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PALGRAVE STUDIES IN
FINANCIAL SERVICES TECHNOLOGY
Regulation of
Cryptocurrencies
and Blockchain
Technologies
National and
International Perspectives
Second Edition
Rosario Girasa
Palgrave Studies in Financial Services Technology
Series Editor
Bernardo Nicoletti, Rome, Roma, Italy
The Palgrave Studies in Financial Services Technology series features orig-
inal research from leading and emerging scholars on contemporary issues
and developments in financial services technology. Falling into 4 broad
categories: channels, payments, credit, and governance; topics covered
include payments, mobile payments, trading and foreign transactions, big
data, risk, compliance, and business intelligence to support consumer and
commercial financial services. Covering all topics within the life cycle of
financial services, from channels to risk management, from security to
advanced applications, from information systems to automation, the series
also covers the full range of sectors: retail banking, private banking, corpo-
rate banking, custody and brokerage, wholesale banking, and insurance
companies. Titles within the series will be of value to both academics and
those working in the management of financial services.
Rosario Girasa
Regulation
of Cryptocurrencies
and Blockchain
Technologies
National and International Perspectives
Second Edition
Rosario Girasa
Lubin School of Business
Pace University
Pleasantville, NY, USA
ISSN 2662-5083 ISSN 2662-5091 (electronic)

Palgrave Studies in Financial Services Technology
ISBN 978-3-031-21811-8 ISBN 978-3-031-21812-5 (eBook)
https://doi.org/10.1007/978-3-031-21812-5
1st edition: © Springer International Publishing 2018

2nd edition: © The Editor(s) (if applicable) and The Author(s), under exclusive license
to Springer Nature Switzerland AG 2023
This work is subject to copyright. All rights are solely and exclusively licensed by the
Publisher, whether the whole or part of the material is concerned, specifically the rights
of translation, reprinting, reuse of illustrations, recitation, broadcasting, reproduction on
microfilms or in any other physical way, and transmission or information storage and
retrieval, electronic adaptation, computer software, or by similar or dissimilar methodology
now known or hereafter developed.
The use of general descriptive names, registered names, trademarks, service marks, etc.
in this publication does not imply, even in the absence of a specific statement, that such
names are exempt from the relevant protective laws and regulations and therefore free for
general use.
The publisher, the authors, and the editors are safe to assume that the advice and informa-
tion in this book are believed to be true and accurate at the date of publication. Neither
the publisher nor the authors or the editors give a warranty, expressed or implied, with
respect to the material contained herein or for any errors or omissions that may have been
made. The publisher remains neutral with regard to jurisdictional claims in published maps
and institutional affiliations.
This Palgrave Macmillan imprint is published by the registered company Springer Nature
Switzerland AG
The registered company address is: Gewerbestrasse 11, 6330 Cham, Switzerland
Also, by author under the name of Rosario Girasa or Roy J. Girasa
Cyberlaw: National and International Perspectives (Prentice-Hall, 2002)
Corporate Governance in Finance Law (Palgrave Macmillan, 2013)
Laws and Regulations in Global Financial Markets Palgrave Macmillan,
(2013)
Shadow Banking: Rise, Risks, and Rewards of Non-Bank Financial
Services (Palgrave Macmillan, 2016)
Regulation of Cryptocurrencies and Blockchain Technologies: National
and International Perspectives (Palgrave Macmillan, 2018)
Artificial Intelligence as a Disruptive Technology (Palgrave Macmillan,
2020)
Regulation of Innovative Technologies (with Gino J. Scalabrini) (Palgrave
Macmillan, 2022)
Bartlett Family—George, Carol, Susan, Karen, and Laura
and
Marie Manganelli
Preface
This study reflects the remarkable changes that have occurred over the
past four years. Few topics are as exciting and interesting as witnessing the
major ongoing efforts to create alternate modes of payments presented by
cryptocurrencies and the innumerable other possible uses that are offered
by blockchain technology. Reading many other studies on diverse topics,
this author often queries what sources of data are used by those scholars.
For my studies, there are several invaluable sources that I examine daily.
The reader need to only examine the endnotes of this work to note that
there were hundreds of sources but, in fact, the most useful were those of
MIT Technology Review, Wired Magazine, The Economist for up-to-date
news related to the subject-matter, Fried Frank Regulatory Intelligence,
Mondaq which offers short essays on the latest legal occurrences, and
other sources. Being in my mid-eighties, I have never been so engrossed
as at the present time when each day presents new possibilities and a
shadowy view of what the future holds for humanity. In discussion with
scientists and other persons with great insight, it has become obvious that
predictions beyond a five-year time frame is fraught with possible errors
and are merely guesswork. This work does not presume to offer a future
insight beyond what has occurred up to the date of the submission of the
volume. Notwithstanding the risk, the conclusion speculates occurrences
that may greatly affect technological outcomes concerning the materials in
the text. Look forward to the future which requires a constantly learning
process which has made life immensely worthwhile.
ix
x PREFACE
The volume could not have been written without the input, advice,
and encouragement of Tula Weis of Palgrave Macmillan who made the
initial suggestion of a follow-up volume to the first edition. She has been
responsible in part or in whole for the other Palgrave Macmillan publica-
tions by me. Naveen Dass managed the practical aspects to be readied for
publication. Thank you to Mahesh Meiyazhagan who edited this text.
I researched alone all of the materials indicated therein and thus any
errors are mine alone.
Pleasantville, USA Rosario Girasa

Table of Cases
Alibaba Group Holding LTD v. Alibabacoin Foundation, No. 1:2018-cv-

02897 (S.D.N.Y. April 2, 2018).
Asahi Metal Industry Co. v. Superior Court, 480 U.S. 102 (1987).
Audet v. Fraser, No. 3:16-cv-940 (D. Conn. Jan. 22, 2019).
Balestra v. Cloud With Me Ltd., 2020 WL 4370392 (W.D. Pa. July 2,
2020).
Chino v. Dept. of Financial Services, Index No. 101880-15 (NY Ct. Cl.,
2015).
CFTC v. Dean, No. 18-cv-00345 (E.D.N.Y., Jan. 18, 2018).
CFTC v. Gelfman Blueprint, Inc. No. 1-17-cv-07181 (S.D.N.Y., Sept.
21, 2017).
CFTC v. HDR Global Trading Ltd., No. 1:20-cv-08132 (S.D.N.Y. Aug.
10, 2021).
CFTC v. McAfee, No. 21-cv-1919 (S.D.N.Y. March 5, 2021).
CFTC v. McDonnell, No. 18-cv-0361 (E.D.N.Y., Jan. 18, 2018).
CFTC v. My Big Coin Pay, Inc., No. 1:18-cv-10077-RWX (D.C. Ma.
Sept. 26, 2018).
Doran v. Petroleum Mgmt. Corp., 545 F.2d. 893 (1977).
Friel v. Dapper Labs, 653134 (N.Y. Sup. Ct. May 12, 2021).
FTC v. BF Labs, Inc., No. 4:14-cv-00815BCW (D.C. Mo. filed Sept. 14,
2014).
FTC v. Chevalier, No. 3:15-cv-01029-AC (D.C. Or. June 10, 2015).
xi
xii TABLE OF CASES
Gallagher v. Bitcointalk.org, No. 3:18-cv-05892 (N.D. Ca. Sept. 24,

2018).
Gordon v. Dailey, No.14-cv-7495 (D.C.N.J., July 25, 2016).
Harper v. Rettig, No. 21-1316 (1st Cir. 2022).
In re BFXNA Inc. d/b/a BITFINEX, CFTC Docket 16-19 (June 2,
2016).
In re Caviar and Kirill Bensonoff, Docket No. E-2017-0120 (Ma. Adm.
Proceeding, Jan. 17, 2018).
In re Coinflip d/b/a Derivavit, CFTC Docket 15-29 (Sept. 17, 2015).
In re Criminal Complaint, No. 22-mj-067-ZMF (D.C.D.C, May 18,
2022).
In re John Doe, No. 3:16-cv-06658 (N.D.Ca. Nov. 17, 2016).
In re Sand Hill Exchange, SEC 3-16598 (2015).
In re TeraExchange LLC, CFTC Docket No. 15-33, (Sept. 24, 2015).
In re Virtual Mining Corporation, Mo. Sec. State, Case No. AP-14-09,
June 2, 2014.
In re Voorhees, SEC No. 3-15902, June 3, 2014.
International Shoe Co. v. Washington, 326 U.S. 310 (1945).
Jarrett v. USA, No. 3:21-mc-09999 (D. Tenn., May 26, 2021).
Kent v. Pooltogether, Inc., No. 21-cv-6026 (E.D.N.Y. Oct. 29, 2021).
Long v. Shultz Cattle Co., 881 F.2d 129 (1989).
Miramax LLC v. Tarantino, No. 2:21-cv-08979 (C.D. Cal. Nov. 16,
2021).
Ox Labs, Inc. v. Bitpay, Inc., 2020 WL 1039012, (C.D. Cal. Jan. 24,
2020).
Ripple Labs Inc. v. R3 LLC, No. CGC 17-561205 (Sup. Ct. San Fran,
Sept. 8, 2017).
Roc-A-Fella Records Inc. v. Damon Dash, No. 1:21-cv-05411 (S.D.N.Y.
Jun. 18, 2021).
R3 Holdco v. Ripple Labs, Inc., No. 655781/17 (Sup.Ct. N.Y.Cty.).
SEC v. Kik Interactive, Inc., No. 19-civ-05244 (S.D.N.Y., June 4, 2019).
SEC. v. Munchee Inc., SEC Adm. Proc. 3, No. 3-18304 (2017).
SEC v. PlexCorps, No. 17-civ-7007 (E.D.N.Y. Dec. 1, 2017).
SEC v. REcoin Group Foundation, LLC, No. 17-civ-5725 (E.D.N.Y.
Sept. 29, 2017).
SEC v. Ripple Labs, Inc. No. 20-civ-10832 (S.D.N.Y., Dec. 22, 2020).
SEC v. Shavers, No. 4:13-cv-416 (S.D. Tex. Aug. 6, 2013).
SEC v. Telegram, No. 19 -civ-9439 (S.D.N.Y. Nov. 25, 2019).
SEC v. Wahi, No. 2:22-cv-01009 (W.D.D.C. July 21, 2022).
TABLE OF CASES xiii
SEC v. W.J. Howey & Co., 328 U.S. 293 (1946).

