Adan’s manifesto to the candidates for the 2022 French presidential election

FRANCE AND CRYPTO ASSETS: AT THE CROSSROADS OF A CITIZEN’S WILL AND A NEW ECONOMIC BREATH

Preface

The crypto-asset sector is growing rapidly and taking up more and more space in the daily routine of our fellow citizens. With a global capitalization peak of over 3,000 billion dollars at the end of 2021 and already 8% of French people holding digital tokens, the spread of this new asset class in our economy is no longer an epiphenomenon.

It is a natural evolution that responds to a societal shift towards a more digital, more flexible, more democratic world. In the 1990s, the Internet revolutionised the way we exchange information; today, crypto-assets are revolutionising the way we exchange value. From now on, an industry is emerging that will disrupt every part of our economy.

However, the experience of digital technology over the last 20 years has shown us that those who seize the opportunities of a technology today and accept to take the associated risks are those who will tomorrow be able to impose their standards, their world vision, but also to reap all the economic benefits.

In this sense, crypto-assets are full of opportunities in terms of jobs, financing of the economy, social responsibility, security, territorial cohesion and the effectiveness of our public policies.

Everyone has a role to play in order to take full advantage of this potential: individuals in their consumption choices, companies in proposing innovative products and services that respect the general interest, but also public authorities in supporting these innovations and the associated transformations.

France and Europe have major assets to be at the heart of this financial revolution, first and foremost world-renowned talent and pioneering regulation. In an ultra-competitive environment where the race for innovation has already begun, it is up to us to pre-empt this strategic industry for the future competitiveness and autonomy of our States.

Adan’s proposals

1. Why the interest in the digital assets sector? State of the industry

An opportunity for citizens

Digital assets were born out of citizens’ expectations for a move towards a world of finance that is more democratic, more respectful of privacy, protects against financial crises and is more accessible to all.

Based on blockchain technologies – transparent, secure registers that allow for low-cost transactions – crypto-assets have emerged as the ideal alternative to embrace their aspirations and practices. As a result, this new asset class is attracting more and more people around the world, but also in France.

According to the report published by Adan in January 2022, the share of French people holding crypto-assets is estimated at 8%. Highlighted to the general public over the past year, notably via social networks, the global crypto-asset market has surpassed $3 trillion at the end of 2021, and the volume of transactions has risen to €116 billion, an increase of more than 500% since December 2017.

This phenomenon is part of a wider context of transition to a “cashless society” where cashless payment methods are becoming increasingly important in the habits of our fellow citizens. Indeed, 76% of Europeans already considered in 2019 that the bank card was the “best” method of payment because it was simpler and more efficient; a trend that has been reinforced by the pandemic, since 87% of consumers who used less cash during this period say they will continue to do so. Crypto-assets are fully in line with this societal change and tomorrow, exchanging cash in digital format will be a matter of course. However, it remains to be seen how this new ecosystem will integrate with incumbent financial institutions, and how to ensure that all citizens are included in this transition, without leaving anyone by the wayside.

With decentralised finance, the programmability of money and the digital representation of any value, new uses are emerging which will continue to convince beyond borders. Since this dynamic cannot be stopped, it is more a question of being an actor and accompanying its development within a framework that we ourselves have defined.

An opportunity for the economy in general

The Covid-19 health crisis has brutally highlighted the necessity to strengthen our independence in France and in Europe in key sectors that influence both the economy and society. Preserving the autonomy and strength of our financial industry must be our main concern in this respect.

Since 2011 and the arrival of its very first players, the French crypto-asset industry has developed and structured itself in many segments: investment, savings, payment, financing, custody, decentralised banking and financial services, etc. Thus, in this new spectrum of the European economy and finance, France undoubtedly has a card to play. 

There are many opportunities to be seized: 

• A new source of growth and employment. As Indeed data shows, global hiring in the digital assets sector grew by 118% between July 2020 and July 2021.
• A revitalisation of territories. New investment models – simpler, more open and more collaborative – could allow local authorities to diversify their financing, for example in favour of the construction or renovation of public infrastructures.
• Support and modernisation of public finances. Some digital assets are structurally designed to be deflationary and as such can contribute to debt reduction. Similarly, the programmability enabled by digital assets would make it possible to combine automaticity and modularity in the collection of taxes and the distribution of social benefits.
• Improving financial services for citizens. Digital assets, combined with blockchain technologies, can reduce the costs, slowness, complexity and opacity of intermediation chains and procedures related to the financial system while contributing to better financial inclusion.
• Innovation that is compatible with environmental issues. Digital assets are anchored in the commitments to green finance. Recent initiatives reveal opportunities to help finance renewable energy, limit energy waste and better monitor our climate commitments.

