Source: Financial Reading Club Editor's Note: Digital currencies first appeared in the form of private digital currencies, which changed the form, circulation and payment methods of traditional currencies. At present, countries have mixed attitudes towards the regulation of private digital currencies. The threat posed by private digital currencies to the legal currency market has prompted central banks to actively participate in the research of legal digital currencies. It can be found that the model design of digital currencies of central banks in various countries has generally reached a consensus on the issuance model, delivery mechanism and regulatory design. This article explores the development trend of legal digital currencies in various countries, which will help clarify the future development pattern of legal digital currencies and provide ideas for reference for the future development direction of legal digital currencies. Please read. Authors: Professor Ba Shusong, Zhang Daichao (School of Finance, Shanghai University of Finance and Economics), Zhu Yuanqian (Peking University HSBC Finance Institute) As one of the important innovative products of financial technology, digital currency has brought far-reaching impacts on the entire financial industry and its regulatory field. Digital currency first appeared in the form of private digital currency, which changed the form, circulation and payment methods of traditional currency, and generated different intrinsic values according to its design. While private digital currency is developing, on the one hand, central banks of various countries (hereinafter referred to as central banks) have also tried sovereign digital currency, which has achieved the requirements of convenience and security while reducing the cost of issuing currency, improved the efficiency of payment and clearing and settlement, and enhanced the control of supply and circulation; on the other hand, regulatory authorities of various countries have improved regulatory rules, refined regulatory requirements, and introduced new regulatory concepts in line with the times to meet the challenges of digital currency to regulation. 1. Private digital currency and its supervisionPrivate digital currency refers to privately issued digital currency, mainly including Bitcoin, Ethereum, Litecoin, Ripple and other digital currencies. Private digital currency originated from Bitcoin invented by Satoshi Nakamoto in 2008, and has the characteristics of decentralization and anonymity. Since then, the scale of the global private digital currency market has shown exponential growth. According to the data of cryptocurrencies website, as of May 27, 2020, there are 5,516 types of private digital currencies in the world, and the total market value of private digital currencies has reached 250.58 billion US dollars, of which Bitcoin has a market value of 117.46 billion US dollars, with a significant head effect. 1. Main categories of global private digital currencies Depending on the method of assigning value, private digital currencies can be divided into two categories: one is the native token based on the blockchain, which refers to the digital currency that relies on the blockchain system and is generated and used within the system, also known as encrypted digital currency; the other is the digital currency issued and operated on the blockchain but supported by off-chain assets, also known as stablecoin. 1. Cryptocurrency. Cryptocurrency is decentralized and anonymous. It is not backed by national sovereign credit, has zero intrinsic value, and has large fluctuations. Their value comes only from the public's belief that they can be exchanged for other goods, services, or a certain amount of sovereign currency across time, that is, value consensus. Value consensus mainly comes from two aspects: first, the speed and cost of cryptocurrency mining. The supply of digital currency is through block formation rewards, which consumes energy and time. A reasonable block reward mechanism can ensure a stable supply of cryptocurrency. Second, the dark web and cryptocurrency are naturally compatible in terms of encryption and concealment. Cryptocurrency is often used as a means of payment in dark web transactions, and there is a demand for cryptocurrency. Once people lose their value consensus, the trade system built by cryptocurrency will collapse instantly, which is similar to a bank run. 2. Stablecoins. Stablecoins use assets denominated in a series of legal currencies as reserve assets, and their value is more stable than that of cryptocurrencies. On the one hand, stablecoins can take advantage of the instant transactions, programmability, openness and anonymity of distributed ledgers; on the other hand, stablecoins are linked to off-chain values, providing a practical carrier for "hybrid anchoring" to alleviate the "Triffin dilemma" of sovereign currencies as international currencies (Zhou Yonglin, 2018). However, since the issuers of stablecoins are non-official institutions and are not restricted by national borders, there is no credibility to ensure the security of reserve assets, the transparency of reserve asset management, and the rights and responsibilities of issuers and holders in the absence of a global unified regulatory framework. All of these will lead to unstable value of stablecoins. For example: