Blockchain Taskforce makes recommendations to strengthen Switzerland as an international blockchain hub

At this year’s Blockchain Summit on 26 April 2018 in the heart of the well-known Crypto Valley in Zug, Federal Councilor Johann Schneider-Ammann received a white paper on the topic “Strengthening Switzerland as a Blockchain Hub” and a position paper on the legal classification of ICOs. The publications were written by the Blockchain Taskforce, a group of around 50 personalities from politics, business and science. The documents contain a series of recommendations on how laws and framework conditions in the Blockchain and ICO field should be adapted in order to strengthen the Swiss Blockchain/ICO location in the best possible way.

The Blockchain Task Force concludes, among other things, that

  • for practical and economical reasons, the possibility of digital transfer of ownership of tokens should already be possible to date applying a broad interpretation of the existing law. Alternatively, a change in the law is proposed;
  • the current Anti-Money Laundering Act does not need to be amended. It is sufficient to consistently apply the existing law to the new technology;
  •  a so-called “sandbox” (an experimental space with lower regulatory requirements) for blockchain start-up companies should be created (similar to the existing Fintech sandbox);
  •  it is extremely important that Blockchain companies can open a bank account without further ado. This is currently only difficult to achieve;
  • new standards (so-called “best practice rules”) for the issuance of tokens and transactions on the blockchain are to be introduced. FINMA should define when tokens should be regarded as securities within the meaning of the Financial Market Infrastructure Act or as deposits within the meaning of the Swiss Banking Act;
  • general criteria for the term “token” should be established. With a so-called “Token Map” a group of criteria and terms shall be proposed, which can be used in connection with the design and evaluation of blockchain-based projects, which issue their own tokens.

The Blockchain Task Force also announced that it would continue its activities but change its name to Swiss Blockchain Institute. An ICO will be launched to finance future activities of the institute.

Further information at:

Starkung des Blockchain-Standorts Schweiz

Positionspapier zur rechtlichen Einordnung von ICOs

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Guenther Dobrauz
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Blockchain: Key challenges to get your solution GDPR compliant

What is the General Data Protection Regulation (GDPR) about?

The General Data Protection Regulation (GDPR) (EU) 2016/679 harmonises personal data protection law on the territory of the European Union (EU). It stipulates rules on data processing and on the transfer of personal data in and outside the EU. Coming into effect on 25 May 2018, it will replace the 1995 Data Protection Directive (Directive 95/46/EC). Non-compliance with the GDPR may lead under some circumstances to severe fines of up to 4% of worldwide annual turnover.

What are the key challenges the GDPR triggers for blockchain?

Depending on the blockchain-based activity the GDPR raises considerable legal concerns. Among the most relevant ones relate to the processing principles of data minimisation and storage limitation. Some key challenges relate specifically to blockchain features, such as:

    • Immutability of transactions
    • Replication
    • Encryption
    • Data controllers and data processors

Read the full article

 

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Dr. Guenther Dobrauz
Leader|PwC Legal Switzerland, Zurich
+41 58 792 14 97
guenther.dobrauz@ch.pwc.com

Susanne Hofmann
Director|PwC Legal Switzerland, Zurich
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susanne.hofmann@ch.pwc.com

Dr. Idir Laurent Khiar
Manager|PwC Legal Switzerland, Zurich
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Orkan Sahin
Assistant Manager|PwC Legal Switzerland, Zurich
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Initial coin offerings (ICOs) in Liechtenstein

At a glance
• An initial coin offering (ICO) or a token sale is when a company sells a predefined number of digital tokens to the public in a limited period of time.
• The ICO market has grown very rapidly in recent months and has been a new avenue for blockchain-based start-ups and projects to get the funding needed to launch their projects.
• In September 2017, the Financial Market Authority Liechtenstein (FMA) published a fact sheet on ICOs which stated that depending on their specifications, tokens may constitute financial instruments subject to financial market law.

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In detail
1. What are ICOs?
Initial coin offering (“ICO”, also referred to as token generation event, token launch or token offering) is a term describing a limited period in which a company sells a predefined number of digital tokens (crypto coins) to the public, typically in exchange for major crypto-currencies (as of today, mostly Bitcoin and Ether). On the side of the token issuer, the collected funds are typically used to finance a project (e.g. the building of a software/ blockchain-based platform). In exchange for the financing, the investor receives a token which may be connected with the right to receive a dividend, a voting right, a licence, a property right or a right to participate in the future performance of the issuer. Usually, tokens are tradable on cryptocurrency exchanges.

