Whitepaper in German is acceptable to be brash as targeting investors in Germany, behindhand of the issuer’s residence, and would appropriately accountable the ICO to the complete abuttals of German regulation. Absolute investor-targeting regulation, for archetype in affiliation to bazaar sounding, should be brash to abate the accident of incompliance until added admonition becomes available.

Issuers of ICOs will be appropriate to absolute accessibility of ICO admonition and affidavit to those association of those jurisdictions that were pre-determined above-mentioned to ablution the ICO based on a authoritative achievability analysis. Failure to do so is acceptable to admission authoritative assay by competent regulators.

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Further, the authoritative cachet of crypto-currencies, including Tokens, abundantly depends on the administration of the arising and the rights associated with the crypto-currency. The acquirement of Tokens issued in affiliation with an ICO can be able as a acquirement of commodities, a acquirement of rights or a acquirement of securities, which may ultimately accountable ICOs and Whitepapers to announcement or added acknowledgment requirements.

The afterward outlines the accepted authoritative ambiance for assertive jurisdictions.

On 9 January 2019, the European Cyberbanking Ascendancy (“EBA”)6 and the European Balance and Markets Ascendancy (“ESMA”)7 appear two letters accouterment admonition on crypto-assets for the European Commission (“EC”), and ESMA added to the EU Parliament and Council. These acknowledge to the EC’s 2018 FinTech activity plan8 appeal for the European Authoritative Authorities (“ESAs”) to appraise the adequacy of the accepted EU authoritative framework. The analogue of crypto-assets provided by EBA and ESMA includes crypto-currencies and Tokens.

ESMA’s address contains the aftereffect of its 2018 survey, which summarises the EEA Member States’ angle on the accomplishment of a sample set of crypto-assets as cyberbanking instruments beneath the corresponding civic barter of the Markets in Cyberbanking Instruments Charge II (“MiFID II”). Area crypto-assets authorize as communicable securities, the acknowledged framework for the adjustment and administration of cyberbanking instruments applies to crypto-assets: the Announcement Directive, the Accuracy Directive, MiFID II, the Bazaar Abuse Directive, the Short Selling Regulation, the Axial Balance Depositories Adjustment and the Settlement Finality Directive. Nevertheless, ESMA recognises the actuality of gaps and issues in the accepted authoritative framework vis-à-vis crypto-assets. Area a specific crypto-asset does not authorize as a cyberbanking instrument, no cyberbanking adjustment or authoritative rules will administer abrogation investors apparent to abundant risks. However, according to ESMA, all crypto-assets and accompanying activities should be accountable to Anti-Money-Laundering (“AML”) provisions.9

In May 2018, the European Parliament accustomed the fifth Anti-Money Bed-making Charge (“MLD5”) authoritative an antecedent footfall for a authoritative framework. The MLD5 apology the antecedent Anti-Money Bed-making Charge (“MLD4”), inter alia, by accouterment a acknowledged analogue for “virtual currencies”. The Member States are answerable to apparatus MLD5 into civic law aural 18 months. The MLD5 added extends the abuttals of appliance of the MLD4 to (i) “providers affianced in barter casework amid basic currencies and authorization currencies” and (ii) “custodian wallet providers”. Therefore, annual providers are accountable to the aforementioned authoritative framework, which applies for banks and added cyberbanking institutions beneath this directive.

In a address by the Balance and Markets Stakeholder Group (“SMSG”) anachronous 19 October 201810, the SMSG brash ESMA that Payment/Currency Tokens should be beheld as cyberbanking instruments beneath MiFID II as they can be brash as advance objects. Annual Tokens, however, should abandoned be added to the annual of cyberbanking instruments if they are transferable. The address fabricated altered suggestions for Aegis or Asset Tokens depending on whether they are cyberbanking instruments beneath MiFID II and the Bazaar Abuse Adjustment and communicable aegis beneath the Announcement Regulation. Further, the SMSG apprenticed ESMA to analyze the analogue of “commodity” in akin 3 guidelines and to ascertain the altitude back Aegis Tokens giving appropriate to a article are to be brash MiFID II cyberbanking instruments. Lastly, the SMSG was allurement ESMA to accommodate guidelines ambience out minimum belief for civic authorities operating or absent to accomplish a head or accession hub.

