Submitted:
03/06/2026

The post GDF & ISDA Response to FCA & Bank of England Call for Input on the Future of Tokenisation appeared first on GDF.

The submission highlights the potential benefits of tokenisation for collateral mobility, liquidity management, operational efficiency, and near-instantaneous settlement, while emphasising that these benefits must be underpinned by robust governance, operational resilience, legal enforceability, and internationally consistent standards. ISDA and GDF also encourage the adoption of common technical standards, including the Common Domain Model, to support interoperability across markets.

Additionally, the response outlines the significant opportunities presented by tokenised money market funds and other tokenised assets as collateral, arguing that tokenisation can reduce operational frictions and improve collateral efficiency without increasing systemic risk. Overall, the associations encourage continued international regulatory coordination to support the safe and scalable adoption of tokenisation across wholesale financial markets.

Submitted:
03/06/2026

The post GDF & ISDA Response to Central Bank of Ireland Discussion Paper 12: DLT & Tokenisation in Financial Services appeared first on GDF.

GDF’s response focuses primarily on the proposed perimeter for arranging deals in cryptoassets and cryptoasset staking. The submission argues that the draft guidance risks extending the regulatory perimeter beyond the policy intent of legislation by applying traditional financial services concepts to fundamentally different cryptoasset business models. GDF recommends that the FCA provide bespoke guidance that better reflects the operational realities of digital asset markets and clearly distinguishes software providers and non-custodial interfaces from regulated intermediaries.

The response also recommends greater clarity around safeguarding, tokenised securities, stablecoins, custody models, and the treatment of transaction-based fees, while encouraging the FCA to preserve technology neutrality and align the UK framework with international approaches. Overall, GDF supports the Government’s objective of establishing a clear and proportionate cryptoasset regime while ensuring the final guidance promotes innovation, legal certainty, and the UK’s competitiveness as a global digital asset hub.

Submitted:
03/06/2026

The post GDF Response to FCA Consultation Paper 26/13 on Cryptoasset Perimeter Guidance appeared first on GDF.

GDF supports the requirement for firms to identify critical business services, set impact tolerances, and embed operational resilience governance at board level in line with international standards. The submission also welcomes the flexibility provided around scenario testing, mapping of critical resources, and resilience planning.

From the perspective of digital asset firms, GDF encourages the DFSA to recognise the unique operational dependencies associated with blockchain infrastructure, smart contracts, custody arrangements, and shared technology providers. The response also recommends additional clarity regarding proportionality for smaller firms, recognition of group governance arrangements, and practical guidance on reassessment triggers and reporting expectations.

Overall, GDF supports the DFSA’s objective of strengthening operational resilience while maintaining a flexible, technology-neutral, and internationally aligned regulatory framework for the DIFC.

Submitted:
20/05/2026

The post GDF Response to DFSA CP170 on Operational Resilience appeared first on GDF.

The response highlights the importance of ensuring that AML/CFT obligations remain workable across a broad range of digital asset business models, including cryptoasset service providers (CASPs), stablecoin issuers, and infrastructure firms.

The submission recommends targeted clarifications regarding the use of privacy-preserving verification technologies, treatment of self-hosted wallets, application of blockchain analytics, and the interpretation of customer risk factors and ownership structures. GDF also encourages AMLA to ensure that technical data collection requirements remain proportionate and aligned with GDPR principles.

Additionally, the response supports the recognition of on-chain transparency and blockchain analytics as effective risk mitigation tools capable of supporting simplified due diligence measures in lower-risk digital asset contexts. Overall, GDF welcomes AMLA’s balanced and risk-based approach and encourages continued engagement with industry to ensure an effective and innovation-friendly AML/CFT framework.

Submitted:
17/04/2026

The post AMLA Consultation Paper on draft RTS on Customer Due Diligence appeared first on GDF.

GDF broadly supports AMLA’s principles-based and proportionate approach aimed at reducing fragmentation across Member States and sectors. The response welcomes the inclusion of online registration as a criterion relevant to establishing a business relationship and supports AMLA’s decision not to introduce additional lower thresholds for occasional transactions at this stage.