2. Token characteristics 
Tokens (coins) can have different functions, which triggers the way in which we treat them from a legal and regulatory perspective. Four main forms exist to date (including many hybrid combinations).

  • Security token
    Tokens with a security character (e.g. debt, equity or derivatives) with an income generating component and potential rights vis-à-vis the issuer (e.g. governance, participation, ownership).
  • Digital currency
    Tokens with an attributed value. They can be used to buy and sell goods and services and can be used to store value (although they can be very volatile).
  • Asset-backed token
    Tokens that provide underlying exposure to real world assets (e.g. gold, diamond, securities, cash, real estate, etc.)
  • Utility token
    Tokens with a utility character provide access to a blockchain-based platform, product or service. They are not primarily designed as a means of an investment.

3. What are the characteristics of an ICO?
In general, an ICO has the following structure:

  • Publication of a white paper describing a project or product as well as the funding via ICO. The white paper also describes the intended use of the tokens to be issued. Software and the technical specifications are published on open source platforms like GitHub.
  • A smart contract is set up, usually based on the Ethereum blockchain. The smart contract is needed to generate and distribute the tokens later on.
  • During a fixed time period, cryptocurrency payments (usually Ether or Bitcoin) are accepted by way of the smart contract.
  • Using the public key for those payments (similar to a digital account number), the smart contract generates the new tokens and makes them available to investors.
  • The tokens may be stored by third parties (wallet providers) and/or made tradable with the help of cryptocurrency trading platforms.
  • Once the funded project is complete, the investor can sell the tokens or exchange them for services.

4. What are the key challenges of an ICO?
Regulators worldwide are starting to look into ICOs, but only few have actually taken action (e.g. China, USA, Singapore). It is expected that the US SEC/EU ESMA and other major regulators will soon regulate the ICO space, particularly from a capital markets, tax and KYC/AML perspective. A further challenge is that many ICOs still lack proper cybersecurity, which can represent a major threat for investors. As most ICOs raise money in the form of cryptocurrencies, high volume transactions provide an attractive target for criminals. Besides ICOs, several cryptocurrency wallets (where tokens/coins get stored) have been hacked recently.

5. How does Liechtenstein treat ICOs from a legal/regulatory
perspective?
In September 2017, the Financial Market Authority Liechtenstein (FMA) published a fact sheet on ICOs which stated that depending on their specifications, tokens may constitute financial instruments subject to financial market law. This may include tokens that have characteristics of equity securities or other investments. In principle, activities relating to financial instruments are subject to licensing by the FMA on the basis of special legislation and may require publication of a prospectus. In all cases, the specific design and de facto function of the tokens are decisive. Any AML/KYC obligations also depend on the specific design. Connecting factors for FMA jurisdiction exist, for instance, if a company’s registered office or branch is in Liechtenstein and/or if relevant activities are pursued on the Liechtenstein market.

6. How is an ICO taxed in Liechtenstein?
Liechtenstein offers a favourable tax system with modest tax rates for issuers of tokens (typically using a foundation structure or a special purpose vehicle), for ICO entrepreneurs and for investors. Careful structuring of the ICO is necessary to manage potential issuance stamp tax consequences (in case of issuance of equity tokens) as well as VAT and corporate income tax consequences (in case of issuance of utility tokens). Since there is no gift tax in Liechtenstein, employing a charitable foundation structure is an option worth considering in detail. Taxation of ICO entrepreneurs and investors domiciled in Liechtenstein depends on the categorisation of a specific token. Capital gains on digital currency tokens should generally be exempt from income tax (due to taxation of notional income from wealth instead of effective investment income).

