1. Abstract
Conventionally, the Reserve Bank of India’s regulatory jurisdiction and supervisory regime is to ensure the depositors’ interest and safety and additionally strengthen India’s banking and financial operations. The RBI represents India’s economic interests at various global platforms such as BASEL, Financial Stability Boards and is thus poised to make decisions attuned to the global scenario in the banking and finance sector. One such challenge is the regulation of the Cryptocurrency or Virtual currencies. Cryptocurrency has taken the world by storm. Unfortunately, most cryptocurrencies do not have their assets backed by either guarantee or any securities. India too with its relatively younger population with a penchant for growth and ambition has jumped on to the bandwagon. India has not yet legitimized the status of cryptocurrency nor deemed it as illegal, however it does tax crypto as an asset class. Given the nature of the technology, and growing concerns for consumer safety, the Reserve Bank of India has maintained a strict stance on the use of crypto; it needs to be seen how it deals with a regulation challenge as puzzling as crypto. The authors throughout this paper thus, seek to analyse the role and function of the RBI in the regulation of blockchain coins, through the employment of doctrinal research methodology whilst comparing the laws and rules that govern the same in different parts of the world such as the U.S, China et cetera. We also explore the possibility of introducing Central Bank Digital Currency (CBDC), which shall be controlled and regulated by the RBI.
Keywords: Blockchain, Reserve Bank of India, Draft Bill on Cryptocurrency, Pump-and-Dump, Terror Financing, Money- Laundering
2. Introduction
The Reserve Bank under the Payment and Settlement Systems Act, 2007 recognises the following categories for setting up and operating payment system in India[1]:
- Financial Market Infrastructure
- Retail Payments Organisation
- Card Payment Networks
- Prepaid Payment Instruments
- Bharat Bill Payment System (BBPS)
- Bharat Bill Payment Operating Units (BBPOUs)
Under this Act, it does not recognise crypto currencies or companies that offer crypto currency services as a valid operating payment system even though such currencies are valued based on their demand in the market. Despite this, the RBI and even the people and companies have come a long way since the RBI was established, both in terms of currency recognition and various policy measures that have been implemented.
Unarguably, Bitcoin is the most well-known and widely used form of crypto currency, first coming into existence in 2008, in hopes of replacing modern government sanctioned securities and currencies with complete online transactions, something that is known as Decentralisation of Finance. The lockdown forced by the COVID-19 pandemic acted as a catalyst in the alternative investment opportunities, of which crypto was the most popular choice. The m-cap for crypto crossed $ 2-trillion[2] as of September, last year. Today, there exist nearly 19,000 types of cryptocurrencies, together referred to as AltCoins[3] (currency other than Bitcoin) all of which are based in blockchain technology. The government has responded by taxing the crypto as an asset class but has remained tight-lipped about the legality or the status of giving legal tender to cryptocurrency. Simultaneously, the RBI has maintained its strong stance against adoption of cryptocurrency.
2.1 History: From Ban to Regulation
The Reserve Bank of India was primarily established on the recommendation of the Hilton Young Commission to regulate the issue of the banknotes, maintain resrves and regulate the currency and credit system to increase the credibility of the rupee as a common currency for India to ensure that monetary stability is maintained throughout.
The first major shift in the Role of the Bank came in the 90’ with the introduction of LPG reforms that required the bank to further the improvement of overseas payments into developing financial markets for Indian investors and companies while maintaining a sound monetary policy[4]. The direct effect of this role of the RBI to ensure a sound monetary policy was seen during the demonetisation in 2016[5] (even though a demonetization had taken place in 1978, this was on a much larger scale with more factors to take into account.)
The role and function of RBI was once again put to the test through the introduction and growth in popularity of cryptocurrency, which it continues to term as a “clear danger” that derives its value from intangible sources[6].
With the introduction of the first cryptocurrencies in 2013, the RBI began issuing warnings to various stakeholders. Despite the warnings issued, Cryptocurrencies continued to grow exponentially in use prompting the RBI to issue a circular in February 2017, stating the potential financial security risks associated with operation and legal aspects of such virtual currency.
Simultaneously, two Public Interest Litigations were filed in the Supreme Court to ban and regulate the use of virtual currencies respectively. This prompted the Government to formulate a committee to study the potential harms that crypto currencies can cause while proposing actions on the same through providing viable alternatives and solutions. A High Level Inter-Ministerial Committee was thus created in November of 2017, that began a thorough study on virtual currencies and released its report in February 2019, that was made available to the public in July of the same year.
