Coalition senators' dissenting report

Background

1.1The Digital Assets (Market Regulation) Bill 2023 (‘the Bill’) seeks to enact a licensing regime for digital assets, with custody, disclosure, and minimum capital requirements that will give consumers protection and the market certainty.

1.2Digital assets have the potential to disrupt traditional financial services and provide better options for Australian consumers with cheaper prices, provided the market is fitted with the proper safeguards.

1.3Digital assets are no longer a niche product. According to a Swyftx analysis published in August 2023, 23 percent of Australians currently own cryptocurrency.[1]We know that young Australians are a group with a particular interest in this market. 54 percent of millennials own or have owned crypto assets in the past.[2]

1.4However, it would be a mistake to look at digital assets through the prism of personal investment. The real value is in the broader application of cryptography and blockchain to disrupt existing industries.

1.5Modelling by Ernst & Young projects that the economic impact of crypto-related activity in Australia will grow from $2.1 billion in 2021 to $68.4 billion by 2030.[3]This would represent over 200,000 jobs in the Australian economy by 2030.[4]

Objective of regulation is clear

1.6The whole point of the exercise of regulating digital assets is twofold: to protect consumers and to promote investment which spurs new ideas and lower prices.

1.7Regulation of digital assets was put on the legislative agenda in 2021. In October 2021, the Senate Select Committee on Australia as a Technology and Financial Centre tabled its final report, which recommended that the Government ‘establish a market licensing regime for Digital Currency Exchanges, including capital adequacy, auditing and responsible person tests under the Treasury portfolio.’[5]Within 8 weeks, the Government of the day had adopted 11 of the Committee’s 12 recommendations.[6]

1.8In December 2021, former Treasurer Josh Frydenberg set out a bold, considered timeline for digital asset reform. Within 12 months, the former Government would have conducted a comprehensive token mapping exercise, examined the potential of Decentralised Autonomous Organisations (DAOs), determined the appropriate taxation framework for digital assets, and assessed the feasibility of a retail Central Bank Digital Currency in Australia.

1.9Critically, Australia would have a settled legislative framework to replace the current one-size-fits-all payment licensing arrangements with a functionally based framework by the end of 2022.

1.10Based on these commitments, Australia was ahead of the pack when it came to digital asset regulation. In March 2022, the release of the Treasury consultation paper entitled, ‘crypto asset secondary service providers (CASSPr): Licensing and custody requirements’, sent strong signals that Australia would soon be cementing its position as a global finance and technology hub.

1.11This ambitious agenda would be junked in May 2022. The change in government signalled a change in approach to digital assets regulation. Instead of progressing and building on the work done already, the Labor Government chose to go back to page 1. The outcome of the CASSPr consultation is unknown. It was thrown in the bin by the Treasury after Labor was elected.

1.12At Senate Estimates and in the hearings into the Bill it was made clear that a future consultation would examine the identical factors already consulted upon. This is not progress.

Labor has put regulating crypto in the slow lane

1.13Minister for Financial Services Stephen Jones said on 22 August 2022 that the Government was ‘ready to start consultation with stakeholders on a framework for industry and regulators.’[7]Jones announced that the Government would commence a token mapping exercise, with a consultation paper to be released ‘soon’.

1.14Six months later, in February 2023, the Treasury released a pamphlet recommencing a public consultation. The pamphlet failed to propose a licensing framework for crypto gatekeepers or signal any draft legislation. Instead, it confirmed much of what was already understood about digital assets and the need for regulation.

1.15Now nearing the end of 2023, the Government has shown no genuine interest in regulating digital assets. There is no indication that draft legislation will be prepared within the next 12 months. What does seem clear, however, is that while our competitors are enhancing their regulatory systems, this Government wishes to commission endless reviews with no clear finish line in sight.

1.16Minister Jones’ choice to go back to the starting block holds two major consequences for the Australian market. First, it has left consumers exposed to the risks of an unregulated market. Second, it has driven investment offshore.

An Australian crypto bill is now entirely viable

1.17Waiting on the Government to act is not an option. That is why the Senate should move to debate and pass this Bill. When former governments have failed to move on proper inquiries into the financial sector, the Senate has forced their hand. The Senate should do the same on crypto regulation.

1.18The idea that the Treasury does not have time or that the concepts are beyond the capability of the draftspersons is ridiculous.

1.19The Bill proves that by listening to industry and consumers and picking up on the work of comparable jurisdictions, a legislative framework to regulate digital assets is achievable. Australia is not Robinson Cruso. A number of other jurisdictions have already progressed the substantial elements of digital asset regulation including by settling on definitions.