SEC v. Willner, 1:17-cv-06305 (E.D.N.Y., Oct. 30, 2017).
Skatteverket v David Hedqvist Case C-264/14, European Court of
Justice, Judgment, October 22, 2015, ECLI: EU:C:205.
State v. Espinoza, 264 So. 3d 1055 (Fla. 3d DCA 2019).
United American Corp. v. Bitmain, No. 1:18-cv-25105 (S.D. Fl. Dec. 2,
2018).
U.S. v. Benthall, 14 MAG 2427 (S.D.N.Y. 2016).
U.S. v. Binh Thanh Le, No. 1:19-cr-10199 (D. Ma. June 19, 2019).
U.S. v. Bridges, No. 1:15-mj-02125-BPG (D.C. Md. Dec. 17, 2016).
U.S. v. BTC-e, No. 16-cr-00227 (N.D. Ca. Jan 17, 2017).
U.S. v. Budovsky No. 13-cr-368 (S.D.N.Y. Sep. 23, 2015).
U.S. v. Cazes, No. 1:17-at-00597 (N.D. Ca. July 17, 2017).
U.S. v. Chastain, No. 22-cr-305 (S.D.N.Y. June 1, 2022).
U.S. v. Coinbase, No. 17-cv-01431-JSC (N.D. Ca. Nov. 28, 2017).
U.S. v. Faiella, No. 14-MAG-0164 (S.D.N.Y. Jan. 24, 2013).
U.S. v. Force, No. 3:15-cr-01319-RS-2 (N.D. Ca. Oct. 20, 2015).
U.S. v. Ghaleb Alaumary, -cr- (C.D. Ca. Feb. 17, 2021).
U.S. v. Harmon, No. 19-cr-395(BAH) (D.C.D.C.2020).
U.S. v. Hyok et al, No. 2:20-cr-00614-DMG (D.C. C.D. Ca., Jan. 2020).
U.S. v. Jong Woo Son, No. 1:18-cr-00243 (D.C.D.C. Aug. 9, 2018).
U.S. v. Le Anh Tuan, No. 2:22-273 (C.D. Ca. June 28, 2022).
U.S. v. Liberty Reserve, No. 13-cr-368 (DLC) (S.D.N.Y. Sept. 23, 2015).
U.S. v. Lichtenstein, No. 1:22-mj-00022 (S.D.N.Y. Feb. 7, 2022).
U.S. v. Lord, No. 15-cr-00240-01 (W.D. La., Apr. 20, 2017).
U.S. v. McAfee, No. 21-cr-138 (S.D.N.Y. March 2, 2021).
U.S. v. Murgio, No. 15-MAG-2508 (S.D.N.Y. July 17, 2015).
U.S. v. Nguyen, No. 22-MAG-2478 (S.D.N.Y. March 15, 2022).
U.S. v. Pines, Gonzales, and Nicholas, No. 2:22-cr-20296 (C.D. Fl.,
2022).
U.S. v. Prihar, No. 2:19-cr-00115 (D.C.W.D. Pa., April 24, 2019).
U.S. v. Saffron, No. 2:22-cr-276 (C.D. Ca. June 28, 2022).
U.S. v. Shrem, No. 14-cr-243 (S.D.N.Y.).
U.S. v. Stollery, No. 2:22-cr-207 (C.D. ca. May 13, 2022).
U.S. v. Ulbricht, No. 15-1815 (2d Cir. March 31, 2017).
U.S. v. Ulbricht, No. 14-cr-68 (KBF) (S.D.N.Y., Sept. 27, 2013).
U.S. v. Ulbricht, No. 1-13 06919-JPO Civ.( D.C.N.Y. Jan. 27, 2014).
xiv TABLE OF CASES
U.S. v. Vasinskyi, No. 3:21:-cr-0366-s (D.C. N.D. Tx, Aug. 11, 2021).
West Virginia v. EPA, 136 S.Ct. 1000 (2016).
Zippo Mfr. Co. v. Zippo Dot Com, Inc., 952 F. Supp. 1119 (W.D. Pa.
1997).
Contents
1 The Digital Transformation 1

Introduction 1
Definitions and Types of Non-Fiat Currencies 3
Money 3
Reasons for the Rise of Digital Currencies 5
Types of Currencies 7
Digital Currencies 9
Virtual Currencies 9
Cryptocurrencies 11
Key Actors in Digital Technology 11
Benefits and Risks of Digital Currencies 14
Benefits of Digital Currencies 14
Risks of Digital Currencies 15
US Government Agencies’ Risks Advisories 16
Commodity Futures Trading Commission (CFTC) 16
Consumer Financial Protection Bureau (CFPB) 17
Government Services Administration (GSA) 18
Securities and Exchange Commission (SEC) 18
Immigration and Customs Enforcement (ICE) 19
Federal Reserve Board (FED) 19
International Risk Assessments 20
International Monetary Fund (IMF) 20
Financial Stability Board (FSB) 20
xv
xvi CONTENTS
European Union Supervisory Authorities (ESAS) 21

European Union Agency for Network and Information
Security (ENISA) 21
Nobel Laureates’ Concerns 22
2 Technology Underlying Cryptocurrencies and Types
of Cryptocurrencies 31
Blockchain Technology 31
Types of Blockchain Technology 34
Uses of Blockchain Technology 34
Banks and Blockchain Technology 35
Varieties of Cryptocurrencies 36
Bitcoin 36
Ethereum 39
Comparison of Bitcoin and Ethereum 42
Other Variations of Cryptocurrencies 43
Forks 43
Altcoins 44
Sidecoin 44
Sidechain 44
Litecoin 45
Bitcoin Cash (BTH) 45
ApeCoin 45
Dogecoin 46
Cardano 46
Ripple 46
Monero 47
Digital Tokens (Cryptotokens) 47
Types of Tokens 48
Non-Fungible Tokens (NFTs) 49
What Are Non-Fungible Tokens? 49
Rewards and Risks of NFTs 50
Legal Issues Affecting NFTs 51
International Regulation of NFTs 58
Web3 and Metaverse 61
Web3 61
Metaverse 62
CONTENTS xvii
Wrapped Assets 64
Stablecoins, Wrapped Assets, and NFTS Comparison 64
Decentralized Finance 65
3 Federal Regulation of Virtual Currencies 81
Introduction 81
Jurisdiction 83
SEC v. Shavers 86
Gordon v. Dailey 87
Alibaba Group Holding v Alibabacoin Foundation 87
Virtual Currencies as Money 88
Audet v. Fraser 90
US Government Agencies Concerned with Virtual
Currencies 91
Securities and Exchange Commission (SEC) 91
Commodity Futures Trading Commission (CFTC) 106
US Department of Justice Attorney General’s
Cyber-Digital Task Force 116
Financial Crimes Enforcement Network (FinCEN) 117
Office of Foreign Assets Control (OFAC) 124
Federal Reserve Board (FED) 126
Consumer Financial Protection Bureau (CFPB) 128
Office of Comptroller of the Currency (OCC) 129
Federal Trade Commission 130
4 Alternatives to Traditional Virtual Currencies:
Stablecoins and Central Banks Digital Currencies 147
Stablecoins 147
Models of Stablecoins 148
Advantages and Risks of Stablecoins 149
US Government Regulation of Stablecoins 150
Stablecoin Cases 152
International Regulation of Stablecoins 154
US Senate Proposed Bills 158
Central Banks and Cryptocurrencies 159
Central Banks’ Role and Mission 159
Central Bank Digital Currency (CBDC) 161
Reasons for Rise of CBDC 161
xviii CONTENTS
Foundational Principles and Features of CBDCs 163

European Union and CBDC 164
Countries’ Adoption of CBDC 165
US Future Adoption of CBDC? 165
President Biden’s Executive Order No. 14067 Concerning
CBDCs 167
Project Hamilton 170
5 Criminal Prosecutions and Civil Litigation Concerning
Blockchain Technologies 179
Criminal Prosecutions 180
Statutory Prohibitions 180
North Korean Prosecutions 185
Darknet Prosecutions 188
Darknet and Child Pornography 192
Darknet Continuing Arrests 192
Ransomware 193
Immigration and Customs Enforcement (ICE) 197
“Silk Road” Prosecutions 198
Bitcoin as Money 203
President Biden’s Executive Order No. 14067 204
Agencies’ Response to Executive Order 206
President Biden’s Comprehensive Framework
for Responsible Development of Digital Assets 208
SEC Civil Enforcement 211
CFTC Civil Enforcement 216
Office of Foreign Assets Control (OFAC) 221
6 States’ Regulation of Virtual Currencies 235
Money Transmission State Laws 235
Proposed Uniform Virtual Currency Codes 237
Uniform Regulation of Virtual-Currency Business Act 237
Conference of State Bank Supervisors: Model Framework
(CSBS) 238
CSBS’ Model Money Transmission Modernization Act 239
States Requiring Licenses for Virtual Currency Businesses 240
Alabama 240
Alaska 240
Arizona 241
Arkansas 241
CONTENTS xix
Connecticut 241
Delaware 242
District of Columbia 242
Florida 242
Georgia 243
Idaho 243
Illinois 243
Nevada 244
New York 244
North Carolina 246
Texas 246
Vermont 247
Virginia 248
Washington 248
West Virginia 248
Wyoming 248
Miscellaneous States Giving Recognition to Virtual
Currencies 249
Hawaii 249
Massachusetts 249
New Jersey 251
States That Have Not Enacted Legislation Concerning
Virtual Currencies 251
California 252
Colorado 252
Kansas 253
Maryland 253
Missouri 254
Miscellaneous States 254
7 Taxation of Virtual Currencies; Environmental,
Social and Governance Considerations; Protection
of Intellectual Property Rights; Antitrust;
and Cybersecurity 261
Taxation of Virtual Currencies 261
Virtual Currency as Property for Tax Purposes 262
Internal Revenue Service Guidance on Crowdfunding
and Virtual Currency 269
The Foreign Account Tax Compliance Act (FATCA) 273
xx CONTENTS
Internal Revenue Service Enforcement of Regulations 274