During this time banks were allowed to deal and trade in virtual crypto currencies at the standard exchange rate till April 2018. On the 6th of April 2018, the RBI on the recommendation of the Central Board of Digital Tax asked all commercial and co-operative banking companies to stop dealing with cryptocurrencies. This led to a crash in the market, despite there being no actual blanket ban[7].
At the end of these two years the following were some of the major findings and recommendations of the committee:
- Cryptocurrencies are a specific type of virtual currency that does not have centralized encryption but is rather maintained through independent computers via Distributed Ledger Technology.[8]
- They are heavily subjected to market fluctuations and because they are decentralized cannot be subjected to regulations
- Since transactions are untraceable and irreversible, wrong transactions cannot be safeguarded and consumers can easily become victims of ponzi schemes and cyber-attacks.
- The large amount of power consumed during the processing of currencies along with the anonymity granted to the user during such transactions can be unfavorable not only to the energy resources but also be used for illicit purposes, scams and insurgent activities.
- The committee examined the framework around the world and stated that private currencies should be banned and their trade criminalized. But rather than a complete ban the committee suggested that the state should use and keep an open mind related to the Official Digital Currency issued by the government for better regulation of fraud and aid in resolving errors in the corporate market for functions such as land market and insurance claims.
Consequently, a draft bill to Ban Cryptocurrency was introduced in the Lower House of the Parliament to prohibit the use of currency and making it compulsory to disclose his assets in virtual currency in case of possession. While it would exempt certain activities in the interest of the public, there would be a ban on currency used as a payment system even as the digital rupee could be recognised as legal tender.
The Bill however, lapsed while under the drafting stage and the 2018 ban on crypto effective as per the notification of the Reserve Bank continued to subsist. After two years of the ban, it was finally challenged in the Supreme Court in the case of Internet and Mobile Association of India[9]the members of which raised an objection to the insentient state that the circular of the RBI left the state of virtual currencies in. The Supreme Court took cognisance of this and thus lifted the ban on cryptocurrency[10].
The issues did not come to an end here however. Concerns around cryptocurrencies were once again raised in 2021, with the Standing Committee on Finance calling for a meeting of the seniors of RBI who continue to underline their views against the use and investment of cryptocurrencies[11].
The impact of all these suggestions is to be seen in the impending 2021 Draft Crypto Bill that is pending in the Parliament that may either decide to either impose a ban, frame regulations or allow only government recognised currencies in India[12]. A deeper analysis of the implementation and implications of the same have been done below.
3. RESEARCH METHODOLOGY
This research paper is based on a non-empirical or doctrinal method of research and is of descriptive nature. This piece of information has been formed using the secondary sources of data like newspapers, journals, and websites used for the research.
4. Literature Review
In their paper titled, “A STUDY ON OPPORTUNITIES AND CHALLENGES OF CRYPTOCURRENCY IN INDIA WITH SPECIAL REFERENCE TO BITCOIN”, Dr. Anil Kumar and Swathy P have discussed the concepts and drawbacks of Bitcoin as a singular cryptocurrency with various growth opportunities in India. This analysis has been conducted from an economic viewpoint only.[13]
Shailak Jani in his paper on, “The Growth of Cryptocurrency in India: Its Challenges & Potential Impacts on Legislation” has examined the impact on the growth of bitcoin on technologies in India and the creation of opportunities through this as well as whether crypto is the next currency. However, because the paper was written when crypto trading was banned in India, it becomes important to revisit the aforementioned issues once again.[14]
“A STUDY ON CRYPTOCURRENCY IN INDIA – BOON OR BANE” by Mr, J.P. Jaideep and Rao Prashanth Jyoty discusses the role and impact of Bitcoin on Technologically driven India and its impact on the future economy[15].
5. Analysis
5.1 Issue: Is Crypto a safe haven for terror-financing, money laundering and fraud?
Due to their untraceability and pseudonymous nature, and digitally enhanced global reach, cryptocurrency can potentially be used for money-laundering, financing of terrorism and tax evasion[16]. In fact, there have been instances of the use of crypto for illegal purposes, Bitcoin was used for illicit drug trafficking in the dark-web marketplace known as Silk Road.[17] Although, it is quite possible that other modes of digital financial instruments however the transactions over crypto mask the identity of the users and transactions. Thus, there is a huge potential for criminals, and fraudsters to perpetrate financial and cyber-crimes using cryptocurrency. Given the huge consumer base of Cryptocurrency in India, it finds itself in murky waters where on one hand there is a growing clarion for the adoption of crypto given its futuristic technology and financial gains whereas on the other hand there is an enhanced risk of cybercrimes, terrorism funding and money-laundering. These issues haven been highlighted below:
- Lack of security: Cryptocurrencies are not backed by an actual asset class, and can’t be particularly defined as currency, commodity or asset. They particularly have no intrinsic value and underlying cash flows. Thus, consumers are left in the lurch due to less market awareness and often get attracted to ponzi schemes or the pump-and-dump schemes.
