Managing the digital

assets environment
Key considerations for traditional finance
firms, crypto natives and policymakers

September 2022
Contents

Introduction 4

Context 5

Traditional finance firms 6

Crypto natives 7

Policymakers 9

Summary 12

Authors 13

Acknowledgements 14

Endnotes 14

The digital assets landscape | 02

Section title

Managing in the digital assets environment

where the market and regulation are
evolving quickly can be challenging for
traditional finance firms, crypto natives
and policymakers differently. How can
understanding the current state of play
and leveraging proven frameworks and
approaches further responsible innovation?
Introduction

Introduction
Digital assets hold the potential to disrupt financial to stablecoins, to Central Bank Digital Currencies In the current environment of uncertainty and growth,
services worldwide. Balancing associated risks and (CBDCs). Another important evolution is the way such regulation can benefit from incorporating those different
opportunities in a way that incorporates the perspectives digital assets are used, including how they underpin the perspectives. This piece offers key considerations and
of traditional financial firms, crypto natives, and broader application of decentralized finance (DeFi) which actions for traditional finance firms, crypto natives,
policymakers can lead to more durable and effective is evolving to mirror financial markets.1 and policymakers to take, with a view of fostering
regulatory outcomes that foster responsible innovation. responsible innovation in the digital asset market.
Against this backdrop, traditional finance firms with
The market is evolving quickly, which impacts the well-established business models are seeking to
balance between opportunities and risks. There is a grow their digital asset footprint responsibly due to
growing variety of digital assets, ranging from several customer demand. Crypto natives are designed around
kinds of tokens that may or may not mimic securities, the technology and seeking clarity and guidance on
how to get ahead of potential regulations. Meanwhile,
policymakers are seeking to protect investors and
Figure 1 – Types of digital assets financial stability.

Fungible tokens are identical to each other and, therefore, can be used and transacted interchangeably. Non-fungible tokens (NFTs) are unique and
non-interchangeable assets stored and
transmissible on blockchain, and can represent
digitally native items or physical items that exist
in the real world (e.g., supply chain products).
CRYPTOCURRENCY STABLECOIN CBDC AND DIGITAL FIAT SECURITY TOKEN
Native Governance Utility Stablecoin assets are crypto Security tokens are on-chain
tokens that are designed to representations of traditional
mirror the price of a fiat securities that exist off-chain. Metaverse
Digital Sand Memorabilia Art
currency like the US dollar. land
Bitcoin Uniswap Chainlink Yuan Dollar

ARCoin
DAI USDC
Cryptocurrency assets e-krona Tickets In-game
Ether are either the native items
asset of a blockchain or
created as part of a
platform that is built on CBDC assets are on-chain representations
an existing blockchain. USDT
of a fiat currency.
Digital fiat assets are tokenized fiat
(e.g., US dollars) legally recognized as
cash and are backed 1:1 with fiat currency.
Source: EY analysis

The digital assets landscape | 04

Context

Context
The crypto market has seen both exponential growth In response to those risks, regulators, acting Meanwhile, regulators are also closely watching
and volatility. By one estimate, the total market value individually and collectively, are issuing statements which will be the first major market to regulate
rose from $620 billion in 2017 to nearly $3 trillion in support of regulatory oversight — including the digital assets and advance the deployment of
in November 2021, with new tokens emerging in the G7, the International Organization of Securities CBDCs because it could give those jurisdictions a
marketplace at an unprecedented speed.2 However, in Commissions (IOSCO), the Financial Stability Board competitive advantage in crypto-asset innovation
May and June 2022, the market plunged significantly (FSB), the Basel Committee on Banking Supervision and economic development more broadly.
to a market value of less than $1 trillion and saw (BCBS), the U.S. Securities and Exchange Commission
It will take some time before CBDCs and regulations
the collapse of well-known tokens such as Luna and (SEC), and others — with the goal of achieving
materialize — particularly in major economies — but
Terra.3 These events together with the collapse of responsible innovation through understanding and
there are some actions traditional financial firms
Three Arrows Capital (a crypto-asset hedge fund) and balancing of the downside risks and opportunities
and crypto natives can take now to prepare, reduce
Celsius (a crypto-asset lender) are fueling concerns germane to digital assets. Many of the elements being
risks, and improve regulatory confidence.
about the risks that digital assets pose to consumers, considered in the crypto regulatory domain are not
investors and financial systems. Such risks include new, with parallels and lessons that can be drawn
low levels of consumer understanding, balance sheet from the regulation of FinTech in some jurisdictions.
exposure to digital assets for the banking sector,
institutional investor exposure to digital assets
relative to the size of their portfolio, and regulatory
fragmentation leading to regulatory arbitrage.4