Congressional Proposals to Tax Virtual Currency
Transactions 276
Taxation of Charitable Donations of Crypto-Assets 278
Environmental, Social, and Governance Considerations
(ESG) 278
President Biden’s Initiatives 281
Intellectual Property Rights 284
IPR Basics 284
IPRs and NFTs 285
Regulations Relating to Cybersecurity 288
Cybersecurity Information Sharing Act of 2015 289
Cybersecurity Act of 2021 289
President Biden’s Executive Order 14028 290
FED’s 2022 Cybersecurity Report to Congress 291
SEC’s 2022 Proposed Rule on Cybersecurity 291
Federal Efforts to Expand Cybersecurity Knowledge Base 292
The State and Local Government Cybersecurity Act
of 2021 292
States’ Regulatory Measures 293
Antitrust 294
Summary of Basic Provisions of US Antitrust Regulation 294
8 International Regulation 313
European Union 313
European Central Bank (ECB) 314
EU Directives on Money Laundering 315
Markets in Crypto-Assets (MiCA) 317
European Securities and Markets Authority (ESMA) 319
ESMA, EBA, and the EIOPA 2018 Warning 321
European Union’s 2018 Blockchain Initiative 321
European Court of Justice Ruling 322
EU-US Joint Financial Regulatory Forum 323
The Bank for International Settlements 324
The Financial Action Task Force (FATF) 325
Organization for Economic Cooperation and (OECD) 326
Financial Stability Board (FSB) 327
United Nations (UN) 328
CONTENTS xxi
International Organization of Securities Commissions

(IOSCO) 328
Miscellaneous International Entities 329
Selected Countries Permitting and/or Regulating Virtual
Currencies 331
Countries Banning Bitcoin and Other Virtual Currencies 357
Alternative National Virtual Currency 359
Conclusion: Quantum Computing and the New Disruption 379

Index 383
Abbreviations
AICPA American Institute of Certified Public Accountants

AIFMD Alternative Investment Fund Managers Directive
AML Anti-Money Laundering
AML/CFT Anti-Money Laundering/Combatting Financing of Terrorism
AML/KYC Anti-Money Laundering/Know Your Customer
ASIC Application-Specific Integrated Circuit
ATM Automated Teller Machine
BIS Bank for International Settlements
BTC Bitcoin
CBDC Central Bank Digital Currency
CBOE Chicago Board Options Exchange
CCO Chief Compliance Officers
CEA Council of Economic Advisers
CFD Contract for Difference
CFPB Consumer Financial Protection Bureau
CFT Countering the Finance of Terrorism
CFTC Commodity Futures Trading Commission
CIS Collective Investment Scheme
CISA Critical Infrastructure and Security
CME Chicago Mercantile Exchange
CPU Central Processing Unit
CRS Congressional Research Service
CSBS Conference of State Bank Supervisors
CSDR Central Securities Depositories Regulation
DAO Decentralized Autonomous Organization
DEA Drug Enforcement Agency
xxiii
xxiv ABBREVIATIONS
DeFi Decentralized Finance

DHS Department of Homeland Security
DLT Digital Ledger Technology
DOE Department of Energy
DOJ Department of Justice
DPRK Democratic People’s Republic of Korea
EBA European Banking Authority
ECB European Central Bank
EIOPA European Insurance and Occupational Pensions Authority
EMIR European Market Infrastructure Regulation
ENISA EU Agency for Network and Information Security
EO Executive Order
EPA Environmental Protection Agency
ESAS EU Supervisory Authorities
ESG Environmental, Social, and Governance
ESMA European Securities and Markets Authority
ETFs Electronic Trading Funds
ETH Ether
EU European Union
FAQs Frequently Asked Questions
FATCA Foreign Account Tax Compliance Act
FATF Financial Action Task Force
FBI Federal Bureau of Investigation
FDIC Federal Deposit Insurance Corporation
FED Federal Reserve System
FinCEN Financial Crimes Enforcement Network
FIUs Financial Intelligence Units
FMP Financial Market Participants
Forex Foreign Exchange
FPGA Field Programmable Gate Array
FRB Federal Reserve Board
FSB Financial Stability Board
FSOC Financial Stability Oversight Council
FTC Federal Trade Commission
GATT General Agreement on Tariffs and Trade
GPU Graphics Processing Unit
GSA Government Services Administration
GSC Global Stablecoins
HSI Homeland Security Investigations
ICE Immigration and Customs Enforcement
ICOs Initial Coin Offerings
IFPCU Illicit Finance and Proceeds of Crime Unit
IMF International Monetary Fund
ABBREVIATIONS xxv
Inline XCRL Inline eXtensible Business Reporting Language

IOSCO International Organization of Securities Commissions
IP Intellectual Property
IPO Initial Public Offering
IPRs Intellectual Property Rights
IRS Internal Revenue Service
IT Information Technology
ITO Initial Token Offering
KYC Know Your Customer
MiCA Markets in Crypto-Assets
MiFID/MiFIR Markets in Financial Instruments Directive and Regulation
NBA National Basketball Association
NCFs National Critical Functions
NFT Non-Fungible Token
NIST National Institute of Standards and Technology
NYS New York State
NYSE New York Stock Exchange
OCC Office of the Comptroller of the Currency
OECD Organization of Economic Cooperation and Development
OFAC Office of Foreign Assets Control
PCAOB Public Company Accounting and Oversight Board
PCS Payment, Clearing, and Settlement
SDRs Special Drawing Rights
SEC Securities and Exchange Commission
SFD Social Fund for Development
SRB Single Resolution Board
SSM Single Supervisory Mechanism
UCITs Undertakings for Collective Investments Securities
UK United Kingdom
UN United Nations
UNCCT UN Counter-Terrorism Centre
UNOCT UN Office of Counter-Terrorism
USDT US Dollar Reserves
VAT Value Added Tax
WEF World Economic Forum
WTO World Trade Organization
CHAPTER 1
The Digital Transformation
Introduction
The advent of the internet and the technological advancements related
thereto have inaugurated a transformation in how we think and act
that exceeds any of the prior historical inventions and discoveries. We
speak to each other instantaneously, spend endless quanta of time on
cell phones, computers, and other devices, and have created totally new
ways of communication with one another. Industries, often reluctantly,
have undergone digital transformations and disruptions in an endeavor to
modernize and not become bankrupt by failure to upgrade and innovate
as the oft-cited lessons of Kodak and Polaroid have imparted.1 Digital
transformation is occurring at an exponential pace without parallel in
human history causing new innovations to rise rapidly fed by venture
capital, crowdfunding, and other monetary investments. These enhance-
ments are creating entirely new workforces but also are causing displace-
ments of workers unable to adapt to the new technologies. Valuations of
new enterprises above $1 billion literally are generated almost overnight
which rival entire economies of many nations, e. g., Apple ($3 trillion),
Google’s parent company Alphabet ($1927 trillion), Microsoft ($2513
trillion), and Amazon ($1728 trillion).2
Successful companies have or are adopting new business models to
meet the technological revolution. IBM has transformed its mainframe
business to technology and consulting business services; Microsoft from
© The Author(s), under exclusive license to Springer Nature 1

Switzerland AG 2023
R. Girasa, Regulation of Cryptocurrencies and Blockchain Technologies,
Palgrave Studies in Financial Services Technology,
https://doi.org/10.1007/978-3-031-21812-5_1
2 R. GIRASA
PC (private copy) royalties to advertising and subscription-based models;

and even LEGO restructured from its near bankruptcy to new digital
businesses such as Lego Digital Designer (replaced in January 2022
by BrickLink Studio) and Lego Mindstorms.3 The “Big 4” accounting
firms are experimenting with blockchain and artificial intelligence tech-
nologies for auditing and related services, exemplified by Deloitte with
its launch of Rubix, a blockchain that provides advisory services and
builds distributed applications for clients worldwide.4 Legal services are
entering the digital arena with firms such as Ross Intelligence that has
leveraged and partnered with Vanderbilt Law and certain law firms to
provide legal information from citations of cases to legal briefs.5 Other
examples include uses of blockchain for a time-stamped, secured, and scal-
able record to document when a trademark was first used; manage client
transactions through a digital wallet; and render advice to clients in the
financial sector on issues arising from the new technology.6
Banks are aware of the digital transformation which may make cash
obsolete particularly as millennials become the mainstay of customers’
banking.7 The World Economic Forum noted that Chinese banks are
leaders in digitalization in banking. It suggested that digital transforma-
tion be accelerated internationally by sharing software solutions, applying
technology across jurisdictions, incentivizing customers concerning their
personal data rights, and safeguarding the interests of disadvantaged
groups.8 The Federal Reserve Board (FED), has become acutely inter-
ested in distributed digital ledger technology (DLT) as it applies to
payments, clearing and settlement procedures, noting that its systems
processes some 600 million transactions daily valued at over $12.6 trillion.
DLT has the potential to create news ways of immutably and securely
store information, offer identity management, provide for cross-border
payments, and other essential uses.9 While recognizing the challenges of
interoperability, ubiquity, and accessibility, nevertheless it is anticipated
that the use of digital currency and DLT will deliver faster payment solu-
tions and enhance the timeliness, cost effectiveness, and convenience of
cross-border payments. The FED is further concerned about the role of
Central Bank Digital Currencies and its competitiveness with non-bank
related digital currencies.10
The latest innovation, generically, that seeks to replace historical modes
of behavior is that of a new format for currencies. Although banks and
other financial institutions have for decades sought to replace checks and
1 THE DIGITAL TRANSFORMATION 3
related financial instruments with the use of the then current technolo-
gies, it appears that money itself will likely diminish in its current form to
be replaced or added to by a virtual currency in a form known as “cryp-
tocurrency”. In this study, we will discuss the nature of digital currencies,
specifically, cryptocurrencies such as Bitcoin, and the latest emanations of
stablecoins; non-fungible tokens; wrapped assets; the technology under-
lying the currencies; and the regulatory enactments either proposed or
already enacted by federal and state governing authorities.
Definitions and Types of Non-Fiat Currencies

