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On this whitepaper, Atty. Rafael Padilla, Co-Founder and Trustee of BlockDevs Asia and Professor of Regulation at San Beda Alabang, examines the up to date guidelines for virtual asset service providers launched by the Bangko Sentral ng Pilipinas. Rafael lately printed the ebook Fintech: Regulation and First Ideas. You’ll be able to obtain the whitepaper here or learn it under:

Insights on BSP Tips for Digital Asset Service Suppliers

Rafael Padilla
Professor of Regulation, San Beda Alabang Faculty of Regulation
Co-Founder & Trustee, BlockDevs Asia Inc.
Writer, Fintech: Regulation & First Ideas
[email protected]
11 February 2021

Introduction

The Financial Board of the Bangko Sentral ng Pilipinas (BSP), in its Decision No. 78 dated 21 January 2021, authorized the brand new guidelines and laws that may govern the operations of Digital Asset Service Suppliers (VASPs) throughout the Philippines. BSP Round No. 1108, Sequence of 2021 established the brand new Tips for Digital Asset Servicer Suppliers.

On the outset, it have to be famous that the principles and laws, in addition to circulars issued by administrative our bodies to interpret the legal guidelines which they’re entrusted to manage have the pressure of legislation, and are entitled to nice respect. Administrative issuances partake of the character of a statute and have of their favor a presumption of legality.[1]

BSP Round No. 1108

Following the rise in the usage of bitcoin and different cryptocurrencies for funds and remittances within the Philippines, the BSP established in January 2017 a proper regulatory framework for what it refers to as “Digital Foreign money Alternate” or VCE underneath BSP Round No. 944. The framework is aligned with the BSP’s coverage to offer an atmosphere that encourages monetary innovation whereas safeguarding the integrity and stability of the monetary system. Beneath the Tips for Digital Foreign money Exchanges,[2] VCEs are outlined as firms or companies engaged in changing digital currencies s into fiat foreign money and vice versa to facilitate funds and remittances.

In BSP Round No. 944, the BSP’s regulation of VCEs was once restricted solely to companies that convert fiat currencies to crypto and vice versa to facilitate funds and remittance transactions. In different phrases, the BSP goals to manage cryptocurrencies when used for supply of monetary companies, significantly for funds and remittances, which have materials impression on anti-money laundering (AML) and combating the financing of terrorism (CFT), shopper safety and monetary stability.[3] The BSP additionally clarified that operators of Automated Teller Machines (ATM) for Digital Currencies that permit buy or alternate of Digital Currencies (VCs) or different units with related performance and functionality, are thought-about as Digital Foreign money Exchanges (VCEs) and will register with the BSP. In accordance with the BSP, “as registered VCEs, they need to adjust to anti-money laundering/terrorist financing legal guidelines and laws, guarantee adequate and acceptable controls and governance framework are adopted to handle the related know-how and different operational dangers, and put in place ample shopper safety and buyer help, amongst others.”[4]

Since 2020, the BSP began to undertake the terminologies (e.g., VA and VASP) employed by the Monetary Motion Activity Pressure (FATF) in referencing cryptocurrency actions. The BSP is continually evolving its regulatory framework for brand spanking new forms of cryptocurrency-based monetary intermediaries, per the steerage prescribed by the FATF for Digital Belongings (VA)and Digital Asset Service Suppliers (VASP).

BSP Round No. 1108 expanded the regulatory framework to cowl different Digital Asset Service Suppliers when their actions fall throughout the broad class of cash service enterprise (MSB). In accordance with the BSP, “virtual-asset (VA) programs have the potential to revolutionize the supply of monetary companies by offering sooner and extra economical means to switch funds, each home and worldwide, and will additional help monetary inclusion.”[5] Nonetheless, it will be important for the BSP that VAs  usually are not abused and that the Philippines shouldn’t be used for cash laundering and terrorist financing actions. The regulation additionally seeks to mitigate know-how dangers and monetary stability considerations related to VA, in addition to strengthen shopper safety.[6]