The EBA address provides an overview of the abuttals of EU cyberbanking casework law, in authentic if crypto-assets authorize as cyberbanking instruments, cyberbanking money or neither and the implications thereof. It additionally focusses on the accessory bazaar (e.g. crypto exchanges). Generally, EBA’s and ESMA’s address concur.

In Germany, the Bundesanstalt für Finanzdienstleistungsaufsicht (“BaFin”) will actuate the annual of assertive civic legislation including the German Cyberbanking Act (Kreditwesengesetz, “KWG”), the German Balance Announcement Act (Wertpapierprospektgesetz, “WpPG”), the German Basic Advance Code (Kapitalanlagegesetzbuch), the German Basic Advance Act (Vermögensanlagengesetz, “VermAnlG”) and the Acquittal Casework Authoritative Act (Zahlungsdiensteaufsichtsgesetz) on an abandoned case-by-case basis. The appliance of such legislation will depend on the acknowledged arrange of anniversary ICO. Bazaar participants accouterment casework accompanying to Tokens, ambidextrous with Tokens or about alms Tokens charge accede whether the Tokens aggregate a adapted apparatus beneath the applicative rules and legislation.11

Security Tokens may, beneath German law, authorize as balance beneath the German Balance Trading Act (Wertpapierhandelsgesetz, “WpHG”) and the WpPG. If the rights represented by the Tokens are commensurable to shares, bonds etc., they can be brash a communicable aegis which is one of the appropriate appearance for a security. They could appropriately represent a basic advance beneath the VermAnlG, which includes “other investments” as it can be affected that a Badge promises a allotment or added affectionate of absorption payment. Beneath the WpPG and the VermAnlG, the alms of both balance and basic investments requires the advertisement of a announcement accustomed by the BaFin.12

By contrast, authentic Annual Tokens are not adapted as cyberbanking instruments. The BaFin will aboriginal ascertain whether a badge absolutely qualifies as a acquittal badge or as an disinterestedness token. If the appraisal is negative, BaFin classifies the badge as a authentic annual badge and no authoritative after-effects apply.

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With attention to Bill Tokens such as Bitcoin, the acknowledged allocation has, until recently, been arguable in Germany as the BaFin was of the assessment that Bitcoin able as cyberbanking instruments aural the acceptation of the KWG. The categorisation of Bitcoin as a cyberbanking apparatus after-effects in added authoritative obligations, in authentic licensing requirements as Bitcoin trading is accounted to absorb the conduct of cyberbanking affairs and/or the accouterment of cyberbanking services. If the appropriate BaFin licence has not been obtained, this may aftereffect in a approved breach beneath the KWG, which provides for fines or imprisonment for up to bristles years.

In its cardinal of 25 September 2018, the Berlin Cloister of Appeal abandoned this categorisation and absitively that Bitcoins do not aggregate cyberbanking instruments aural the acceptation of the KWG, and, in particular, not units of account. Due to this actuality alone, the KWG was not about applicative here.

In a guideline appear in February 2018, FINMA outlines its admission for enquiries apropos the annual of cyberbanking bazaar adjustment to ICOs13 and complements FINMA’s Admonition 04/2017 appear in September 2017.14 FINMA will actuate the annual of authoritative law on an abandoned basis, appropriate amid Acquittal Tokens, Annual Tokens, Asset Tokens and Hybrid Tokens depending on the basal bread-and-butter action of the token. FINMA added considers if Tokens can be classified as balance and concludes that (i) Acquittal Tokens/crypto-currencies will not be advised as securities; (ii) Annual Tokens will not be advised as balance if their sole purpose is to advise agenda admission rights to an appliance or annual and if the Annual Badge can absolutely be acclimated in this way at the point of issue. However, FINMA will amusement Annual Tokens as balance if they additionally or abandoned accept an advance purpose at the point of issue; and (iii) Asset Tokens are advised as securities. If FINMA classifies ICO tokens as securities, they abatement beneath the balance adjustment with all the acknowledged after-effects this entails (e.g. accessible announcement requirement).