A quarter of French unicorns belong to the Fintech sector, and nearly 10% of start-ups valued at more than one billion euros are companies operating in the digital assets sector. With a round of financing of 680 million dollars last September, Sorare broke the record for the largest fundraising in the history of FrenchTech. At a time when we are thinking about the economy and growth of tomorrow, it would seem inconsistent to do without such potential.

Abroad, many have already taken the measure and the urgency of the challenge: to establish on its territory the future GAFAMs of the financial sector and preserve its sovereignty in the light of the digitalisation of the economy. 

France and Europe must not be left behind. We can already be proud of our attractiveness to international companies, which see our pioneering regulation for crypto-assets as a source of confidence and stability. However, our companies are facing structural obstacles that need to be removed as a matter of urgency in order to bring out the future champions of digital finance. 

With this in mind, Adan would like to make recommendations to the candidates in the 2022 presidential election, aimed at creating the conditions for the success of these champions, overcoming the existing obstacles, and establishing France as the driving force – in Europe – of the new global economic momentum that the ambitions of this new breeding ground of players make possible.

2. Emerging digital finance champions in France and Europe 

Digital sovereignty: reasserting our economic power in the face of international competition

The advent of digital technology has reshuffled the cards of decision-making power. The hegemony of certain players now allows them to set the rules of the economic, geopolitical and even socio-cultural game. The effects of networks lead to the emergence of “winner takes all” phenomena, i.e. the dependence of the entire economic fabric on these “gatekeepers”, without whom it becomes difficult, if not impossible, to operate, and who sometimes exercise unfair competition. The host countries of these giants are the receptacles of economic spin-offs that enable them to shine globally by asserting their political influence.

Today, in addition to the Internet of information, the Internet of value is creating a new space that is in turn preparing to redistribute economic power. Redefining the contours of ownership, blockchain technologies and digital assets are forcing a rethink of existing business models, opening up the field of possibilities in terms of economic opportunities. Thus, they suggest that authors will once again have control over the circulation of their works, that Internet users will be able to value their personal data on social networks themselves, and that platform workers will be able to regain control of the profits linked to their activity.

Therefore, in order to prevent new gatekeepers from imposing themselves on French industry with the associated cybersecurity risks – particularly in the field of finance – it is necessary for the public authorities to support and encourage the development of projects related to crypto-assets on their territory. It is a question of anticipating the challenges to come and creating the conditions for future success.

The digital assets sector can be described as strategic because it helps to meet the needs of our society by contributing to the achievement of key objectives:

• It strengthens our economic sovereignty because mastering the technology would help guarantee both our independence and our financial and monetary security.
• It is in line with the economic, environmental and social imperatives of the time because it brings growth and jobs, new sources of financing for renewable energy and the democratisation of finance.
• It brings coherence to the economy because it allows different industries to be interconnected.
• It strengthens our human capital and know-how because it is in a highly qualified field.

Many countries have grasped the revolutionary potential of digital assets and have moved quickly into the international race for innovation in this industry. The United States, encouraging private initiatives and contributing to the fact that already more than 99% of stablecoins are backed by the dollar. Conversely, with a more centralist vision, China has been working since 2014 on the launch of a digital yuan. Each in their own way, these countries are trying, through innovation, to strengthen the weight of their currency in world trade.

In an environment where competition is synonymous with rapid innovation cycles, regulation must be flexible and agile. Europe, however, seems to be slow to take a position on its vision for the future. It is struggling to find its way between protection and innovation. Indeed, although the project for a digital euro is being studied, our institutions seem to have great difficulty in defining its contours, always delaying the launch of the project. At the same time, political support and favourable regulatory conditions for the issuance of euro stablecoins by continental players, which are crucial to rapidly counterbalance the hegemony of dollar stablecoins, are far from being achieved.

To date, the French and European sectors are already under intense, sometimes unfair, competitive pressure from foreign companies. On the euro stablecoin side, non-European entities are beginning to occupy this relatively uncharted territory left by Europe, while the American Tether launched its EURT this summer. On the crypto-asset markets, while France already imposes requirements on providers, French companies that play the game face illegal competition from unregistered players promoting their services to French customers without being worried. In addition to the credibility of the current regime, its effectiveness is thus called into question.