The submission provides targeted recommendations to improve clarity and operational consistency for cryptoasset service providers (CASPs), including clarification of the interaction between onboarding processes and ongoing business relationships, proportional application of linked transaction criteria, and recognition of blockchain analytics as a valid evidential tool. GDF also encourages AMLA to ensure that technical indicators such as IP addresses and geolocation data are not treated as standalone indicators of linked transactions and that implementation remains consistent with data protection obligations.

Overall, GDF supports the adoption of a workable and proportionate framework that promotes supervisory consistency while recognising the operational characteristics of digital asset business models.

Submitted:
17/04/2026

The post GDF Response to AMLA CP on draft RTS on criteria for identifying business relationships, occasional and linked transactions and lower thresholds appeared first on GDF.

GDF and CCI argue that qualifying stablecoins should be treated as money-like for tax purposes, rather than as speculative cryptoassets. The response highlights that the current Capital Gains Tax (CGT) treatment creates disproportionate administrative burdens for individuals using stablecoins for routine payments and remittances, discouraging adoption and undermining the UK’s broader digital asset and payments innovation objectives.

The submission recommends a full CGT exemption for qualifying stablecoins and advocates for a more coherent Corporation Tax framework that treats qualifying stablecoins consistently with fiat currency and money debts. It also calls for greater clarity regarding the tax treatment of stablecoin lending and stresses the importance of ensuring that tax reforms align with the UK’s wider regulatory framework for digital assets and payments innovation.

Overall, GDF and CCI encourage HMRC to adopt a proportionate, future-proof, and internationally coherent tax framework that supports stablecoin adoption and reinforces the UK’s ambition to become a global digital finance hub.

Submitted:
(TBC)

The post GDF & CCI Response to UK HMRC Call for Evidence on Stablecoin Taxation appeared first on GDF.

Submitted:
01/05/2026

The post GDF Response to OCC Request for Comments on Proposal to Implement GENIUS Act appeared first on GDF.

GDF welcomes the inclusion of online registration as a criterion for identifying business relationships, noting that this is well suited to crypto-asset service provider (CASP) business models where onboarding and customer due diligence are typically completed through digital registration processes. GDF also supports AMLA’s decision not to introduce additional lower thresholds for occasional transactions at this stage and welcomes the proportionate treatment of sector-specific requirements for CASPs.

The response recommends targeted clarifications to improve operational certainty and proportionality, particularly regarding when a business relationship should be considered established for CASPs, the application of linked transaction criteria, and the recognition of blockchain analytics as valid evidence for identifying common transaction characteristics. GDF also highlights the need to ensure that technical indicators such as IP addresses, device identifiers, geolocation, and common intermediaries are not treated as standalone indicators of linked transactions and should only be assessed alongside additional corroborating factors. The submission further addresses the proportionality of the rolling one-month linked transaction window, interaction with the Transfer of Funds Regulation, and the importance of aligning implementation with data protection requirements and broader compliance obligations across the sector.

Submitted:
17/04/2026

The post GDF Response to AMLA Consultation Paper on Draft Regulatory Technical Standards on Business Relationships, Occasional Transactions and Linked Transactions appeared first on GDF.

GDF and CCI welcome the application of established client asset protections to cryptoasset activities and support the FCA’s objective of ensuring consistent safeguarding standards across traditional and digital financial services. The response recommends targeted clarifications to strengthen the framework, particularly regarding stablecoin backing assets, the application of CASS 8 mandate rules, and the treatment of technology providers involved in custody arrangements, including multi-party computation (MPC) solutions.

The submission also provides recommendations on reconciliation requirements, cross-border custody arrangements, operational resilience, and the interaction between different CASS chapters. Overall, GDF and CCI encourage a technology-neutral, proportionate regulatory approach that supports innovation while maintaining robust client asset protections and advancing the UK’s ambition to become a global digital finance hub.

Submitted:
13/04/2026

The post GDF & CCI Response to FCA CP26/8: Quarterly Consultation Paper No. 51 appeared first on GDF.