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Cryptocurrency Regulatory and Legislative Analysis #11

Republished by Plato
Republished by Plato

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Cryptocurrency Regulatory and Legislative Analysis #11

July 5, 2023

Demetrios Tseas

Regulatory and Legislative Analysis – GLOBAL

Basel Committee on Banking Supervision publishes guidelines for cryptoassets treatment

The Basel Committee on Banking Supervision published its guidelines for the prudential treatment of cryptoassets exposures.  The standard outlines minimum regulatory, supervisory review and disclosure requirements of banks’ cryptoasset exposures under Pillars 1, 2 and 3 of the Basel Framework. Pillar 1 identifies two groups of cryptoassets. Group 1 assets refer to tokenized traditional assets and cryptoassets with effective stabilization mechanisms (i.e. “stablecoins”). Group 1 assets must meet the full set of classification conditions and need to be redeemable at the peg value at all times, including periods of extreme stress. The capital requirements of Group 1 assets are based on the risk weights (RWs) of underlying exposures. Group 2 assets are unbacked cryptoassets and tokenized traditional assets and stablecoins that fail to meet any of the Group 1 classification conditions. Group 2 assets have more stringent capital requirements than those applied to Group 1. Pillar 2 outlines the risk management of cryptoasset activities, noting that such frameworks must consider cryptoasset technology risk; general information; communication, technology and cyber risk; legal risks; and money laundering and financing of terrorism risks. Supervisors need to review the appropriateness of banks’ policies and procedures in line with these considerations. Pillar 3 states that banks must disclose information regarding any material cryptoasset exposures on a regular basis.

IMF working on CBDCs to enable transactions between countries

The International Monetary Fund (IMF) is reportedly working on a platform for CBDCs to enable transactions between countries.

World Economic Forum publishes whitepaper for DAOs 

On June 23, the World Economic Forum published a whitepaper “DAOs for Impact”.  Though nascent, Decentralized Autonomous Organizations (DAOs) are already driving change, revealing insights about the future of social impact.  This white paper seeks to summarize the nascent but growing field of experimentation in Impact DAOs.  It offers seven in-depth case studies of Impact DAOs and, based on this analysis, also presents common themes across these early experiments in using decentralized governance for social impact.

FATF moves Croatia, Cameroon and Vietnam to grey list

In a statement following a three-day summit in Paris, the Financial Action Task Force (FATF) moved Croatia, Cameroon and Vietnam onto what is called its grey list, a global watchlist of nations with strategic gaps in their anti-financial crime defenses. The FATF separately urged countries to strengthen regulatory supervision of cryptocurrency platforms.

FATF releases its targeted update on VA and VASPs implementation standards

On June 27, the Financial Action Task Force (FATF) released its targeted update on the implementation of the FATF Standards on Virtual Assets and Virtual Asset Service Providers (VASPs). FATF’s report finds that jurisdictions continue to struggle with fundamental requirements such as undertaking a risk assessment, enacting legislation to regulate VASPs, and conducting a supervisory inspection.  More than half of the 151 jurisdictions that responded to FATF’s 2023 survey, have still not taken any steps towards implementing the Travel Rule, which is a serious concern.  Regarding DeFi and unhosted wallets, FATF highlights that they are at risk of misuse, including by sanctioned actors, although they do not account for a large share of transactions.

Mastercard introduces Multi-Token Network

On June 28, Mastercard introduced Multi-Token Network (MTN), a tailor-made solution for the industry. Mastercard’s vision for MTN is to provide a set of foundational capabilities designed to make transactions within the digital asset and blockchain ecosystems secure, scalable and interoperable — ultimately enabling more efficient payment and commerce applications. MTN network has four pillars of trust, aiming to meet four key industry needs: Trust in counterparty; Trust in digital payment asset; Trust in technology; Trust in consumer protections. Trust in counterparty refers to effective identity management and permissions and the MTN will leverage Mastercard Crypto Credential to achieve this aim. Announced in April 2023, Mastercard Crypto Credential will establish a set of common standards and infrastructure that will help attest trusted interactions among consumers and businesses using blockchain networks. To achieve trust in digital payment assets, Mastercard will continue to support initiatives like the Regulated Liability Network by enabling regulated payment tokens to power financial applications. MTN seeks to bring trust in technology by ensuring scalability of blockchain networks and interoperability among them, as evidenced by its work with the Reserve Bank of Australia earlier this year. Finally, MTN will draw on Mastercard’s years of experience developing standards and rules for its card network to provide a common framework for trust in consumer protections. Beginning this summer, the beta version of MTN will be available in the U.K.  The first phase of the applications will be powered by tokenized bank deposits. Over time, MTN will be made available in additional markets around the world.