Business growth: supporting the financial champions of tomorrow

According to a survey by CBInsights, the European Union accounted for less than 4% of global funding to the crypto/blockchain sector between 2015 and 2019, compared to more than 50% for the US and 18% for China. As a result, despite the sector’s strong appeal (nearly 10% of French unicorns are crypto companies), companies are struggling to raise funds in amounts to compete internationally.

There are various obstacles to this problem. 

Firstly, digital asset projects could theoretically qualify for funding under the future investment plan or the France 2030 Plan. However, the intrinsic structure of blockchain networks, based on an assembly of technologies, makes it difficult to fit into the traditionally defined investment criteria. In operational terms, a vertical vision of research and development as it exists today therefore seems unsuitable.

Moreover, as is often the case in the new technologies sector, the innovation cycles of digital assets are very rapid. In this respect, funding programmes and tools appear to be outdated and less and less adapted to the projects presented by the holders.

Thus, in order to access funding, projects with high innovation value are obliged to distort their activity, sometimes lowering their ambitions in order to fit into the existing boxes. 

This situation is just as blocking for investors wishing to support projects as it is for very young companies seeking capital to develop. French investors, especially public ones, are less and less competitive; they are struggling to cope with the speed of technical developments and the amounts invested. It is therefore not uncommon for only foreign venture capital funds, which allow more flexibility in their eligibility criteria for financing, to support project leaders.

It is therefore appropriate, in view of the sovereignty challenges posed by digital assets, to assert a real political ambition for these technologies that will make it possible to support the growth of start-ups in order to build the champions of tomorrow in digital finance.

Employment: encouraging employment and motivating employees in the crypto sector

A number of companies issue tokens to finance their activities or to operate their services. The value of these tokens is closely linked to the success of the company. In fact, it is the value of the tokens issued rather than the value of the company’s shares that reflects this success. Thus, the allocation of part of the tokens issued by the company represents a greater incentive for the company’s employees than the traditional allocation of shares. 

In addition, there are situations in which projects to issue tokens are not developed by employees, but by employees who do not benefit from any protection scheme and whose main remuneration consists of tokens for the project. 

However, the qualification of these allocations depends on the relationship between the issuer and the beneficiary. This implies a sometimes complex analysis in a situation that is nevertheless simple, resulting from the desire to directly interest the persons participating in the project. For example, these allocations raise numerous difficulties in determining the taxable event and, above all, the tax base, especially when the tokens allocated were not listed on trading platforms or offered to the public at the time of allocation.    

Therefore, it would seem desirable to define a clear tax regime for the free allocation of tokens that provides a protective framework for the contributors to the project, allowing them to benefit from an effective incentive and providing an incentive for them to be paid.

Security: fighting financial crime with crypto-assets

While any emerging technological innovation opens up a new gap for criminal activity, in reality, crypto-assets are much more like a tool to support the fight against money laundering and terrorist financing than an obstacle to it.

For the year 2020, Europol has put money laundering at €2,129 billion globally (or 3% of global GDP) and €130 billion in Europe. By way of comparison over the year 2021, Chainalysis, a US company specialising in crypto-asset transactional analysis, reports that crypto-asset crime would have amounted to $14 billion. Fraudulent transactions thus represent only 0.15% of global crypto-asset transactions. While this figure is still too high, it should be noted that the percentage of fraudulent transactions is constantly decreasing. Thus, according to the data listed by Chainalysis, fraudulent transactions represented 3.37% of crypto transactions in 2019 and 0.69% in 2020.

This decrease in the use of crypto-assets by criminals, despite their spread among the general public, is not surprising. Indeed, the traceability that intrinsically characterises blockchain technologies makes it possible to follow a transaction chain in its entirety and therefore to make a relatively easy link between an illicit operation and its author.

Also, the holding of a large majority of crypto-assets is based on pseudonymity, thus making it possible to identify a user in the same way that an IP address makes it possible to identify an Internet user. In this respect, the use of crypto-assets in malicious financing cases has helped to guide intelligence services in their investigations rather than complicate them.  

Nevertheless, the role of mixing tools, regularly decried in the use of crypto-assets for fraudulent purposes, should not be minimised. These tools allow digital assets to be mixed together in order to blur the traceability of transactions. However, with the help of increasingly sophisticated transactional analysis tools, the transition of a crypto-asset through a blending service remains identifiable. Therefore, a transaction can be clearly identified as suspicious by the platforms responsible for carrying out the transaction. They can thus trigger enhanced monitoring measures. Such an approach is difficult to implement in the context of cash transactions, which remain the preferred method of financial crime. Indeed, whatever the modus operandi, a passage through currencies is always required to finalise the laundering operation. It is therefore on the points of passage between crypto-assets and legal tender that regulations must focus.