- National Security– Due to their functioning on the P2P or the peer-to-peer mechanism attracts economic offenders and money launderers. It essentially allows them to cash out less than 15% of the proceeds of the crime, compared to other money laundering methods costing up to 50%, this is because in crypto, the transaction source can’t be traced, making it impossible to bring it under the regime of Prevention of Money Laundering (PMLA), secondly under Section 12 of the PMLA, an obligation is imposed upon banking companies, financial institutions, and intermediaries to maintain and upkeep records[18]. This is not the case with crypto as crypto transactions are unregulated in the Indian Banking system. Such siphoning off of funds has led to an increase in the illicit drug trafficking, terror financing and economic frauds.
- Governance Risk– Currently due to the gap in the regulation regime in this space, there exists a lot of unregulated players, and there is little to no accountability mechanism. Many crypto exchanges have faced operational and governance risks especially during market turbulence, colloquially known as “crypto winter”. They are marked by frequent hacking related thefts of customer funds. Due to the lack of traceability of crypto, it is not easy to track down the hacker(s). Currently, the RBI mandates the KYC (Know Your Customer), for all the customers and traders on these crypto exchanges which ensures some sense of security, however it not enough to trace down criminals in case of hacking-based theft. For instance, the recent case of rug-pull where tokens were promoted as being part of the Netflix show called ‘Squid Games’, after which the trading activity stopped enabling the makers to misappropriate all the money, thereby duping the investors.[19]
- Market Integrity– it refers to the need to ensure that markets operate fairly and safely, now the lack of information regarding the market itself, participants as well as third party exchanges leads to opaqueness. In such a scenario, the chances of abuse of market have increased. There have been various instances where influential gamers, celebrities and businessmen have tried to increase the prices of these tokens, artificially and thereafter sold all of their tokens.
- Financial Stability– There has been unprecedented number of people who are investing and trading in the crypto market, although the number is less than the traditional stock market investing yet it needs to be closely monitored. Especially in the case of ‘Stablecoins’, these cryptocurrencies are backed by an actual currency such as let’s say the U.S dollars, for example Tether (USDT) or Dai (DAI). In a recent report[20], the IMF has highlighted risks related to operational resilience, financial integrity and investor protection related to the use or trade of stable-coins.
5.2 Comparative Structure (Regulation)
In this section we analyse how crypto policies are being drafted by financial regulators in other jurisdictions wherein some countries are moving towards adoption while others are outrightly banning the same. India, can essentially look at various frameworks to draft a comprehensive policy.
USA- Adoption towards CBDCs
In the United States of America, cryptocurrency presently is considered as legal exchange but not legal tender. They are considered to be money transmitters because they are believed to be other value substitutes for cryptocurrency. Cryptocurrency exchanges are regulated under the Bank Secrecy Act (BSA) which is an anti-money laundering regulation which requires financial institutions to comply with certain obligations. Considering, India faces an actual threat in terms of terror-financing, ensuring regulation requiring Crypto exchanges to maintain records of trading and transaction can help subvert the threat. The Exchange would also be required to maintain systematic and appropriate records and submit reports to the authorities.
However, the US Securities and Exchange Commission (SEC) considers cryptocurrencies as securities and therefore applies securities laws to exchanges. On the contrary Commodities Futures Trading Commission (CFTC) has deemed Bitcoin to be a commodity.
The USA is currently in the process of developing a federal legislation and the Treasury Department has also proposed the “Crypto Anti-Money Laundering Rules” which seeks to implement the following changes: –
- Clarification of definition of ‘money’ under the Bank Secrecy Act which would apply to virtual currencies that can convert into legal tender or act as a substitute for fiat currency.
- Update FinCEN’s (Financial Crimes Enforcement Network) ‘travel rule’ which requires transactions to be reported when multiple financial institutions are involved. It also involves sharing information about the originators and beneficiaries of crypto transactions.
