Notabene, a crypto compliance firm that offers compliance solutions with FATF Travel Rule, has shown interest in Qatar’s proposed digital assets regulatory rules framework and has commented on Qatar’s consultation paper.

Notabene offers Safe Transact platform that helps financial institutions and crypto businesses unlock their full potential in the digital economy. With a focus on security, privacy, and end-user experience, Notabene customers use a multi-source data and software to automate real-time decision-making, perform counterparty sanctions screening, identify self-hosted wallets, and complete the smooth roll out of Travel Rule compliance, all in line with global and local regulations.

In a recent tweet on X Notabene welcomed the opportunity to comment on Qatar’s proposed digital assets regulatory rules consultation paper.

Notabene noted that they applaud the Qatar Financial Centre (“QFC”) Regulatory Authority (“Regulatory Authority”) and the Qatar Financial Centre Authority (“QFC Authority”) for taking the time to put together a comprehensive framework for digital assets.

Notabene added,” The process undertaken by both the QFC Regulatory Authority and QFC Authority to solicit public engagement on this important topic and welcome the opportunity to be part of the ongoing dialogue.”

Notabene, the crypto industry’s y pre-transaction authorization decision making platform, helps to identify and stop high-risk activity before it occurs. The platform offers a secure, holistic view of crypto transactions, enabling customers to automate real-time decision-making, perform counterparty sanctions screening, identify self-hosted wallets, conduct VASP Due Diligence, and complete the smooth rollout of Travel Rule compliance, in line with global regulations.

According to Notabene only Travel Rule compliance gives VASPs transaction-level counterparty and sanction insight, allowing them to recognize if their clients are sending transactions to sanctioned entities, wallets, or jurisdictions. VASPs worldwide are in different stages of compliance, which leaves many companies vulnerable to exposure to sanctioned individuals.

In its comment to Qatar’s consultation paper, Notabene states, “In particular, strict compliance with the Travel Rule is a prerequisite for VASPs to obtain licenses in these jurisdictions. We recommend that the QFC Regulatory Authority take the same approach. The ideal way to avoid dealing with non-compliance after settlement and its associated challenges is to ensure both TSPs assess and approve the
transaction before the Originator TSP executes it. This is in line with FATF’s recommendations.”

Qatar recently released its digital assets framework requesting feedback on it by January 2nd 2024.

Henk Jan Hoogendoorn has confirmed that Qatar Genesis Technologies, a Qatar University tech spinoff is working with Qatar Financial Center Authority on possible use cases in their digital assets labs.

Lebanese-Canadian national Mazen El Masri, Co-Founder and CEO of Genesis Technologies, the tech company which developed Maxya, is working with QFC digital assets labs on several blockchain use cases.

As per the post the possible use case could include tokenization, security tokes and fractional ownership.

On Sunday October 29th, Qatar announced one of the biggest digital assets initiatives in the country and the GCC region, the Qatar Innovation Dome for digital assets. As per the live event keynotes, the digital assets lab will develop tokenization platforms and ecosystems for everything that has value whether tangible assets or intangible assets including real estate assets, securities, Sukuk, bonds and others in the future utilizing DLT ( distributed ledger technologies), blockchain, and smart contracts.

Qatar Financial Centre Authority (QFCA) signed MOUs with Blockchain solution provider R3 and Blockchain SettleMint platform. The agreement with Settlemint will also as with R3 work on Blockchain and digital asset initiatives in the financial sector in the digital assets lab.

In a recent LinkedIn post, Henk Jan Hoogendoorn, Chief Financial Sector Officer at Qatar Financial Centre Authority (QFCA) announced the commencement of next steps with Blockchain solutions provider Settlemint to tokenize private shares and equity for companies.

As noted in the post, “ Next steps on tokenization of private shares / Private Equity discussed with our digital asset lab partner SettleMint both for Qatar Financial Centre (QFC) Authority and any  investment manager that would that would like to tokenize or fractionalize investments.”

Matthew Van Niekerk, Co-founder, SettleMint, commenting on the post stated, ” Thank you for hosting us both physically and digitally for the meeting Henk Jan Hoogendoorn! Really appreciated the opportunity to exchange views on the future of finance, financial markets infrastructure and the tokenization of private securities. Exciting times ahead for the industry!”

In April 2023, Qatar Financial Centre Authority (QFCA) signed its second Blockchain MOU with Settlemint, after signing its first with R3. The agreement with Settlemint aimed to work on Blockchain and digital asset initiatives in the financial sector. QFCA and Settlemint agreed to explore potential synergies with industry participants, including financial institutions, fintech firms, and corporate organizations, to accelerate the adoption of blockchain and digital asset business models and solutions.