VASP as Cash Service Enterprise

BSP’s new pointers embodied in Round No. 1108 requires sure VASPs to register with the BSP and safe a Certificates of Authority to function as MSB.[7]  A Cash Service Enterprise or MSB is an entity that gives monetary companies that contain “the acceptance of money, checks, different financial instrument or different shops of worth and the cost of a corresponding sum in money or different kind to a beneficiary by way of a communication, message, switch or via a clearing community to which the service supplier belongs.”[8]

The Financial Board has the facility to authorize entities to have interaction in MSB.[9] The BSP’s supervisory authority over MSB has been reaffirmed in Part Three of the New Central Financial institution Act, as amended by R.A. No. 11211 in 2019. Part Three supplies that as could also be decided by the Financial Board, the BSP workouts regulatory and examination powers over MSB.[10] By the way, the registration of a VASP with the BSP additionally triggers the requirement to register with the Anti Cash Laundering Council(AMLC) as MSB, thus making the registered VASP  a “Lined Particular person” throughout the context of Philippine Anti-Cash Laundering (AML) legislation and regulation.

BSP regards sure VASPs as cash service enterprise underneath the speculation that after fiat foreign money is exchanged or transformed right into a digital asset, it turns into simply transferrable, facilitating expedient motion or switch of funds and cost service.[11] Nonetheless, it ought to be emphasised that the BSP doesn’t essentially regulate all types of digital asset enterprise actions or all forms of Digital Asset Service Suppliers[12] (VASP) as this time period is outlined by the Monetary Motion Activity Pressure’s Steering for Digital Belongings and VASPs.[13]  To be lined by the BSP’s regulatory regime, the VASP ought to fall throughout the definition of MSB (i.e., the exercise throughout the regulatory ambit of the BSP) and be engaged within the conduct of a number of of the next actions:

  1. alternate between VAs and fiat currencies;
  2. alternate between a number of types of VAs;
  3. switch of VAs; and
  4. safekeeping and/or administration of VAs or devices enabling management over VAs.[14]

Certainly, the BSP Tips for VASPs particularly excludes VASP who’re concerned within the participation and provision of monetary companies associated to an issuer’s provide or sale of a VA. Such exercise accurately falls throughout the regulatory perimeter of the Securities and Alternate Fee (SEC). BSP’s regulation additionally doesn’t apply to entities solely appearing on their very own behalf, or those that don’t act, as a enterprise, on behalf of consumers to facilitate digital asset-related actions.[15]

VASP evaluation

In accordance with the FATF Steering for VAs and VASPs, there are two key components to qualify as a VASP: (1) there’s a supplier that actively facilitates VA-related actions; and (2) the supplier acts as a enterprise on behalf of the purchasers.[16] In assessing whether or not an entity ought to be thought-about as a VASP, the actions and capabilities carried out ought to be thought-about—whatever the know-how used. An entity could be a VASP, whether or not they use a decentralized or centralized platform, good contract, or another mechanism. For instance, when a decentralized utility (dApp) actively facilitates or conducts the alternate or switch of worth (whether or not in VA or conventional fiat foreign money), the dApp, its proprietor/operator(s), or each may probably fall underneath the definition of a VASP. Even the people who developed a decentralized VA cost system could also be handled as a VASP after they interact as a enterprise in actively facilitating or conducting the funds.[17] Whether or not a platform is centralized or decentralized could also be a key side in assessing the cash laundering and terrorist financing threat; however this query shouldn’t be a controlling issue within the VASP evaluation.