- Suspicious Activity Reports (SAR) must be filed for transactions over $10,000 and Wallet owners must identify themselves if they send $3,000 over a single transaction.
Singapore: Towards Crypto-Adoption
Cryptocurrency in Singapore much like USA is not considered legal tender but crypto exchanges and trading is allowed as long as they are registered with the Monetary Authority of Singapore. The Monetary Authority of Singapore has somewhat of an accommodating approach towards cryptocurrency and therefore have a much-relaxed framework for the same.
The Payment Services Act, 2019 brought exchanges and other cryptocurrency businesses under the purview of the Monetary Authority of Singapore from January 2020. This is the parent legislation which regulates cryptocurrency in Singapore. This legislation is compliant with the Financial Action Task Force’s Guidelines on Cryptocurrency. It imposes upon them the following rules: –
- An obligation to obtain a MAS operating license.
- Providing access to any information as and when requested by the Monetary Authority.
- Submission of periodic reports to the Monetary Authority.
- It is the discretion of the Monetary Authority to designate an institution as a payment system.
European Union
Much like everyone else the European Union has neither legalised nor declared cryptocurrency as illegal. The European Union in January 2020 published the Fifth Anti Money Laundering Directive which aims to bring cryptocurrency-fiat currency exchanges under the European Union Anti Money Laundering Legislation.
In June 2022, the European Union reached a provisional agreement on the markets in crypto-assets (MiCA) proposal which has been provided a wide ambit include within its purview issuers of e-money tokens, asset referenced tokens, utility tokens, unbacked crypto assets, stablecoins and trading venues and wallets of crypto assets. MiCA will apply directly across the European Union without any needs for national laws. The EU legislation has a very consumer forward approach wherein its objective is to provide effective and harmonised access to crypto asset markets while simultaneously ensuring the consumer is protected.
Some of the key obligations of issuers of cryptocurrency under MiCA are as follows: –
- Publication of a whitepaper under Article 4 to be admitted as an issuer of crypto assets on a trading platform.
- Information on marketing communications shall be consistent with the information in the crypto-asset white paper.
- The obligation to act honestly, fairly and professionally vis-à-vis crypto-asset holders, in particular in relation to conflict management and prevention or maintenance of security access protocols.
China: Blanket Ban in 2021
Cryptocurrency in China is not considered as legal tender. The People’s Bank of China banned financial institutions from handling crypto transactions in 2017. Moreover, in June 2021, China banned all domestic cryptocurrency mining followed by outlawing cryptocurrencies outright in September 2021. The new regulation effectively banned the use of all cryptocurrency exchanges (foreign and domestic) and prompted a major token sell-off.
India, which also has the world’s fastest-growing start-up sector, needs to protect innovators’ interests and foster innovation. To do this, it could benefit from examining international markets like Singapore and the United Kingdom, where cryptocurrencies are not considered legal tender (money which can be offered as a payment to pay the debt) but rather properties, requiring crypto-exchanges to adhere to financial regulators’ rules.
Even though China has outlawed cryptocurrencies, the industry has grown due to investments from major corporations, and a complete embargo has allowed Chinese companies to export their mining operations to the United States. A global ban on cryptocurrencies will benefit some nations while hurting others, given how the US has emerged as the centre for cryptocurrency mining as a result of China’s embargo.
The only way India benefits from China’s crypto crackdown is by being progressive. Encouraging crypto transactions, mining, NFT adoption, and even ICOs will play a pivotal role in driving the crypto craze in the country. China banning digital assets has already forced several miners to move out to other countries. And with leading crypto-exchanges like Huobi having to drop the Chinese users, the Asian crypto juggernaut will inadvertently head towards India.
Provided India softens its stance towards crypto and becomes more accommodative towards miners, and we could see an influx of crypto-minded nerds and colossal players into the country.
The inflow of miners followed by the sentiment-driven price drops is expected to work well for significant crypto exchanges, with traders and investors finding this scenario opportune enough to enter Bitcoin or Altcoins for the longer haul.