In April 2019, the New York Attorney General's Office sued Tether for misappropriating stablecoin USDT reserves to make up for a loss of US$850 million, causing a sharp drop in the value of USDT. 2. Main characteristics of global private digital currencies First, decentralization brings cost reduction and efficiency improvement. Private encrypted digital currency adopts a decentralized point-to-point transaction model, which does not rely on financial intermediaries, can reduce transaction costs and improve efficiency. Traditional currency electronic transactions rely on intermediaries such as banks, and realize exchange receipts and payments through the payment system provided by the central bank. The domestic large-value payment system cannot guarantee the real-time arrival of funds. In international financial transactions, the Society for Global Financial Telecommunication provides the Swift system, which ensures the security of international capital flows through a highly redundant and cumbersome mechanism composed of hardware, software and personnel, and has low payment efficiency. Private digital currency runs accounting in the form of blockchain, and uses public and private keys to verify transaction signatures, eliminating the need for intermediaries, reducing transaction costs, and making transactions more efficient (Denis, 2019). The second is the reliability brought by the consensus algorithm. Private digital currencies eliminate the need for trusted intermediaries through various consensus algorithms and mechanisms (such as proof of work or proof of equity), rely on predetermined algorithmic rules and complete and reliable databases to complete credit endorsement, and ensure that there are no problems such as "double spending". This self-proving credit paradigm greatly reduces the cost of trust. However, in reality, due to the lack of usage scenarios, there may still be problems with asset security and fairness. Because it maintains nodes through consensus mechanisms such as proof of work (POW) or proof of equity (POS), the POW mechanism requires a lot of computing power for node confirmation, and the currency throughput is limited, which cannot meet the high concurrency requirements of retail currencies. The POS mechanism requires a certain amount of digital assets to participate in bookkeeping, which has fairness issues. The third is the security brought by the encryption algorithm. Blockchain achieves anonymity behind transparent data through asymmetric encryption technology, which can protect personal privacy. The asymmetric encryption mechanism adopted by blockchain uses a "key pair", in which the public key and the private key appear in pairs. The sender uses the public key for encryption, and the receiver uses the paired private key for decryption and signing. Both parties do not need to disclose their identities to gain each other's trust. The public key cannot be used to deduce the private key, which represents both the identity of the transaction party and the ownership of the assets in its account, thus forming a password protection and confirmation mechanism. However, due to the decentralized issuance of encrypted digital currencies in reality, the Bitcoin system identifies personal identities through private keys, which are only known to the account owner, and the owner needs to enter the code to transfer ownership to the other party. The loss or cracking of the private key means the loss of encrypted digital currencies, and the security of assets will no longer exist. 3. Supervision of global private digital currencies At present, due to the decentralized and anonymous characteristics of private encrypted digital currencies, they may pose a threat to financial stability, causing regulators in many countries to be cautious about private digital currencies. In July 2019, the G7 group agreed that stablecoins must be prudently regulated in accordance with the highest regulatory standards, and any possible regulatory loopholes should be filled. The reason is that, on the one hand, the further development of private digital currencies may affect the monetary sovereignty of non-major international currency countries and further affect the stability of local financial systems. On the other hand, the decentralized and anonymous characteristics of private digital currencies have created fertile ground for money laundering, terrorist financing and other illegal financial activities (Long Baitao, 2019). Some countries consider private cryptocurrencies to be legal. For example, private cryptocurrencies are legal in the United States. The U.S. Financial Crimes Enforcement Network (FinCEN) classifies cryptocurrency exchanges as "money transmitters" and defines private crypto assets as currencies, which are subject to currency-related laws; the U.S. Internal Revenue Service classifies cryptocurrencies as valuable property and taxable goods; the U.S. Securities and Exchange Commission (SEC) believes that digital assets are securities and should be regulated by it; the Commodity Futures Trading Commission (CFTC) also classifies it and its derivatives as commodities and regulates them. Cryptocurrencies are also considered legal in the European Union, but the specific regulatory rules vary among member states. At present, the European Parliament has not passed specific laws on cryptocurrencies