Money
Back to Basics: What Is Money?
On this author’s office desk is a government issued One Hundred Tril-
lion Dollars banknote disseminated by the Reserve Bank of Zimbabwe in
2008 that occurred during its period of hyperinflation from the late 1990s
through 2011, emanating from government policies of seizures of private
land and its participation in the Congo Wars. The sole value of the bank
note is the cost to purchase them as souvenirs or as curiosities to illus-
trate the government’s failings and the total lack of trust by possessors
of such currency.11 Human beings have used money as a substitute for
goods and services for thousands of years. Although one may barter, for
example, one’s services such as plumbing, legal, or even medical services,
in exchange for another person’s goods or services, among the difficul-
ties are matching the needs of both parties and the valuations thereof.
The commencement of substitutes led to a variety of means that was
acceptable to a broader population whereby individuals could use them as
desired rather than by barter that often was unacceptable or inconvenient.
Early exchanges of primitive societies included the use of shells in
African cultures, particularly cowrie shells around 1200 B.C., as well
as salt, seeds, cattle, and other valued assets. Gradually, metal objects,
especially gold bars, were used in Egypt and Mesopotamia about 3000
B.C., which were later transformed into metallic money. Other forms of
metallic assets also came into existence including gold rings and other
valuable metals. Metallic-like money appeared in China by 1000 B.C.,
bronze coins therein from the seventh- to the third century B.C., and
even leather money was used in the second century B.C. Metallic coins
were introduced in Ephesus, Turkey in the seventh century B.C. and used
4 R. GIRASA
extensively in Greece and Rome soon thereafter.12 Barter has never totally
been banished completely to history’s dustbin but has continued in some
form, including among nations, to the present time.
A form of barter used extensively in the twentieth century is counter-
trade. At various times, countries or entities within nations have engaged
in countertrade whereby large quantities of products or services have been
exchanged without use of money, particularly when a nation’s currency
has lost credibility. During World War II and thereafter, nations found
countertrade to be beneficial due to the decimation of the industrial plants
destroyed during the war. Companies and individuals in countries that
had a trustworthy currency at times chose countertrade in order to avoid
imposition of taxes on goods or services exchanged. Nations participated
in countertrade also to offset trade imbalances and protect local indus-
tries. Usually, such trade concerns sellers who desired to convey goods
to a country that lacked or had severe limits on the use of hard currency
such as some nations in sub-Sahara Africa and on the Indian continent.
There are many types of countertrade, exemplified by barter (exchange
of goods or services): counter purchase (party selling goods or services to
another party agrees to buy back a specific product in exchange there-
from in the future); compensation (part of payment is in hard currency);
buyback (generally, a company may invest in constructions of a plant or
other facility and agrees to purchase products manufactured from the
said facility); clearing arrangement (exemplified by the trade between
West and East Germany before unification whereby companies in both
nations sold goods and services and registered the sales in clearing banks
in the respective countries which were then settled at the end of a
designated time frame and any balances became the obligation of the
obligor country); switch trade (one party provides goods and/or services
in exchange for an arrangement to purchase goods from the buying
nation); and offsets (company may construct plants or provide other
services in another country in order to diminish costs due and owing
to the supplier).13
Money, in its many emanations, became a substitute for the exchange
or barter of goods and services. It is based on the perception of persons
using currency that it has equivalent value for such items. The Interna-
tional Monetary Fund (IMF) defines “money” as anything that may act
as a (a) store of value that persons in possession may keep and use it at a
later time; (b) as a unit of account providing a common base for prices;
or (c) as a medium of exchange that people use and exchange with one
another.14 Historically, the IMF has used a form of digital currency by its
creation and distribution of “special drawing rights” (SDRs) commencing
in 1969 as an international reserve asset which supplemented a member
state’s official reserves and which may be exchanged for usable currencies.
Although the IMF states SDRs are not a form of currency, neverthe-
less, they may be used by member states as a voluntary exchange for
existing currencies and as units of account of the IMF and other interna-
tional organizations. SDRs are issued in accordance with a member state’s
quotas, i.e., required depository amount assigned by the IMF to a nation
dependent on its financial status. Interest is paid or charged for borrowing
on such holdings. As of August 2021, a total of SDR 660.7 billion (equiv-
alent to about US $943 billion) have been allocated to member states
including approximately SDR 456 billion approved on August 2, 2021,
to contribute to the long-term global need for reserves, and assist coun-
tries to cope with the impact of the COVID-19 pandemic. The value of
the SDR is based on a basket of five currencies—the US dollar, the euro,
the Chinese renminbi, the Japanese yen, and the British pound sterling.15
Reasons for the Rise of Digital Currencies

There are a number of factors that gave rise to digital currencies in the
form of cryptocurrencies including the following factors:
• Costs of Third-Party Servicing. The revolution in the mode of

the types of currencies used for payments, clearing, settlements,
and other services is inevitable. As noted in The Economist, the
technological revolution in digital technology has brought about
significant progress in bringing about financial services to previously
underserved areas, particularly in sub-Saharan Africa.16 In devel-
oped countries, the cost for such services is staggeringly high. The
US Consumer Financial Protection Bureau estimates that Americans
averaged $120 billion annually payments in credit card interest and
fees for the period 2018–2020.17
• Lack of Security. There are a multitude of problems in connection
with the current system of payments by cash, credit cards, automated
teller machines (ATMs), and other current modes of payment for
goods and services. As witnessed on numerous occasions in the past
several years, hacking of credit cards and, also, ATMs by wrongdoers
are ongoing problems inasmuch as cybersecurity systems in place are
6 R. GIRASA
subject to major tampering as witnessed by cybercriminals’ access to

some 143 million US persons’ highly personal information including
names, social security numbers, birth dates, addresses, and drivers’
licenses.18 There were many other reported breaches, which raise
the specter of the oft-quoted comment by Scott McNealy of Sun
Microsystems who said: “You have zero privacy. Get over it”.19
• Lack of Convertibility or Unavailability of Funds in Poor Countries.
Other problems that affect persons with less than excellent credit,
particularly poorer third-world type economies, include the cost of
access and interest charges for credit cards; lack of convertibility
of the national currency, e.g., Venezuela in recent times; illiteracy,
which affects ability to engage in financial transactions; inconve-
nience of cash wherein merchants accept cash in small denominations
only; lack of transnational exchanges of currency except by payment
often at poor exchange rates coupled with sizable fees; the sums
banks and related institutions charge for certain uses of credit cards
and debit cards as well as for an abundant of other services; and
the refusal of cash payments by some merchants. Thus, Bitcoin and
subsequent digital currency facilities, with their blockchain founda-
tion, provide partial responses to negative aspects of the current
financial system. Inasmuch as traditional banking services may be
unavailable and a large percentage of the world’s poor lack bank
accounts, digital technologies offer possible alternatives to them.
• Anonymity or Pseudonymity. Many users who distrust government’s
alleged invasion of privacy want to remain unknown, but the feature
also includes wrongdoers who commit criminal acts, engage in
terrorism, or desire to avoid tax payments. Anonymity means that the
person is unidentifiable while pseudonymity means that the person is
identifiable but his or her actual name is unknown and not ascertain-
able, e.g., in Bitcoin, miners and others know that there is a person
engaged in a transaction but not his or her actual name or private
key signature.20
• Universality of Particular Cryptocurrencies. Cryptocurrencies like
Bitcoin are exchangeable everywhere where accepted and not
forbidden without need for currency exchangers or other third-party
intervention.
• Inevitable Modernization of Payments. It appears clearly in hindsight
that millennials, who live by use of smart phones and other computer
technology, view fiat currencies in derogatory terms due to their

inconvenience, cost, and other annoyances.
• Profit Motivation. The run-up in value of cryptocurrencies had
persuaded persons, even of modest means, of the possibility of
substantial returns on moneys invested in the new technologies.
• The Trust Factor. The key to money, as illustrated above, is the
trust that possessors of it have in the value and use of the currency.
If a large percentage of the population does not have faith in the
currency, then its value declines. There is trust in fiat money in the
US and in the European Union (EU) because of their central banks’
guarantees of payment. Although Bitcoin and other cryptocurrencies
have no such backing, the technology underlying them does assure
a high degree of trust by their near-guarantee of immunity from
hacking, transactional transparency, reliability, simplicity and speed,
and security against fraud and cybercrime.21
Digital services are a response and means to greatly lower costs both
to financial institutions and to their customers. Digital technology has
extended to use of smart phones and computers to engage in deposits;
transactions in securities and other transactions; and, when coupled with
ATMs, has lessened the need for tellers and other banking personnel.22
The next anticipated innovations are expected to feature the substitu-
tion of greatly enhanced digital technology for the present technologies
that will be transformative in almost unimaginable ways. In the near
future, cash will be viewed as primitive as the Underwood typewriter
of old to students preparing research papers for class today. Credit
cards have already served comparable needs for consumers and may be
on the descent thereby deeply discounting the costs to merchants and
consumers. The latest modernization and its regulatory issues are the
focus of this paper.
Types of Currencies
Currency (real currency or fiat currency) is defined as “the coin and paper
money of the United States or of any other country that is designated
as legal tender and that circulates and is customarily used and accepted
as a medium of exchange in the country of issuance”.23 It includes US
notes and silver certificates, Federal Reserve notes, and official foreign
8 R. GIRASA
bank notes. Electronic money (e-money) may be defined as “electroni-

cally, including magnetically, stored monetary value as represented by a
claim on the issuer which is issued on receipt of funds for the purpose
of making payment transactions and which is accepted by a natural or
legal person other than the electronic money issuer”.24 Examples of e-
money include storage on a chip card or on a hard drive in a personal
computer. They are generally denominated in the same currency as central
bank or commercial bank money and usually redeemable at par value or
in cash.25 Digital currency is a medium of exchange and may act as a
currency where accepted but lacks the attributes of real currency. They
are denominated in their own units of value rather than directly connected
to the national currency. Distinguishing among digital currencies, virtual
currencies, and cryptocurrencies often leads to differing interpretations. It
is suggested that authors of a study at the IMF appear to present the most
logical representation of the generic and specific sequential taxonomy of
the three modes of currencies in descending order as follows:
• Digital currencies —represent value denominated in legal tender such