Neither the BSP Tips nor the FATF Steering search to manage the know-how that underlies VAs. The VASP regime intends to manage the individuals behind such know-how or software program purposes that will use know-how or software program purposes to facilitate monetary exercise or conduct as a enterprise sure VA actions on behalf of one other particular person. Due to this fact, as a secure harbor for builders, any one who develops or sells both a software program utility of a brand new VA platform shouldn’t be thought-about VASP when solely creating or promoting the applying or platform. Furthermore, those that present ancillary service or product to a blockchain community, akin to {hardware} pockets producers and non-custodial wallets, must also not be thought to be VASP, so long as they don’t actively facilitate as a enterprise the VASP actions for his or her clients.[18] 

With respect to alternate actions, the “alternate” regulated by the BSP refers to intermediaries that actively facilitate the conversion of VA or fiat foreign money in relation to a cash service enterprise. The time period “alternate” shouldn’t be interpreted to incorporate market or services for bringing collectively purchasers and sellers or for performing capabilities generally facilitated by securities alternate, i.e., the buying and selling of VA which can be within the nature of safety, crypto derivatives and different artificial VAs that behave like securities; this particular sort of VASP and their exercise could also be lined by the provisions of the Securities Regulation Code[19] administered by the SEC.

With respect to VASPs engaged within the switch of VAs, the time period “switch” refers back to the conduct a transaction on behalf of one other individual that strikes a digital asset from one digital asset handle or account to a different.[20] Due to this fact, such a VASP contemplates those that function as middleman to actively facilitate the switch of VA.

Different monetary use circumstances for digital belongings that don’t contain cash service enterprise could also be topic to different regulatory or licensing regimes, whether or not or not they fall throughout the definition of VASP, which can be administered by the BSP, the SEC, the Insurance coverage Fee or different regulators.  Talking of assorted monetary use circumstances, the BSP has acknowledged in BSP Round No. 982[21] that cryptocurrencies and distributed ledgers, “if prudently harnessed, can considerably enhance market share, enhance buyer expertise, improve safety, and promote monetary inclusion.” However BSP prescribes that previous to adopting these rising applied sciences, monetary establishments ought to “absolutely perceive the mechanics, implications to shopper safety, money-laundering and total safety posture in addition to inherent dangers related to these new applied sciences.” In circumstances the place relevant laws or necessities are unclear, BSP-supervised monetary establishments ought to seek the advice of with the BSP previous to implementation.[22]

What’s a Digital Asset?

Inside the scope of BSP’s regulatory framework —particularly the VASP Tips, the idea of “digital asset” or VA is outlined as “any sort of digital unit that may be digitally traded, or transferred, and can be utilized for cost or funding functions.” BSP additionally regards VA as “property”, “proceeds”, “funds or different belongings” and different “corresponding worth”, which can be utilized as a medium of alternate or a type of digitally saved worth—whether or not issued by a central administrator or by a decentralized community.[23]

BSP Round No. 1108 excludes from the fabric scope of its regulation digital items which can be used for “cost of products and companies solely offered by its issuer or a restricted set of retailers specified by its issuer (e.g. present checks).” It additional excludes digital items for the cost of digital items and companies inside a web based sport (e.g. gaming tokens).  That is per the FATF’s Steering that additionally excludes closed-loop gadgets which can be non-transferable, non-exchangeable, or non-fungible throughout the which means of VA. Such closed-loop gadgets would possibly embrace airline miles, bank card awards, or related loyalty program rewards or factors, so long as their proprietor can’t promote them in a secondary market.[24] With respect to non-fungible tokens or NFTs, varied NFT-based platforms will not be essentially thought-about as VASP, except they’re additionally engaged within the energetic facilitation of transactions equally carried out as a enterprise by VASPs.

The time period “digital asset” must also not be construed to incorporate digital representations of fiat currencies which can be issued or assured by any jurisdiction and have authorized tender standing (e.g. Central Financial institution Digital Foreign money or CBDC). Fiat foreign money refers to government-issued foreign money that’s designated as authorized tender in its nation of issuance via authorities decree, regulation, or legislation.[25]

Compliance

A BSP-registered VASP should adjust to BSP’s guidelines and laws akin to these regarding operational threat administration, outsourcing, know-how threat administration, liquidity threat administration, inner management, enterprise continuity administration, monetary shopper safety, anti-money laundering (AML), and company governance. In the middle of the applying for a Certificates of Authority (COA), the BSP will take note of the health and propriety of the useful homeowners of the VASP. VASPs must also adjust to the necessities, guidelines and laws of the BSP with respect to actions requiring prior BSP approval or notification.