at the EU level. Only the Anti-Money Laundering (AML) Directive requires cryptocurrency exchanges to comply with the EU's anti-money laundering regulations. Some countries strictly prohibit encrypted digital currencies. For example, Namibia cited the research of encrypted digital currencies by multiple international organizations, explaining that encrypted digital currencies are not legal tender and may threaten the central bank's decision-making position in monetary policy, so it explicitly prohibits encrypted digital currencies as a means of payment, and Bitcoin transactions are considered illegal. The People's Bank of China also banned financial institutions from participating in Bitcoin transactions as early as 2013. In 2017, the People's Bank of China and seven other departments jointly issued the "Announcement on Preventing the Risks of Token Issuance and Financing", which clearly stated that the initial coin offering (ICO) initiated by non-monetary authorities is actually unauthorized financing and is illegal. In terms of private cryptocurrency transactions, the announcement explicitly prohibits so-called token financing trading platforms from converting legal tender into cryptocurrency, prohibits platforms from setting prices for cryptocurrency or providing other related agency services, and platforms that do not meet the requirements will be rectified or banned. 2. Central Bank Digital CurrencyFaced with the threat of private digital currencies to legal tender, in order to actively respond and take the initiative in the future international monetary field, central banks of various countries have actively participated in the research of legal tender digital currencies. At present, there is no unified definition of central bank digital currency (CBDC) in the world. Most of them refer to a new form of currency issued by the central bank, which is different from physical cash and central bank reserve funds or funds in clearing accounts. Central bank digital currency can replace cash and be active in various scenarios of financial transactions. According to the different receptors and technologies, the Bank for International Settlements distinguished three forms of central bank digital currency in relevant reports, two of which are based on the token system and one is based on the account system. Among the two central bank digital currencies based on the token system, one is a payment tool for the public, mainly for retail transactions of the public, that is, the retail model; the other is the payment, clearing and settlement and delivery business for financial institutions, that is, the wholesale model. 1. Current status of development of global central bank digital currencies In 2019, the Bank for International Settlements and the Committee on Payments and Market Infrastructures conducted a survey on the current status of central bank digital currency research in various countries. A total of 66 central banks responded to the survey, covering 75% of the world's population and 90% of economic output. The survey data shows that 80% of countries are actively studying sovereign digital currency issues, of which about 50% are studying both retail and wholesale models, 35% are only studying retail models, and 15% are only studying wholesale models. Most of the current research involved is conceptual, mainly focusing on the release of sovereign digital currencies and the potential impact of reshaping the payment system on the country (Codruta et al., 2020). Combined with the above surveys and studies, we have sorted out the current status of central bank digital currency research in various countries. See Table 1 for details. Table 1: Current status of central bank digital currency research in various countries 2. Main features of global central bank digital currencies At present, the digital currencies of central banks of various countries are still in the research and development stage and have not yet been fully issued. However, judging from the existing public information, various countries have generally reached a consensus on the model design of central bank digital currencies (see Table 2), which mainly has the following characteristics: In terms of the issuance model, it is issued in a centralized form, and the reserve fund is paid in full. The value of digital currency comes from the public's belief that they have the ability to exchange for other goods, services or a certain amount of other sovereign currencies across time. Although private digital currency has the characteristics of decentralization, it can avoid the possibility of excessive issuance of currency by the issuer, but it also leads to the lack of value basis for private digital currency and the inability to maintain currency stability. Unlike private digital currency, the central bank's digital currency has the characteristics of centralized issuance, and the digital currency is endorsed by the national credit to avoid drastic fluctuations in currency value. At the same time, the central bank's digital currency is issued in the form of 100% reserve funds to avoid hyperinflation caused by excessive issuance of digital currency, which is conducive to maintaining the value of digital currency and the stability of the financial system. Table 2: Main characteristics of central bank digital currencies 3. Main advantages of central