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Guenther Dobrauz
Partner, Leader of PwC Legal Switzerland
Office: +41 58 792 14 97
Email: guenther.dobrauz@pwc.com

Martin Meyer
Director, Leader of Financial and Private Wealth Services PwC
Liechtenstein
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Email: martin.meyer@ch.pwc.com

Mark Schrackmann
Assistant Manager, PwC Legal Switzerland
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Orkan Sahin
Assistant Manager, PwC Legal Switzerland
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FinTech Action Plan – European Commission launches measures for a more competitive and innovative financial marketplace

For many financial services companies, financial technology (short “FinTech”) and technological innovation in general offer tremendous opportunities in terms of access to finance, operational efficiency, cost savings and competition. On March 8th 2018 the European Commission presented an action plan with a total of 23 measures to make better use of the opportunities offered by technological innovations in the financial services sector. The EU wants to become a global hub for FinTech in the future.

The Action Plan has three main objectives:

  • to support innovative business models to scale up across the single market;
  • to encourage the uptake of new technologies in the financial sector; and
  • to increase cybersecurity and the integrity of the financial system.

The FinTech Action Plan

In order to achieve the above mentioned objectives, the following measures are planned, among others:

  • The Commission will operate a FinTech laboratory in which European and national authorities will be able to collaborate with technology providers in a neutral environment.
  • Continuation of the already opened EU Blockchain Observatory and Forum. The Forum will report on the opportunities and challenges of crypto assets later in 2018 and is already working on a comprehensive study of distributed ledger and blockchain technologies.
  • The use of innovative technologies to interconnect national databases is intended to promote the digitization of information published by listed companies in Europe. In the future, this will enable investors to access essential information in order to make their investment decisions easier.
  • In order to improve the exchange of information on cyber security, the Commission will organise regular workshops.
  • The Commission will present a best practice guide on regulatory sandboxes based on guidance from the European Supervisory Authorities. A sandbox is a safe and controlled space where FinTech companies can test innovations in the market, with or without regulatory relief.

Regulation on Crowdfunding

In the field of crowdfunding, the European Commission has put forward a comprehensive proposal for a regulation which will create a European legal framework for this form of financing for the first time. The European Commission wants to make it easier for start-ups and small businesses to raise funds from investors via the internet. Due to different regulations, it is currently difficult for platforms to expand into other EU countries. Crowdfunding should therefore be subject to uniform rules in the future and the ownership of the license of one country should be sufficient to operate the respective platform throughout Europe.

In contrast, investors should be protected by clear rules on disclosure of information, governance and risk management rules and a coherent approach to the oversight of crowdfunding platforms.

The EU member states and the European Parliament still have to approve the proposal.

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Legal FS Regulatory & Compliance Services
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Legal FS Regulatory and Compliance Services
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SEC issues statement reminding virtual exchanges to register Also warns other parties to transactions

US regulators are catching-up
Last night’s statement from the SEC is another in a line of sequentially increasing announcements from US regulatory and tax authorities showing that after several years of a wait-and-see posture, the US is now moving to catch-up enforcement of activities in the virtual marketplace.

SEC statement of 7 March 2018 regarding virtual exchanges
The SEC’s Divisions of Enforcement and Trading and Markets has issued a statement stating that online trading platforms trading virtual assets that qualify as securities under US securities law must either (1) register with the SEC as an exchange and meet the regulatory requirements of such status, or (2) qualify for an explicit exemption.

The statement addresses parties other than exchanges
Platforms that offer digital wallet services may also need to register with the SEC and meet the regulatory requirements of such status. Finally, other market participants such as promoters, broker-dealers, transfer agents, and clearing agencies may also have a registration requirement.

Coming enforcement efforts
Although not expressly mentioned in the statement, this is another step in the SEC and other US regulatory and tax authorities signalling that they intend to regulate the virtual assets world as aggressively as they do the traditional financial one. The statement of 8 March comes on the heels of highly publicized enforcement actions by the SEC and the launch of investigations by the IRS. This activity will only increase from now on.

Jurisdictional considerations
What the statement does not explain is when an online activity falls under the jurisdiction of the SEC as a geographical matter (as opposed to purely a question of subject matter jurisdiction). Exceptions are provided for under US law and the SEC regulations for parties that are not US Persons. Here, unlike under the US tax system, US Persons are usually limited to people or entities present in the US (there are a few exemptions to this rule). The SEC has not expressly stated that this general physical presence principle also applies to virtual currency activities, so any forthcoming US regulations could prove challenging in navigating what crypto activity does and does not fall under US jurisdiction.