The digital assets landscape | 05

Traditional finance firms

Traditional finance firms

Innovation brings risks. In the absence of specific
regulation and authorization by regulatory and supervisory
authorities (and, in some cases, cautionary messages
from those authorities), traditional financial firms need
to look to their overall risk and compliance frameworks in
order to guide them through their innovation journey.
Currently, such firms appear to be cautious when it
comes to using digital assets in their businesses, in light
of heightened market volatility and increased regulatory
scrutiny more broadly. Several factors could explain the
apparent caution, including the need to: The U.S. Federal Reserve published guidance in August • Evaluating whether their marketing and
2022 for banks, which was as an important step in communications strategy allows their customers to
• Better understand the technology among senior
creating a supervisory process for banks engaging in make informed choices; and ensuring that they provide
managers and board members.
activities involving digital assets.5 This guidance directed options to customers when their expectations differ
• Identify opportunities to access crypto-related products banks to establish adequate systems and controls to from what the offering provides.
and services within the ecosystem that align with conduct activities safely. In our view, it is important
existing offerings and related comparative advantages. for traditional financial firms to integrate digital
• Determining how to treat customers “fairly” and
providing a degree of recourse that takes into
• Incorporate digital asset activity into existing risk asset activities into their existing risk and compliance
consideration customer expectations.
management and compliance frameworks. frameworks and requirements, including:
• Providing services (e.g., safeguarding customer assets,
• Address regulatory considerations and inquiries. • Deciding on an overarching strategy prior to further trade execution, settlement) in a manner consistent with
action. Some firms have started with research
Some traditional finance firms are implementing industry practices observed in more regulated markets.
projects before confirming strategies in this area.
targeted digital asset strategies due to increased • Verifying that risks (e.g., credit, conduct, operational
customer interest. Firms that seek to move forward will • Reviewing changes to business models and updates to and third-party risks), including those bespoke to digital
need to consider how to best access the ecosystem while operational infrastructure.
assets, are identified and assessed comprehensively and
embedding digital asset activities into their overall risk • Confirming the outcome that they are trying to achieve embedded in the internal control environment.
and compliance frameworks. These firms will also need for their target customers.
to consider additional investments in people, process • Providing informative, digestible and actionable
and technology to ensure that prospective digital asset • Understanding the expectations of their regulator(s) internal reporting for senior management
activities remain aligned with risk and compliance regarding the treatment of digital assets exposures and the board regarding the inherent risk
frameworks, and consistent with the firm’s risk appetite. under existing rules, including the need for explicit and effectiveness of internal controls.
Making these investments can help a firm better notifications or approvals and existing or different
understand and mitigate these risks, such as liquidity, jurisdictional regulatory requirements.
credit, market, compliance, and operational risks.
The digital assets landscape | 06
Crypto natives

