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ARTICLE · 24 JULY 2019

Cryptoassets – What Should The Second Line Of Defence Be Focussing On?

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

United KingdomTechnology
Wendy Saunders
Wendy Saunders

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

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