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Günther Dobrauz 
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Director, PwC Legal Switzerland
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Thomas Plank
US Lawyer & Senior Manager, Financial Services Tax
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EMIR II: The European Parliament’s (preliminary) answer to EMIR as we know it

EMIR II brings with it many simplifications for market participants, not just in the EU/EEA, but globally. The reporting duty being simplified will noticeably reduce the burden, particularly for non-financial counterparties.

Moreover, financial counterparties themselves can also look forward to benefits: the introduction of a small financial counterparty category will limit the scope of the clearing obligation, while intra-group transactions with non-financial counterparties will be fully exempt from the reporting obligation. The current exemption for pension schemes will be continued for at least another three years.

Only Securitisation Special Purpose Entities and Alternative Investment Funds registered under national law in the European Union are expected to be negatively impacted by EMIR II.

Read more

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Guenther Dobrauz
Partner, Leader PwC Legal Services Switzerland
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Senior Manager | PwC Legal Services Switzerland
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Consultant | PwC Legal Services Switzerland
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FINMA publishes Initial Coin Offering (ICO) guidelines

In its media release of 16 February 2018 the Swiss Financial Market Supervisory Authority FINMA published its long-awaited guidance on Initial Coin Offerings (ICO) which defines the minimum information required and principles for requests for negative clearance.

An ICO is a digital form of public fund-raising for entrepreneurial purposes. Blockchain-based “coins” or “tokens” are sold in exchange for cryptocurrencies (e. g. Bitcoin) or FIAT currencies. The token represents a certain value or service that the issuer defines prior to the ICO.

In its media release of 29 September 2017 FINMA already acknowledged the innovative potential of this technology and pointed out to intersections between ICOs and the applicable financial market laws. In its new guidance FINMA rightly points out that generalized statements with respect to the applicability of financial market laws is not possible due to the variety of tokens and ICOs. Instead, every ICO must be assessed individually on a case-by-case basis.

Types of token

FINMA basically distinguishes between three different types of tokens (although hybrid forms are possible):

  • Payment tokens: These are considered standard crypto currencies. They can be used as means of payment for the purchase of goods or services as well as for the transfer of money and values. They are not associated with any other functions or projects.
  •  Utility tokens: They provide access to a blockchain-based applications or services.
  • Investment tokens: These tokens represent assets (such as shares of companies, revenues or entitlements to dividends or interest payments). Depending on its design, this type of token is similar to a share, bond or derivative financial instrument.

Legal assessment

FINMA came to the conclusion that it is particularly the Anti-Money Laundering and securities regulations that are concerned with respect to ICOs. Conversely, the Banking Act (“BA”) and the Collective Investment Schemes Act (“CISA”) are typically not concerned.

Based on the functionality of the various tokens FINMA makes the following legal considerations with respect to ICOs:

  • Payment ICOs: Payment tokens fall within the scope of the Anti-Money Laundering Act (“AMLA”) but do not qualify as securities under the Financial Markets Infrastructure Act (“FMIA”) and the Securities Trading and Exchange Act (“SESTA”).
  •  Utility ICOs: Utility tokens are basically not qualified as securities provided that they are intended to provide access digitally to an application or service and may be used in this capacity at the moment of issuance. Conversely, if a utility token is also used for investment purposes it is qualified as security.
  •  Asset ICOs: Asset tokens are treated as securities by FINMA.

Combinations of the various types are also possible.

FINMA recognizes the innovation potential of ICOs and the block chain technology but also highlights risks that result for investors.

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Günther Dobrauz
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Legal FS Regulatory & Compliance Services
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Legal, FS Regulatory & Compliance Services
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FINMA revises circular on video and online identification

On 18 March 2016, the Swiss Financial Supervisory Authority FINMA brought into force the circular 2016/7 “Video and online identification”. Since then, financial intermediaries have been able to identify new clients digitally, in addition to face-to-face meetings or the opening of a client relationship by correspondence.

In its media release of 13 February 2018, FINMA announced that due diligence obligations in the area of digital client on-boarding are being adapted to technological developments. The draft of the partially revised circular includes the following innovations in particular with regard to the digital identification of new clients:

Video identification

  • In order to ensure secure identification and make the use of counterfeit ID cards more difficult, financial intermediaries should now check at least three randomly selected optical security features of the ID documents (e. g. holograms, laser-tilt images, security thread, micro text, etc.);
  • The formal characteristics (e. g. layout, orthography, font, etc.) are to be compared with references from an identity card database;
  • The verification of the contracting party in the identity process using a one-time password (TAN) will no longer be required;
  • The identification process should now be allowed to continue even if there are indications of increased risks. However, the business relationship shall only be established after additional clarification and approval of a superior person/ management.