as PayPal, e-money or may have their own value based not on the
national or other governmental currency but on the law of supply
and demand, i.e., the values a person possessing and attributes to
them from actual usage or based on current posted values.
• Virtual currencies —represent a new asset class that competes and
may eventually overtake fiat currency—they are currencies not
denominated as legal tender and may be either:
– Convertible (open)—can be exchanged for real-world goods,
services, money (e.g., Bitcoin), and which may be:
• Centralized—with a central authority or trusted third-
party, convertible to fiat money, such as WebMoney26 ;
or
• Decentralized—peer-to-peer, without a central authority
or trusted third-party ledger; or
– Non-Convertible (closed)—such as use of game coins; not
exchangeable for fiat currency.
• Cryptocurrencies —is a subset of virtual currencies that uses tech-
nology from cryptography to validate the transfer of transactions
as exemplified by several thousand of such currencies such as
Bitcoin, Ethereum and numerous other formats using blockchain
as its underlying technology.27 Included and discussed hereafter are

stablecoins which have underlying backup of assets unlike other
cryptocurrencies.
Expanding on the above characterizations:
Digital Currencies
Digital currency is an intangible mode of currency in electronic format
whereby payments may be transferred between parties through the use of
current technologies of computers, the internet, and smart phones. It is
used for payments made person-to-person or with entities for common
purchases of goods and services both domestically and internationally or
may be confined to gaming or social networks.28 It may be either fiat
(real) currency, e.g., e-money, or non-fiat currency as virtual currency. It
is borderless and occurs instantaneously just as speedily as communica-
tion by email but may be dependent on governmental restrictions and
access. It may also include, under some definitions, as sovereign cryp-
tocurrency. The term is often used synonymously with virtual currencies
but encompasses all types of currencies that have an electronic format.
Virtual Currencies
Virtual currency is a digital representation of value that is not government
or central bank issued that can be digitally traded and functions as a (1)
medium of exchange; (2) unit of account; or (3) store of value.29 Rather
than possessing status like the legal tender of fiat currency, such as physical
coins or bills, it is generally not widely used or circulated and has no
government backing. A distinction should be made from e-money which
is fiat currency transferring value by electronic means and does possess the
characteristic of legal tender. Virtual currency may operate like so-called
real currency but lacks legal status in the US. Its value is what users or
traders ascribe to it.30
Convertible (or opened) virtual currency refers to unofficial convert-
ibility or exchangeability as proposed and accepted by the participants
thereof which may include exchange for fiat currency, property, or other
forms of value. The primary example is Bitcoin which can be used to
purchase goods, real property, or services from parties accepting the
10 R. GIRASA
exchange as equivalent value with the understanding that it is not govern-

ment backed.31 Non-convertible virtual currency, generally, is a form
of centralized currency issued by a central authority or administrator
limited almost exclusively to particular uses and parties, mostly for gaming
purposes or sites such as Amazon-com. Other examples include Q coins,
Project Entropia Dollars, and the like.32
Convertible virtual currency may be either centralized or decentral-
ized. Centralized virtual currency is one that has a central authority
or administrator that sets the rules, issues the currency, maintains a
central payment ledger, and may redeem or withdraw the currency. It
may have a “floating” exchange rate or “pegged” with the former based
on market supply and demand and the latter determined by the central
administrator, usually based on gold, a basket of currencies, or other real-
world values. Examples include WebMoney, World of Warcraft gold, and
PerfectMoney. Decentralized virtual currency, exemplified by Bitcoin, is
without a central administrator or oversight but is peer-to-peer (person-
to-person) and its value is determined by the parties entering into such
transactions.33
Non-convertible (or closed) virtual currencies are decentralized, i.e.,
they require a central authority to act as an administrator. They operate
in a closed environment specific to a virtual domain such as game playing,
whereby the user must conform to the rules set forth by the administrator
usually from an online store. Any attempt to evade the rules of the game
may result in termination of the user’s access or other penalties. They
are used for online games whereby the holder may trade for other in-
game online tools or currency. Other examples may include credit cards
or gift cards that are only redeemable at the store; frequent flyer miles;
video arcade tokens; and other restricted uses. Store gift cards and other
restricted use currencies theoretically that can be given freely (as most gifts
are) or even may be sold to other persons willing to accept the currency
with its restrictive use. Unlike convertible currencies, they are restricted
in number, are not liquid, and are easily lost through misuse or theft.
A similar characterization of digital currency is found in the Office
of Foreign Assets Control’s (OFAC) Sanctions Compliance manual34
that takes note of the latest trend in digital currencies, namely that of
“sovereign cryptocurrency” discussed in Chapter 4 of the text as “Cen-
tral Bank Digital Currency” (CBDC). Thus, OFAC states that digital
currency includes sovereign cryptocurrency, virtual currency (non-fiat),
and a digital representation of fiat currency. It defines “virtual currency”
as a digital representation of value that functions as (i) a medium of

exchange; (ii) a unit of account; and/or (iii) a store of value; and is neither
issued nor guaranteed by any jurisdiction.35
Cryptocurrencies
The word crypto has many meanings dependent on its use as a noun,
adjective or used in connection with particular modes of study. When
applied in connection with currencies, we call it cryptocurrency defined
as “a digital decentralized convertible currency or medium of exchange
using encryption technology to verify its exchange and hinder counterfeit-
ing”.36 It is mined at a mathematically controlled rate, anonymous, reliant
on public and private keys to exchange value on a peer-to-peer basis, and
supply is based on free market demand.37 The term is often used inter-
changeably with convertible, decentralized virtual currency. Bitcoin and
Ethereum are leading examples of cryptocurrencies. In the context of
most commentaries, cryptocurrency is synonymous with virtual currency
although, theoretically, a distinction should be drawn between the two
types of currencies.
The discussion hereafter will focus on the generic terms of virtual
currencies and cryptocurrencies and their regulation.
Key Actors in Digital Technology38

Although digital and non-fiat forms of currencies have been utilized for
decades, nevertheless, the current emanation is substantively far superior
and complex. The players in the latest innovative financial evolution are
as follows:
• Inventors (creators). The major figure who created initially the

distributed digital ledger technology (DLT) is the mysterious
figure(s) of Satoshi Nakamoto, who is or are responsible for the
creator of Bitcoin which is used as its basis a form of blockchain
technology, discussed in greater detail hereinafter. Alternate versions
of blockchain later evolved and made separate from Bitcoin so
that an almost infinite multitude of players could utilize the posi-
tive benefits of DLT by government agencies, financial institutions,
private businesses, professional firms, and individuals due to their
alleged total prevention from hacking and affording privacy. Among
12 R. GIRASA
the emanations evolving from blockchain are smart contracts; secu-

rity by “proof of stake” (groups called “miners” are able to use
computing power for decision-making and have “proof of work”);
and “blockchain scaling” (acceleration of blockchain transactions).39
Another major inventor is Vitalik Buterin who, with others, created
the Ethereum blockchain which differs from Bitcoin (discussed at
greater length below) in transaction time, the amount of Ether
distributed, method of costing transactions, and other differences.
The Walt Disney Company created Dragonchain which is yet
another form of blockchain and is also a further evolution of Disney’s
prior creations of animatronics and digital animation.40
• Issuers or administrators. After the dizzying success of Bitcoin, a
multitude of individuals and companies were created which offered
and sponsored a large variety of virtual currencies and other inno-
vations, maintaining ledgers, and redeeming virtual currency. Their
activities will inevitably transform how the financial and social world
operates.
• Miners. Miners generate new virtual currency by utilizing special
computer hardware, usually with application-specific integrated
circuit (ASIC) machines that solve cryptographic (mathematical)
problems in return for which bitcoins, Ether, or other forms of cryp-
tocurrencies’ tokens or awards may be issued in return.41 The word
“miners” is derived from miners who dug mines in search of valuable
minerals such as diamonds. They validate, often as a group, a set of
transactions called a “block”.
• Processing service providers. They are firms that provide the means
of transfer of virtual currencies from one user to another. There are
numerous companies formed and are being created to provide these
services, e.g., DC POS, Coinfy, CoinCorner, Coinbase, et al.42
• Users. There are an almost infinite number of users of the tech-
nology with applications being added daily exponentially as the
technology takes hold. Among the major areas of uses and persons
are financial services including international payments; trades of
securities; improvement of capital markets; use of smart contracts;
improvement of online identity management; regulatory compli-
ance; protection against money laundering and theft of assets;
healthcare services given the need for privacy protections of patients’
data and records; real estate transactions; record management; cyber-

security; accounting; and numerous other uses and the persons
connected thereto.43
• Wallet. A virtual currency wallet is a secure medium that is used to
store, send, and receive digital currencies such as Bitcoin. Almost all
coins issued require the use of the particular wallet to store the desig-
nated cryptocurrency. The wallet is actually a private key containing
a secure digital code known only by the person possessing the cryp-
tocurrency together with the public key used to send and receive
coins.44 Individuals and firms engaged in mining are not without
risks as evidenced by the theft of some 4736.42 BTC (bitcoins) on
December 6, 2017, from NiceHash, valued at $78.3 million from
the cryptocurrency mining marketplace. At the time, the stolen BTC
was worth roughly $70 million. The company stated its belief that
the attacker was able to obtain a NiceHash employee’s credentials
via a phishing email. With the credentials, the attacker subsequently
emptied all of the BTC in the NiceHash wallet. Although none of
the bitcoins was returned, the company stated it was crediting its
customers the full sum of the losses.45 Hacking remains a major issue
as evidenced that in 2021, $14 billion in cryptocurrency was hacked
from diverse sources.46
• Wallet provider. A wallet provider is an entity that uses software
applications or other means to enable the user to store, hold, and
transfer virtual currencies as well as provide the means of maintaining
a customer’s balance online or offline, and security.
• Exchanges. Exchanges are persons (individuals and companies),
almost always businesses, which operate analogously to stock
exchanges by exchanging convertible virtual currency for fiat money
or for other virtual currencies, precious metals, and other compa-
rable assets and vice versa. Bitcoin has become mainstream with
the announcement that Chicago’s two largest financial exchanges,
the Chicago Mercantile Exchange (CME) and the Chicago Board
Options Exchange (CBOE) have made available Bitcoin futures that
investors could engage in by shorting or otherwise thereby giving
legitimacy to these cryptocurrency trades.47 In October 2021, CME
became the largest Bitcoin exchange surpassing Binance48 CBOE,
which had discontinued the Bitcoin futures market, reentered it
anew in October 2021.49
14 R. GIRASA
• Trading platforms. A trading platform is the means wherein curren-