Regulatory and Legislative Analysis – NAM (United States & Canada) 

Genesis and Gemini Request Court to Dismiss SEC Suit Targeting Earn Program

Bankrupt crypto lender Genesis Global Capital and exchange platform Gemini have filed a request with a U.S. court to dismiss a lawsuit by the Securities and Exchange Commission (SEC) accusing them of selling unregistered securities. The lawsuit targets Gemini’s Earn program, alleging that the entities raised billions of dollars in crypto assets from investors. Gemini argues that it did not require any lending or borrowing and disputes the SEC’s treatment of the Master Digital Asset Loan Agreement (MDALA) as an unregistered security. Genesis, which is owned by the Digital Currency Group (DCG), held around $900 million in assets belonging to Gemini Earn investors before freezing withdrawals and filing for bankruptcy.

SEC charges Binance for misrepresenting trading controls and for operating unregistered exchanges and securities

On June 5, the Securities and Exchange Commission (SEC) sued Binance and its founder Changpend Zhao (CZ), and filed thirteen charges against Binance entities and CZ.  The charges include operating unregistered exchanges, broker-dealers, and clearing agencies; misrepresenting trading controls and oversight on the Binance US platform; and the unregistered offer and sale of securities.  In response to the current legal and regulatory environment in the United States, Binance US announced that it will temporarily suspend USD transactions starting on June 13th, temporarily transitioning to an all-crypto exchange.

SEC charges Coinbase for operating as an unregistered agency and sale of securities

On June 6, the SEC sued Coinbase for allegedly violating securities laws by operating an unregistered exchange, noting the company has never registered with the SEC as a broker, national securities exchange or clearing agency.  The suit points out Coinbase’s products like Prime, Wallet, and staking as well as highlights thirteen tokens Coinbase offered and sold as investment contracts: Solana (SOL), Cardano (ADA), Polygon (MATIC), Filecoin (FIL), The Sandbox (SAND), Axie Infinity (AXS), Chiliz (CHZ), Flow (FLOW), Internet Computer (ICP), NEAR Protocol (NEAR), Voyager (VGX), Dash (DASH), and NEXO (NEXO).  Under what is known as the “Howey Test” an investment contract is defined as an investment of money, in a common enterprise, with the expectation of profit, generated form the efforts of others. Accordingly, this test determines what is considered a “security” and thus falls under the oversight of the SEC.

U.S. court rejects Federal Reserve’s motion to dismiss Custodia Bank case

In Oct 2020, Custodia applied to the Federal Reserve Bank of Kansas (FRBKC) to obtain a Federal Reserve “master account,” an  account that an approved financial institution can use to directly access wholesale payment systems and certain Fed payment services.  In Aug 2021, Custodia also applied to the Federal Reserve Board of Governors for membership in the Federal Reserve, which would subject Custodia to oversight and regulation by the Federal Reserve Board.  Roughly two years later, FRBKC has yet to grant or deny Custodia’s application for a master account.  In June 2022, Custodia sued the Federal Reserve, claiming an “unlawful delay” in processing an application for its master account.  The Federal Reserve’s latest motion to dismiss Custodia Bank’s lawsuit was rejected which now allows Custodia to continue its pursuits.  Wyoming-based Custodia Bank is a depository institution that presents itself as unlike a  traditional bank because it is “designed to provide custody services for digital assets such as Bitcoin via their trust departments” and “provide a bridge connecting digital asset companies to the U.S. payments system”.  Custodia is state-chartered as a Special Purpose Depository Institution (SPDI), intended to facilitate cryptocurrency banking that is prohibited from making loans. It is also chartered to allow the traditional banking service of U.S. Dollar deposit-taking.

Coin Dispute Network, a fraudulent crypto recovery company, is taken down by Manhattan’s District Attorney’s Office

On June 7, Manhattan’s District Attorney Office announced that it seized the website domain for Coin Dispute Network, a fraudulent cryptocurrency recovery company exposed during an investigation that has identified multiple victims in Manhattan and dozens more across the country.  Coin Dispute Network purported to act as a tracing and recovery service for people whose cryptocurrency was stolen in exchange for a fee.