Online identification

  • Financial intermediaries should be encouraged to obtain a photograph from all relevant pages of the identification documents. Similar to video identification, the comparison with an ID card database should also be required for the online identification;
  • As an additional safety element, a liveness detection is required;
  • A money transfer from a bank in Switzerland shall no longer be a mandatory requirement. Under certain conditions, money transfers from banks in Liechtenstein or a member state of the Financial Action Task Force on Money Laundering (FATF) should also be sufficient.

FINMA holds a hearing until 28 March 2018. As soon as the revised circular will enter into force, financial intermediaries are required to adapt their video and online identification process within 6 months.

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Head Banking
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Legal FS Regulatory & Compliance Services
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Manager
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UPDATE: FinSA and FinIA: Commission for economy and taxes concluded its debation

The Commission for economy and taxes (WAK-S) concluded the debation relating to the Financial Services Act (FinSA) and the Financial Institutions Act (FinIA). This information has been released in the press today.

Thereby the WAK-S endorsed almost all proposals made by the National Council (Nationalrat). In particular, WAK-S has unanimously approved the possibility for the early entry into force of the Fintech provisions, and has also largely agreed with the National Council on the material provisions relating to Fintech. Thus, there is a good chance that the Banking Act will create a new license category for enterprises that accept public deposits of up to 100 million francs without investing or paying interest. For the new category of companies, simplified approval and operating requirements in the areas of accounting, auditing and deposit securities are to be applied.

However, the following outlines the most significant amendments and changes made to the resolution of the National Council:

  • As opposed to the proposal made by the National Council, WAK-S resolved that the threshold for the obligation to publish a prospectus for public offers of securities shall be increase from 2.5 million francs to 8 million francs.
  • Regarding the „door-to-door selling” (Haustürgeschäft) which is stated in the Swiss Code of obligations, the WAK-S endorsed by the majority to the proposal made by the National Council that the door-to-door selling of banking and financial services shall be exempted. However, the exception shall only be applicable to offers which have been made to existent clients of the financial institution or the bank.
  • The grand-fathering clause which is stipulated in the FinIA shall not be cancelled according to the WAK-S, as opposed to the proposal made by the National Council.
  • Regarding the financial market supervisory act, as opposed to the proposal made by the National Council, the WAK-S resolved that also persons and entities holding a qualified or substantial participation in a supervised institute shall provide the supervisory organization with all information and documents necessary for the performance of its duties.

The Council of States will now take over and could already be debating the topics in its spring 2018 session. Subsequently, the Commission for economy and taxes (WAK-N) as well as the National Council will deliberate, so that the bill has to pass the final hurdle before becoming enacted.

The document regarding comparison of the resolutions of the WAK-S is now available under the following Link.

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Dr. Guenther Dobrauz
Partner
Leader PwC Legal Switzerland
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guenther.dobrauz@ch.pwc.com

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Head Banking
Director
Legal FS Regulatory & Compliance Services
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Dr. Jean-Claude Spillmann
Head Wealth Management
Senior Manager
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Claudia Thalmann
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MIFID II requirements for direct electronic access (DEA)

Direct electronic access (“DEA”) enables a person to access a trading venue directly, using the trading code of an investment firm to do so, or directly placing an order with the Automated Order Routing (“AOR”) of the investment firm. This gives the client full control of the exact fraction of a second in which the order is placed and the lifetime of the order, as well as discretion as to which broker or trading venue the order is placed with.

Such discretion clashes with the objectives of MiFID II, which aims at increasing market transparency and oversight functions. Therefore, the regulation mandates the investment firm providing DEA to monitor the client closely.

Download full article

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Dr. iur. Guenther Dobrauz
MBA | Partner, Leader PwC Legal Services Switzerland
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Michael Taschner
Senior Manager | PwC Legal Services Switzerland
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Yari A. Iannelli
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Dr. iur. Alexandra G. Balmer
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Email: alexandra.balmer@ch.pwc.com