This announcement also comes immediately after the Qatar Financial Centre launched its digital assets Lab under the name Qatar Innovation dome. The event which was held on Sunday 29th of October 2023 included various keynotes, that explained how the digital assets lab will develop tokenization platforms and ecosystems for everything that has value whether tangible assets or intangible assets including real estate assets, securities, Sukuk, bonds and others in the future utilizing DLT ( distributed ledger technologies), blockchain, and smart contracts.

Yousuf Mohamed Al-Jaida Board Member and Chief Executive Officer of Qatar Financial Centre in his speech announced that one of the first use cases to be explored within the digital assets lab will be tokenized carbon assets. He goes on to state, “Secondly will be tokenizing private company shares to facilitate trading and management of these shares, as well as transforming Sukuk bonds into digital assets in addition to tokenized real estate to facilitate the buying and selling of real estate assets.”

On Sunday October 29th, Qatar announced one of the biggest digital assets initiatives in the country and the GCC region, the Qatar Innovation Dome for digital assets. As per the live event keynotes, the digital assets lab will develop tokenization platforms and ecosystems for everything that has value whether tangible assets or intangible assets including real estate assets, securities, Sukuk, bonds and others in the future utilizing DLT ( distributed ledger technologies), blockchain, and smart contracts.

Present at the launch was His Excellency Sheikh Bandar bin Mohammed bin Saoud Al-Thani, Governor, Qatar Central Bank, and His Excellency Sheikh Mohammed Bin Hamad Bin Qassim Al-Abdullah Al-Thani, Minister of Commerce and Industry.

Bandar bin Mohamed bin Saud Al-Thani, The Governor and Chairman of the Board of Directors of Qatar Central Bank noted in his speech, “ It is my pleasure to be at the launch of the Digital Assets Lab where as a country we are working to discover new tools to increase, enhance our competencies and capabilities in the digital sector. We have achieved strides in digital technology through a number of initiatives chief among them is electronic KYC ( Know your Customers) ad are working to develop and establish an ecosystem for startups and new companies to enhance the role of KYC.”

He added, “We are encouraging entrepreneurship as part and parcel of new financial technology strategy with local, regional and international customers with initiatives such as blockchain and digital assets. These are steps in the direction with initial modules for digital assets, modern databases, and increased internet speed as such as welcome collaboration for the sustainable development of the state of Qatar.”

Yousuf Mohamed Al-Jaida Board Member and Chief Executive Officer of Qatar Financial Centre in his speech offered a detailed explanation on the technology relevant to this lab, the benefits, pillars and the coding system and tokenization process. He explained, “The digital assets projects leans on three Qatar National strategies, the Qatar National Vision 2030, the Qatar Financial Center strategy and the fintech strategy of the state of Qatar, which aims to make the country a financial commercial hub 2030.”

He explained, “Tokenization is the process of creating tokens that represent tangible and intangible assets using DLT. The tokens could represent tangible assets such as real-estate or intangible assets such as securities. We will also work on fractionalization of assets, and will allow property to be part of those tokenized assets democratizing the process of investment.”

He added, “Smart contract, which are self-implementing contracts built on cryptographic programming systems, will allow the transfer of property, in distributed format.”

He discussed how DLT is an innovative technology that registers transactions, and can be expanded to include investment opportunities. As per Al Jaida, in the first phase tokenization will verify property, second will entail economy of tokens, third will entail development of smart contracts and the application which will manage these digitized tokens after which they will be offered on secondary markets.

As per the objectives of the digital assets lab, it will reinforce innovation and research as well as the establishment of DLT enabled startups, and companies, helping participants transform their ideas into tangible reality. Al Jaida states, “Participants in the digital assets lab will have three to six months to test their ideas, where they will have to meet feasibility requirements, benefits towards fintech ecosystem in Qatar before they graduate.”

The Digital asset lab will offer technology support, operational support, where startups and companies can cooperate with experts, regulators, test their use cases and register their businesses and receive licenses, offering the support from pilot to company formation allowing them to operate in Qatar’s fintech ecosystem.

Al Jaida announced that one of the first use cases to be explored within the digital assets lab will be tokenized carbon assets. He goes on to state, “Secondly will be tokenizing private company shares to facilitate trading and management of these shares, as well as transforming Sukuk bonds into digital assets in addition to tokenized real estate to facilitate the buying and selling of real estate assets.”