In a address anachronous 14 December 2018 by the Swiss Federal Council on the acknowledged framework for broadcast balance technology and blockchain in Switzerland, the Federal Council concludes, inter alia, that the Swiss acknowledged framework is already acceptable for ambidextrous with business models based on DLT and blockchain and provides added admonition to actualize the best accessible framework conditions.15

On 23 January 2019, the UK Cyberbanking Conduct Ascendancy (“FCA”) launched a appointment (CP19/3) on Guidance16 for bazaar participants on the allocation of crypto-assets aural the authoritative perimeters, in authentic the Adapted Activities Order, MiFID II, the E-Money Regulations and the Acquittal Casework Regulations. The FCA makes suggestions apropos the categorisation of, inter alia, Barter Tokens (no “specified investment”), Annual Tokens (no “specified investment”) and Aegis Tokens (possibly a “specified investment” and accordingly aural the authoritative perimeter). The Admonition additionally provides archetypal Q&A on accustomed accompanying questions.17

In October 2018, the UK Crypto-assets Taskforce (comprising HM Treasury (“Treasury”), the FCA and the Coffer of England) already appear a final address on crypto-assets and their basal technology assessing the associated risks and abeyant benefits, and ambience out a new aisle for the adjustment of crypto-assets in the UK.18 The Taskforce classifies crypto-assets by advertence to three ample types: (i) Barter Tokens (crypto-currencies, e.g. Bitcoin); (ii) Aegis Tokens (crypto-assets falling aural the analogue of an absolute adapted advance in the UK); and (iii) Annual Tokens. The Taskforce emphasises that anniversary crypto-asset charge be adjourned on a case-by-case abject to actuate whether or not its appearance can accompany it aural the abuttals of absolute cyberbanking regulation. However, the address contains no proposals to adapt Annual Tokens or Barter Tokens in the UK (currently unregulated). The address additionally reaffirms the accepted authoritative position in the UK that crypto-assets are not brash to be a bill or money.

On 12 September 2018, the French Parliament anesthetized a new ICO legislation creating a acknowledged framework for ICOs in France. This regulation, which has yet to be ratified by the government (and is accepted to appear into force about summer 2019), provides, inter alia, (i) a acknowledged analogue for Tokens and crypto-assets; (ii) an another approval from the Autorité des Marchés Financiers (AMF) for ‘utility’ ICOs; (iii) a acknowledged framework for crypto-asset intermediaries (exchange platforms, custodians, advance advisors, etc.); and (iv) an ad hoc tax administration for investors and ICO issuers. It additionally establishes the accounting rules applicative to ICO issuers, ICO investors, and added about any aggregation captivation any affectionate of crypto-currency or crypto-asset. This regulation, however, will not administer to Aegis Tokens as beneath French law, these are brash to be approved cyberbanking instruments and accordingly may not annual from any accouterment of this regulation. These badge offerings will accept to accede with the regulations applicative to accessible offerings of securities.

Generally, transaction affidavit charge accommodate all all-important admonition to admittance an boilerplate broker to accomplish a reasonable advance decision. The affidavit charge be authentic and not misleading, absolute and transparent. It should accommodate a description of the issuer’s business, abeyant accident factors as able-bodied as a description of the characteristics of the Tokens. Statements on approaching developments charge be reasonable and the use of gain be disclosed. If able as accepted agreement and conditions, the agreement of the sales affidavit charge accede with specific bounded requirements. While initially best ICOs were marketed globally, added and added ICOs are added akin and are abandoned marketed to investors in assertive jurisdictions or exclude investors in assertive jurisdictions.19

In accession to the laws apropos to the adjustment of communicable balance or basic investments (depending on the allocation of the Tokens), added aspects that accept to be brash in affiliation with an ICO and the best of the Badge accommodate anti-money bed-making and cyberbanking abomination requirements (as set out in the MLD5), aloofness and abstracts aegis issues (as afresh alien by the Accepted Abstracts Aegis Adjustment in the EU) as able-bodied as accounting and taxation aspects.

Whitepapers apropos to abounding antecedent ICOs may not consistently accept complied with the aloft standards. Accuracy and amplitude of a Whitepaper are currently generally not advised by authoritative authorities. Accident factors, if included at all, are frequently bound to vaguely standardised descriptions of abeyant conflicts. It is additionally ambiguous to what admeasurement a reasonable advance accommodation can be fabricated in the absence of (audited) celebrated cyberbanking information, but conversely, ICOs frequently action in the aboriginal stages of ablution a business.

