Could Qatar be creating a cloud based blockchain platform to accelerate its Blockchain blueprint strategy?

Could Qatar be creating a cloud based blockchain platform to accelerate its Blockchain blueprint strategy?

Dr Mohamed Abdallah and Dr Aiman Erbad, Associate Professors at  Qatar’s HBKU College of Science and Engineering published an article on how Qatar’s Blockchain blueprint will boost the adoption of blockchain and their recommendations for accelerating the growth. They proposed hosting a high-performance cloud based blockchain platform to accelerate prototyping and testing or creating a physically distributed blockchain network among different institutions, including ministries and universities, which can serve as a test bed that can also host actual blockchain applications, among other recommendations.

The College of Science and Engineering at Hamad Bin Khalifa University (HBKU), as well as the College of Engineering at Qatar University (QU), and the Communications and Regulatory Authority jointly developed the National Blockchain Blueprint, aimed at defining the requirements and incentives necessary for the adoption of blockchain technology in Qatar.

As per the article, the blueprint has several goals, including facilitating the emergence of startups and new companies, identifying successful methods through pilot projects, promoting creativity and innovation, and upgrading infrastructure to enable a conducive environment for blockchain technology.

The authors also discuss various recommendations that could be incorporated within the Blockchain blueprint.

One of the key recommendations of the blueprint is to encourage the development of pilot projects in priority sectors such as Fintech, Energy, and Health.

The Blockchain blueprint also wants to provide an adequate incubation environment for promising blockchain startups. The authors recommend creating a new consortium-based funding organization that involves all stakeholders to promote blockchain-based startups and businesses.

To facilitate the deployment and testing of new blockchain applications, The authors also recommend hosting a high-performance cloud-based blockchain platform to accelerate prototyping and testing.

The final recommendation is to create a physically distributed blockchain network among different institutions, including ministries and universities, which can serve as a test bed that can host actual blockchain applications. By having a distributed network, blockchain-based solutions can be tested in a real-world environment, and the risks and potential opportunities can be identified.

Qatar has been moving forward with its blockchain initiatives and the Qatar Financial Centre Authority has been at the forefront of integrating blockchain, DLT, digital assets into the financial market. More recently they even discussed digital assets for Islamic Finance and signed an MOU with Malaysian Labuan IBFC well known for its Islamic finance products.

Finally and most recently Qatar Financial Authority were in discussions with Qatar Development Bank to discuss the need for digitization of products and services in digital assets, kYC, SMEFinance and the metaverse. 

It would seem that the Qatar Blockchain blueprint is moving forward in great strides. 

Gemini digital asset exchange joins other global players in eyeing UAE for a license

Gemini digital asset exchange joins other global players in eyeing UAE for a license

In a Zawya exclusive interview, GEMINI, digital asset exchange founders expressed their interest in applying for a license in UAE. As per the article US crypto exchange Gemini, is interested in a license in UAE because of the hostility and lack of clarity in the USA. Several other global virtual asset service providers have already expressed their interest as well including Coinbase, Bittrex, IoTa, and Circle. 

The license application is set to come after meetings in both Dubai and Abu Dhabi.

Cameron and Tyler Winklevoss are the founders of GEMINI. Tyler told zawya, “There is a lot of customers and amazing investors here.” As for the USA, Tyler told Zawya it as hard to get things done in the US.

He added, “You don’t want the Wild West, but you also don’t want a wall or a gate to innovation, getting that balance right builds the healthiest markets. We have always believed that, and always tried to get that message across to the regulators to provide that clarity and consistency in guidelines, because we think that the outcomes are just so positive.”

Prior to this Gemini announced that it was launching its European HQ in Dublin. But Tyler affirmed to Zawya that Gemini would not be giving up on the USA.

This would make Gemini the latest global entity to see regulation in UAE, over the past two months, entities such as CoinBase, IoTa, Circle, Bittrex, have all expressed their interest to set up in the UAE.

This is being further pushed with the new UAE Central Bank’s AML CFT guidance for financial entities regarding their dealings with virtual asset service providers.