He called for continuous suggestions on what else can be tokenized moving forward as well as input into the regulations for digital asset ecosystem.

He then announced the name of the lab, which is the “QFC Innovation Dome”

Michael G. Ryan, the Chief Executive Officer at Qatar Financial Center Regulatory Authority, believes that the digital asset economy has a transformative nature and cooperation will be essential because as promising as it is, it also faces challenges.

He believes that with the equilibrium between innovation and regulatory oversight, confidence and trust will prevail among investors and firms. This is why the digital assets framework that QFCR has developed requires the engagement of all participants. He called for feedback on the digital assets public consultation paper announced in early October 2023, which will be open until January 2nd 2024, as these feedback will play a strong role in their policy decisions.

One of the Blockchain entities participating in QFC Innovation dome is R3. Bryan D’Souza Strategic Alliances & Partner Ecosystem Lead for EMEA at R3 stated in a comment made on the live LinkedIn event, “R3 is proud to be partnering with the QFC for this exciting Digital Assets Lab initiative.” Settlemint Blockchain is also one of the participants.

Prior to this The Qatar, Ministry of Finance, signed an agreement  with the World Economic Forum (WEF) to establish a “Centre of Excellence for the Fourth Industrial Revolution” in Qatar that will help to foster an environment for research and development in technologies that include AI ( artificial intelligence), blockchain, IoT (Internet of Things), renewable energy and others.

The Qatar Financial Centre Authority (QFCA), the legal and tax arm of the Qatar Financial Centre (QFC have signed an MOU with the Asian Institute of Digital Finance (AIDF), a research institute of the National University of Singapore (NUS), to embark on projects encompassing ESG, Fintech, digital assets, Web3 and other emerging technologies.

In addition to these efforts, both partners will actively facilitate the exchange of knowledge and insights to further their common goals and objectives.

Yousuf Mohamed Al-Jaida, Chief Executive Officer, QFC, expressed his optimism about this partnership, stating, “We are excited to join forces with the Asian Institute of Digital Finance at the National University of Singapore to explore and capitalize on the numerous opportunities in the ever-evolving digital landscape. This partnership reflects our commitment to innovation and our belief in the power of collaboration to drive positive change. We see this collaboration as a significant step, not only in the direction of constructing a more inclusive financial sector but also in forging a path towards a more sustainable future.”

Likewise, Associate Professor Huang Ke Wei, Executive Director, NUS Asian Institute of Digital Finance expressed their enthusiasm for the collaboration, saying, “The NUS Asian Institute of Digital Finance empowers the future of finance through digital innovation and academic excellence, and provides thought leadership through a holistic blend of education, research, and business incubation. Our vision is to catalyse the evolution of the digital economy by fostering innovation and imparting knowledge. This collaboration with QFC marks a significant step towards fostering cross-regional knowledge exchange, setting the stage for a brighter, interconnected digital future.” The partnership between the QFC and NUS AIDF underscores their shared commitment to innovation and sustainability and catalysing positive global transformation by leveraging technology.

QFC has been moving forward with its digital asset strategy and framework.

As expected The Qatar Financial Centre (“QFC”) Regulatory Authority (“Regulatory Authority”) and the Qatar Financial Centre Authority (“QFC Authority”) have published a consultation paper for their digital assets framework which seeks to regulate investment tokens.

QFC is seeking feedback for the proposed digital assets legislation at a date no later than January 2nd 2024 which means the final legislation will not be available until the first or second quarter of 2024. This comes at the heels of QFC’s launch of its digital assets Lab which will be launched on October 29th.

Aditya Kumar Sinha,  Head Fintech & Digital Innovation at Qatar Financial Centre (QFC) Authority · states on LinkediN, “ The Qatar Financial Centre Regulatory Authority (QFCRA) and the Qatar Financial Centre (QFC) Authority have jointly released a Consultation Paper, and we’re seeking your insights and feedback on our proposals to introduce a QFC Digital Assets Framework. This comprehensive framework is being developed in phases, with phase one dedicated to establishing legislation for a QFC tokenization framework. To make this vision a reality, the QFC Regulatory Authority and QFC Authority have meticulously prepared a range of draft legislative instruments.”

As part of the digital assets legislation is rulebook for Investment Tokens. These rules define the treatment of investment tokens representing specified products, making their activity subject to authorization and supervision, and amendments to existing rules to accommodate investment tokens.”

