Autor Cointelegraph By Thibault Verbiest

European ‘MiCA’ regulation on digital assets: Where do we stand?

European ‘MiCA’ regulation on digital assets: Where do we stand?

Uverejnil používateľ | mar 19, 2022 |

The proposed European Union Regulation on Markets in Crypto Assets, or MiCA, (hereinafter the “regulation”) was put to a vote in the European Union Parliament’s Committee on Economic and Monetary Affairs on March 14, 2022, and in the end, the proposed amendment to ban or restrict proof-of-work-based crypto assets, which would have effectively resulted in a ban on Bitcoin (BTC), was rejected.The question of how crypto assets will be assessed from an environmental regulation perspective remains, however, with the Member of the European Parliament in charge of the text indicating that crypto assets will be included, like all other financial products, in the area of the union’s taxonomy (the process of classifying economic activities that have a favorable impact on the environment), without specifying the treatment of these assets in view of this taxonomy.The proposed regulation is part of the digital finance package that also includes a proposal for a pilot scheme for market infrastructures based on distributed ledger technology (DLT) of interest to the security token sector, adopted by the Parliament’s Economic and Monetary Affairs Committee in January this year and due to come into force by the end of 2022.The EU Commission has been considering several options for regulating the crypto asset sector. It finally chose the option of full harmonization within the EU of the rules applicable to issuers and service providers in crypto assets, with an EU passport, over the option of an opt-in regime to obtain the EU passport with the application of national regimes. For stablecoins, the Commission has favored a tailor-made legislative regime combined with regulation under the E-Money Directive. Related: Europe awaits implementation of regulatory framework for crypto assetsLet us take stock of the main provisions of the MiCA Regulation, which, after the trialogue among the Council, the Parliament and the Commission following the vote on March 14, should also enter into force before the end of the year and which pursues four objectives: legal certainty, support for innovation, consumer and investor protection and market integrity, and financial stability.In addition to determining the competent authorities and their administrative sanctioning powers, as well as the anti-market abuse rules, the main provisions of the Regulation relate to the purpose and scope of the Regulation (I), the rules applicable to the issuance of utility crypto assets (II), asset-referenced tokens (III), electronic money crypto assets (IV), and the rules applicable to crypto asset service providers (V).I. Purpose and scope of the regulationThe purpose of the regulation is to establish rules concerning:Transparency and disclosure requirements for the issuance and admission to trading of crypto assets.The authorization and supervision of crypto asset service providers, issuers of asset-based tokens and issuers of electronic money tokens. The operation, organization and governance of asset-based token issuers, electronic money token issuers and crypto asset service providers.Consumer protection rules for the issuance, trading, exchange and custody of crypto-assets.Measures to prevent market abuse in order to ensure the integrity of the crypto-asset markets.The regulation applies to persons in the EU who issue crypto assets or provide services relating to crypto assets. The Regulation does not apply to:rypto assets that are financial instruments (equity securities issued by companies with shares, debt securities, units or shares in collective investment undertakings and financial futures contracts) or electronic money except where the latter qualifies as electronic money tokens under the Regulation.ertain entities or persons, such as the European Central Bank and the national central banks of the member states, insurance undertakings, a liquidator or administrator acting in insolvency proceedings, persons providing crypto asset services exclusively for their parent undertaking, their subsidiaries or other subsidiaries of their parent undertaking, the European Investment Bank, the European Investment Bank and public international organizations. Authorized credit institutions and investment firms will only be subject to certain provisions of the Regulation or will have the provisions governing them adapted.Related: Consolidation and centralization: How Europe’s new AML regulation will affect cryptoII. Rules applicable to the issuance of crypto utilitiesThis category, which the Regulation calls “crypto-assets other than tokens referring to assets or electronic money tokens,” corresponds to crypto assets intended to provide digital access to a good or service, available on the DLT system, and which are only accepted by the issuer of this token (“utility tokens”). These “utility tokens” have a non-financial purpose related to the operation of a digital platform and digital services and should be considered as a special type of crypto asset. These may include cryptocurrencies such as Bitcoin, Ether (ETH) or Tezos (XTZ).The Regulation prohibits offering to the public or seeking admission to trading on a trading venue crypto assets unless the issuer is a legal entity and a white paper complying with the Regulation has been prepared, notified to the competent authority and published.Rules in terms of fair, honest and professional conduct and communications are provided for, as well as in terms of managing conflicts of interest and compliance with protocol security standards.The obligation to produce a white paper does not apply when crypto assets are offered free of charge (which is not the case when buyers provide personal data or when the issuer receives payment of third-party fees, commissions or other benefits); are automatically created by mining or transaction validation; when they are unique and nonfungible (nonfungible tokens are, therefore, excluded from the obligation to publish a white paper); offered to fewer than 150 persons per member state; the amount of the offer does not exceed 1 million euro over a period of 12 months; or when the offer is reserved solely for qualified investors.It should also be noted that the issuer of crypto assets must offer a right of withdrawal to the consumer, which can be exercised over a period of 14 calendar days.Related: Inflation spikes in Europe: What do Bitcoiners, politicians and financial experts think?III. Rules applicable to the issuance of asset-referenced tokens This category of crypto assets consists of tokens that aim to maintain a stable value by referring to several legal tender currencies, one or more commodities, one or more crypto assets, or a basket of these assets. By stabilizing their value, these