cies are exchanged. The most well-known exchange platform for
exchange for foreign currencies is FOREX which enables parties
to exchange currencies of different countries, often coupled with
a short-term gain, for a fee. The ascendance of virtual currencies
added a new wrinkle to the conversion inasmuch as trading may be
a closed virtual currency between two parties without the interven-
tion of a third party. Nevertheless, there are numerous platforms
that have arisen to engage in electronic trading of virtual curren-
cies particularly by parties who wish or may only be able to afford
a percentage ownership of the cryptocurrencies made available for
purchase. They permit the exchange of fiat currencies for digital
currencies. The exchanges may be private or open to the public. The
exchanges vary in fees, verification requirements, exchange rates, and
other features. Among the best exchanges, according to a Forbes
commentator, in descending order, depending on purpose, use, and
type of customer, are Binance.US, Coinbase, BlockFi, Crypto.com,
and Bisq.50 Investors are cautioned to be wary about platform
trading especially, according to the Federal Bureau of Investigation
(FBI), with respect to schemes operated by perpetrators who falsely
represent that their platforms afford above-average market returns at
below-market risk through the trading of bank instruments.51
• Numerous other actors —they may include merchants, brokers and
dealers, software developers, and various other potential actors
engaged in the latest innovative advances in virtual currencies.
Benefits and Risks of Digital Currencies

Benefits of Digital Currencies
As with almost all technological innovations, there are benefits and risks
associated with the latest advances. Benefits include:
• Verification of identity;
• Significant reduction in costs due to the removal of intermediaries
such as banks in the payment processes;
• Speed of money transfers by the elimination of clearing houses;
• Facilitation of micro-payments for low cost online goods and
services;
• Reduction of exposure risks that may occur when transacting bearer

instruments;
• Use by persons unable to use banking and credit facilities for lack
of credit, e.g., having refugee status or lack of credit history—in the
US, an estimated 5.4% of US households (approximately 7.1 million)
were “unbanked” in 2019, meaning that no one in the household
had a checking or savings account at a bank or credit union52 ; and
• Recording of transactions including deeds and other indicia of
property ownership.
The uses which may have both positive and negative outcomes are:
• Store of value—comparable to precious metals in that they do not

ordinarily pay dividends or interest but, unlike metals, are assets that
may be divisible and portable;
• Trading—Virtual currencies may be purchased, sold, and act as secu-
rity as other assets which may result in capital gains or losses but,
at least at this juncture, are much more volatile causing heightened
speculation;
• Payments and transactions—may be used where acceptable as
payment for real and personal property or fees; and
• Transfer of money—may be utilized at a lower cost internationally
to transfer remittances or similar purposes.53
Risks of Digital Currencies

The negative aspects of digital currencies include:
• Lack of acceptance by banks and the protections afforded by them

and by merchants;
• Loss of interest on deposits;
• Security concerns such as use by terrorists, drug dealers, money
launderers, and other criminal elements;
• Currency volatility54 —events of mid-2022 illustrate the dramatic
drop in value of cryptocurrencies in the 70–80% range;
• Runs caused by crypto contagion resulting in major defaults and
runs especially in exchanges55 ;
16 R. GIRASA
• Payment beneficiary identification—loss of identity as through death

or mental incompetence may cause loss of holdings and transactions;
• Limited user base;
• Uncertainty concerning future regulation and tax treatment—There
is substantial confusion among the different branches of govern-
ment, e.g., the US Internal Revenue Service (IRS) treats cryptocur-
rencies as property that is subject to capital gains taxation56 while the
Securities and Exchange Commission (SEC) considers it as possible
involvement as an investment contract or other type of security if
the digital asset is in the form of a note57 ; the SEC has the authority
to govern “securities”4 , which has been defined to include, among
other things, “investment contracts albeit “currency” is not per se a
security. To the extent that a form of a digital asset is determined to
be a note, investment contract or other type of security, it would be
subject to SEC oversight and applicable securities laws.
• Cyber-threats such as hacking, theft, and loss58 ;
• Cross-national nature makes prosecutions very difficult;
• Lack of governmental backstops—Federal Deposit Insurance Corpo-
ration (FDIC) insurance does not cover cryptocurrency transac-
tions59 ;
• Lack of backing by other secure assets (exception may be stablecoins
discussed in Chapter 4);
• Lack of intrinsic value, and
• Ecological challenges due to extreme use of electrical power (see
discussion in Chapter 7).
US Government Agencies’ Risks Advisories

Commodity Futures Trading Commission (CFTC)
The CFTC categorized risks of virtual currencies as: operational risks —
virtual currencies, having many different platforms, are not subject to
supervision that otherwise are applicable to regulated exchanges; these
platforms may be missing critical safeguards and customer protection;
cybersecurity risks—some platforms may commingle customer assets which
may affect whether or how one can withdraw the currency; and some
may be vulnerable to hacks resulting in theft of virtual currency or loss of
customer assets; speculative risks—virtual currency is subject to substan-
tial volatility and price swings often due to inadequate trading volume;
and fraud and manipulation risk—depending on the platforms, they may

be vulnerable to hacks resulting in theft of virtual currency and loss of
assets, Ponzi schemes, promises of guaranteed returns as part of fraud-
ulent schemes, and fraudulent “bucket shop” schemes.60 An example of
the risks is the theft of $30,950,010 USDT (cryptocurrency pegged to
the US dollar)61 that was removed from the Tether Treasury wallet on
November 19, 2017 and transferred to an unknown Bitcoin address. The
company, in announcing the theft, stated that it was in the process of
recovering the stolen funds and further warned potential purchasers of
the funds that none would be honored.62 There were other Tether hacks
mainly from dealers such as the theft of $3.1 million of Tether from a
Taiwanese dealer.63
Consumer Financial Protection Bureau (CFPB)

The CFPB also has posted consumer advisories noting risks as stated
above by the CFTC and added problems associated with bitcoins. Among
the added risks were: (1) persons alleging they were exchange represen-
tatives to whose accounts moneys were transferred to purchase bitcoins
but which exchanges never transpired; and (2) Bitcoin kiosks that are
connected to the internet to permit exchange of cash for bitcoins appear
to be ATMs but do not function as traditional ATMs in that they are not
connected to a bank; lack safeguards of bank ATMs; often charge large
transaction fees as high as 7%; may have high exchange rates; that inser-
tion of a wrong 64-character public key can result in funds being sent
to another person; and that the loss of the private key may cause a total
loss of the bitcoins.64 Initially, the Bureau had few complaints pertaining
to virtual currency transactions (6 in 2016) but in 2017 through 2022,
there have been hundreds of complaints consisting of inability to access
funds within the time period promised, transaction or service problems,
and fraud.65
Although Bitcoin and other forms of digital currencies have been asso-
ciated with money laundering and unlawful drug transactions because of
anonymity as in the use of bitcoins, nevertheless, it has been suggested
that these risks are overestimated. The ownership of virtual currency is
public thereby permitting substantial analysis of the transactions. Bitcoins
have come out from under their cover to uses by large companies inter-
nationally.66 A possible contrary view was voiced by the chairman of the
FED, Jerome Powell,67 who warned that central banks which engage in
18 R. GIRASA
issuing digital currencies are vulnerable to cyberattacks, criminal activities,

and privacy concerns. He stated further that there are trade-offs between
strengthening security and enabling illegal activity. Advanced cryptog-
raphy, while reducing vulnerability to cyberattacks, also facilitate unlawful
activity.68
Government Services Administration (GSA)

The GSA and other federal agencies are exploring the use of DLTs like
blockchain for financial management, procurement, internet technology
(IT) asset and supply chain management, smart contracts, intellectual
property, and other utilizations through their Emerging Citizen Tech-
nology program. The program included the US Federal Blockchain
platform for federal agencies and US businesses which are interested in
exploring DLT and its implementation within government. It hosted
the first US Federal Blockchain Forum on July 18, 2017, uniting more
than 100 federal managers from dozens of unique agencies to discuss
use cases, limitations, and solutions.69 Periodically, it has been auctioning
bitcoins that had been seized in drug raids by the FBI especially when
the Silk Road black market was terminated.70 At the present time, the
GSA’s Office of Technology Policy is working closely with other federal
agencies to facilitate the implementation of technology policy, large-scale
IT initiatives, and legislation. Areas of concern include IT initiatives in
digital strategy, information security, IT accessibility, IT infrastructure
modernization, emerging technologies, and IT spending transparency.71
Securities and Exchange Commission (SEC)

The SEC has issued a series of investor bulletins warning of the risks asso-
ciated with initial coin offerings (ICOs) and other digital related offerings.
Its Office of Investor Education and Advocacy issued a report on July 25,
2017, cautioning issuers and investors that virtual coins or tokens offered
may be securities depending on the facts and circumstances of each ICO
and may have to comply with registration requirements under the secu-
rities laws. It cautions investors to be wary of claims that an offering is
exempt from registration particularly if he or she or it is not an accred-
ited investor or is described as crowdfunding. Investors are advised to
ask what the moneys invested will be used for and the rights the virtual
coin or token provide. Investors are particularly warned about persons
using innovative technology do so to commit fraud or theft. The lack of

a central authority and the international scope of offerings may preclude
governmental intervention and assistance. Issuers are cautioned about
compliance with applicable federal and state registration requirements.72
In a follow-up alert, the SEC’s Office of Investor Education and Advo-
cacy repeated earlier warnings to investors due to the increasing use of
ICOs by developers, businesses, and individuals who may use the offer-
ings for publicity purposes to enhance the price of the company’s stock.
The SEC advises it may suspend trading under circumstances where there
is a lack of current accurate information about the company; when ques-
tions arise about the accuracy of publicly available information; and when
there are concerns about the trading in the stock, particularly by insiders
who may engage in market manipulation such as by “pump-and-dump”
schemes. Investors additionally were given tips before making invest-
ments including research about the company; caution regarding stock
promotions; possible microcap fraud; online blogs; promotional and press
releases; frequent changes in a company’s name, management, and type
of business; and other cautionary guidelines.73
Immigration and Customs Enforcement (ICE)

