導讀
監管加密貨幣生態系統是涉及全球金融穩定的熱門話題。
最近加密市場震蕩嚴重，加密生態系統出現了快速增長和退縮的反復周期，穩定幣、對沖基金和交易所出現了市場失靈，引發了人們對市場行為、客戶保護、系統的風險監督和金融穩定的關切。
我們的報告從兩個層面解決這些問題：首先，我們從大處入手，放眼於行業內履行核心職能的關鍵實體，然後再將我們的結論和建議應用到整個加密資產生態系統；其次，我們聚焦穩定貨幣。
穩定幣是一種加密資產，能夠通過各種穩定機制抑制價格波動，但是目前沒有一個市場的穩定貨幣可以隨時隨地做到這一點。
加密資產不是全球系統性的資產。
在新興市場經濟體中，加密資產化有可能導致資本外流和貨幣主權的喪失，從而給政策制定者帶來挑戰。
發達經濟體中也有機構投資者一直被穩定幣的高回報所吸引，不斷增加持有量，也有可能受到風險沖擊。
因此監管當局必須迅速采取行動，管理加密貨幣資產產生的風險，同時不扼殺創新。
我們的報告提出了五個建議。
首先，提供關鍵服務的加密資產提供商應得到許可、註冊和授權，要明確闡述許可和授權標準，指定負責機構，建立起機構間協調機制。
第二，多職能的實體應受到額外限制。
要區分客戶資產與其他功能，減少風險。
第三，嚴格要求穩定幣的發行者。
隨著越來越多的穩定幣在其他領域發行，需要對穩定幣進行強有力的銀行式監管，央行應發揮主導作用。
第四，明確對受監管的金融機構在從事加密貨幣方面的要求。
第五，建立起一個全面協調、強大有效的全球應對機制，對加密貨幣進行有效監管，適應不斷變化的環境和風險。
另外，在有效監管下，針對性的限制措施也會帶來良好的公共政策成效。
作者丨李波，IMF副總裁
Some Key Elements of Crypto Regulation
By Bo Li，IMF Deputy Managing Director
Roundtable on Regulation and Supervision of Crypto Assets
December 9，2022
Good morning. Thank you for joining us today for the launch event of our two recently published Fintech Notes. The notes address a very topical issue of global financial stability— regulating the crypto ecosystem. I am very pleased that we are joined today by leading policy makers working on this topic.
The timeliness of our reports is illustrated by the severe turmoil and disruption in many parts of the crypto asset market recently and by repeated cycles of rapid growth and retreat of the crypto ecosystem. During times of stress，we have seen market failures of stablecoins，hedge funds and exchanges，which have raised serious concerns about market practices，client protection，and where interlinkages with the core financial system are deepening，for systemic risk oversight and financial stability. Many of these concerns can be addressed by strengthening financial regulation in this area，and by developing global standards that can be implemented consistently by national regulatory authorities.
Our reports address these issues at two levels. First，we take a broad approach，looking across key entities that carry out the core functions within the sector，and hence，our conclusions and recommendations apply to the entire crypto asset ecosystem. Second，we focus more narrowly on stablecoins and their arrangements. Stablecoins are a type of crypto asset that aspire to dampen their price volatility through various stabilization mechanisms，but there is no stablecoin in the market right now that can assure this under all circumstances.
Crypto assets，including stablecoins，are not globally systemic，but in some emerging market economies，they might be on the verge of generating risks to financial stability. Some of these countries are seeing large retail holdings and cryptoization，or currency substitution by crypto assets. Cryptoization has the potential to lead to capital outflows，and a loss of monetary sovereignty，thereby creating new challenges for policy makers. Authorities need to address the root causes of cryptoization to improve trust in domestic currencies，in domestic banking system，and in domestic economic policies.
Advanced economies are also potentially susceptible to financial stability risks from crypto assets，given that institutional investors had been increasing their stablecoin holdings，attracted by higher returns on DeFi platforms in what had been a low interest rate environment. This is why we think it is important that regulatory authorities move quickly to manage the risks that crypto assets generate，while not stifling innovation.
Our reports make five key recommendations:
First，we believe that crypto asset service providers delivering critical functions should be licensed，registered，and authorized. Such entities include those providing storage，transfer，exchange，settlement，and custody services. Rules should be similar to those applying to providers of these services in the traditional financial sector. Licensing and authorization criteria should be clearly articulated，the responsible authorities clearly designated，and coordination mechanisms among them well defined.
Second，entities carrying out several functions should be subject to additional prudential requirements. The recent FTX failure showed how the combination of exchange，wallets，and market making services under one group creates significant risks to the customers. It is particularly important that customer assets are segregated from other functions.
Third，stablecoins issuers should be subject to strict prudential requirements. Some stablecoins are starting to find acceptance outside the crypto space，and they have the potential of becoming widely used payment instruments. As such，they look more and more like 『money.』 If not properly regulated，stablecoins could pose serious challenges to monetary and financial stability. We need strong，bank-type regulation for stablecoins，and central banks should take the lead in such an endeavor given stablecoins’ potential presence in the monetary system.
Fourth，there should be clear requirements on regulated financial institutions，concerning their exposure to，and engagement with，crypto. If regulated entities provide custody services，requirements should be clarified to address the risks arising from those functions.
Fifth，and eventually，we need robust，globally consistent，comprehensive regulatory responses to achieve effective crypto regulation and supervision. The cross-sector and cross-border nature of crypto assets limits the effectiveness of uncoordinated national approaches. For such a global approach to be effective，it must also be adaptable to a changing landscape and risk outlook.
More generally，we believe that targeted restrictions could deliver better public policy outcome provided there is sufficient regulatory capacity. For instance，we can restrict the use of certain crypto derivatives，as shown by Japan and the UK. We can also restrict crypto promotions，a step taken in Spain and Singapore.
Having said all this，developing global standards takes time. I was very pleased to see the excellent work the FSB has done in this space. They have provided high-level recommendations for crypto assets，and revised them for global stablecoins to close gaps in the market. Our Fintech Notes draw many of the same conclusions，and this is a testament to our close collaboration and shared observations on the market.
With that，let me pass the floor to Tobias Adrian，our Financial Counsellor and Director of the Monetary and Capital Markets Department，to moderate the dialogue. I very much look forward to hearing your views on these critical issues.
Thank you very much.
編譯：張曉晗
監制：董熙君
來源｜ IMF
版面編輯｜王懿萱
責任編輯｜李錦璇、蔣旭
總監制｜朱霜霜
近期熱文