Mt. Gox hackers charged in the South District of New York

Russian Nationals Bilyuchenko and Verner were charged in the Southern District of New York with conspiring to launder approximately 647,000 bitcoins from the 2011 hack of Mt. Gox.  Bilyuchenko was separately charged in the Northern District of California with conspiring with Alexander Vinnik to operate the illicit cryptocurrency exchange BTC-e from 2011 to 2017. At the time, Mt. Gox was the largest bitcoin exchange in existence, servicing thousands of users worldwide, including users in the Southern District of New York.

CFTC finds a “DAO is a Person”

On June 9, the Commodities Futures Trading Commission (CFTC) released a statement on a federal judge’s ruling  in favor of the CFTC in a civil enforcement action against Ooki DAO, declaring that the Decentralized Autonomous Organization (DAO) is considered a “person” under the Commodity Exchange Act and therefore can be held liable for violations of the law. The court then held that the Ooki DAO did, in fact, violate the law as charged.  The founders of Ooki DAO settled the case with a fine, while the DAO itself was ordered to pay a civil monetary penalty, shut down completely, and remove its content from the internet, setting a precedent that raises concerns for the viability of DAO structures.

Blackrock and Fidelity file for a spot Bitcoin EFT

On June 15, Blackrock, the world’s largest asset manager, filed paperwork with the U.S. Securities and Exchange Commission (SEC) to form a spot bitcoin Exchange-traded fund (ETF).  The ETF will be named iShares Bitcoin Trust and will consist of bitcoin held by a custodian (Coinbase) on behalf of the trust.  A few days later, on June 29, Fidelity Investments also filed an application to launch a spot bitcoin Exchange-Traded Fund (ETF) as well as  list the Wise Origin Bitcoin Trust, the name of Fidelity’s previously proposed bitcoin ETF  denied by the Securities and Exchange Commission on Jan 2022.  ETFs are pools of bitcoin related assets offered on traditional exchanges by brokerages, which allow investors to invest in crypto without actually owning any.

U.S. attorney and federal law enforcement partners announce formalization of Darknet marketplace and digital currency crimes task force

U.S. Attorney Gary M. Restaino, HSI SAC Scott Brown, IRS-CI SAC Al Childress, DEA SAC Cheri Oz, and United States Postal Inspection Service Acting Inspector in Charge Greg Torbenson announced  the formalization of a Darknet Marketplace and Digital Currency Crimes Task Force (DNMDCC Task Force). Since 2017, these federal partners in Arizona have focused on darknet drug vendors and cryptocurrency-enabled crimes, and have collectively investigated and prosecuted many cases in recent years.  As the technology evolves, criminal activities have become more sophisticated. As such, law enforcement tools, resources, and intelligence have had to adapt. The stated goal of the DNMDCC Task Force is to “provide increased collaboration, enhance resources, and disrupt and dismantle criminal organizations that are using these new and emerging technologies.”

Fed chair Jerome Powel calls stablecoins a “form of money” and says CDBD is far from being a reality

On June 21 Federal Reserve Chair Jerome Powel testified before the House Committee on Financial Services. In his testimony he calls crypto an asset class and stablecoins a “form of money”: “We do see payment stablecoins as a form of money, and in all advanced economies, the ultimate source of credibility in money is the central bank. We believe it would be appropriate to have quite a robust federal role.”  The Fed Chair also talked about the potential of a Central Bank Digital Currency (CBDC), stating that the US is a long way from making this happen.

Crypto-custodian Prime Trust ordered by Nevada’s regulator to cease all activities

On June 21, Nevada’s Department’s Financial Institutions Division (FID), which oversees state regulated trust entities, ordered crypto-custodian Prime Trust to cease all activities, in violation of Nevada regulations.  The order says that Prime Trust is allegedly operating at a substantial deficit, or may even be insolvent, and that it had lost access (private keys) to legacy wallets in 2021 and used customer assets to buy back crypto. A few days earlier, Bitgo announced it was terminating its bid to acquire Prime Trust.