5.3 Recommendations
- Taxing is not a one-stop solution, we need a more comprehensive policy– While presenting the Union Budget 2022, the Indian government declared a 30% tax on revenue earned by cryptocurrencies and other virtual digital assets. Not only that, but the government declared that beginning July 1, 2022, it will levy a 1% TDS on all crypto transactions. All of these pronouncements appear to be unfavourable for Indian individual investors as such a hefty levy will ultimately discourage Indians from investing in cryptocurrencies. To begin, bitcoin is not a type of gambling, lottery, or any sort of game, rather, it is an asset class as well as an investment product. Trading cryptocurrency needs specialized knowledge and cannot be likened to gambling. The high taxation of cryptocurrencies may slow their adoption and cause exchanges to lose volume. Low volumes and trade will also reduce the amount of additional trade, resulting in low taxes for the government, low income for exchanges, and reduced profits for dealers.
Therefore, it is suggested that if the country does not decrease taxes and become more crypto-friendly, the country may risk a brain drain. The job possibilities generated by blockchain start-ups will no longer be available. Most competent individuals will most certainly be willing to migrate elsewhere, particularly to more crypto-friendly nations. Secondly it will severely hamper the investments in the early-stage startups in the crypto space, forcing these companies to partner with countries having crypto-friendly policies.
- Introducing CBDCs, and imposing stricter regulations for Crypto Exchanges– Recently, the Reserve Bank of India (RBI) advised the government to establish regulations for cryptocurrencies. If such a prohibition must be implemented, the Indian government should seek international cooperation. The RBI believes that cryptocurrency should be banned as they are, by definition, borderless and require international cooperation to prevent regulatory arbitrage. Time and again, the RBI has issued instructions, circulars, directions, warnings, etc. regarding restricting the issuance, buying, selling, holding, and circulation of Cryptocurrency in India. It is suggested that if the RBI wants to ban the digital asset thinking of all of its drawbacks, then a stringent stance should be taken by our government like that of China. After initially allowing its residents to sell or mine crypto currency, China launched a crackdown on mining operations and prohibited the trading in June 2021. Those operating cryptocurrency infrastructure, including exchanges, were forced to relocate their businesses outside of the nation. Although, the nation is developing a digital version of currency and is testing the centrally regulated crypto coin.
This CBDC will be a legal tender, which will lessen the woes of economic fraud, secondly it might position India as a leader with an RBI backed CBDC as India already is a leader in online payment or what we call as UPI based payments. However, there are several fundamental challenges that need to be addressed such as how will the technology intensive CBDC be integrated into our payments system, secondly how do we ensure financial inclusion, given that cryptocurrency is a complex procedure and requires at least a basic understanding of complex terms and processes.
- Consumer Awareness is the key– As mentioned previously, the RBI has issued warnings to the general public about the potential abuse of private cryptocurrencies in a variety of ways. However, if the New Bill completely prohibits private cryptocurrencies, cryptocurrency investors would be forced to invest and trade in unregulated marketplaces, which will ultimately defeat the very objective of bringing the whole concept of cryptocurrency into the system. The objective of enacting a virtual currency/ cryptocurrency law is to streamline the process of trading and holding in a safer technological environment. However, even with the introduction of state-owned cryptocurrency that will be controlled by the RBI, the risk element associated in cryptocurrency investing and ownership will remain the same. As a result, the government should address this issue when enacting legislation, so that the interests of the state and citizens can be met on equal footing.
- Lack of specific legislation pertaining to Cryptocurrency– Currently, the transactions in cryptocurrencies must conform with the general law in force in the country, including the Prevention of Money Laundering Act, the Indian Penal Code, the Foreign Exchange Management Act, the Tax legislation, the NDPS Act, etc. This leads to difficulty in efficient adjudication of the judiciary in our country as there is unavailability of a specific legislation which exclusively tends to deal with problems pertaining to cryptocurrency. Due to the escalating increase of cybercrimes that are unrestricted by national or geographical boundaries, new legislation to regulate cryptocurrencies and secure the traceability of crypto-traded funds is much needed. If the government deems that it must keep up with global advancements in this space then it needs to implement efficient and suitable procedures to efficiently monitor and regulate cryptocurrencies.
6. Conclusion
The increasing number of cryptocurrency users shows a shift in the financial paradigm in a nation that is traditionally recognised for investing mostly in gold and other secure assets. According to existing indicators, very soon, India will be implementing a robust regulatory framework for cryptocurrencies but it is still undecided as to which regulatory authority will handle the matter. Most likely, the government would view cryptocurrencies as a category of assets and not as a currency. The objective behind this regulation will be to increase the openness and accountability of cryptocurrency trading platforms. A system of checks and balances should also be implemented to prevent fraud and monitor international transactions. In spite of uncertainties over the future of the unregulated digital asset, cryptocurrency adoption has gained tremendous traction over the past two years, with India being one of the largest investors. Consequently, it would be intriguing to observe what direction India’s crypto adventure goes after the passage of the bill.
