First published on Thomson Reuters Regulatory Intelligence on 12
June 2019 (this version includes updates as at 28 June 2019).
In our first article on cryptoassets we discussed considerations
for boards and senior management. This second article considers
regulatory risks specific to cryptoassets which the second line of
defence (i.e. compliance and risk functions) within the three lines
of defence (TLOD) model of compliance should consider.
Traditional Sector: Banks and Investment Firms
When dealing with cryptoassets, banks and investment firms will
need to be able to:
- identify the risks associated with a
cryptoasset proposition;
- design and implement an appropriate
control environment which ensures that cryptoasset business is
undertaken in compliance with applicable requirements and in
alignment with the firm’s risk appetite; and