1.20Instead of taking Minister Jones’ approach and placing digital asset regulation into the ‘too hard’ basket, our competitors are progressing forward:

In December 2022, Hong Kong ‘passed legislation establishing a new licensing regime for virtual asset service providers’, which commenced in June 2023.[8]

In April 2023, the EU’s Parliament ‘approved the Markets in Crypto-Assets Regulation (“MiCA”) which will regulate crypto asset issuers and service providers.’[9]

In June 2023, the UK Parliament passed the Financial Services and Markets Act 2023.[10]The Act ‘enables the regulation of crypto assets to support their safe adoption in the UK.’[11]

In July 2023, U.S. Senators Cynthia Lummis and Kirsten Gillibrand reintroduced the Lummis-Gillibrand Responsible Financial Innovation Act which aims to ‘create a comprehensive regulatory framework for crypto assets.’[12]This is but one piece of legislation among many that are currently before the U.S. Congress.[13]

1.21The idea of Minister Jones directing the Australian Treasury to develop an unique solution to the various definitional issues is completely misguided.

1.22It risks a slow and isolationist approach when Australia could simply leverage the work of our allies and partners.

Enacting a law will end policy through grudge enforcement

1.23Through a grudging and sometimes ugly approach, Australian regulators are being left to pick up the slack. ASIC has provided guidance and taken various regulatory actions against crypto businesses.

1.24Many of these businesses expected the reform schedule of the prior Government would be maintained and took decisions based on these assumptions.

1.25While we have strong reservations about ASIC’s law enforcement efforts, ASIC cannot be blamed for the gaping hole of digital asset regulation created by Minister Jones and Treasurer Chalmers.

1.26ASIC has administered its powers to the extent that it applies to digital assets type products. ASIC cannot make the law, however. Where a particular product falls outside the existing regulatory powers, ASIC has no option to protect consumers.

1.27Until there are laws, ASIC will continue using its tools in the void. This is going to damage existing and new investments designed to bring competition to Australia. The failure to legislate is driving investment offshore.

1.28The purpose of this Bill is to get Australia back in the race to regulate. If Minister Jones is unwilling to get on with the job of drafting legislation, the Parliament should act.

The Government’s slow approach

1.29Stakeholders told the Committee that Australia is getting left behind in the race to regulate digital assets:

I think this is important from a global perspective so that Australia does not get left behind. It goes back to the history of innovation we have always had in this country. We need to create an environment within which our domestic, national and local providers are able to grow, to flourish and to have some certainty that the businesses that they are beginning—they are employing people, creating jobs, paying taxes—continue to grow, and that they have a clear roadmap and a clear rulebook through which they are going to operate.[14]

1.30Evidence provided to the Committee indicated that the former Government was attracting investment onshore and sending the right market signals. Since this momentum has been lost in the change of government, Australia is risking losing this investment:

That's part of the reason we came onshore— because we perceive it as a market that's headed on a trajectory of regulatory clarity and certainty. The sooner Australia acts, the sooner we can build and invest towards a framework that we understand will be stable and resilient for us to grow into.[15]

How has it slowed us down? It does weigh into our decision-making around the certainty of the regime we are operating in. … [I]s there a risk of Australia being left behind in terms of additional investment[?] … I think those risks do exist.[16]

1.31When asked how this Government’s slow approach would affect their future business decisions, BTC Markets told the Committee that it may have to look outside Australia to obtain a licence:

Perhaps we will look at the UK, Europe or Singapore, as examples, to get a licence. Obviously, we're aware of the regulatory arbitrage, but there's also the credibility issue: proving our credibility by getting that kind of licensing requirement. If it drags on much longer for Australia, I think that would be an important point for us.[17]

1.32Witnesses from Clyde & Co and Blockchain & Digital Assets agreed that this was consistent with what they were hearing in the market.[18]

1.33When asked what affect this would have on our domestic investment and employment prospects, Mr Michael Bacina of Piper Alderman said:

We'll become an importer of the technology instead of an exporter of it. At the end of the day, I'd love to see the innovation and jobs stay in Australia, but we need that regulatory certainty for that investment to take place and for people to build businesses here and keep them here. … Those people might otherwise be building overseas and bringing to another country those jobs and that revenue—including, fundamentally, tax revenue that would help the government as well—that could be brought to Australia instead.[19]

1.34It is not only the slow pace this Government is moving at, but its failure to provide any indication around what legislation might look like which is deterring investment. Kraken Exchange told the Committee:

Mr Miller: … I would suggest that we are yet to see enough from the government as to the shape of the potential legislation. That obviously carries some risk for players in the market because it is uncertain. It still remains uncertain.

Senator BRAGG: Is that impacting on any decisions you are making about investment or employment?

