Shift to a More Crypto-Friendly Regulation A closer look at some of the most popular emerging domiciliations - and actions taken in respect to regulation of crypto assets. HONG KONG ZUG, SWITZERLAND Action: Multiple warnings have been issued hinting that tokens may Action: Became a “crypto nation” by announcing a set of positive be subject to the securities law of Hong Kong. No clear guidelines have guidelines, differentiating between payment, utility, and asset been published so far.tokens. ICO Approach: Allowed; cautious regulationICO Approach: Allowed; methodical and forward-thinking approach Capital raised in ICOs in 2018: $272MCapital raised in ICOs in 2018: $556M SINGAPORE UNITED KINGDOM Action: Singapore government stated that cryptocurrencies are “capital Action: Launched a special “crypto assets task force” alongside the Bank market products” and may be subject to regulation under the securities of England & the FCA, striving to make the country the “global centre” for law. ICO issuers who structure security tokens must obtain a licence. crypto projects. ICO Approach: Allowed; heavy regulationICO Approach: Not yet regulated; approaches being evaluated Capital raised in ICOs in 2018: $658MCapital raised in ICOs in 2018: $490M MALTA FRANCE Action: “Blockchain Island” passed three cryptocurrency/blockchain bills Action: France pledged not to “miss out on the blockchain revolution” and in June 2018 and became the first country to approve a full framework for has launched the “PACTE” regulatory project. The new legal scheme - if distributed ledger technology regulation, that are due to come into effect approved by the parliament - will introduce legal definitions of Tokens and in Q4 2018. Malta’s transparent approach has attracted major exchanges ICOs, as well as a set of rules for securing the AMF’s “license” - certifying such as Binance, OKex, ZB.com, and Bitbay. transparency and diligence towards investors. ICO Approach: Allowed; transparent and forward-thinking regulationICO Approach: Not yet regulated; new legislation in development Capital raised in ICOs in 2018: £105MCapital raised in ICOs in 2018: $63M GIBRALTAR LITHUANIA Action: Government launched DLT regulatory framework in January 2018, Action: Lithuania issues a comprehensive set of “ICO Guidelines” covering with plans to set up a legal framework for ICOs and be the first country to regulation, taxation, accounting, and Anti-Money Laundering/ Combating offer proper regulatory oversight for token sales.the Financing of Terrorism (AML/CFT). The new regulation clearly ICO Approach: Allowed; transparent and forward-thinking regulationdistinguishes between security and utility tokens, and provides guidelines Number of successful ICO projects to date: $157Mon corresponding laws already in place. ICO Approach: Allowed; transparent and forward-thinking approach Capital raised in ICOs in 2018: $271M 18 19

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