Crypto natives
In contrast to traditional finance firms, crypto natives risks. These principles are not easily embedded as For these players, it’s critical to understand that
are designed around crypto based models. Examples programmable code via smart contracts and it may not compliance with regulation is not a black-and-white
of crypto natives include crypto exchanges, crypto be feasible to do so given the complexity of digital assets exercise. It entails ongoing subjective decision-making
custodians, cryptocurrency funds, digital wallet providers and the proliferation of individual use cases. Some crypto and judgment calls amid ambiguity. In addition,
and crypto mining companies. natives have perceived the principles-based foundation many crypto native firms may not have institutional
of regulation as fostering regulatory uncertainty and mechanisms in place to support compliance like
As such, crypto natives have management teams with therefore stifling to innovation. Given their lack of traditional finance firms, such as governance and
significant technology expertise, but can lack experience experience with risk and compliance management, a controls and a client acceptance methodology to
with risk and compliance management – particularly familiar refrain that is common among some crypto mitigate potential risks, which could lead to challenges
those that are governed through decentralized means. natives is: “Just tell us what to do and we’ll do it,” which when new and existing regulations take effect.
They can also be more vulnerable during heightened speaks to the differences in expectations between some
market volatility, as evidenced by the recent failures of The FinTech industry offers some lessons in the
crypto natives and the regulatory community, with the
several high-profile firms. For crypto natives that are importance of proactive risk management for new
regulatory community expecting proactivity and some
governed through decentralized means, a significant products and services. Many of the firms that resisted
crypto natives seeking more guidance.
challenge is determining how to embed regulatory risk management or treated it as a burdensome cost
considerations related to risk management and In addition, there is a risk that interpreting regulatory of doing business ran into challenges. In the U.S., for
compliance directly into a crypto-asset architecture compliance too narrowly or in isolation, at the expense example, a peer-to-peer lending firm grew extremely
which is rules-based and programmable via smart of sound and prudent risk management and compliance rapidly in the late 2000s and early 2010s, and drew
contracts. Such contracts are self-executing contracts principles, can create additional risks. For example, there significant institutional backing, leading to an IPO in
with the terms of the agreement directly written into could be scenarios where jurisdictional definitions of a 2014. But the company collapsed just two years later
lines of code. They execute when the buyer and seller security transaction may be used by crypto natives to due to employee fraud, conflicts of interest among
meet pre-determined conditions. classify their assets. This regulatory categorization of management, a lack of transparency, and poor credit
a crypto transaction as a securities transaction could risk management. (The company still exists under new
Existing regulatory rules relating to risk management result in crypto natives rejecting higher-quality asset management). In the UK, some FinTechs ran into similar
and compliance are often principles-based and can offerings deemed securities as the compliance burden issues, primarily because of poor risk management and
require interpretation to tailor guidance or requirements may be perceived to be too high. This in turn would not failing to follow fair lending practices, and this ultimately
to the risk-profile of the organization. Under this be the best path in terms of their portfolio as the crypto required the UK Financial Conduct Authority (FCA) to
approach, senior management plays a significant role in native could be left with lower-quality and riskier assets. intervene.
applying regulatory rules to verify that their activities
are both fit-for-purpose and reflective of the underlying

The digital assets landscape | 07

Crypto natives

Increased regulation over digital assets is inevitable, and • Undertaking due diligence and third-party risk
we believe that a proactive approach that embeds sound management to monitor suppliers, particularly those
risk management and compliance into operating models, providing critical business services.
product design and execution can help crypto natives
better anticipate regulatory change and strengthen their
• Developing extensive cyber controls and testing,
particularly around smart contracts.
resiliency. A proactive approach is quickly becoming
a comparative advantage especially in light of recent
market volatility and the insolvency of several high-
profile market players. Although it’s impossible to make a
Figure 2 – Enterprise risk management
precise forecast about crypto regulation, there are some • Engage board and senior committees • Embed digital assets within risk
to approve digital asset ventures appetite (e.g., expanding tolerance)
baseline, no-regret moves that crypto natives can take to • Policy governance • Enhance resiliency planning given
manage risk starting today, including: • Third-party risk management
(including vendors)
heightened cyber/third-party risk
• Strategic, capital and liquidity planning

• Considering supplementing technology with human

intervention to ensure good governance and balance • Blockchain analytics tools
Governance
• Data visualization/analytics tools
efficiency with safety and risk management. • Modeling and stress testing and
• Node infrastructure management oversight

• E valuating and assessing the relevance and reliability Strategy

of blockchain information evidencing the existence of and risk
appetile
digital assets held. Tools and
architecture Enterprise Risk
culture
• Understanding, evaluating, and considering third party risk Risk
validation of an entity’s exposure to vulnerabilities in Risk data management Management
lifecycle
smart contracts.
Internal
• Monitoring trends on the blockchain to help identify and control
• Talent management
framework
mitigate risks such as fraud and money laundering. • Communication and education
• Change management
• Establishing new product approval processes. • Digital asset market data
• Blockchain data capture
• Implementing “know your customer” (KYC) checks early • Data flow/lineage
• Identify existing revevant and
incremental risk for digital assets
in the product lifecycle. • Assess/measure risks
• Determine monitoring, reporting and
• Disclosing the type and amount of digital assets held for • Control design and implementation
• Testing and validation
response processes
consumers and customers. • Control monitoring and reporting
• Issue and action management