VASPs intending to have interaction with different VASPs and different monetary establishments ought to transact solely with counterparties which can be duly licensed and licensed by the suitable regulatory authorities. As a coverage, the BSP prohibits licensed VASPs to clear and settle transactions with unregulated VASPs and platforms. The coverage is designed to make sure that all VASP actions are executed inside an unbroken chain of regulated entities.[26]

A VASP that creates and maintains fiat wallets to facilitate the conversion or alternate of fiat foreign money to VA or vice versa are required to keep up adequate unencumbered liquid belongings to make sure that VA redemptions are adequately met always. It must also undertake management mechanisms that may guarantee immediate recording of receipt of fiat currencies.

Custodians which can be chargeable for custody of consumers’ VAs, whether or not via proprietary or outsource preparations, ought to undertake measures to make sure ample reserves for the VAs they maintain in custody. Mentioned VA Custodians should incorporate efficient mechanism to correctly report and segregate clients’ VAs from their proprietary VAs.

 

a. Capital requirement

By way of capital requirement, VASPs with safekeeping or administration companies for VA (e.g. custodians, escrow service and pockets suppliers) are required to have a minimal paid-in capital of fifty million pesos (PHP50,000,000.00). Different VASPs are required solely to have a minimal paid-in capital of ten million pesos (PHP10,000,000.00).[27]

There appears to be some vagueness on whether or not the overall capital necessities for MSBs as present in BSP Round No. 942 nonetheless apply to VASPs—significantly for Kind A MSB the place common month-to-month quantity of transactions is taken into account in figuring out the capital requirement. For instance, what if a blockchain-based remittance firm, with out offering pockets or custodial companies, is projected or in a position to generate a month-to-month common quantity of transactions within the quantity of PHP100 million (which exceeds the PHP75 million threshold for Kind A remittance agent)? Such firm could be thought-about a VASP engaged within the switch of VA. Would it not solely want PHP10 million (in accordance with BSP Round No. 1108) or wouldn’t it be required to have a minimal paid-in capital of PHP50 million (in accordance with BSP Round No. 942)?

b. Know-how threat administration

VASPs offering pockets companies for holding, storing and transferring  cryptocurrencies, ought to have an ample cybersecurity framework and undertake acceptable safety measures and controls to make sure confidentiality, integrity and availability of knowledge/data uploaded, saved, processed and transmitted into and out of the system and to guard the infrastructure from malware, cyber assaults and different rising threats.[28]

VASPs must also incorporate sound outsourcing mechanisms to handle dangers arising from outsourcing, particularly these regarding confidentiality, knowledge privateness, knowledge administration, contract administration, cybersecurity, efficiency monitoring and enterprise continuity, amongst others. In all situations the place know-how is outsourced, say to a cloud service supplier (CSP), the VASP stays to be in the end chargeable for the efficiency of the monetary service in the identical method and to the identical extent as if the VASP was instantly performing mentioned exercise.[29]

c. Inside management and company governance

VASPs are required by the BSP to keep up and inner management system commensurate to the character, dimension and complexity of their respective companies. VASPs are additionally anticipated to stick to BSP’s minimal management requirements {that a} VASP ought to observe of their operations.[30]

Important management capabilities akin to audit, compliance, AML, data safety and different important roles have to be carried out by competent officers. The VASP’s board of administrators and administration have to be match and correct which ought to be assessed based mostly on sound company governance procedures.[31]

d. Monetary shopper safety

A BSP-registered VASP is anticipated to undertake buyer consciousness measures to teach its clients on the use and safeguarding of their digital asset wallets in addition to log-in credentials, use of cell platforms and wallets, precise charges and expenses associated to the usage of cell platform and withdrawal transactions, and dispute decision procedures.