A look into UAE Central Bank’s AML guidance document for virtual assets and what it means for the future of VASPs in UAE

A look into UAE Central Bank’s AML guidance document for virtual assets and what it means for the future of VASPs in UAE

The UAE Central Bank has issued its long awaited virtual assets and virtual assets service provider framework under the umbrella of a new guidance on anti-money laundering and combating the financing of terrorism (AML/CFT) for licensed financial institutions (LFIs) with a focus on the risks of dealing with virtual assets.

The actual document is more telling than the initial press release. In reality the UAE Central Bank has clarified what is considers as virtual assets and who can offer services in this realm, as well as how banks and financial institutions will work with VASPs when it comes to opening accounts for them and meeting compliance requirements. It also makes clear that virtual assets are not considered a legal tender in the UAE.

Now a lot has been made clear. Earlier this month, there was a position for a Fintech virtual assets senior manager job at a UAE Bank who was required to be specialized in Fintech and virtual assets compliance from a finance crime perspective, which was eye catching because there wasn’t anything yet announced from the UAE Central Bank. Yet now one thing is for certain, banks in the UAE will be scrambling to hire talents who understand the virtual asset ecosystem so they will be able to comply with the recent guidance.

Definition of virtual assets and VASPs

First the UAE Central Bank has defined as they mention in alignment with FATF definitions, what virtual assets are, leaving out of the definition CBDCs and security tokens, as well as some NFTs. As per the guidance, “A virtual asset is a digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes, excluding digital representations of fiat currencies, securities, and other funds (such as those separately regulated by the competent authorities of the UAE, including the CBUAE, SCA, VARA, FSRA, and the Dubai Financial Services Authority (“DFSA”).”

It goes on to explain, “Virtual assets, so defined, typically include assets commonly referred to as cryptocurrencies, cryptocoins, payment tokens, exchange tokens, and convertible virtual currencies. Without prejudice to the definitions in the laws and regulations referred to above, stablecoins may be considered either virtual assets or traditional financial assets depending on their exact nature. No asset should be considered a virtual asset and a traditional financial asset (e.g., a security) at the same time.”

The guidance also discusses payment tokens offered and licensed by payment token service providers. Payment Tokens are defined as a type of Crypto-Asset that is backed by one or more Fiat Currency, can be digitally traded, and functions as a medium of exchange and/or a unit of account and/or a store of value, but does not have legal tender status in any jurisdiction. A Payment Token is neither issued nor guaranteed by any jurisdiction and fulfills the above functions only by agreement within the community of users of the Payment Token. Payment Token Service Providers, in turn, are defined as persons engaged in Payment Token issuing, Payment Token buying, Payment Token selling, facilitating the exchange of Payment Tokens, enabling payments to Merchants and/or enabling peer-to-peer payments, and Custodian Services related to Payment Tokens.

What Virtual assets are not

As for NFTs, they are not considered virtual assets, but this does depend on the nature of the NFT and its function. As stated, “Some NFTs that on their face do not appear to constitute VAs may fall under the VA definition if they are used for payment or investment purposes in practice.”

The guidance makes it clear that the Central Bank of the UAE does not accept or acknowledge virtual assets as a legal tender/currency in the UAE; rather, the only legal tender in the UAE is the UAE dirham. As such, those accepting VAs as payment for goods and services or in exchange for other assets bear any risk associated with the future acceptance or recognition of VAs.

The guidance adds,  by definition VAs cannot be digital representations of fiat currencies, securities, or other separately regulated financial assets, a bank record maintained in digital format, for instance, that represents a person’s ownership of fiat currency is not a VA. However, a digital asset that is exchangeable for another asset, such as a stablecoin that is designed to be exchangeable for a fiat currency or a VA at a fixed rate, could still qualify as a VA, depending on the relevant features of such a stablecoin.