Source: EY analysis

The digital assets landscape | 08

Policymakers

Policymakers
Stablecoins are a good example of where there is these reach a mass market.7 The UK FCA established
I. Regulatory approaches
regulatory convergence. Regulators seem to agree its regulatory sandbox in 2014, and it has been
Policymakers acknowledge the need to provide that fiat-based stablecoins are the preferred model copied by around 40 jurisdictions. The Monetary
regulatory clarity, but regulatory clarity is often a (as opposed to algorithmic stablecoins). Fiat-based Authority of Singapore (MAS) also has a well-regarded
journey, not a destination, and typically a slow one stablecoins have clear parallels with money market regulatory sandbox, with MAS recently announcing
that evolves with changes in innovation and the market funds, provided they are backed by fiat currency a new project with the financial industry to pilot the
environment. Although policymakers acknowledge on deposit with a recognized depository. Many testing of digital assets and DeFi.8 A key challenge
that crypto-asset activity has not yet risen to a level policymakers, including in the UK, the EU, and Japan, for regulators remains in articulating expectations
that creates systemic risk, they are keenly sensitive to are now moving rapidly to establish specific regulatory within their jurisdictions in a transparent fashion
the scale and scope of growth, as well as the potential regimes for stablecoins, particularly those used as a that gives clarity to firms as to when requirements
for interconnectedness with traditional finance firms. means of payment (in some cases, for crypto-based, to exit the regulatory sandbox have been met and
The risks for policymakers lie in regulating too heavily and those linked to money). In the U.S., legislation is to apply those expectations consistently to firms.
or too lightly. Over-regulate and policymakers risk under discussion that would allow stablecoins to be
criticism for hampering innovation, denying innovative issued by regulated banks or non-banks that back their
products to consumers, and ceding momentum to issuance 100% with liquid assets. Legislation has also
other jurisdictions. Under-regulate and policymakers been proposed to limit issuance solely to regulated
could leave instability risks unaddressed, customers banks. Regulators remain cautious about stablecoins,
unprotected, and potentially threaten the digital asset acknowledging both the risks and opportunities, but
market’s integrity. Engaging with both traditional note the increasing urgency of a regulatory response
finance firms and crypto natives to align on a common considering the growth of the market, and events such
understanding of the risks, opportunities, and tradeoffs, as the recent collapse of Terra.
in anticipation of regulation, could better foster
more durable and effective regulatory outcomes. Greater reliance on and harmonization of sandboxes
across jurisdictions could encourage responsible
A likely path for regulation, and one that many innovation by allowing firms the opportunity for
policymakers have begun to take (as evidenced by the controlled experimentation while enabling regulators
FSB’s recent statement on crypto-asset regulation) is to to assess risks and unintended consequences within
draw parallels and apply existing regulations to crypto- and across jurisdictions. They are an example of public-
assets and to products that function most like existing private collaboration which is arguably key in getting
crypto-assets, and then to apply additional safeguards any closer to an answer to regulating digital assets.
where needed.6 A one-size-fits-all approach may not First introduced for FinTech firms, regulatory sandboxes
necessarily be appropriate for the regulation of digital enable regulators to work with innovators to ensure
assets, and an understanding of the unique ecosystem that appropriate consumer protection safeguards
must be taken into consideration. are built into their new products and services before