In accordance with BSP’s monetary shopper safety laws, a VASP ought to disclose the precise charges and expenses that apply to the usage of the platform and withdrawal transactions. They need to additionally put in place dispute decision procedures, in addition to undertake a system for promptly addressing the complaints of its clients.

VASPs ought to clearly talk to its clients the phrases and circumstances prescribing the way on how the losses and liabilities from safety breaches, system failure or human error shall be settled between the VASP and its clients.

Earlier than transacting with a shopper and on a unbroken foundation, a VASP ought to disclose all materials dangers in a fashion that’s clear, honest and never deceptive. Such disclosure should embrace data concerning the dangers related to the acquisition, possession, and buying and selling of digital belongings. VASPs must also disclose whether or not they’re holding digital belongings in custody and the dangers related to such custodial association, or whether or not the purchasers have full management and duty of defending and safeguarding their VAs.

e. Due diligence

A VASP should conduct due diligence (CDD), observing KYC/CDD guidelines and business finest practices—particularly when it establishes enterprise relations with any buyer, undertakes any occasional enterprise transactions with a buyer, the place there may be suspicion of cash laundering or terrorist financing, or the place there may be doubt on the authenticity or adequacy of the client’s identification knowledge.[32]

BSP-licensed VASPs should additionally set up sturdy due diligence and accreditation procedures in deciding on the VAs that shall be listed or traded of their platform (e.g. by formulating a token itemizing/delisting coverage). As well as, VASPs ought to undertake a fraud threat administration system that’s commensurate to the dangers related to explicit VA varieties or particular VA actions (risk-based strategy).

f. Particular transactions necessities for digital belongings

In accordance with BSP’s VASP Tips, VASPs and different BSP Supervised Monetary Establishments (BSFI) that interact in or facilitate VA transfers shall take into account all VA switch transactions as cross-border wire transfers and adjust to pertinent guidelines on wire transfers.[33] The coverage implications of this rule have to be highlighted: first, it treats all VA transfers no matter origin as if they’re worldwide transfers; second, it implies that different BSFIs akin to industrial banks can interact in or facilitate precise VA transfers.[34] The latter implication tends to bolster and implement the FATF’s coverage in opposition to “derisking” of VA and VASPs, i.e., FATF doesn’t help the wholesale termination or restriction of enterprise relationships with VASPS to keep away from, quite than handle, dangers.[35]

For giant worth pay-outs of greater than PHP500,000 or its equal in overseas foreign money, in any single transaction with clients or counterparties, enhanced due diligence (EDD) ought to be performed and mentioned pay-outs ought to solely be made through test cost or direct credit score to deposit accounts or account to account switch utilizing digital fund switch services.[36] On this context, the time period “pay-out” seems obscure and appears to recommend that solely the sale of VA is roofed by this rule whereas the acquisition of VA exceeding PHP500,000 shouldn’t essentially set off enhanced due diligence. In any case, VA transactions exceeding PHP500,000 may even set off the submission of a lined transactions report (CTR) with AMLC.

g. Journey Rule

BSP Round No. 1108 requires the implementation of the Journey Rule pursuant to FATF’s Steering for Digital Belongings and Digital Asset Service Suppliers. The jargon displays the essence of the rule, that’s, figuring out data should “journey” together with the fund switch. In accordance with this rule, a VASP or “the originating establishment” that facilitates a digital asset switch amounting to PHP50,000.00 or extra, or its equal, should receive and maintain required originator data and required beneficiary data, which have been verified for accuracy, and submit mentioned data to beneficiary establishments. For this goal, the required data that ought to be collected by a BSP-supervised VASP or originating establishment consists of:

  1. originator’s identify (i.e., the sending buyer);
  2. originator’s account quantity the place such an account is used to course of the transaction (e.g., the VA pockets);
  3. originator’s bodily (geographical) handle, or nationwide identification quantity, or buyer identification quantity (i.e., not a transaction quantity) that uniquely identifies the originator to the ordering establishment, or date and place of origin;
  4. beneficiary’s identify; and
  5. beneficiary account quantity the place such an account is used to course of the transaction (e.g., the VA pockets).