Regulatory and Legislative Analysis – EMEA

UAE Central Bank issues new AML/CFT guidance for licensed financial institutions

The Central Bank of the UAE (CBUAE) issued new guidance on anti-money laundering and combatting the financing of terrorism (AML/CFT) for Licensed Financial Institutions (LFIs), which includes banks, finance companies, exchanges, payment service providers, registered hawala providers and insurance companies, agents and brokers. The new guidance discusses risks arising from dealing with virtual assets (VA) and virtual asset service providers (VASP) (i.e. hacks; scams; disintermediating third-party regulated entities; lack of KYC due to anonymous transactions; use of mixers and tumblers; high-volume and high-frequency cross-border transactions) and sets out clear descriptions of VAs, VASPs and VASP business models.  The guidance outlines the customer due diligence (CDD) and enhanced due diligence (EDD) for LFIs to take towards potential VASP customers and counterparties, with the aim of managing financial crime risk, supporting them with training programs,  governance system development and record-keeping mechanisms. The new guidance will come into effect within one month.

Bybit obtains pre-approval in Kazakhstan shortly after exiting Canada

Cryptocurrency exchange Bybit received “in-principle” approval from Kazakhstan’s Astana Financial Services Authority (AFSA) to operate as a digital asset trading facility and custody services provider at the Astana International Financial Centre (AIFC).  AFSA registry’s records indicate that Bybit (Bybit Limited) is registered in Kazakhstan with a BIN 211140900046.  A few days earlier, on May 30, Bybit announced it was exiting Canada, claiming recent regulatory developments.  Effective July 31, 2023, Canadian customers will no longer be able to make new deposits, but they can withdraw or reduce their positions.

UK’s FCA published policy statement: Financial promotion rules for cryptoassets

UK’s Financial Conduct Authority (FCA) published a policy statement on financial promotion, as well as a guidance on  cryptoasset financial promotions.  Under the proposal, cryptoassets will be classified as Restricted Mass Marketed Investments (RMMI) under  the financial promotion rules. Thus, such promotions are subject to rules such as risk warnings, a ban on inducements to invests and rules for direct offer financial promotions.  The FCA welcomes views on the topic covered in the guidance consultation by August 10th, before the regime comes into force on October 8th, 2023, giving 4 months for implementation.

EU’s landmark MiCA crypto law published in official journal

On June 9, the European Union’s Markets in Crypto Asset law (MiCA) was published in the Official Journal of the European Union.  The new law specifies the implementation of the so-called “travel rule”, meaning that information on the source of the asset, the payer and beneficiary will have to “travel” with the transaction and be stored on both sides of the transfer.  The law also covers transactions above €1,000 from self-hosted wallets when they interact with hosted wallets managed by crypto-asset service providers. The rules do not apply for person-to-person transfers conducted without a provider or among providers acting on their own behalf. They also introduce the concept of “passporting”, meaning that a payment service provider that has a license within one EU member state can “passport” this license to any other EU member state. Finally, the new law covers issuers of stablecoins and service providers such as trading venues and the wallets where crypto-assets are held.  The two laws enter into force in 20 days’ time, and its provisions apply on December 30, 2024, with certain provisions taking effect slightly earlier on June 30, 2024.

Binance asks UK’s FCA to cancel unused permissions, leaves the Netherlands, withdraws its registration in Cyprus and Austria and is ordered to cease offers in Austria

UK’s Financial Conduct Authority has cancelled several permissions given to Binance’s subsidiary, Binance Markets Limited, for “activities it never carried out or offered” in the UK, on the company’s request.  A few days earlier, Binance announced it is leaving the Netherlands after not being able to obtain a Virtual Asset Service Provider (VASP) license these.  It is also withdrawing its license registration with the  Cyprus regulator and with the Financial Market Authority of Austria.  Apparently, Binance wishes to focus on preparations to be fully compliant with MiCA when it is implemented in the next 18 months, which will allow license passporting throughout Europe.   Belgium’s Financial Services and Markets Authority (FSMA), ordered Binance to immediately cease all offers of virtual currency services in the country, while Nigeria’s Securities and Exchange Commission (SEC) announced that Binance Nigeria Limited is neither registered nor regulated by the Commission and its operations in Nigeria are therefore illegal.