The digital assets landscape | 09

Policymakers

II. CBDCs
Outside of regulation, there is heightened focus in the why several governments, including the U.S., adopted a paths to a CBDC with different speeds to “market” and
industry and among policymakers around CBDCs, which “whole-of-government” approach toward digital assets implications for each of the policy dimensions. Perhaps
remains an ongoing area of debate. that places “high urgency” on CBDC research design, the quickest path to a CBDC would be for the central
development, and deployment options. bank to provide accounts and associated services to non-
CBDCs are digital representations of central bank bank issuers of stablecoins. A longer path would entail
liabilities that are broadly accessible and usable by the Developing and deploying a CBDC is a complex
developing a permissioned blockchain where participating
public.9 Central bank liabilities include both commercial undertaking, which requires careful consideration of the
institutions would serve as presenters and validators of
bank money (i.e., reserves) and currency (i.e., cash). In trade-offs associated with CBDC design, architecture,
transactions. There are many potential options in between
modern central banking systems, reserves — which are participation, and infrastructure. Each choice has
and no one-size-fits-all for jurisdictions given how each
traded among banks in wholesale markets — are already important implications for public policy dimensions:
prioritizes and adjudicates tradeoffs.
digitized and are recorded electronically on central bank competition and costs, privacy, financial inclusion,
balance sheets but are not widely available to the public. payments resiliency, and integrity. There are many
Currency or cash, in contrast, is widely available to the
public for use in retail transactions but not in digitized
form as a liability of the central bank (but as a liability
of a commercial bank). When policymakers discuss the
desirability and feasibility of a CBDC, they are really
focused on whether the central bank should make a
digitized central bank liability available to the public.
The emergence of CBDCs is consistent with historical
innovations in money that have reduced both holding and
transaction costs over time. Nevertheless, several factors
explain the recent growing interest in CBDCs. First, the
scale and scope of digital assets have grown significantly
over the past year, raising concerns in the official sector
that, absent further regulatory actions, growth may
outpace regulatory requirements, promote illicit finance,
and ultimately undermine financial stability. Second, there
has been increased research and exploration of CBDCs
among central banks to achieve various public policy
goals, including promoting monetary sovereignty and
fostering financial inclusion. Third, some believe that the
creation of a CBDC could help support national economic
competitiveness. Many of these factors were a key reason

The digital assets landscape | 10

Policymakers

Support remains mixed within and across jurisdictions • Carefully considering the trade-offs relating to CBDC
because of differing views on the opportunities and design, architecture, participation, and infrastructure
risks. Proponents suggest that CBDCs could strengthen including unintended consequences.
national competitiveness and promote growth due to
their programmability feature. CBDCs could also enhance
• Setting clear expectations with respect to roles,
responsibilities and accountability between public sector
the efficacy of fiscal and monetary policy, particularly
and private sector (e.g., “know you customer” (KYC),
during periods of economic stress. Other advantages
data security and privacy, operational resiliency).
include fostering standards that create greater
interoperability, thus enhancing digital connectivity • Consensus building mechanisms for developing of
and reducing financial transaction costs. Detractors technology standards that balance both domestic and
raise privacy, cybersecurity, financial stability and international use cases.
technological feasibility concerns. Some question the
• Understanding the programmability of payments.
underlying value proposition in light of the proliferation
of private stable coins and faster payment alternatives
(e.g., fast payment settlement systems). As a result,
the outlook for CBDCs is still being decided in major
economies given their potential impact on the balance
between opportunities and risks not just for the crypto-
asset market but for the economy as a whole.

As jurisdictions move forward with developing CBDCs,

key considerations for policymakers include:

• Clearly articulating the policy objective(s) the CBDC is

intended to achieve.

• Understanding what impact CBDC implementation could

have on the financial system.

• Assessing whether technological requirements are

specified in a manner consistent with stated policy
objectives.

The digital assets landscape | 11

Summary

Summary
There are close analogies already available to drive
regulation of digital assets with some modifications
to support the digital nature of these ecosystems. For
policymakers, this presents an opportunity to leverage
proven approaches that exist within their toolkit and
could incentivize earlier adoption by traditional financial
firms and crypto natives.
For traditional financial firms, they will need to come to
decisions soon about why and how they might engage in
crypto-asset markets and what areas they can engage
in prudently in a manner consistent with existing risk
management and compliance frameworks, as well as
regulatory requirements. For crypto natives the big issue
will be how they adapt to regulation by making greater
investments in risk management and compliance in the
absence of regulatory clarity and adapt their business
models to accommodate an environment that looks to be
increasingly more regulated.
CBDCs are gaining momentum as the trend toward
regulation evolves. The development and implementation
of CBDCs bears close watching as CBDCs can impact the
opportunities and risks in the digital asset market and,
therefore, the regulatory outcomes that responsible
innovation is intended to achieve. Policymakers are
considering fundamental design decisions to ensure
the successful deployment of CBDCs and take into
consideration the impact not just on digital asset
markets, but on economic growth, market functioning
and financial stability.