In this respect, it should be stressed that France is exemplary in the regulation of digital assets in the context of the fight against money laundering and terrorist financing.

Firstly, the Law for the Growth and Transformation of Businesses (Pacte) has provided for two frameworks for digital asset service providers (DASPs): mandatory registration and optional authorisation. In order to be registered (without which they are not allowed to promote their services to the French public), companies must comply with the same anti-money laundering and anti-terrorist financing regulations as other regulated entities, such as banks.

Secondly, these provisions have been strengthened twice by the orders of December 2020 and April 2021, in order to ensure that DASPs undertake advanced identification procedures on their users from the first euro of a transaction. In this respect, DASPs are therefore subject to stricter regulatory requirements than traditional financial players in terms of anti-money laundering and combating the financing of terrorism. The various studies carried out on the subject all agree that DASPs present a minimal risk in terms of financial crime.

However, on the pretext of a risk inherent in their activity, they are regularly refused access to banking services in France, a situation that pushes them to bank abroad. However, as the supervisory rules are not uniform and some legislations are less strict, the current situation actually undermines France’s determination to fight effectively against the risks of money laundering and terrorist financing.

If we can hope that the revision of the European AML/CFT framework will bring improvements in this sense, the draft presented by the European Commission on 20 July seems at least to address a major issue related to cyber security.

Indeed, in line with recommendation number 16 of the Financial Action Task Force (FATF) guidelines, the Commission plans to extend the Transfer of Funds Regulation of 2015 to make DASPs subject to the “travel rule”. Thus, in the context of a transaction between two customers of different providers, the latter would be obliged to exchange sensitive data about their users, such as the account number. As it stands, this provision raises two questions: no technical solution exists to date to ensure that these transmissions are made automatically and smoothly; the only existing initiatives in this regard are not European and do not seem to comply with the regulatory standards in force on the Old Continent. As such, DASPs would be obliged to transmit European citizens’ data to foreign entities, thus raising questions of data governance, cyber security, financial security and distortion of competition.

Environment: crypto-assets at the heart of the ecological transition

Crypto-asset players are aware that the ecological transition is a major challenge for our society, and are willing to take part in it. This is evidenced by the Crypto Climate Accord initiative, supported by several environmental organisations, which has set the goal of achieving zero net emissions in the global crypto industry by 2030.

It should also be added that digital assets are compatible with demanding and ambitious environmental objectives.

Firstly, miners – those who validate transactions and therefore ensure their security – are increasingly using renewable energy in their activity. Already in 2018, a study by the University of Cambridge estimated that most of the energy used came from hydroelectric power stations, which are the source of around 60% of mining, regardless of the continent on which the activity is located. This figure has been reinforced by the Chinese government’s ban on mining within its borders. Miners are migrating to less coal-consuming countries and prefer low-cost power generation.

Secondly, many initiatives are emerging to couple mining with other activities to act as a “recycler of wasted energy”. This reduces the environmental footprint of crypto-assets while making energy consumption in general more efficient.

Renewable energies, particularly wind and solar, have a significant potential in this respect, which could contribute to the greening of crypto-assets. Indeed, despite very competitive tariffs, these renewable energies are confronted with major and well-known problems, which are currently holding back their large-scale deployment. Insufficient demand, intermittent production and grid congestion are all difficulties, often compensated for by subsidies, that are difficult to overcome by setting up a viable economic model. A partnership with miners could prove beneficial in this respect. Crypto-asset validators could buy back and consume the energy produced but not sold, in order to meet a dual objective: to prevent this energy from being wasted and to make the construction of infrastructure associated with renewable energy development projects more profitable.

Several companies have already been set up around the world to buy and reuse, for mining purposes, gases (mainly methane) from oil production that have been burned to date and released into the air using the “flaring” method without being used for anything. Crypto-assets would thus contribute to the “zero flaring by 2030” objective set by the World Bank.

The funds from the sales of this so far unsold energy could be reinvested in green energy, in the development of sustainable projects and in research and development.

Conversely, a partnership realized with a British Columbia heating and hot water provider will, from this year, recycle the heat produced by crypto mining to heat about 100 homes and businesses in the municipality of North Vancouver in Canada.