Gemini becomes first company to be registered as a VASP in Ireland

On June 19, Gemini announced that it is the first company to be registered as a Virtual Asset Service Provider (VASP) by the Central Bank of Ireland. Earlier in May Gemini selected Dublin as the location of its European headquarters.  This move is associated with the new Markets in Crypto-Assets (MiCA) regulation, published in the Official Journal of the European Union as of June 9 and which is set to apply from next year.  Gemini is undergoing preparations to apply for a MiCA license (which can then be passported to any EU member state) as soon as the regulator begins accepting applications.

Deutsche Bank applies for a digital asset custody license in Germany

On June 20, Deutsche Bank, Germany’s largest banking institution, reportedly applied for a digital asset custody license with the country’s regulator, the Federal Financial Supervisory Authority (BaFin).  This comes days after Blackrock applied for a spot bitcoin ETF with the SEC in the United States.

UK passes Financial Services and Markets bill, setting the stage for stablecoins

The UK’s House of Lords passed the Financial Services and Markets Bill (FSMB), recognizing cryptocurrencies as regulated activities and stablecoins as a viable means of payment.  The UK’s regulatory approach aligns with that of the European Union (EU), which recently introduced the Markets in Crypto Assets (MiCA) legislation. However, the FSMB may be returned to the lower house of parliament for finalization and alignment with EU standards.

Lithuania’s regulator revokes Cryptopay EU card provider license

On June 22, the Bank of Lithuania revoked the license of the electronic money institution UAB PAYRNET, the EU debit card provider for Cryptopay, for “serious, systematic and multiple violations of legal acts.” ncluding violations related to the prevention of money laundering and terrorist financing, the implementation of international sanctions and restrictive measures. This means that the institution can no longer provide financial services and has to return the funds to its clients within the set time limit. The Bank of Lithuania will apply to the court for the initiation of bankruptcy proceedings against the institution and also intends to apply to law enforcement authorities.

JP Morgan rolls out its JPM Coin blockchain payments to the eurozone

On June 23, JP Morgan announced its JPM Coin blockchain payments to the Eurozone, after announcing plans last year. Until now, the solution from the JP Morgan Onyx division was only available in US dollars.  Deposit tokens, also referred to as “tokenized deposits”, are transferable tokens issued on a permissioned blockchain, by a licensed depository institution, which evidence a deposit claim against the issuer.  Given that deposit tokens are commercial bank money embodied in a new technical form, they sit as part of the banking ecosystem, subject to regulation and supervision applicable to commercial banks today (i.e. capital and liquidity requirements).  Tokenized deposits can serve as payment rails and as well as a deposit account ledger used within the bank (JP Morgan) or JP Morgan participating clients to transfer funds on deposit with J.P. Morgan within the system. This facilitates the institutional movement of liquidity funding and payments in real time.  Reportedly, Siemens was the first client to use the euro JPM Coins.

Israel seizes crypto accounts controlled by Hezbollah and Quds Force

On June 27, Israel reportedly seized crypto accounts controlled by Hezbollah and Quds Force, the extraterritorial branch of Iran’s Islamic Revolutionary Guard Corps, in a first of its kind operation. The accounts had millions of dollars and came thanks to a new tool developed by Israeli security agencies.

Law Commission of England and Wales publish recommendations for the law relating to digital assets.

On June 28, the Law Commission of England and Wales published recommendations for the reform and development of the law, relating to digital assets, which include crypto-tokens (sometimes referred to as ‘cryptocurrencies’) and non-fungible tokens (NFTs).  These recommendations included the following:   1) Confirm and establish the existence of a distinct third category of personal property under the law which can better recognize, accommodate and protect the unique features of digital assets;  2) Create a panel of industry-specific technical experts, legal practitioners, academics and judges to provide non-binding advice to courts on complex legal issues relating to digital assets; 3) Create a bespoke legal framework that better facilitates the entering into, operation and enforcement of collateral arrangements relating to crypto-tokens and crypto-assets;  and 4) Statutory law reform to clarify whether certain digital assets fall within the scope of the Financial Collateral Arrangements (No 2) Regulations 2003.

Seychelles-based crypto exchange KuCoin to introduce mandatory KYC for all clients

Seychelles-based crypto exchange KuCoin (ranked #4 in terms of 24hrs trading volume), announced it will introduce mandatory Know Your Customer (KYC) for all its clients, aiming to be better compliant with the applicable regulatory requirements.  Starting July 15th, new registered users must complete KYC in order to use KuCoin’s products and services. Services that will still be allowed without completing KYC procedures include spot trading sell orders, futures, trading deleveraging, and margin trading deleveraging.

