Montreal, Canada, July 15, 2020 BY EMAIL :
[email protected] Secretariat to the Financial Stability Board Bank for International Settlements Centralbahnplatz 2 CH-4002 Basel Switzerland Subject : Addressing the regulatory, supervisory and oversight challenges raised by “global stablecoin” arrangements: Consultative document1 (“Consultation”) Dear Sirs and Madams : We welcome the Financial Stability Board’s (“FSB”) invitation to respond to its Consulation on global stablecoin (“GSC”) arrangements, and hope that the present submission will useful in your deliberations regarding the foregoing. This submission forms part of a series of submissions filed before the Canadian Standing Committee of Finance (FINA)2 in its statutory review of the Proceeds of Crime and Terrorist Financing Act (of which myself, David Durand, and Mr. Drew Dorweiler presented thereto) as well as IIROC/CSA3 and IOSCO4 consultation. A copy of our FINA submission is enclosed at Schedule 15 hereof; of which, our recommendations are found at Section 11 (at page 26) thereof, namely : concentrating regulatory efforts at the locus of cryptoasset transactions – the convertibility mechanism, as well as address definitions of key terms, such as commodity, currency, cryptoasset and securities. INTRODUCTION Little did we know the stir the Satoshi Nakatomo white paper6 of October 2008 was going to create. Indeed the Nakatomo paper, cited over ten thousand times per Google®, has caused government, public and private sector, advocates, as well as the legal system to spend an incalculable amount of hours studying the attributes of cryptoassets and their impact on the financial system, monetary policy7,8, data 1 https://www.fsb.org/2020/04/addressing-the-regulatory-supervisory-and-oversight-challenges-raised-by-global-stablecoin- arrangements-consultative-document/.