Dear Financial Action Task Force…

MAMA response to the public consultation of the FATF VA Guidance update

1. The revisions listed above will be perceived as non-technologically neutral.

Simply because a hammer can be used to hurt someone, does not mean that every manufacturer of hammers must conduct extensive customer due diligence or implement data collection and tracking procedures to ensure they can identify hammers used in a crime.

2. You will create barriers to entry for lowest income people who already struggle to access the financial system today. You will remove all the efficiencies that blockchain technology has promised to bring to the lower end of the financial spectrum.

While virtual assets enabling P2P transactions present unique difficulties, they also present opportunities; the opportunity, for example, to free countless millions from inefficient payment systems that not only cost them exorbitant fees, but do not meet the current goals of the FATF themselves.

3. This will drive many small to medium sized businesses, developers out of business, while big businesses will get bigger and more powerful.

We believe that regulation must refrain from imposing obligations on persons and countries that cannot fulfill these obligations.

4. Your revisions will be perceived as an encroachment on basic human rights of freedom to operate in a private way.

By requiring, for example, VASPs to obtain information on unhosted counterparty wallets from their own customers, the draft guidance encourages mass data collection and surveillance without consent.

5. The additional scope will be prohibitively expensive to enforce and likely to be highly ineffective, as history has shown.

We feel that treating new architecture with the same old methods doesn’t qualify as a “risk-based approach” and is out of proportion to what you want to achieve.

About MAMA

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Multichain Asset Managers Association. Working towards a new vision for #assetmanagement using #blockchain and other supporting decentralised technologies.

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Multichain Asset Managers Association. Working towards a new vision for #assetmanagement using #blockchain and other supporting decentralised technologies.

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