Regulatory and Legislative Analysis – APAC

Bali, Indonesia warns foreign tourists not to pay with crypto

Local authorities in Bali, Indonesia reportedly issued a warning to foreign tourists, stating that those who use cryptocurrency as a means of payment in hotels, restaurants, shopping centers etc., will face strict consequences (fines, imprisonment).  In Indonesia, the ability to hold crypto as an asset is permitted. However, all payments in crypto are banned, as Indonesia requires that payments be settled  in the local currency (Rupiah).

Crypto.com receives MPI license in Singapore

On June 1, Crypto.com announced that it obtained a major payment institution license from the Monetary Authority of Singapore.

Circle receives a digital token license in Singapore

On June 7, Circle announced that it has secured a Major Payment Institution (MPI) from the Monetary Authority of Singapore (MAS), meaning that it can offer USDC digital payment token domestic and cross-border money transfer services in the city state.  Services will be provided by Circle Internet Singapore Pte. Ltd. (Circle Singapore) is an affiliate of Circle Internet Financial, LLC (Circle) based and incorporated in Singapore.

Australian Government releases its Strategic Plan for the future of payments

On June 7, the Australian Government released its Strategic Plan for the future of Australia’s payment system, which sets out its policy objectives and priorities for its payment system. Some of the priorities include: reducing the prevalence of scams and fraud; supervising systematically important payment systems; updating the payments regulatory framework; establishing a new payments licensing framework; and supporting the broader use of Digital ID and Exploring the policy rationale for a CBDC in Australia. The government has also issued a consultation “Licensing of payment service providers-payment functions” that is intended to underpin a new licensing framework for payment service providers. Responses to this consultation can be submitted until 19 July 2023.

Hong Kong’s SFC publishes Licensing Handbook for Virtual Asset Trading Platforms

Hong Kong’s Securities and Futures Commission (SFC) published in June its “Licensing Handbook for Virtual Asset Trading Platform Operators”.  This Handbook provides general information on licensing matters in relation to virtual asset trading platform operators under the Securities and Futures Ordinance and AML/CFT laws. In Hong Kong it is a serious offence to carry on a regulated activity and/or a Virtual Asset service without the required license.

HKMA is pressuring major banks to take on crypto exchanges as clients

The Hong Kong Monetary Authority (HKMA), reportedly has put pressure on major banks to take-on crypto exchanges as clients.  Hong Kong is pushing to establish itself as a global center for the crypto-industry. However, banks are reluctant to take on crypto-exchanges as their customers, over fears they could be prosecuted over money laundering and other illegal activity consideration.  “Banks should not be afraid while due diligence on potential (crypto-exchanges) customers should not create undue burden,” says the HKMA.

High yield lenders Delio and Haru Invest halt withdrawals in Korea

Two high-yield crypto lenders in Korea, Delio and Haru Invest, have reportedly halted withdrawals and deposits, expecting class-action lawsuits from their investors.

Nigeria’s SEC: Binance Nigeria neither registered nor regulated

Nigeria’s Securities and Exchange Commission (SEC) announced that Binance Nigeria Limited, is neither registered nor regulated by the Commission and its operations in Nigeria are therefore illegal.

Regulatory and Legislative Analysis – LAC

Brazil’s Largest Exchange – Mercado Bitcoin Granted Payment License

The company has reportedly received authorization to function as a payment institution, operating as an electronic money issuer.

IMF Releases Statement on Central Bank Digital Currencies and Crypto Use Trends in Latin America and the Caribbean

On June 22, the International Monetary Fund (IMF) released a statement regarding the use of digital assets in Latin American and the Caribbean (LAC) and the potential central bank digital currencies (CBDCs) have in the region. The authors provide an overview of the history of CBDCs in the LAC, noting the Bahamas’ 2020 Sand Dollar as a global pioneer in the space. The statement also notes that four Latin American countries (Argentina, Brazil, Colombia and Ecuador) ranked among the top 20 in global crypto adoption in 2022. Finally, the authors also note that, if well-designed, CBDCs can strengthen the resiliency of Latin American payment systems and increase financial inclusion in the region.

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