[1] Certificates of Authorisation issued by the Reserve Bank of India under the Payment and Settlement Systems Act, 2007 for Setting up and Operating Payment System in India, Publication, Reserve Bank of India. 25th August 2022. https://www.rbi.org.in/Scripts/PublicationsView.aspx?id=12043
[2] Dmitri Drakopoulos et al., Crypto Boom Poses New Challenges to Financial Stability, IMF, (Last accessed August 28)
https://blogs.imf.org/2021/10/01/crypto-boom-poses-new-challenges-to-financial-stability/
[3] Arjun Kharpal, Crypto firms say thousands of digital currencies will collapse, compare to markert to early dotcom days, CNBC, (Last accessed August 28), https://www.cnbc.com/2022/06/03/crypto-firms-say-thousands-of-digital-currencies-will-collapse.html
[4] Brief History, Reserve Bank of India, rbi.org.in (Last accessed 2nd September 2022, 7PM).
[5] IIM Raipur Media and PR Cell, Role of RBI and Fianance Ministry in Demonetization ,Feb 2017 (Last accessed: 1st Sept 2022) https://insideiim.com/role-of-rbi-and-finance-ministry-in-demonetization.
[6] Cryptocurrencies clear danger, says RBI Governor, Economic Times June 2022.
[7]Committee Report Summary: Virtual Currencies in India. PRS India (Last accessed 2nd September 2022) https://prsindia.org/policy/report-summaries/virtual-currencies-india.
[8] DLT is the underlying technology of crypto-assets. It refers to processes and related technologies that enable participants (nodes) in a network to securely propose, validate and record changes to a ledger that is distributed across the network’s participants. It does not rely on a centralized controller.
[9] Internet and Mobile Association of India v. Reserve Bank of India, 2020 SCC OnLine SC 275.
[10] Prachi Bharadwaj, “SC quashes RBI ban on Cryptocurrency Trading” SCC OnLine 4th March 2020. (Last Accessed on 2nd September 2022).
[11] Report on Currency and Finance: Reviewing the Monetary Policy Framework, Reserve Bank of India
[12] The Indian Crypto Bill 2021: What lies ahead for Crypto Investors, Times of India, Jan 2022.
[13] Anil Kumar, Swathy P, A STUDY ON OPPORTUNITIES AND CHALLENGES OF CRYPTOCURRENCY IN INDIA WITH SPECIAL REFERENCE TO BITCOIN, IJRAR, March 2019, (1st September 2022)
http://ijrar.com/upload_issue/ijrar_issue_20543250.pdf.
[14] Shailak Jani, The Growth of Cryptocurrency in India: Its Challenges & Potential Impacts on Legislation“, Research Gate, April 2018 (1st September 2022). https://www.researchgate.net/publication/324770908_The_Growth_of_Cryptocurrency_in_India_Its_Challenges_Potential_Impacts_on_Legislation
[15] “A STUDY ON CRYPTOCURRENCY IN INDIA – BOON OR BANE””, International Journal of Emerging Technologies and Innovative Research (www.jetir.org), ISSN:2349-5162, Vol.6, Issue 2, page no.412-417, February-2019, Available :http://www.jetir.org/papers/JETIRZ006066.pdf
[16] Dong He et al., Virtual Currencies and Beyond : Initial Considerations, IMF, (August 28, 10:28 AM), https://www.imf.org/external/pubs/ft/sdn/2016/sdn1603.pdf.
[17] David Adler, Silk Road: The Dark Side of Cryptocurrency, Fordham Corp. & Fin. Rev. J, (August 29, 11:05 AM), https://news.law.fordham.edu/jcfl/2018/02/21/silk-road-the-dark-side-of-cryptocurrency/.
[18] Matthew Leising, Booming Decentralized Finance a Potential Haven for Money Laundering, Bloomberg.
[19] IOSCO, Issues, Risks and Regulatory Consideration relating to Crypto-Asset Trading Platforms, (August 29, 12:00 PM), https://www.iosco.org/library/pubdocs/pdf/IOSCOPD627.pdf.
[20] IMF, The Crypto ecosystem and the Financial Stability Challenges, IMF Blog 41, 44 (2021), https://www.imf.org/- /media/Files/Publications/GFSR/2021/October/English/ch2.ashx.