On December 27, 2020, the Monero Policy Working Group (MPWG) responded to the European Commission’s request for comment on exploring crypto-assets.

The MPWG was one of thirty-three respondents.

In summary, some of the key points of our response are:

  • We agreed that the sector required clearer regulation, especially with regards to ICOs (or similar), exchange services, and centralised projects.

  • We urged the European Commission to provide clarity and certainty for those involved in decentralised open-source projects, especially developers.

  • We specifically requested that the Commission direct concrete attention to the seeming disregard found within the sector, and the proposed Regulation, for financial privacy and data protection.

  • We urged clarification on wording regarding the phrase “inbuilt anonymisation function”, as it was not clear to us what this is purported to mean.

  • We respectfully brought to the attention to the Commission that placing ‘ex-post’ regulation that affected the disposal of specific ‘types’ of crypto-assets may be viewed through the lens of existing European Court of Justice rulings, as infringing on property rights.

  • We requested that the Commission look closely at the ways in which existing protocols (those with “dev-taxes”) and exchanges (opaque calculations) handle fee calculation.

  • We argued that transparent chains if left unchecked would cause concern related to financial stability and market integrity, as insider trading (market abuse) would be more difficult to identify and/or investigate as it is possible to ‘watch’ known exchange addresses (or similar) from any computer terminal.

Please see our response in full here.

The Monero Policy Working Group (MPWG) is responsible for this content. This is not legal advice, and it should not be relied upon for any purpose by third parties. To learn more about the MPWG, click here.