The Breakdown - IMF Financial Stability Report Highlights Crypto
Episode Date: April 20, 2022This episode is sponsored by Nexo.io, Arculus and FTX US. On today’s episode, NLW looks at the latest Financial Stability report from the International Monetary Fund. The report looks at ho...w the war in Ukraine is impacting financial stability. NLW argues that it sends mixed messages on crypto – arguing that the war highlights a set of new risks arising from cryptocurrencies while also recognizing that the prognostications of sanctions evasion haven’t come to pass. - From cash to crypto in no time with Nexo. Invest in hot coins and swap between exclusive pairs for cash back, earn up to 17% interest on your idle crypto assets and borrow against them for instant liquidity. Simple and secure. Head on to nexo.io and get started now. - Arculus™ is the next-gen cold storage wallet for your crypto. The sleek, metal Arculus Key™ Card authenticates with the Arculus Wallet™ App, providing a simpler, safer and more secure solution to store, send, receive, buy and swap your crypto. Buy now at amazon.com. - FTX US is the safe, regulated way to buy Bitcoin, ETH, SOL and other digital assets. Trade crypto with up to 85% lower fees than top competitors and trade ETH and SOL NFTs with no gas fees and subsidized gas on withdrawals. Sign up at FTX.US today. - Consensus 2022, the industry’s most influential event, is happening June 9–12 in Austin, Texas. If you’re looking to immerse yourself in the fast-moving world of crypto, Web 3 and NFTs, this is the festival experience for you. Use code BREAKDOWN to get 15% off your pass at www.coindesk.com/consensus2022. - Enjoying this content? SUBSCRIBE to the Podcast Apple: https://podcasts.apple.com/podcast/id1438693620?at=1000lSDb Spotify: https://open.spotify.com/show/538vuul1PuorUDwgkC8JWF?si=ddSvD-HST2e_E7wgxcjtfQ Google: https://podcasts.google.com/feed/aHR0cHM6Ly9ubHdjcnlwdG8ubGlic3luLmNvbS9yc3M= Join the discussion: https://discord.gg/VrKRrfKCz8 Follow on Twitter: NLW: https://twitter.com/nlw Breakdown: https://twitter.com/BreakdownNLW -- “The Breakdown” is written, produced by and features Nathaniel Whittemore aka NLW, with editing by Rob Mitchell, research by Scott Hill and additional production support by Eleanor Pahl. Jared Schwartz is our executive producer and our theme music is “Countdown” by Neon Beach. The music you heard today behind our sponsor is “I Don't Know How To Explain It” by Aaron Sprinkle. Image credit: Al Drago/Bloomberg via Getty Images, modified by CoinDesk. Join the discussion at discord.gg/VrKRrfKCz8.
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Welcome back to The Breakdown with me, NLW.
It's a daily podcast on macro, Bitcoin, and the big picture power shifts remaking our world.
The breakdown is sponsored by nexus.io, Arculus, and FtX, and produced and distributed by CoinDesk.
What's going on, guys? It is Tuesday, April 19th, and today we are talking about the IMF's latest financial stability report.
And specifically, it's kind of extensive comments about the...
crypto and digital asset space. Before we dig in, however, a few housekeeping items.
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So today we're going to touch on a couple of different topics, but first we're going to go to this
title story of the International Monetary Fund's just released report called
Shockwaves from the War in Ukraine test the financial system's resilience.
The subheader is financial stability risks have risen as war tests the resilience of the
financial system through various channels.
Now, this is a really important topic, right?
We live in a highly globally interconnected economy and such a big disruption has
ramifications for the resilience of the system.
In fact, in a lot of ways, you could view the breakdown for the past couple of months as being a daily update on the resiliency or threats to resiliency of the financial system.
What's interesting here is how much crypto features as a part of this report, even though the conclusion is largely about stuff that might happen in the future.
The introduction says crypto asset trading volumes against some emerging market currencies have spiked, following the introduction of sanctions against Russia and the use of capital restrictions in Russia and Ukraine.
This is occurring against a longer-term increase in such cross-border transactions,
bringing to the four the challenges of applying capital flow measures and sanctions.
And really here in this first couple of sentences, you have the position, I believe, of this report,
which is more or less using the Ukraine and Russia war as a way to talk about how crypto could be
a problem in the future, despite there not being a lot of evidence that it's a problem right now.
