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Payments & FinTech Lawyer

Resiliency, data protection and initial coin offerings: the FCA dissects distributed ledger technology

The UK’s Financial Conduct Authority (‘FCA’) released a discussion paper in April this year on distributed ledger technology (‘DLT’), with a view to gathering industry feedback on a range of issues connected to DLT, such as operational risks. The paper is notable for what it reveals about how the FCA views its role as regulator at this stage, for instance in the sense that the FCA is interested as to whether DLT will require it to shift its usual ‘technology-neutral’ approach. The paper also touches upon Initial Coin Offerings (‘ICOs’), an area relating to DLT that is attracting considerable attention at present. Robert Courtneidge and Charlie Clarence-Smith of Locke Lord LLP dissect the paper and the issues it raises.

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