Thirdly, environmental issues have been integrated into the development of the crypto-asset ecosystem. Although the validation protocol that consumes the most energy – proof-of-work – is also the one that is currently the most widely used, particularly because the best-known crypto-asset uses it (bitcoin), it is important to remember that more and more blockchain networks are using other, less energy-intensive methods of transaction validation. Indeed, the proof-of-work principle is a complex mathematical calculation race using a computer which, when won, is rewarded by obtaining crypto-assets. Miners are therefore financially incentivised to consume computer electricity, which at the same time ensures the security of the network, since the number of checks required for consensus and the electricity expenditure are proportional to the number of participants. It should be noted that energy consumption and environmental footprint are not synonymous, and that proof-of-work is currently the protocol that provides the best security.

In the case of proof-of-stake, miners must invest their wealth in order to participate and are randomly selected to validate the various blocks of transactions. The use of this validation method therefore eliminates the need for a computational race. The Ethereum blockchain hopes to reduce its electricity consumption by more than 99% by switching from proof-of-work to proof-of-stake. Moreover, Tezos, a partially French protocol, has always been based on proof-of-stake and its annual carbon footprint is limited to the average consumption of 17 people.

In addition, delegated-proof-of-stake allows the network of users to vote with the assets they hold for validators of the next transaction blocks. Again, this method of validation allows less computing power to be committed.

Finally, an article published by experts from the United Nations Organisation highlights the many opportunities represented by blockchain technologies for sustainable development. According to the experts, they “could accurately track where and how recovered waste is used, as well as identify who collected it, ensuring that the right people are rewarded for their efforts”. Its emergence could put an end to illegal fishing or provide financial incentives for more sustainable practices.

Thanks to their traceability characteristics, crypto-assets and the blockchain would also make it possible to better verify, and in complete transparency, the C02 emission data published by the countries that have committed to the COP 26. This transparency also makes it possible to bring more readability at the international level to the market for carbon quotas set up by the European Union in 2005.

Furthermore, according to the findings of a partnership between UNEP (United Nations Environment Programme), the Technical University of Denmark and the Danish Ministry of Foreign Affairs, there are “three main areas where blockchain can accelerate climate action: transparency, climate finance and clean energy markets”.

Education: preparing our citizens for the economy of the future

There are a number of training issues facing the digital assets sector.

The first is for companies, which lack technical resources and are struggling to hire developers in the crypto sector in particular. This is a complex technical field, which often requires mainly self-learning, and therefore engaging and long training, in order to understand all its complexity. Professional training courses, which are often short and dedicated to people with other initial training in the process of retraining, are, in this sense, not sufficiently adapted to companies’ recruitment expectations.

The second is for universities.  They are having difficulty keeping up with the pace of innovation cycles. The first modules related to crypto-assets are only just beginning to emerge in higher education, almost 14 years after the creation of the first digital asset and at a time when the sector is changing towards complex issues such as decentralised finance.

The third is for public and private decision-makers, who must also be able to understand the innovative issues that will drive the future economy. They must support these sectors in their development by being able to understand both the risks and the opportunities. It is in this respect that the representatives of the public authorities sometimes lack training in digital innovation, too often trying to understand it through existing schemes and to fit it into unsuitable or even inapplicable boxes, without distorting it. The same applies to traditional market players, who sometimes struggle to integrate the innovation that would promote their own competitiveness because of a reluctance linked to imperfect knowledge.

The last one is for citizens. Indeed, finance and digital technology are areas that are becoming increasingly important in the daily routine of French people. However, for some of them, these sectors remain abstract and not very accessible. As such, they may be more vulnerable to cybercrime such as ransomware attacks. Enabling them to better understand these issues would be a guarantee that they are better equipped to face these risks, to strengthen banking and financial inclusion, but also to make them aware of the opportunities offered by digital finance.

  3. About Adan

Adan (Association for the Development of Crypto-Assets) is a non-profit bringing together and representing crypto-assets and blockchain professionals in France and Europe. Adan’s members cover a wide range of activities: crypto-asset markets, custody, payments, investment management, blockchain analysis tools, support for crypto/blockchain projects, IT security, etc. Adan’s mission is to promote the development of the crypto-assets industry in favour of a new digital economy. To this end, the Association has technical and regulatory expertise in the world of digital assets and maintains a close dialogue with public authorities and industry associations.

Contacts :

• Faustine Fleuret, President and CEO: [email protected]
• Mélodie Ambroise, Director of Strategy and Institutional Relations: [email protected]

Website: www.adan.eu

Twitter : @adan_asso

Mail : [email protected]