The key section is called risks of cryptoization and sanction evasion
through the crypto ecosystem.
And here's the key section.
The war in Ukraine has brought to the forefront
some of the challenges that regulators face
in terms of applying sanctions
and capital flow management measures.
Crucially, the implementation of such measures
require that intermediaries
verify the identities of the transacting parties.
The crypto ecosystem, however,
could allow users to circumvent such requirements
through several means,
including, one, the use of exchanges
and other crypto asset providers
that are non-compliant with sanctions
and or capital flow management measures,
two, poor implementation of adequate due diligence procedures by crypto asset providers, and three,
the use of technologies and platforms that increase the anonymity of transactions, such as mixers,
decentralized exchanges, and privacy coins.
Interestingly, the report also hones in on mining, saying, over time, sanctioned countries
could also allocate more resources towards evading sanctions through mining.
Mining for energy-intensive blockchains like Bitcoin can allow countries to monetize energy
resources, some of which cannot be exported due to sanctions.
The monetization happens directly on blockchains and outside the financial system where the sanctions
are implemented.
Miners can also generate revenues directly from users that pay transaction fees to miners, which
in this case might be sanctioned governments.
At this point, the share of mining in countries under sanctions and the overall size
of mining revenues suggest that the magnitude of such flows is relatively contained, though
risks to financial integrity remain.
For example, the monthly average of all Bitcoin mining revenues last year was about $1.4 billion,
of which Russian miners could have captured close to 11%, and Iranian miners 3%.
Now, there's a lot to unpack around this mining section.
For example, one could reverse this argument in a pretty significant way.
What I mean by that is that the IMF is coming at this talking about how it would be within the power
of sanctioned governments to use mining to evade those sanctions, or to just have another way
to monetize their energy resources.
You could also see this as a strategic imperative for those countries that are applying
sanctions on places like Russia and Iran to create incentives for Bitcoin miners to be located there.
Remember, in the wake of China's mining ban, the biggest beneficiary in the world was the United
States. We've recently read a number of pieces on Longreed Sunday about Bitcoin as a strategic
national imperative, and this is a great example of why, even though the IMF is kind of making
the case from the opposite angle. Now, when it comes to their arguments around sanctions evasion,
they do note in the report that this is largely future-focused because in terms of right now,
they write, liquidity in the rubble and herivnia trading pairs in centralized exchanges remains limited
and has even declined more recently in the case of the rubble, making large-scale transfers of value
through crypto-asset exchanges impractical.
So to be clear, despite giving a bunch of time and space to crypto and digital assets
destabilizing effect in the context of this war, they're also saying that the evidence suggests
that it's not actually happening in this war
and it's just something to look at going forward.
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What really got people's attention was a call for crypto to be included in capital controls.
Quote, laws and regulations for foreign exchange and capital flow management measures should
be reviewed and amended if necessary to cover crypto assets, end quote.
This is despite the fact that Bitcoin and other crypto assets don't formally count as financial
assets or foreign currency in most places. There is something of an interesting divide.
growing, it seems, between the U.S. and Europe as it relates to the digital asset industry
and the impact of Russia's war in Ukraine. In the U.S., we've seen no less than the Treasury of
the Secretary Janet Yellen and other members of the Treasury Department, having to frequently
explain to press, to the Congress, to Senate, that crypto is not, in fact, being used for sanctions.
European politicians and political bodies, however, have been somewhat more hostile.
There are recent comments of folks like Christine Lagarde, the president of the European Central Bank,
who have continued to argue that digital assets should be a bigger focus given their potential for sanctions evasion,
but it's also playing out in the regulatory sphere as well.
Remember, the European Parliament is moving forward with rules that would force exchanges to collect data
on basically any transaction that interacts with a self-hosted wallet.
Crypto advocates in Europe are saying that this is more burdensome than rules for traditional finance,
and that community is really worried about the potential implications and chilling effect on European
crypto.
Meanwhile, over in the UK, the Chancellor of the Exchequer is now making a new push to turn Britain
into a global hub for crypto.
This includes new regulatory review around defy, integration of stablecoins as a recognized
form of payment, and even the Royal Mint printing their first NFT.