VASP activities overview

There are five basic activities that fall under VASPs as per the UAE Central Bank, but these are not considered as comprehensive only meant for illustrative purposes. They include virtual asset exchange, virtual asset brokers, who transfer ownership of VA from one user to another, virtual asset custodians, P2P exchanges, remittance payments, payment for nonfinancial g goods or services, or payment of wages. A provider offering such a service will likely be a VASP.

The UAE Central Bank has even considered decentralized virtual assets Exchanges or decentralized finance (“DeFi”) application creators, owners, and operators as VASPs given they maintain control or sufficient influence in the DeFi arrangements, even if those arrangements seem decentralized, may fall under the definition of a VASP where they are providing or actively facilitating VASP services. For example, there may be control or sufficient influence over assets or over aspects of the service’s protocol, and the existence of an ongoing business relationship between themselves and users; even if this is exercised through a smart contract or in some cases voting protocols.

Even entities that provide related financial services to issuer’s who offer or sell virtual assets through participation in and provision of financial services related to an issuer’s offer or sale of a Virtual asset through activities such as initial coin offerings (“ICOs”) are considered as VASPs.

Licensed Financial Institutions AML CFT

Finally as per the AML-CFT Decision, every natural or legal person who carries out any VASP activities, provides VASP products or services, or carries out VASP operations from the state must be licensed, enrolled, or registered by a competent supervisory authority in the UAE.

LFIs are strictly prohibited from establishing relationships or processing transactions with individuals or entities that perform covered VASP activities and are not licensed to do so by UAE authorities. It is therefore essential that LFIs form an understanding of whether its customers perform covered VASP activities and, if so, whether they have fulfilled applicable UAE licensing requirements. LFIs are not permitted to establish relationships or process transactions with foreign VASPs that have not secured a license to operate as a VASP from UAE authorities, even if the foreign VASP is duly licensed or registered outside the UAE.

The guidance warns that LFIs may be indirectly exposed to VA or VASP activity through its customers that use their account or relationship with the LFI to provide downstream financial services to VASPs. In the case of VASP customers, this may include the provision of accounts or custodial wallets that can be used directly by customers of a third-party VASP to transact business on the customer’s own behalf.

The AML-CFT Law brings virtual assets and virtual asset service providers within the scope of the UAE’s AML/CFT legal, regulatory, and supervisory framework. Under Articles 9 and 15 of the AML-CFT Law, VASPs must report suspicious transactions and information relevant to such transactions to the UAE FIU, and under Articles 13 and 14, supervisory authorities are authorized to assess the risks of VASPs, conduct supervisory operations (including inspections) of VASPs, and impose administrative penalties on VASPs for violations of applicable laws and regulations.

Conclusion

In conclusion this is the first comprehensive framework that the UAE Central Bank has published which will allow a select number of VASPs to be able to deal with the licensed financial institutions in the UAE. It will not be easy for the financial sector as the AML and CFT requirements are exhaustive, but it will also not be easy for the VASPs.

Moreover, there is one gap that seems huge and over looked by the UAE Central Bank, and that is what if licensed financial institutions actually want to offer Virtual asset services. So what if a bank actually wants to offer VA custodial services, or VA payment services, or brokerage services, can they both be the provider and the client and what happens to AML and CFT requirements then.

In Bahrain for example the Central Bank is allowing crypto entities to move into the other financial arenas and has even allowed the first digital bank which deals in digital assets to make their base in the country.

Another question that can be raised, is that in a country which has called for more international cooperation and coordination when it comes to regulating virtual assets, then concurrently does not allow any of its financial institutions to deal with any VASP not regulated in the UAE even if they are regulated in other jurisdictions, what precedence is the UAE making in this regards and is reciprocity the new name of the game?

With regulations taking force in UAE especially when it comes to virtual assets, the country that once boasted of having 1800 blockchain and crypto entities might see that number dwindle as most of these companies will not be able to comply to the regulatory requirements rendering them unable to receive services from the banking sector. 

We can already see this decline in number on the new website for VARA, where there were once dozens of names listed as on the course of receiving licenses, today there is a handful.

Next to be published will definately be the payments rulebook under VARA which was missing before. Can’t wait to see what that will bring to the table.