The digital assets landscape | 12

Authors

Authors
EY Global Regulatory Network EY Global Public Policy

Chris Woolard CBE Shawn Maher

GRN Chair and Partner, EMEIA Financial Global Vice Chair, Public Policy
Services Consulting Ernst & Young LLP
Ernst & Young LLP [email protected]
[email protected]

Katie Kummer
Alejandro Latorre Deputy Vice Chair, Public Policy
Principal, Financial Services Risk Ernst & Young LLP
Management Advisory [email protected]
Ernst & Young LLP
[email protected]
Fatima Hassan-Szlamka
Associate Director, Global Public Policy
Danielle Grennan Ernst & Young LLP
Senior Manager [email protected]
EMEIA Financial Services Regulatory
& Public Policy
Ernst & Young LLP
[email protected]
Blockchain

Assurance Paul Brody

Global Blockchain Leader
Ernst & Young LLP
Mike Leonardson
[email protected]
Partner
Ernst & Young LLP
[email protected]

Amarjit Singh
EMEIA Assurance Blockchain Leader
Ernst & Young LLP
[email protected]

The digital assets landscape | 13

Acknowledgments and Endnotes

Acknowledgments
We would like to thank the following individuals from the EY organization for
their contributions to this work: Laura Winthrop, Kevin Hannan, Andrew Hobbs,
Bridget Neil, Shauna Steele, Stevy Loy, Julia Tay, Lowri Maher, Kurt Hohl,
Eugene Goyne, Debra Greenberg, Chris Barford, and Igor Mikhalev.

Endnotes
1. IOSCO Decentralized Finance Report, International Organization of Securities Commissions, https://www.iosco.org/
library/pubdocs/pdf/IOSCOPD699.pdf, March 2022.
2. “Crypto Prices Move More in Sync With Stocks, Posing New Risks,” IMF Blog, https://blogs.imf.org/2022/01/11/
crypto-prices-move-more-in-sync-with-stocks-posing-new-risks/, January 2022.
3. “Crypto Market Sinks Below $1 Trillion After Latest DeFi Blowup,” Bloomberg News, https://www.bloomberg.com/
news/articles/2022-06-13/bitcoin-sinks-to-18-month-low-as-us-inflation-impact-spreads, 13 June 2022.
4. Assessment of Risks to Financial Stability from Crypto-assets, Financial Stability Board, https://www.fsb.org/wp-
content/uploads/P160222.pdf, 16 February 2022.
5. “FSB issues statement on the international regulation and supervision of crypto-asset activities,” Financial Stability
Board press release, https://www.fsb.org/2022/07/fsb-issues-statement-on-the-international-regulation-and-
supervision-of-crypto-asset-activities/, 11 July 2022.
6. “Federal Reserve Board provides additional information for banking organizations engaging or seeking to engage in
crypto-asset-related activities” - Federal Reserve Board, https://www.federalreserve.gov/newsevents/pressreleases/
bcreg20220816a.htm, 16 August 2022.
7. Regulatory sandbox, Financial Conduct Authority, https://www.fca.org.uk/firms/innovation/regulatory-sandbox,
November 2015.
8. “MAS Partners the Industry to Pilot Use Cases in Digital Assets,” Monetary Authority of Singapore press release,
https://www.mas.gov.sg/news/media-releases/2022/mas-partners-the-industry-to-pilot-use-cases-in-digital-assets,
31 May 2022.
9. See Neha Narula, “Building A Stronger Financial System: Opportunities of a Central Bank Digital Currency,”
testimony before the Senate Banking Subcommittee on Economic Policy, 9 June 2021.

The digital assets landscape | 14

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