asset-based tokens are often intended to be used by their holders as a means of payment for the acquisition of goods or services and as a store of value.An issuer wishing to offer or apply for admission to trading on a trading venue of asset tokens is required to obtain authorization from the competent authority of its home member state unless the average amount outstanding of the asset tokens does not exceed 5 million euro over a period of 12 months, or the offer is intended only for qualified investors.The authorization gives access to the European passport. A white paper must be prepared.Such an issuer is subject to a number of obligations, including those relating to marketing communications, conflicts of interest and governance: 350,000 or 2% of average reserve assets, whichever is higher.These reserve assets must be prudently and efficiently managed, segregated from the issuer’s assets and entrusted to credit institutions or crypto asset service providers. These reserve assets may only be partially invested in highly liquid and low-risk financial instruments.Furthermore, interest payments to holders of such tokens are prohibited.Specific rules are provided for acquisitions of issuers of tokens referring to assets, including the obligation to notify the competent authority of the proposed acquisition, which may object to the acquisition. Finally, there are additional obligations for issuers whose tokens refer to assets that are material. The European Banking Authority shall determine what tokens are material, for example, in view of the market capitalization of the tokens (such determination may also be requested voluntarily by the issuer).Related: Are NFTs an animal to be regulated? A European approach to decentralization, Part 1IV. Rules applicable to the issuance of crypto assets of electronic money This third category corresponds to crypto assets intended primarily as a means of payment with the aim of stabilizing their value by reference to a single fiat currency. Like e-money, these crypto assets are electronic substitutes for coins and banknotes and are used to make payments. They differ from e-money in that holders of e-money always have a claim on the e-money institution and have the contractual right to demand repayment of the e-money held, at any time and at face value, in legal tender fiat currency, which is not necessarily the case for e-money tokens. The main obligation for the issuer of electronic money tokens is the authorization as a credit institution or as an electronic money institution within the meaning of Directive 2009/110/EC (hereinafter “Electronic Money Directive”), which it must obtain, as well as the publication of a white paper in accordance with the Regulation.Such authorization and publication of a white paper will not be required if the electronic money tokens can only be held by qualified investors or if the average outstanding amount of tokens over 12 months does not exceed 5 million euro (or such lower threshold as may be set by a member state).Holders of electronic money tokens have a claim on the issuer of the tokens. Electronic money tokens that do not confer a claim on all their holders are prohibited.By way of derogation from the Electronic Money Directive, no issuer of electronic money tokens or provider of crypto asset services shall grant interest to the holders of such tokens.Specific rules are provided for electronic money tokens of significant importance.Related: How should DeFi be regulated? A European approach to decentralizationV. Rules applicable to providers of crypto asset services Crypto asset services shall only be provided by legal persons who have their registered office in a member state of the union and who have been authorized as crypto asset service providers.Authorization as a crypto asset service provider will be valid throughout the union and must enable crypto asset service providers to provide throughout the union the services for which they have been authorized, either under the right of establishment, including through a branch or under the freedom to provide services.Crypto asset service providers will act honestly, fairly and professionally in the best interests of their clients and potential clients and will provide their clients with fair, clear and not misleading information, in particular in their commercial communications, which must be identified as such. Crypto asset service providers must warn their customers of the risks associated with the purchase of crypto assets. They must make their pricing policy available to the public by posting it in a prominent place on their website.A crypto asset service provider must at all times have in place prudential safeguards in an amount at least equal to the higher of the following two amounts:(a) The amount of the minimum ongoing capital requirement applicable to it, depending on the nature of the crypto asset services it provides, either:For the services of reception and transmission of orders on behalf of third parties, advice on crypto assets, execution of orders on crypto assets on behalf of third parties and placement of crypto-assets: 50,000 euros.For services of custody and administration of crypto assets on behalf of third parties: 125,000 euros.For services of operating a platform for trading crypto assets, exchanging crypto assets for fiat currency or for other crypto assets: 150,000 euros.(b) One-quarter of the previous year’s fixed overheads, which are recalculated annually.There are a number of specific obligations depending on the crypto asset service. An acquisition regime for crypto asset service providers is also provided.This article was co-authored by Thibault Verbiest and Jérémy Fluxman.The views, thoughts and opinions expressed here are the authors’ alone and do not necessarily reflect or represent the views and opinions of Cointelegraph.This article is for general information purposes and is not intended to be and should not be taken as legal advice.Thibault Verbiest, an attorney in Paris and Brussels since 1993, is a partner with Metalaw, where he heads the department dedicated to fintech, digital banking and crypto finance. He is the co-author of several books, including the first book on blockchain in French. He acts as an expert with the European Blockchain Observatory and Forum and the World Bank. Thibault is also an entrepreneur, as he co-founded PayFoot. In 2020, he became the chairman of the IOUR Foundation, a public utility foundation aimed at promoting the adoption of a new internet, merging TCP/IP and blockchain.Jérémy Fluxman has been an associate at international law firms in Paris and Luxembourg in the fields of private equity and investment funds, as well as at a Monaco law firm since 2017. He holds a Master II in international business law and is currently an associate at the Metalaw firm in Paris, France where he advises on fintech, blockchain and crypto finance.