ICE is particularly concerned with the unlawful use of virtual currency
on an international plane. Its HSI [Homeland Security Investigations]
Illicit Finance and Proceeds of Crime Unit (IFPCU) operates in conjunc-
tion with members of the compliant virtual exchange industry and with
the financial industry to combat the movement of illicit funds through
the financial services industry. Among its activities is the expansion of
its knowledge base by overcoming technological obstacles, its agents
encounter involving the emerging technologies such as blockchain; inves-
tigator training and procurement of equipment to enable investigators
to combat illicit online activity; and to collaborate with industry leaders
to acquire the latest innovative forensic tools to analyze and identify
information through the blockchain.
Federal Reserve Board (FED)

The FED does have an interest in the digital economy inasmuch as the
payment, clearing, and settlement processes (PCS) involves some 600
million transactions per day. Accordingly, as stated in a study of DLT, it
20 R. GIRASA
has expressed a keen interest in the development of innovations that affect

the structural design and functioning of the financial markets. It cited
approvingly of the risks stated by the Financial Stability Board discussed
below associated with crypto-assets.74
International Risk Assessments

International Monetary Fund (IMF)
The IMF, in its Global Financial Stability Report,75 noted the risks
to crypto-asset trading volumes as a result of the Russian invasion of
the Ukraine in 2022 and the ensuing introduction of sanctions against
Russia. The sanctions halted the former longer-term increase in cross-
border transactions with the interruption of capital flow measures and
sanctions. Risks are exacerbated by the less stringent regulatory measures
imposed on fintechs. Among the measures proposed by the IMF is for
policymakers to develop comprehensive global standards for crypto-assets
along the activity and risk spectrum. There should be much more over-
sight of fintech firms and decentralized finance to assure taking advantages
offered but also mitigate against risks. It further proposed introduction of
exchange governance mechanisms, resiliency of trading systems, concen-
tration of risk, margin setting, and trading transparency in exchange and
over-the-counter markets.76
Financial Stability Board (FSB)

The FSB, according to its website, is an international body that moni-
tors and makes recommendations about the global financial system.77
It assesses vulnerabilities affecting the global financial system, promotes
coordination and information, sets guidelines, advises on best practices,
and other mandates. In a February 2022 Report,78 it advised that the
crypto-asset market could reach a critical point in which it poses a threat
to global financial stability. The report discusses three areas of vulnerabil-
ities, namely, unbacked crypto-assets (such as Bitcoin); stablecoins; and
decentralized finance and crypto-asset trading platforms. The risks are
the increased linkages between the financial system and the crypto-assets
markets; liquidity mismatch; susceptibility of stablecoins to sudden runs
on their reserves and their spillover effects; concentration risk of trading
platforms; and the lack of clarity and regulatory oversight of the sector.
The report further noted that investors and consumers have low levels of
understanding of the complexity of the sector which are subject to fraud,
money laundering, and ransomware. The FSB expressed its intent to care-
fully monitor future events as the crypto-asset markets grow competitive
to traditional finance and make high-level recommendations including
global stablecoin arrangements.
European Union Supervisory Authorities (ESAS)

ESAS, composed of the European Banking Authority (EBA), the Euro-
pean Securities and Markets Authority (ESMA), and the European Insur-
ance and Occupational Pensions Authority (EIOPA), issued a warning in
March 2022 of the risks of many crypto-assets and cautioned that use
thereof is highly risky and speculative. ESAS was concerned about the
proliferation and aggressive marketing of the assets and products to the
public, particularly through social media. They indicated that most of the
offerings are not suitable for most retail customers either as investments or
as payments systems. There is a high degree of loss of entire sums used for
their acquisition. Consumers are warned about misleading advertisements
especially when promises of fast or high returns are made. Users will have
no recourse because the crypto-assets are outside of the protective barrier
under current EU financial services rules. Restrictions against Russia and
Belarusian entities have further exacerbated the dangers inherent in their
expenditure.79
European Union Agency for Network and Information Security

(ENISA)
ENISA, which is the center for cybersecurity in Europe headquartered in
Greece, repeated many of the concerns stated above and adds or modifies
them, which are (1) key and wallet management —need to protect one’s
private key which a malicious user may attempt to discover or reproduce;
(2) cryptography risks —need for following stringent key management
policies and procedures to avoid software programs used to generate
keys that are weak and vulnerable to attack; (3) attacks on consensus
protocol —the concern that it may be vulnerable to a “consensus hijack”
or a “51% attack” where a malicious party may try to obtain more than
50% of the computing power of the entire network and possibly trigger
double spending attacks; (4) distributed denial of service—use of large
22 R. GIRASA
numbers of spam transactions in the cryptocurrency network by multiple

users that may cause denial of services that actually occurred in March
2016; (5) smart contract management —the substitution of code for legal
language increases the complexity of the contract and requires skill usage
or else be open to human error; (6) illegal use—terrorist and/or criminal
usage; (7) privacy—the EU General Data Protection Regulation80 may
be violated by the public nature and permanency of the ledger because
it requires deletion of personal data when no longer necessary; and (8)
future challenges —the technology, especially that of quantum computing,
may impede the security of algorithms and protocols.81
Nobel Laureates’ Concerns

Two Nobel Prize Laureates in Economics expressed their apprehensions
concerning virtual currencies, particularly, Bitcoin. Professor Robert J.
Shiller of Yale U. noted at the World Economic Forum (WEF) that while
Bitcoin is a clever idea and will not be a permanent part of our lives,
its underlying technology blockchain will have other applications. At the
Forum, there appeared to be a consensus that fiat money (cash) is going
out of style.82 Shiller said at another conference in Vilnius, Lithuania in
December 2017, “Bitcoin, it’s just absolutely exciting”. He noted that the
concept of Bitcoin as anti-government and anti-regulation is a wonderful
story, “if it were only true”. Another Nobel laureate, Joseph Stiglitz,
of Columbia U., expressed the view that Bitcoin should be outlawed
inasmuch as it does not serve any socially useful function.83 In 2020,
Harvard’s 2007 Nobel Prize Laureate economist, Eric Maskin, stated his
belief that CBDC (discussed in Chapter 4) will displace cryptocurrencies
and generally praised blockchain for its transformative, positive affect on
economic growth.84
In Chapter 2, we will examine the underlying technology of Bitcoin
and other cryptocurrencies and examine some of the types of these
currencies that have created a revolution in the manner in which virtual
currencies are currently exchanged and their increasing use in the near
future.
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B u b a l u s m i n d o r e n s i s Heude
Fig. 1 c. ⅛ n. Gr. Fig. 2 c. ⅓ n. Gr.
Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7

Nr. 6 Meyer, Säugethiere Celebes-Philippinen Taf. IX
1 A b n o r m e S c h w e i n e - E c k z ä h n e 2–3 B a b i r u s a a l f u r u s Less.
n. Gr.
Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7 Nr. 6

Meyer, Säugethiere Celebes-Philippinen Taf. X
1 S c i u r u s t o n k e a n u s A. B. Meyer c. ¾ n. Gr. 2 S c i u r u s
l e u c o m u s Müll. Schl. unter ⅓ n. Gr. 3 S c i u r u s r o s e n b e r g i
Jent. c. ⅓ n. Gr. 4 S c i u r u s t i n g a h i A. B. Meyer c. ⅗ n. Gr.

Meyer, Säugethiere Celebes-Philippinen Taf. XI
1 S c i u r u s m i n d a n e n s i s Steere 2 S c i u r u s s a m a r e n s i s
Steere
c. ⅔ n. Gr.

Meyer, Säugethiere Celebes-Philippinen Taf. XII
P h l œ o m y s c u m i n g i Wtrh.
c. ¼ n. Gr.

Meyer, Säugethiere Celebes-Philippinen Taf. XIII
1–2 P h l œ o m y s c u m i n g i Wtrh. 3–6 C r a t e r o m y s s c h a d e n b e r g i (A. B. Meyer) n.
Gr.

Meyer, Säugethiere Celebes-Philippinen Taf. XIV
C r a t e r o m y s s c h a d e n b e r g i (A. B. Meyer)
⅓–¼ n. Gr.