The transmission of the above figuring out data ought to be instant and safe. VASPs ought to shield the integrity and availability of the required data to facilitate record-keeping and the usage of such data by receiving VASPs or different lined entities, in addition to to guard it from unauthorized disclosure. It’s a vital requirement of this rule that entities ought to submit the required data concurrently or concurrently with the switch itself.[37]

It ought to be famous that the Journey Rule has all the time utilized to all banks and non-bank monetary establishments[38] (which incorporates VCEs or VASPs which can be categorised as MSBs), however the BSP makes it specific that this rule additionally applies to VASPs which is per the FATF Tips.

h. Reporting and record-keeping necessities

As a BSP supervised monetary establishment, a VASP is required to periodically submit stories to the BSP. All reporting and notification necessities imposed to MSBs usually apply to VASPs.  However there are additionally stories particularly prescribed for VASPs. These reporting necessities embrace submission of monetary statements audited by a BSP-accredited exterior auditor, quarterly reporting of quantity and worth of VA transactions, and quarterly reporting of checklist of places of work and web sites.[39]

 In observe, VASPs are additionally anticipated to adjust to extra requests from BSP to submit particular knowledge and knowledge via surveys or questionnaires to help the BSP within the conduct of in-depth research and knowledge assortment.[40]

Lastly, VASPs should make sure that transaction and due diligence data are maintained for a interval of at the least 5 (5) years and cling to different record-keeping pointers issued by the BSP and AMLC for AML functions.

Conclusion: prospects on future authorized and regulatory developments

As of February 2021, the present model of the Anti-Cash Laundering Act (AMLA) doesn’t but embrace VASPs throughout the which means of the time period “Lined Individuals” which can be required to register with the AMLC.Because of this different forms of VASPs—whose actions are outdoors the BSP, the SEC or the Insurance coverage Fee’s supervisory authority underneath current legal guidelines—can’t be required to register with the AMLC as a Lined Particular person. An administrative issuance from the AMLC won’t suffice to legally compel different forms of VASPs to register with the company and to submit lined or suspicious transaction stories. The AMLA must be amended by the Philippine Congress to statutorily incorporate the FATF’s Advice on the inclusion of VASPs as a Lined Particular person for AML/CFT functions.

Contemplating the Philippines’ constant observe of adhering to FATF Suggestions, an modification  of the AMLA to cowl VASPs will possible occur within the brief to medium time period. Such modification to categorise all forms of VASPs as “Lined Particular person” would additionally set up a statutory coverage requiring new crypto-based intermediaries to watch know-your-client, record-keeping, lined transactions and suspicious transactions reporting, in addition to the appointment of AML compliance officer.

It may also be anticipated that different monetary regulators such because the SEC and the Insurance coverage Fee may additionally difficulty bespoke guidelines or issuances for VASPs which can be engaged in monetary actions regulated by these businesses. Such initiative would display a progressive and revolutionary strategy in regulating new forms of monetary intermediaries. Extra importantly, it will make it clear that not all VASPs are throughout the regulatory perimeter of the BSP, and that the precise actions of a VASP ought to in the end decide the suitable monetary service guidelines that should apply to them.

This text is first printed on BitPinas: Insights on BSP Guidelines for Virtual Asset Service Providers by Atty. Rafael Padilla


References:

[1] As such, courts can’t ignore administrative issuances particularly when its validity was not put in difficulty. Except the principles and laws are declared invalid, courts are certain to use them. Landbank of the Philippines v. Celada, 515 Phil. 467 (2006), cited in Land Transportation Franchising and Regulatory Board v. Valenzuela, G.R. No. 242860 (2019).

[2]Id.

[3] Part 4512N, Handbook of Laws for Non-Financial institution Monetary Establishments (MORNBFI). (2017)

[4] See BSP Memorandum M-2019-06 (2019).