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Are NFTs an animal to be regulated? A European approach to decentralization, Part 1

Are NFTs an animal to be regulated? A European approach to decentralization, Part 1

Uverejnil používateľ | feb 6, 2022 |

Nonfungible tokens (NFTs) are constantly in the news. NFT platforms are springing up like mushrooms and champions are emerging, such as OpenSea. It is a real platform economy that is emerging, like those in which YouTube or Booking.com gained a foothold. But it is a very young economy — one that is struggling to understand the legal issues that apply to it.Regulators are starting to take an interest in the subject, and there is risk of a backlash if the industry does not regulate itself quickly. And, as always, the first blows are expected east of the Atlantic.In this first article devoted to the legal framework of NFTs, we will focus on the application of the digital asset regime and financial law to NFTs in France. In a second article, we will come back to the issues of liability and copyright.Related: Nonfungible tokens from a legal perspectiveA digital asset?In France, the definition of digital assets includes two types of tokens. On the one hand are utility tokens, i.e., all intangible assets representing, in digital form, one or more rights, which can be issued, recorded, stored or transferred by means of a shared electronic recording device allowing the owner of the asset in question to be identified, directly or indirectly.NFTs are intangible assets that can be issued, recorded, retained or transferred through shared electronic records.On the other hand are payment tokens, i.e., any digital representation of value that is not issued or guaranteed by a central bank or public authority, is not necessarily linked to a legal tender, and does not have the legal status of money, but is accepted by natural and legal persons as a medium of exchange that can be transferred, stored or exchanged electronically. Is an NFT a digital asset under French law?An NFT is acquired to obtain a property right, but it can also be acquired to claim the performance of one or more services related to that NFT.Furthermore, an NFT can be seen as a digital representation of value that is not issued or guaranteed by a central bank or public authority, that is not necessarily linked to a legal tender and does not have the legal status of money, and that can be stored or exchanged by electronic means. It follows that NFTs could be classified as digital assets, either as a token of use, a token of payment, or both.The consequence of classifying NFTs as digital assets would be twofold.Registration as a virtual asset service providerIf the platform issuing NFTs implements, in addition to its primary market, a secondary market on which users would benefit from: 1) a digital asset storage service or access to digital assets for the benefit of a third party in order to hold, store or transfer these digital assets, and/or 2) a service of purchase or sale of digital assets in legal tender, and/or 3) a service of exchange of digital assets for other digital assets, and/or 4) the operation of a platform of trading of digital assets, then a compulsory registration as a digital asset service provider with France’s financial regulator, the Autorité des Marchés Financiers (AMF), is required. In addition, clients must be identified through a Know Your Customer. Our analysis is supported by the fact that NFTs are referred to as “crypto-assets” by the proposed European regulation, “Markets in Crypto-assets” (MiCA).Related: How should DeFi be regulated? A European approach to decentralizationThe Financial Action Task Force (FATF) has also issued an opinion on the assimilation of NFTs into “digital assets” in its famous recommendation of October 2021. It states that NFTs are “generally not considered [virtual assets].”However, like its approach to DeFi, FATF emphasizes that regulators should “consider the nature of the NFT and its function in practice, not the terminology or marketing terms used.” In