Meyer, Säugethiere Celebes-Philippinen Taf. XV
1 Phalanger celebensis (Gr.) 2–3 P h a l a n g e r s a n g i r e n s i s A. B.
Meyer
c. ⅓ n. Gr.
[I]
[Inhalt]
Abhandlungen und Berichte des
Königlichen Zoologischen und
Anthropologisch-Ethnographischen
Museums zu Dresden Bd. VII 1898/99
Nr. 7
Säugethiere
vom
Celébes- und Philippinen-
Archipel
II
Celébes-Sammlungen der Herren
Sarasin
von
A. B. Meyer
Anhang
J. Jablonowski: D i e l ö f f e l f ö r m i g e n
Haare der Molossi
M i t 1 1 Ta f e l n , d a v o n 8
colorirt
Verlag von R. Friedländer & Sohn in
Berlin
1899
[III]
[Inhalt]
Inhaltsverzeichniss
Seite
Tafelerklärung V
Alphabetischer Index VII
Addenda VIII
Einleitung 1
Primates
1. M a c a c u s m a u r u s F. Cuv. Taf. I und II 2
M a c a c u s t o n k e a n u s n. sp. 3
2. C y n o p i t h e c u s n i g e r (Desm.) 4
3. C y n o p i t h e c u s n i g e r n i g r e s c e n s (Temm.) 4
4. Ta r s i u s f u s c u s Fisch.-Waldh. Taf. III Fig. 1–2 4
Chiroptera
5. P t e r o p u s w a l l a c e i G r . Taf. IV Fig. 1 5
6. P t e r o p u s a l e c t o Temm. 5
7. P t e r o p u s h y p o m e l a n u s Temm. 6
8. P t e r o p u s m a c k l o t i Temm. 6
9. X a n t h a r p y i a m i n o r (Dobs.) 6
10. C y n o p t e r u s l a t i d e n s Dobs. 7
C y n o p t e r u s b r a c h y o t i s (S. Müll.) 7
11. U r o n y c t e r i s c e p h a l o t e s (Pall.) 8
12. C e p h a l o t e s p e r o n i Geoffr. 9
13. C a r p o n y c t e r i s a u s t r a l i s (Ptrs.) 10
14. R h i n o l o p h u s m i n o r Horsf. 11
15. H i p p o s i d e r u s d i a d e m a (Geoffr.) 11
16. M e g a d e r m a s p a s m a (L.) 12
17. V e s p e r u s p a c h y p u s (Temm.) 12
18. V e s p e r u g o p e t e r s i n. sp. Taf. IV Fig. 2 13
V e s p e r u g o p a p u a n u s o r i e n t a l i s n. subsp. 14
19. V e s p e r u g o m i n a h a s s a e n. sp. Taf. IV Fig. 3 14
20. V e s p e r t i l i o m u r i c o l a Hdgs. 16
21. N y c t i n o m u s s a r a s i n o r u m n. sp. Taf. IV Fig. 4–6
und Taf. X Fig. 3, 4 und 28, und Taf. XI Fig. 2 und 2a 16
N y c t i n o m u s a s t r o l a b i e n s i s n. sp. Taf. X Fig.
19 und 30, und Taf. XI Fig. 6 19
Insectivora
22. C r o c i d u r a f u l i g i n o s a (Blyth) 20
Carnivora
23. V i v e r r a t a n g a l u n g a Gray 20
24. P a r a d o x u r u s h e r m a p h r o d i t u s (Schreb.) 20
25. P a r a d o x u r u s m u s s c h e n b r o e k i Schl. 20
Rodentia
26. S c i u r u s l e u c o m u s Müll. Schl. 21
27. S c i u r u s l e u c o m u s o c c i d e n t a l i s A. B. M. [IV] 21
28. S c i u r u s s a r a s i n o r u m A. B. M. Taf. V 21
29. S c i u r u s m u r i n u s Müll. Schl. 21
30. S c i u r u s r u b r i v e n t e r Müll. Schl. 22
31. M u s r a t t u s L. 22
32. M u s n e g l e c t u s Jent.(?) 22
33. M u s e p h i p p i u m Jent. 23
34. M u s m u s s c h e n b r o e k i Jent. Taf. VI Fig. 1 23
35. M u s c a l l i t r i c h u s Jent. Taf. VII Fig. 1 24
36. M u s h e l l w a l d i J e n t . Taf. VII Fig. 2–10 25
37. M u s x a n t h u r u s Gr. Taf. VI Fig. 2–10 25
38. L e n o m y s m e y e r i (Jent.) Taf. VIII 26
39. C r a u r o t h r i x l e u c u r a (Gr.) Taf. IX 27
Ungulata
40. S u s v e r r u c o s u s c e l e b e n s i s (Müll. Schl.) 27
41. B a b i r u s a a l f u r u s Less. 28
42. C e r v u s m o l u c c e n s i s Q. G. 29
Marsupialia
43. P h a l a n g e r u r s i n u s (Temm.) 31
44. P h a l a n g e r c e l e b e n s i s (Gr.) 31
Anhang: D i e l ö f f e l f ö r m i g e n H a a r e d e r M o l o s s i
von Dr. J. J a b l o n o w s k i , Assistenten am Museum. Hierzu
Taf. X und XI 32
[V]
[Inhalt]
Tafelerklärung
Tafel I M a c a c u s m a u r u s F. Cuv. vom Pik von Seite 2

Bonthain, Süd Celébes, mas sen. Circa ⅓
nat. Grösse
Tafel II Schädel von M a c a c u s m a u r u s F. Cuv. Seite 2
vom Pik von Bonthain, mas sen. 1 norma
facialis, 2 norma lateralis, 3 norma verticalis,
4 norma basalis. ¾ nat. Grösse.
Tafel III 1–2 Ta r s i u s f u s c u s Fisch.-Waldh. von Seite 4
Nord Celébes. 1 mas ad., nat. Grösse; 2
juv., circa ⅔ nat. Grösse.
3 Ta r s i u s s a n g i r e n s i s A. B. M. von Seite 5
Siao, Sangi Inseln. Circa ½ nat. Grösse.
Tafel IV 1 P t e r o p u s w a l l a c e i Gr. von Nord Seite 5
Celébes. Nat. Grösse.
2 Kopf von V e s p e r u g o p e t e r s i n. sp. Seite 13
von Nord Celébes. Doppelte nat. Grösse.
3 Kopf von V e s p e r u g o m i n a h a s s a e Seite 14
n. sp. von Nord Celébes. Doppelte nat.
Grösse.
4–6 N y c t i n o m u s s a r a s i n o r u m n. Seite 16
sp. von Central Celébes. 4 nat. Grösse. 5
Kopf in doppelter nat. Grösse, 6 Tragus in
vierfacher nat. Grösse.
Tafel V S c i u r u s s a r a s i n o r u m A. B. M. von Seite 21
Central Celébes. 1 nat. Grösse, 2 ½ nat.
Grösse.
Tafel VI 1 M u s m u s s c h e n b r o e k i Jent. von Seite 23
Nord Celébes. Nat. Grösse.
2–10 M u s x a n t h u r u s Gr. von Nord Seite 25
Celébes. 2–8 nat. Grösse, 9 und 10 circa
fünffache nat. Grösse.
rechter
3 Vorderfuss von unten
rechter
4 Hinterfuss von unten
Schädel
5–6 in der norma lateralis
Schädel
7 in der norma verticalis
Schädel
8 in der norma basalis
linke obere
9 Zahnreihe in
derselben Orientirung wie der
Schädel
linke10
untere Zahnreihe,
desgleichen
Tafel VII 1 M u s c a l l i t r i c h u s Jent. von Nord Seite 24

2–10 M u s h e l l w a l d i Jent. von Nord Seite 25
Celébes. 2–8 nat. Grösse, 9 und 10 circa
siebenfache nat. Grösse.
rechter
3 Vorderfuss von unten
rechter
4 Hinterfuss von unten
Schädel
5–6 in der norma lateralis
Schädel
7 in der norma verticalis
Schädel
8 in der norma basalis
linke obere
9 Zahnreihe in
derselben Orientirung wie der
Schädel
linke10
untere Zahnreihe,
desgleichen
Tafel VIII L e n o m y s m e y e r i (Jent.) von Nord Seite 26
linker 2Vorderfuss von unten

linker 3Hinterfuss von unten
Tafel IX C r a u r o t h r i x l e u c u r a (Gr.) von Nord Seite 27

linker 2Vorderfuss von unten

linker 3Hinterfuss von unten
Tafel X und XI H a a r e d e r M o l o s s i . Seite 32 fg.

Siehe nähere Erklärung Seite 53 des
A n h a n g e s von J. J a b l o n o w s k i .
[VII]
[Inhalt]

Regulation of Cryptocurrencies and Blockchain Technologies National and International Perspectives 2Nd Edition Rosario Girasa All Chapter

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Regulation of Cryptocurrencies and

Blockchain Technologies - National and

ISSN 2662-5083 ISSN 2662-5091 (electronic)

1st edition: © Springer International Publishing 2018

Pleasantville, USA Rosario Girasa

Alibaba Group Holding LTD v. Alibabacoin Foundation, No. 1:2018-cv-

Gallagher v. Bitcointalk.org, No. 3:18-cv-05892 (N.D. Ca. Sept. 24,

SEC v. W.J. Howey & Co., 328 U.S. 293 (1946).

1 The Digital Transformation 1

European Union Supervisory Authorities (ESAS) 21

Foundational Principles and Features of CBDCs 163

Internal Revenue Service Enforcement of Regulations 274

International Organization of Securities Commissions

Conclusion: Quantum Computing and the New Disruption 379

AICPA American Institute of Certified Public Accountants

DeFi Decentralized Finance

Inline XCRL Inline eXtensible Business Reporting Language

The Digital Transformation

© The Author(s), under exclusive license to Springer Nature 1

PC (private copy) royalties to advertising and subscription-based models;

Definitions and Types of Non-Fiat Currencies

Reasons for the Rise of Digital Currencies

• Costs of Third-Party Servicing. The revolution in the mode of

subject to major tampering as witnessed by cybercriminals’ access to

technology, view fiat currencies in derogatory terms due to their

bank notes. Electronic money (e-money) may be defined as “electroni-

• Digital currencies —represent value denominated in legal tender such

as its underlying technology.27 Included and discussed hereafter are

Expanding on the above characterizations:

exchange as equivalent value with the understanding that it is not govern-

as a digital representation of value that functions as (i) a medium of

Key Actors in Digital Technology38

• Inventors (creators). The major figure who created initially the

the emanations evolving from blockchain are smart contracts; secu-

data and records; real estate transactions; record management; cyber-

• Trading platforms. A trading platform is the means wherein curren-

Benefits and Risks of Digital Currencies

• Reduction of exposure risks that may occur when transacting bearer

• Store of value—comparable to precious metals in that they do not

Risks of Digital Currencies

• Lack of acceptance by banks and the protections afforded by them

• Payment beneficiary identification—loss of identity as through death

US Government Agencies’ Risks Advisories

and fraud and manipulation risk—depending on the platforms, they may

Consumer Financial Protection Bureau (CFPB)

issuing digital currencies are vulnerable to cyberattacks, criminal activities,

Government Services Administration (GSA)

Securities and Exchange Commission (SEC)

using innovative technology do so to commit fraud or theft. The lack of

Immigration and Customs Enforcement (ICE)

Federal Reserve Board (FED)

has expressed a keen interest in the development of innovations that affect

International Risk Assessments

Financial Stability Board (FSB)

European Union Supervisory Authorities (ESAS)

European Union Agency for Network and Information Security

numbers of spam transactions in the cryptocurrency network by multiple

Nobel Laureates’ Concerns

Fig. 1 c. ⅛ n. Gr. Fig. 2 c. ⅓ n. Gr.

Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7

Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7 Nr. 6

Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7 Nr. 6

Abh. Ber. K. Zool. Anthr. Ethn. Mus. Dresden 1896/7 Nr. 6