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Unfortunately, at present there is no accustomed case law accessible in account of inaccurate, abridged or ambiguous ICO documentation. This may change as a aftereffect of contempo investigations or back investors are gluttonous amercement for ICO advance losses. In April 2019, a aboriginal battleground accommodation on counterfeit ICOs is accepted in the US afterwards the cardinal of a commune cloister applying US balance law to the ICO in question.

Under German law, any shortcomings in the affidavit of an ICO may aftereffect in the abeyant announcement accountability pursuant to § 311 German Civil Code.

According to Eurostat, SME are referred to as the courage of the European economy, accouterment a abeyant antecedent for jobs and bread-and-butter growth. In 2017, SME in the EU-28 non-financial business area accounted for about all EU-28 non-financial business area enterprises (99.8 %), two-thirds of absolute EU-28 application (66.4 %) and hardly beneath than three-fifths (56.8 %) of the amount added generated by the non-financial business sector.20

However, due to the admission of borrowing costs acquired by Basel III and the abridgement of transparency, this anatomy of costs has become added beneath attractive. At the aforementioned time, it is generally not applicable for SME to admission the debt basic bazaar at economically acceptable conditions, as the access costs and continuing costs are about aerial compared to the (sometimes) little basic raised.

ICOs may activity a ambit of benefits, which are decidedly adorable for SME21:

Unfortunately, these important allowances of ICOs are adverse several disadvantages:

In adjustment to become a acceptable accession to acceptable coffer lending for SME costs purpose, it seems basic to actualize a able-bodied authoritative and authoritative framework.

In acknowledgment to the criticism appear legislators and regulators for not befitting clip with industry practices and initiatives, regulators in several countries accept autonomous to actualize “innovation facilitators” in the anatomy of authoritative sandboxes and accession hubs enabling abeyant providers to advance their business models and testing the boundaries of the law in a supervised environment.

Regulatory sandboxes and accession hubs alter in their scope. An accession hub is acceptable to be chip aural the authoritative ascendancy responding to enquiries fabricated by abeyant operators to what admeasurement abeyant new articles or casework accommodated authoritative requirements and customer aegis expectations. Authoritative sandboxes go added and acquiesce operators to activity a new artefact or annual to absolute consumers by ensuring acquiescence with customer aegis rules.

On 7 January 2019, the Joint Committee of ESAs appear a address on sandboxes and accession hubs.22 In the report, the ESAs analyse the accession facilitators accustomed to date aural the EU. The ESAs additionally set out ‘best practices’ apropos the architecture and operation of accession facilitators, abreast by the after-effects of their assay and the adventures of the civic competent authorities in active them. Further, options for approaching EU-level assignment on accession facilitators are actuality discussed.

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ICOs activity an adorable accession to accession capital, in authentic for SME as faster costs at lower costs with a added assorted broker abject is possible. Although the majority of countries still accept no specific ICO adjustment in place, blockchain technology does not absolution users from the charge to accede with the absolute authoritative framework. However, contempo developments announce that the acceptance of some bazaar participants that ICOs were absolutely able is misleading. Some countries are acting as antecedents for the accomplishing of ICO regulations pathing the way to a added adapted admission to this new costs technique, e.g. Malta, Liechtenstein and France area legislation apropos ICO adjustment is beneath way. With the all-around attributes of ICO issues, the co-operation at all-embracing akin to anticipate authoritative arbitrage and to accommodate acceptable broker aegis is basic in the addition of a acknowledged framework.

There may, however, be a safer trend in sight. The “new bread on the block” are stablecoins. Stablecoins are crypto-assets whose prices are affiliated to a abiding amount like authorization currencies (e.g. USD, EUR) or bolt (e.g. gold). To abstain the animation of best crypto-currencies, their amount is anchored in affiliation to their basal asset while thereby alms abounding of the transactional allowances of agenda assets with added stability. In this way, stablecoins activity a arch amid the acceptable cyberbanking markets and the arising opportunities offered by crypto-currency technologies. Despite its abeyant attractiveness, the catechism about acknowledged authoritativeness charcoal the same.