bank digital currency In terms of cost control, the central bank's digital currency can provide a faster means of payment and reduce costs. As the country's legal digital currency, sovereign digital currency is easier to be accepted by the public than private digital currency. Through top-level design, it can avoid the anti-counterfeiting and loss costs of physical currency, and reduce the third-party fees and friction costs of intermediaries in value exchange. Internally, it can resist the erosion of sovereign currency by private digital currency, improve the efficiency of payment and clearing infrastructure, and boost public confidence in the country's financial system. Externally, it can provide customers with more convenient and lower-cost cross-border payment methods, and enhance the internationalization of the country's currency. Three digital currency case studiesSince the advent of Bitcoin, the development of digital currencies has been changing with each passing day. Digital currencies such as Ripple that focus on cross-border payments have emerged, as well as private digital currencies such as Libra that may have disruptive significance. At the same time, it has also attracted widespread attention from central banks and regulators in various countries, promoting the development of central bank digital currencies in various countries. 1. Case Study of Private Digital Currency One is Bitcoin. Bitcoin is an anonymous digital currency generated based on an open source algorithm, relying on P2P network transactions, combining peer-to-peer technology and cryptography technology. It is characterized by decentralization, not relying on specific institutions to issue, and having an unlimited number of distributed nodes. In recent years, the controversy over whether Bitcoin is a huge speculative bubble or a monetary revolution has been escalating. Bitcoin verifies and stores data through a chain data structure, applies a distributed node consensus algorithm to generate and update data, uses smart contracts written in automated script code to program and operate data, and uses cryptography technology to maintain the security of data transmission and information access. Based on the blockchain, a new distributed infrastructure and computing paradigm, Bitcoin has creatively solved the "double-spending" problem and the "Byzantine problem" by constructing a positive cycle economic system with "competition-bookkeeping-reward" as the core. 2. Case Study of Central Bank Digital Currency Benefiting from the rapid development of domestic mobile payments and electronic payments, China's research progress in legal digital currency ranks first in the world; as a recognized world financial technology center, the United Kingdom also has great potential in the research and development of legal digital currency. 4. The development and prospects of digital currency In monetary policy, central bank digital currency will gradually replace private digital currency and become the main force in the digital currency market. The decentralized architecture of private digital currency will weaken the effectiveness of the central bank's monetary policy and may further affect the stability of the financial system. Central bank digital currency can achieve precise loan placement by limiting the use scenarios and channels of credit through built-in smart contracts (Xie Xing and Feng Sixian, 2019). Therefore, it is expected that central banks of various countries will actively promote central bank digital currency for a long time in the future, so as to take the initiative in the competition for the right to speak in the future digital currency world. References[1] Zhou Yonglin. The nature and future of cryptocurrency[J]. China Finance, 2018, (17). [2]DenisBeau.2019.TheRoleofCryptoassetsinthePaymentSystem[EB/OL].https://www.bis.org/review/r191015b.pdf. [3] Long Baitao. Central Bank Digital Currency: Global Consensus and Division [EB/OL]. https://baijiahao.baidu.com/s?id=1653696180111267976&wfr=spider&for=pc, December 2019. [4] Codruta Boar, Henry Holden, Amber Wadsworth. 2020. Impending arrival-asequel to the survey on central bank digital currency [EB/OL]. https://www.bis.org/publ/bppdf/bispap107.pdf. [5]Benoît Coeuré.2019.DigitalChallengestotheInternationalMonetaryandFinancialSystem[EB/OL].https://www.bis.org/review/r190918b.pdf. [6] Zero One Think Tank. RMB 3.0: China’s central bank digital currency: operating framework and technical analysis [EB/OL]. https://www.vzkoo.com/doc/9377.html?a=3, 2019-10. [7]EuropeanCentralBank.2019.ExploringAnonymityinCentralBankDigitalCurrencies[EB/OL].https://www.ecb.europa.eu/paym/intro/publications/pdf/ecb.mipinfocus191217.en.pdf. [8] BankofEngland.2020. Central Bank Digital Currency: opportunities, challenges and design [EB/OL]. https://www.bankofengland.co.uk/paper/2020/central-bank-digital-currency-opportunities-challenges-and-design-discussion-paper. [9] Xie Xing, Feng Sixian. Theoretical study on the impact of legal digital currency on my country's monetary policy [J]. Economist, 2019, (9). [10] Feng Sixian, Yang Jing. International practice and enlightenment of legal digital currency operation[J]. Reform, 2020, (5). [11] Yao Qian, Tang Yingwei. Some thoughts on the central bank’s legal digital currency [J]. Financial Research, 2017, (7). |
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