particular, FATF argues that NFTs that “are used for payment or investment purposes” can be virtual assets.Related: FATF guidance on virtual assets: NFTs win, DeFi loses, rest remains unchangedAlthough the directive does not define “for investment purposes,” FATF likely intends to capture those who purchase NFTs with the intent to resell them later for a profit. While many buyers purchase NFTs because of their connection to the artist or work, a large portion of the industry buys them because of their potential to increase in value. In other words, many NFTs could qualify as digital assets to follow this interpretation.Application of the ICO regime?As soon as there is a public offering of digital assets (to more than 150 potential buyers) in France, the French ICO regime applies. The issuer is then subject to the following rules: The “simple” advertising of the token offering is allowed, but any canvassing would be prohibited as well as any “quasi canvassing,” except if the issuer has obtained the AMF visa.This is a delicate point here because the NFT issuer could not “invite” French residents to register on its site without violating the law. It would then be required to never target “French” groups or communities.However, we do not believe that the ICO regime is applicable to NFTs, because this regime is designed to regulate a fundraising operation and protect the investor. Certain provisions of the law are incompatible with an NFT offer (i.e., offer limited to 6 months, sequestration of funds during the ICO, etc.).This is the spirit of the proposed MiCA regulation, which considers NFTs as digital assets by default, but excludes them from certain obligations specific to ICOs (publication and notification of a white paper).Anti-money laundering obligations and KYC?We have already noted the risk of qualifying as a virtual asset service provider (VASP), which would entail a KYC obligation (from 1 euro of transaction). In addition, persons acting as intermediaries in the art trade, including when it is carried out by art galleries, when the value of the transaction is equal to or greater than 10,000 euros, are subject to an obligation to apply due diligence measures based on the assessment of the risks presented by their activities in terms of money laundering and terrorist financing.Related: NFTs and compliance: Why we need to be having this conversationIn short, all NFT platforms, which are linked to digital works of art, should implement KYC procedures even if they do not qualify as digital assets, which today is far from being the case.In the United States?We know that the approach in the United States is different than in Europe because the U.S. Securities and Exchange Commission (by applying the famous “Howey Test”) qualifies tokens that would be seen as digital assets in Europe, as securities.The risk of the SEC classifying tokens as “securities” is therefore significant. The SEC has not yet come to a firm conclusion on the issue, but there have already been suggestions that some NFTs could be qualified as securities, especially when they are sold in a fractional manner.This article does not contain investment advice or recommendations. Every investment and trading move involves risk, and readers should conduct their own research when making a decision.The views, thoughts and opinions expressed here are the author’s alone and do not necessarily reflect or represent the views and opinions of Cointelegraph.Thibault Verbiest, an attorney in Paris and Brussels since 1993, is a partner with Metalaw, where he heads the department dedicated to fintech, digital banking and crypto finance. He is the co-author of several books, including the first book on blockchain in French. He acts as an expert with the European Blockchain Observatory and Forum and the World Bank. Thibault is also an entrepreneur, as he co-founded CopyrightCoins and Parabolic Digital. In 2020, he became chairman of the IOUR Foundation, a public utility foundation aimed at promoting the adoption of a new internet, merging TCP/IP and blockchain.