The Regulatory Authority and the QFC Authority has developed a QFC digital assets framework designed to achieve the following objectives,  develop a legal and regulatory framework for digital assets through the establishment of a tokenization framework in the QFC that will provide legal certainty and a trusted technology environment for digital assets;  provide legal recognition of digital assets and address issues such as ownership of the underlying assets, custody arrangements, the transfer of ownership, trading and exchange of digital assets, smart contracts, among other relevant matters.

It also seeks to develop a trusted technology infrastructure that embeds the standards necessary to ensure trust and confidence among consumers and support for the framework from high quality service providers; and develop a framework that delivers certainty and promotes trust and confidence in digital assets, the market, and the service providers.

QFC authority as mentioned based their proposed framework on benchmarks in Lichtenstein, Switzerland, the European Union, the Monetary Authority of Singapore, various states, and offshore financial Center frameworks in the GCC and other benchmark regulatory jurisdictions.

Henk Jan HoogendoornHenk Chief Financial Sector Officer at Qatar Financial Centre (QFC) Authority added in a post on LinkedIn, Our ambition is to have a solid Digital Asset Framework where real Asset can be tokenized with trusted tokenization partner and supervised by Qatar Financial Centre (QFC) Authority and Qatar Financial Centre Regulatory Authority (QFCRA) .”

As per the documents the proposed digital assets framework is being developed on a phased basis with phase one focusing on the establishment of legislation to provide for a QFC tokenization framework.

In terms of investment tokens, they are tokens that represent underlying’s that are Specified Products under the QFC Financial Services Regulations (“FSR”). They provide for any person who carries out an activity in relation to such a token to be conducting a regulated activity, requiring authorization and supervision by the Regulatory Authority.

So what is the Investment Tokens Rules 2023? It introduces enabling provisions for tokenizing rights (described as investment tokens), in specified products under the QFC Financial Services Regulations (“FSR”) and certain derivatives and Islamic financial contracts declared to be specified products in Regulatory Rules.

Stablecoins, CBDCs, and crypto are not under the regulatory guidelines and as such are prohibited. As per the legislation framework, “

As noted a cryptocurrency token that is used as an alternative to fiat currencies but is not issued or backed by any governmental authority and does not represent any ‘off-chain’ property, is an example of an excluded token. This includes tokens commonly referred to as fully backed stablecoins, as these are regarded as substitutes for currency but are not themselves fiat currency or monetary instruments.”

Yet regulated token services include token validators, token generation services, token custody services, operation of a token exchange, and token transfer services fall under the activities within the digital asset framework.

In addition the proposed amendments to the Special Company Regulations enable Special Companies to conduct the additional activity of issuing certificates, receipts, or other instruments, which would include tokenized instruments. This amendment is proposed on the basis that parties conducting a transaction in digital assets from the QFC (i.e., by way of example, a sukuk or bond Token issuance) may use a Special Company for this purpose.

This comes after QFC has commenced working with blockchain, DLT, and consultancies to develop their digital asset and DLT framework infrastructure.

This week Dubai’s DIFC (Dubai International Financial Center) also released its digital assets consultation paper.

In a recent LinkedIn post, Henk Jan Hoogendoorn , Chief Financial Sector Officer at Qatar Financial Centre (QFC) Authority revealed that the digital assets framework that the authority has been working on will soon be launched along with the digital asset lab.

As noted, QFC is working with Price Waterhouse Cooper ( PWC) to finalize the digital assets framework and the launch of the digital assets lab.

As Hoogendoorn noted, “ We are working on digitalassets framework together with Qatar Financial Centre Regulatory Authority (QFCRA) supported by the expertise of PwC .We are making good progress on preparation of Digital Asset Lab to be launched soon.”

Prior to this Qatar Financial Authority had taken several inititiatves towards advancing DLT, Blockchain and digital assets within the financial sector.

In May speaking to LaraontheBlock, Hoogendoorn stated, “We are developing our digital assets framework to allow for public tokenization of assets, including securities, bonds, and real-estate.” He emphasized that they will not go into crypto, NFTs (Non Fungible Tokens) or commodities at this time.

In addition Qatar Financial Centre Authority and Blockchain solution provider R3 signed an MOU to develop and grow Qatar’s fintech industry using technologies such as DLT (Distributed Ledger Technology), as well as an MOU with Blockchain entity Settlemint.

In August 2022 Qatar had released a national consultation paper about the “National Blockchain Blueprint for Qatar”. The paper was collaboratively developed by CRA, Hamad Bin Khalifa University, and Qatar University. The final version was released in March 2023.

Again it seems countries across the GCC and MENA region are embracing blockchain, digital assets, and to some degree virtual assets, the future is looking crypto bright.