Meanwhile, as I mentioned a minute ago, in the U.S., there has been a lot of optimism in the wake of
Biden's executive order on crypto. We neither got the rushed rulemaking that some were worried about,
nor certainly anything resembling a ban that some commentators had said was likely to come.
Instead, what we got was a pretty standard there are opportunities and there are challenges
political document. But the practical action was to organize the various departments of the
government in a large-scale coordinated research process to help create coherent national policy
around crypto and digital assets. This more positive tone was validated a couple of weeks ago
by Treasury Secretary Yellen's speech, which featured, among other things, an articulation of the
history of Satoshi and Bitcoin. But while the general trajectory of U.S. regulation is heading in a
positive direction, there is currently a bit of a dust-up right now around an SEC rulemaking process
that some think would expand the definition of exchanges in ways that could be bad for crypto
and, frankly, technology in general. The block points to two recent recent,
proposals from the SEC, which, quote,
push for expanded definition of terms that appear in the 1934 Securities Exchange Act.
In general, the rulemaking seems to require crypto exchanges to register with the SEC
as exchanges and market makers to register with the SEC as broker dealers.
The big concern here is not just crypto specifically, but just the potential implications
of those expanding definitions as a whole.
SEC Commissioner Hester Purse, in her dissenting statement on this from January, wrote,
A final message to those who operate any service that is designed to facilitate any communication
between potential buyers and sellers of any type of security.
Read this release.
Even if you have nothing to do with government securities or even fixed income, or with traditional
securities, read this release.
Preferably as soon as it is published on the commission's website.
It covers a lot of ground and you should not assume that it has nothing to do with you, because
it probably does.
Fin twit main state chairman, Burr-Bernacki, said,
the SEC really said, screw it, we should make everything in exchange. That language, by the way,
was edited for family safety. Going on, Burb says, technology, and exchange. Signal, exchange. Ice chat,
separate from ice, it's now its own exchange, too. If they go by the broader definition of bringing
together people to buy and sell stuff, Facebook marketplace is in exchange. There have been a ton
of crypto companies commenting on this as well as you might expect, but it's not just the industry
that has taken notice. On April 18th, two,
senior members of the House Financial Services Committee, including ranking Republican
member Representative Patrick McHenry, Republican from North Carolina, and Bill Huizenga,
Republican from Michigan, wrote a letter to SEC Chair Gary Gensler with a pretty loud
critique of these recent rulemakings. They write, the SEC fails to identify the problem that the
rulemakings are intended to solve, particularly as it relates to requiring certain market
participants facilitating digital asset transactions to register with the SEC. The letter from the
representatives also critiques the approach to the rulemaking specifically in terms of their length.
Quote, we are concerned the proposed rulemakings total nearly 800 pages and include more than 300
questions for comments combined. So where we are now is we're in the open comment period and, as I said,
crypto organizations of All Stripes have been sharing their public comments. If you want to see the
tenor of that discussion and their specific arguments, go check out Jake Chavinsky on Twitter.
Jake is at Jay Chavinsky and he's the head of policy.
blockchain association. He sums it up, quote, as usual, the crypto industry is showing up in a big
way. And I think this is a really important thing to keep in mind as we have more and more of these
moments where there are big things going on around the world of regulations in particular that seem
like they might have dramatic impact for the crypto industry. More than ever, the digital asset space
is in the regulatory and political spotlight. There are going to be more of exactly these types of
debates and discussions. The government, particularly in the U.S., laborious though it might be,
also creates space for public comment, for discussion, for discourse. There are paths and avenues
for companies and advocates for this industry to go speak to representatives. Indeed, for as much
as we see on Twitter now with public comments, there's a huge amount of dialogue and discourse going on
constantly and not just around frustrating rules, but around everything between the industry,
elected officials and representative bodies. I continue to think that while we're in a period of
heightened importance as it relates to the regulatory process, it's hard not to see it as a net
positive thing given how engaged the industry is and given how many politicians seem to be willing
to be engaged with us as well. There is a huge amount of open space to educate and engage
politicians from all parts of the political spectrum, and each one of these moments offers a chance
to do exactly that. For now, I want to say thanks again to my sponsors, nexo.io, Arculus and FtX, and thanks to
you guys for listening. Until tomorrow, be safe and take care of each other. Peace.
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