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How should DeFi be regulated? A European approach to decentralization

How should DeFi be regulated? A European approach to decentralization

Uverejnil používateľ | jan 22, 2022 |

Decentralized finance, known as DeFi, is a new use of blockchain technology that is growing rapidly, with over $237 billion in value locked up in DeFi projects as of January 2022. Regulators are aware of this phenomenon and are beginning to act to regulate it. In this article, we briefly review the fundamentals and risks of DeFi before presenting the regulatory context.The fundamentals of DeFiDeFi is a set of alternative financial systems based on the blockchain that allows for more advanced financial operations than the simple transfer of value, such as currency exchange, lending or borrowing, in a decentralized manner, i.e., directly between peers, without going through a financial intermediary (a centralized exchange, for example).Schematically, a protocol called a DApp (for decentralized application), such as Uniswap or Aave, is developed in open source code on a public blockchain such as Ethereum. This protocol is powered by smart contracts, i.e., contracts that are executed automatically when certain conditions are met. For example, on the Uniswap DApp, it is possible to exchange money between two cryptocurrencies in the Ethereum ecosystem, thanks to the smart contracts designed to perform this operation automatically.Users are incentivized to bring in liquidity, as they receive a portion of the transaction fee. As for lending and borrowing, smart contracts allow those who want to lend their funds to make them available to borrowers and borrowers to directly borrow the money made available by guaranteeing the loan with collateral (or not). The exchange and interest rates are determined by supply and demand and arbitrated between the DApps.The great particularity of DeFi protocols is that there is no centralized institution in charge of verifying and carrying out the transactions. All transactions are performed on the blockchain and are irreversible. Smart contracts replace the intermediary role of centralized financial institutions. The code of DeFi applications is open source, which allows users to verify the protocols, build on them and make copies.The risks of DeFiBlockchain gives more power to the individual. But with more power comes more responsibility. The risks DeFi are of several kinds: Technological risks. DeFi protocols are dependent on the blockchains on which they are built, and blockchains can experience attacks (known as “51% attacks”), bugs and network congestion problems that slow down transactions, making them more costly or even impossible. The DeFi protocols, themselves, are also the target of cyberattacks, such as the exploitation of a protocol-specific bug. Some attacks are at the intersection of technology and finance. These attacks are carried out through “flash loans.” These are loans of tokens without collateral that can then be used to influence the price of the tokens and make a profit, before quickly repaying the loan.Financial risks. The cryptocurrency market is very volatile and a rapid price drop can occur. Liquidity can run out if everyone withdraws their cryptocurrencies from liquidity pools at the same time (a “bank run” scenario). Some malicious developers of DeFi protocols have “back doors” that allow them to appropriate the tokens locked in the smart contracts and thus steal from users (this phenomenon is called “rug-pull”).Regulatory risks. Regulatory risks are even greater because the reach of DeFi is global, peer-to-peer transactions are generally anonymous, and there are no identified intermediaries (most often). As we will see below, two topics are particularly important for the regulator: the fight against money laundering and terrorist financing, on the one hand, and consumer protection, on the other.The FATF “test”: Truly decentralized?As of Oct. 28, 2021, the Financial Action Task Force (FATF) issued its latest guidance on digital assets. This international organization sought to define rules for identifying responsible actors in DeFi projects by proposing a test to determine whether DeFi operators should be subject to the Virtual Asset Service Provider or “VASP” regime. This regime imposes, among other things, Anti-Money Laundering (AML) and Counter-Terrorist Financing (CFT) obligations.The FATF had initially considered, last March, that if the decentralized application (the DApp) is not a VASP, the entities “involved” in the application may be, which is the case when “the entities engage as a business to facilitate or conduct activities” on the DApp.The new FATF guidance drops the term “facilitate” and instead adopts a more functional “owner/operator” criterion, whereby “creators, owners, and operators … who retain control or influence” over the DApp may be VASPs even though the project may appear decentralized.Related: FATF guidance on virtual assets: NFTs win, DeFi loses, rest remains unchangedFATF, under the new “owner/operator” test, states that indicia of control include exercising control over the project or maintaining an ongoing relationship with users. The test is this:Does a person or entity have control over the assets or the protocol itself?Does a person or entity have “a commercial relationship between it and customers, even if exercised through a smart contract”?Does a person or entity profit from the service provided to customers?Are there other indications of an owner/operator?FATF makes clear that a state must interpret the test broadly. It adds:”Owners/operators should undertake ML/TF [money laundering and terrorist financing] risk assessments prior to the launch or use of the software or platform and take appropriate measures to manage and mitigate these risks in an ongoing and forward-looking manner.”The FATF even states that, if there is no “owner/operator,” states may require a regulated VASP to be “involved” in DeFi project-related activities… Only if a DeFi project is completely decentralized, i.e., fully automated and outside the control of an owner/operator, is it not a VASP under the latest FATF guidance.It is regrettable that a principle of neutrality of blockchain networks has not been established, similar to the principle of neutrality of networks and technical intermediaries of the internet (established by the European directive on electronic commerce more than 20 ago).Indeed, the purely technical developers of DeFi solutions often do not have the physical possibility to perform the checks imposed by the AML/CFT procedures in the design of current DApps. The new FATF guidance will likely require DApp developers to put in Know Your Customer (KYC) portals before users can use the DApps.Application of security law?We are all familiar with the legal debate that has become classic when it comes to qualifying a token: Is it a utility token, now subject to the regulation of digital assets (ICOs and VASPs), or is it a security token that is likely to be governed by financial law?We know that the approach is very different in the United States where the Securities Exchange Commission (by applying the famous “Howey Test”) qualifies tokens as securities that would be seen as digital assets in Europe. Their approach is, therefore, more severe, and this will certainly result in more prosecutions of “owners” of DeFi platforms in the U.S. than in Europe.Thus, if DeFi services do not involve digital assets, but tokenized financial securities as defined by the European Markets in Financial Instruments Directive (MiFID Directive), the rules for investment services providers (ISPs) will have to be applied. In Europe, this will be a rare case as the tokens traded would have to be actual financial securities (company shares, debt or investment fund units).Related: Collateral damage: DeFi’s ticking time bombHowever, national regulations are likely to apply. For example, in France, it will be necessary to determine whether the regulation on intermediaries in various goods (Article L551-1 of the Monetary Code and following) applies to liquidity pools.Indeed, pools allow clients to acquire rights on intangible assets and put forward a financial return. Theoretically, it would no longer be excluded that the Autorité des marchés financiers (AMF) decides to apply this regime. As a consequence, an information document will have to be approved by the AMF before any marketing.However, in practice, there is not one person who proposes the investment, but a multitude of users of the DApp who bring their liquidity in a smart contract coded in open source. This brings us back to the test proposed by the FATF: Is there an “owner” of the platform who can be held accountable for compliance with the regulations?The MiCA regulationOn November 24, the European Council decided its position on the “Regulation on Cryptoasset Markets” (MiCA), before submitting it to the European Parliament. It is expected that this fundamental text for the cryptosphere will be adopted by the end of 2022 (if all goes well…).The draft EU regulation is based on a centralized approach by identifying a provider responsible for operations for each service, which does not work for a decentralized exchange platform (like Uniswap) or a decentralized stablecoin.Related: Europe awaits implementation of regulatory framework for crypto assetsWe should think about a legal system that takes into account the automated and decentralized nature of systems based on blockchain, so as not to impose obligations on operators who do not have the material possibility of respecting them or who run the risk of hindering innovation by removing the reason for progress: decentralization.Europe has already shown itself capable of subtle arbitration in matters of technological regulation if we refer in particular to the proposal for a European Union regulation on artificial intelligence. This approach could serve as a source of inspiration.Regardless of the balance chosen by the regulator, investors should become as informed as possible and pay attention to the technological, financial and compliance risks before undertaking a DeFi transaction.As for DeFi application developers and service providers in this field, they must remain attentive to regulatory developments and cultivate a culture of transparency in their operations to anticipate regulatory risk as much as possible.This article was co-authored by Thibault Verbiest and Jérémy Fluxman.This article does not contain investment advice or recommendations. Every investment and trading move involves risk, and readers should conduct their own research when making a decision.The views, thoughts and opinions expressed here are the authors’ alone and do not necessarily reflect or represent the views and opinions of Cointelegraph.Thibault Verbiest, an attorney in Paris and Brussels since 1993, is a partner with Metalaw, where he heads the department dedicated to fintech, digital banking and crypto finance. He is the co-author of several books, including the first book on blockchain in French. He acts as an expert with the European Blockchain Observatory and Forum and the World Bank. Thibault is also an entrepreneur, as he co-founded CopyrightCoins and Parabolic Digital. In 2020, he became chairman of the IOUR Foundation, a public utility foundation aimed at promoting the adoption of a new internet, merging TCP/IP and blockchain. Jérémy Fluxman has been an associate at international law firms in Paris and Luxembourg in the fields of private equity and investment funds, as well as at a Monaco law firm since 2017. He holds a master II in international business law and is currently an associate at the Metalaw firm in Paris, France where he advises on fintech, blockchain and crypto-finance.

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