Tokenised Payments – A Regulatory Perception

Focus

The Financial Stability Board (FSB), the Bank of International Settlements (BIS) and the Committee on Payments and Market Infrastructure (CPMI) have all clearly stated that there are current issues concerning cross-border payments. Cross-border payments initially faced four particular challenges: high costs, low speed, limited access and insufficient transparency. It is becoming more apparent that faster, cheaper, more transparent and inclusive cross-border payments would have widespread benefits for supporting economic growth, international trade, global development and financial inclusion. This topic was initially brought to the industry’s attention and discussed within the G20 in 2020.

Introduction

The G20 made enhancing cross-border payments a priority. The ability to make cross-border payments faster, cheaper, inclusive and more transparent while maintaining their safety and security would have widespread benefits for citizens, businesses, and economies worldwide.

The FSB, in coordination with the CPMI and other relevant international organisations and standard-setting bodies (SSBs), developed a Roadmap to address these challenges. The G20 Leaders endorsed the Roadmap at their November 2020 Summit. The Roadmap was designed to be a comprehensive, high-level plan that remains flexible and adaptable over time as the work progressed and the cross-border payments landscape evolved.

During the first two years, the work focused on establishing the foundational elements of the Roadmap. This work covered topics as diverse as existing international standards and guidance, existing national and regional data frameworks, operating hours and access to payment systems, common elements of service level agreements/schemes, the use of payment-versus-payment mechanisms, the interlinking of payment systems, and factoring an international dimension into central bank digital currency (CBDC) designs.

Quantitative Targets

A key foundational element in the Roadmap was the publication of quantitative targets that define the Roadmap’s ambition for achieving cheaper, faster, more transparent, and more accessible cross-border payments and creating accountability. The targets are directly related to the four challenges faced by cross-border payments with a goal for achieving them in most cases by the end of 2027.

The plan discusses:

Market Reaction

The market has aggressively reacted to this global requirement and numerous crypto assets have been created to meet global demand.

Crypto Assets

The vulnerabilities in crypto-asset markets relating to leverage, liquidity mismatch, operational or technological fragilities and interconnectedness are similar to those in traditional finance. These vulnerabilities might have implications for financial stability through different channels:

  1. Financial sector exposure to crypto-assets and related financial products;
  2. Wealth effects impacting investors and the wider financial system;
  3. Confidence effects influencing broader market stability;
  4. The extent of crypto-assets use in payments and settlements.

Crypto-assets also raise broader policy issues, such as the need for consumer and investor protection; strong market integrity protocols; AML/CFT regulation; tax compliance; capital control enforcement; and concerns relating to illegal securities offerings.

Global Stablecoins

There is no universally agreed legal or regulatory definition of stablecoin. Stablecoins are generally created and distributed through trading platforms in exchange for fiat currency.

The FSB identifies three characteristics of global stablecoins (GSCs):

  1. The existence of a stabilisation mechanism
  2. Usability as a means of payment and/or store of value
  3. Potential reach across multiple jurisdictions

Stablecoins may improve payment efficiency and financial inclusion, but widely adopted GSCs could become systemically important across jurisdictions.

Crypto and GSC Concerns

Although the market is commencing engagement within the crypto and GSC arena, there are still significant concerns from both governmental and corporate perspectives.

Government

  1. Regulatory oversight of global sanctions
  2. Compliance-driven AML initiatives
  3. Geographical tax conformity
  4. Security and transparency of funds

Corporate

  1. Regulatory oversight
  2. Security of funds in transfer and on deposit
  3. Risk of value tied to a single fiat currency
  4. Asset value based solely on supply and demand

G30 Seminar Requirements

The G30 Seminar (2024) outlined the following requirements for cross-border payment innovation:

  1. Innovation must address global concerns identified by Central Banks and BIS.
  2. Preferably achieved through modernisation of legacy banking systems rather than crypto exchanges.
  3. Alignment of Central Bank and Commercial Bank money improves transition feasibility.
  4. Central Banks must act as anchors for fund security — something crypto/GSCs cannot currently provide.

StableNotes

StableNote is a new digital asset being launched into the market in 2027 that is not based on crypto or blockchain. The foundation of a StableNote is built upon digital technology with banks providing a supporting role via safeguarded currency deposit accounts. This algorithmic model enables all the features of both crypto and GSCs but provides the supporting requirements of the FSB, BIS, CPMI, G20 and G30.

StableNote provides the following:

  1. Global regulatory oversight
  2. Compliance-driven objectives
  3. Transparency of assets held on reserve
  4. 100% security on asset value
  5. Security of fund transfers
  6. Hedged against the world’s top five traded fiat currencies
  7. Real-time settlement
  8. Decentralised verification and authorisation
  9. Proven technology
  10. Carbon friendly

Summary

The crypto and GSC markets, although still in their infancy, require vast improvements before meeting global regulatory compliance requirements and the needs of corporate cross-border payment markets.

StableNotes, built on legacy banking systems with enhanced technology layers, provide a transparent, secure and robust method of cross-border payment for the foreseeable future.