[5] BSP Round No 1108, Tips for Digital Asset Service Suppliers, See Coverage Assertion, p. 1 (2021).

[6] Id.

[7] See BSP Round No. 942 for the amended guidelines on Cash Service Enterprise Operations (2017). See additionally BSP Round No. 1039 , which streamlines the necessities for utility for registration as MSB (2019). The appliance course of was simplified to adapt with the mandates of the Ease of Doing Enterprise and Environment friendly Authorities Service Supply Act (R.A. No. 11032, 2018).

[8] BSP Tips for Digital Asset Service Suppliers, p. 3 (2021).

[9] Sec. 3, New Central Financial institution Act, as amended by R.A. No. 11211 (2019).

[10] Part 3. Duty and Major Goal. — The Bangko Sentral shall present coverage instructions within the areas of cash, banking, and credit score. It shall have supervision over the operations of banks and train such regulatory and examination powers as offered on this Act and different pertinent legal guidelines over the quasi-banking operations of non-bank monetary establishments. As could also be decided by the Financial Board, it shall likewise train regulatory and examination powers over cash service companies, credit score granting companies, and cost system operators. The Financial Board is hereby empowered to authorize entities or individuals to have interaction in cash service companies.

[11] See Coverage Assertion, BSP Tips for Digital Asset Service Suppliers, p. 1 (2020).

[12] Contemplating the definition of VASP as famous within the succeeding discussions, it will likely be noticed that whereas a Digital Foreign money Alternate (VCE) is a VASP, not all VASPs are VCEs.

[13] FATF Steering For Digital Belongings and Digital Asset Service Suppliers (2019).

[14] BSP Tips for Digital Asset Service Suppliers, p. 3 (2021).

[15] BSP Tips for Digital Asset Service Suppliers, p. 2 (2021).

[16] To simply recall, we refer to those key components as (1) energetic facilitator aspect and (2) enterprise aspect.

[17] FATF Steering For Digital Belongings and Digital Asset Service Suppliers, p. 17 (2019).

[18] FATF Steering For Digital Belongings and Digital Asset Service Suppliers, p. 17 (2019).

[19] R.A. No. 8799 (2000).

[20] FATF Steering For Digital Belongings and Digital Asset Service Suppliers, p. 57 (2019).

[21] Enhanced Tips on Info Safety Administration (Nov 2017); See http://www.bsp.gov.ph/downloads/regulations/attachments/2017/c982.pdf

[22] BSP Round 982 (2017).

[23] See Definition of Phrases, Tips for Digital Asset Service Suppliers, p. 2 (2021).

[24] FATF Steering For Digital Belongings and Digital Asset Service Suppliers, p. 17 (2019).

[25] BSP Round No. 944 (2017).

[26] Id.

[27] See Capitalization, Tips for Digital Asset Service Suppliers, p. 4 (2021).

[28] Part 4512N.6, Handbook of Laws for Non-Financial institution Monetary Establishments (MORNBFI). (2017)

[29] Id.

[30] Part 4512N.7, Handbook of Laws for Non-Financial institution Monetary Establishments (MORNBFI). (2017)

[31] BSP Tips for Digital Asset Service Suppliers, p. 4-5 (2021).

[32] BSP Tips for Digital Asset Service Suppliers, p. 5 (2021).

[33] BSP Tips for Digital Belongings and Digital Asset Service Suppliers, p. 6 (2021).

[34] These coverage implications shall be examined in-depth in our succeeding papers.

[35] FATF Steering For Digital Belongings and Digital Asset Service Suppliers, p. 9 (2019).

[36] BSP Tips for Digital Belongings and Digital Asset Service Suppliers, p. 7 (2021).

[37] Id.

[38] See for instance BSP Round No. 1022 (2019).

[39] The reporting of checklist of places of work and web sites grew to become semestral underneath BSP Round No. 1039 (2019). BSP Round 1108 reverted to the earlier rule of quarterly reporting.

[40] BSP Tips for Digital Asset Service Suppliers, p. 8 (2021).

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