导读
监管加密货币生态系统是涉及全球金融稳定的热门话题。最近加密市场震荡严重，加密生态系统出现了快速增长和退缩的反复周期，稳定币、对冲基金和交易所出现了市场失灵，引发了人们对市场行为、客户保护、系统的风险监督和金融稳定的关切。
我们的报告从两个层面解决这些问题：首先，我们从大处入手，放眼于行业内履行核心职能的关键实体，然后再将我们的结论和建议应用到整个加密资产生态系统；其次，我们聚焦稳定货币。稳定币是一种加密资产，能够通过各种稳定机制抑制价格波动，但是目前没有一个市场的稳定货币可以随时随地做到这一点。
加密资产不是全球系统性的资产。在新兴市场经济体中，加密资产化有可能导致资本外流和货币主权的丧失，从而给政策制定者带来挑战。发达经济体中也有机构投资者一直被稳定币的高回报所吸引，不断增加持有量，也有可能受到风险冲击。因此监管当局必须迅速采取行动，管理加密货币资产产生的风险，同时不扼杀创新。
我们的报告提出了五个建议。首先，提供关键服务的加密资产提供商应得到许可、注册和授权，要明确阐述许可和授权标准，指定负责机构，建立起机构间协调机制。第二，多职能的实体应受到额外限制。要区分客户资产与其他功能，减少风险。第三，严格要求稳定币的发行者。随着越来越多的稳定币在其他领域发行，需要对稳定币进行强有力的银行式监管，央行应发挥主导作用。第四，明确对受监管的金融机构在从事加密货币方面的要求。第五，建立起一个全面协调、强大有效的全球应对机制，对加密货币进行有效监管，适应不断变化的环境和风险。另外，在有效监管下，针对性的限制措施也会带来良好的公共政策成效。
作者丨李波，IMF副总裁
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.
编译：张晓晗
监制：董熙君
来源｜ IMF
版面编辑｜王懿萱
责任编辑｜李锦璇、蒋旭
总监制｜朱霜霜
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