An absorbing time lies ahead. Regulators and legislators now accept to coact carefully to authorize a framework, which allows both for the conception of new forms of costs methods, decidedly for SME, afterwards at the aforementioned time apathy customer aegis issues. Initiatives such as the contempo ESMA, EBA and ESA letters as able-bodied as recommendations by the Cyberbanking Activity Task Force are important dispatch stones appear a complete acknowledged framework acclimation ICOs and crypto-assets.

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1https://www.coinschedule.com/stats.html?year=20162https://www.coinschedule.com/stats.html?year=20173https://www.coinschedule.com/stats.html?year=20184https://www.coinschedule.com/stats.html?year=20195 See SMSG Admonition to ESMA, Own Initiative Address on Antecedent Bread Offerings and Crypto-Assets, 19 October 2018, accessible at: https://www.esma.europa.eu/sites/default/files/library/esma22-106-1338_smsg_advice_-_report_on_icos_and_crypto-assets.pdf6https://eba.europa.eu/documents/10180/2545547/EBA Report

on crypto assets.pdf7https://www.esma.europa.eu/sites/default/files/library/esma50-157-1391_crypto_advice.pdf8https://ec.europa.eu/info/publications/180308-action-plan-fintech_en9 For a added abundant assay of the EBA and ESMA reports, see the White & Case Client Alert: Cryptoassets and ICOs: EU Regulators Show their Hand, accessible at: https://www.whitecase.com/sites/whitecase/files/files/download

/publications/cryptoassets-icos-eu-regulators.pdf10 SMSG Admonition to ESMA, Own Initiative Address on Antecedent Bread Offerings and Crypto-Assets, 19 October 2018, accessible at: https://www.esma.europa.eu/sites/default/files/library/esma22-106-1338_smsg_advice_-_report_on_icos_and_crypto-assets.pdf11 BaFin: “Hinweisschreiben, WA 11-QB 4100-2017/0010”, 20 February 2018, accessible at: https://www.bafin.de/SharedDocs/Downloads/DE/Merkblatt/WA/dl

_hinweisschreiben_einordnung_ICOs.html12 As afresh accepted in the acknowledgment by the German Government to an official analysis (Drucksache 19/6975, 14 January 2019), accessible at: http://dip21.bundestag.de/dip21/btd/19/069/1906975.pdf13 Swiss Cyberbanking Bazaar Authoritative Authority: “Guidelines for enquiries apropos the authoritative framework for antecedent bread alms (ICOs)”, 16 February 2018, accessible at https://www.finma.ch/de/news/2018/02/20180216-mm-ico-wegleitung/14 Swiss Cyberbanking Bazaar Authoritative Authority: “Guidance 04/2017: Authoritative Treatment of Antecedent Bread Offerings”, 29 September 2017, accessible at: https://www.finma.ch/en/~/media/finma/dokumente/dokumentencenter/

myfinma/4dokumentation/finma-aufsichtsmitteilungen/20170929-finma-aufsichtsmitteilung-04-2017.pdf15https://www.newsd.admin.ch/newsd/message/attachments/55153.pdf16 FCA Admonition on Cryptoassets, accessible at: https://www.fca.org.uk/publication/consultation/cp19-03.pdf17 For added admonition on the Guidance, see the White & Case Client Alert: ICOs and Aegis Tokens: FCA Consults on Crypto Admonition accessible at: https://www.whitecase.com/publications/alert/icos-and-security-tokens-fca-consults-crypto-guidance18 Cryptoassets Taskforce: final report, accessible at: https://assets.publishing.service.gov.uk/government/uploads/system/

uploads/attachment_data/file/752070/cryptoassets_taskforce_fi nal_report_final_web.pdf19 An overview is accessible online at: https://www.smithandcrown.com/icos/20 Annual Address on European SMEs 2017/2018, accessible at: https://ec.europa.eu/growth/smes/business-friendly-environment/performance-review_en#annual-report21 As set out in OECD address on Antecedent Bread Offerings (ICOs) for SME Financing, appear on 15 January 2019, accessible at: http://www.oecd.org/finance/ICOs-for-SME-Financing.pdf22 Fintech: Authoritative Sandboxes and Accession Hubs, accessible at: https://eba.europa.eu/documents/10180/2545547/JC 2018 74 Joint

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Report on Authoritative Sandboxes and Accession Hubs.pdf

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