Mr Miller: Yes, I would say it is fair to say that uncertainty makes it hard to make decisions. There are lots of layers to that. In particular, I think it's well known that there are businesses in Australia that are deciding that other regimes are more certain for them. It is well known that banking relationships for crypto businesses are hard to manage because there is uncertainty in the market. It is well known that consumers have a tough time assessing the options. In particular, larger, more regulated firms struggle to make a decision about risk when they have nothing to measure that risk against. So there is certainly a downside to uncertainty. In terms of our specific context, we are very committed to Australia and its market. We have been for many years. But it is tricky to make decisions when you don't have a clear view.[20]

1.35Adviser to the Commonwealth Secretariat on Digital Assets, Loretta Joseph, told the Australian Financial Review that Australia was falling behind Nigeria on crypto regulation. Ms Joseph said that the ‘political will to regulate crypto has fallen away.’[21]

1.36It is no secret that the Government does not take digital asset regulation seriously. It is just another part of the Labor Party’s productivity malaise.

1.37In response to a question on notice, the Treasury could not tell the Committee how many briefings had been provided to the Treasurer or Assistant Treasurer on crypto policy.[22]

1.38While the Government is failing to engage in good faith on these matters, it is no surprise that our competitors are speeding ahead.

1.39Coinbase explained to the Committee that Australia is now far behind the EU, UK, Singapore, Hong Kong and Japan:

There is a migration of development of talent and investment that's occurring around the world. There is also, commensurately, a tendency for customers to go offshore as domestically regulated exchanges are not available or if they're not offering compelling services. National authorities in places like Australia certainly need to move quickly but thoughtfully, recognising that important advances in proximate regional markets—in this case, Hong Kong and Singapore—are available to customers who may be looking for options. That is why timely action is critical.[23]

1.40Ms Joni Pirovich also informed the Committee how the industry has responded to the Labor Party’s anti digital assets agenda:

I perhaps will be a little bit more brutal. Apart from traditional finance and these opportunities around CBDC and stablecoins, there has been a mass exodus of talent and capital from Australia since around mid-2022, and that's not coming back anytime soon unless we have a bespoke regulatory framework or clarity in how the existing regime applies…

But if we want to capture startups, innovation, talent, entrepreneurship and jobs then we are behind, and we're not even in a place of having a lot of talent still left here, because it's been attracted overseas with entrepreneurship grants, bespoke regimes and well funded agencies, such as VARA in Dubai. You can speak to MiCA. The list goes on and on, and I see this in the work I do globally. I'm sorry to say it, because I love Australia and I wish we had more innovation staying here.[24]

1.41Revolut Payments Australia urged the Government to move quickly, noting that there are already clear options on the table to inform regulation:

We think it's something that should be expedited for lots of different reasons, such as ensuring that the industry is operating at an appropriate standard, that at the end of the day consumers are properly protected and that there is stability around the system. I think all of those features are really important. We'd like to see that accelerate. It feels like we've been talking about this for a few years now. There are some really clear options in front of the government, either extending the existing licensing regime or a regime that's outlined in the bill in terms of determination by the minister. I think, as Mr Percy outlined, every other international jurisdiction, or a number of the more mature ones, are moving at pace on this. Those original submissions we made about the risk of Australia being left behind are real, in our view.[25]

1.42Ultimately, the wealth of evidence provided to the Committee indicated that regulating digital assets is an urgent task.

1.43Comparing the Labor timeline to the timeline set by the former Liberal Government tells an unfortunate story about the progress that could have been made if a bold, ambitious approach had been sustained.

1.44As Associate Professor Chris Berg told the Committee, we have all of the information needed to act on regulation. All that remains is for the Government to prioritise it.

I don't think it's a challenging problem. I think the question is: Will parliament prioritise it? Will the government prioritise this as an industry? We are now more than a year past some of the really big downturns in the cryptocurrency industry that revealed many of these problems to be serious consumer harm problems. Now is the opportunity. We should have acted on it before, but certainly we have all the knowledge necessary to act on that low-hanging fruit. So, yes, to support your argument there, I do think it is urgent. It is not necessarily a difficult thing; it just requires a bit of oomph on behalf of the parliament.[26]

1.45The Government’s current approach won’t deliver any regulation of digital asset gatekeepers in this term of Parliament. This is not good enough, as consumers are unprotected and investment and productivity gains are being lost as a result.

TABLE COMPARING LABOR AND LIBERAL TIMELINE

The Bill

1.46The Bill is designed to do what this Government is refusing to do: provide protection for consumers and certainty for investors.

1.47At its core, the Bill is regulating the digital asset industry gatekeepers. It does so by creating a single licensing structure with various authorisations, which will impose a range of obligations on licensees.

1.48These obligations, to be developed in consultation with industry and the community, would include:

Minimum capital requirements to provide a buffer in downturn scenarios;

Segregation of customer funds, to ensure those funds are not tied up with corporate funds in the event that a digital currency exchange or custody service declares bankruptcy;

Governance standards to bring the industry up to par with other financial services and products;

Disclosure requirements to both participants and government agencies; and

Record-keeping and reporting requirements.

1.49The Bill provides critical consumer protections that would have safeguarded consumers during recent notable exchange failures, including FTX, ACX.io, My CryptoWallet and Blockchain Global Limited.

1.50The Bill empowers ASIC to monitor and enforce licensee requirements, with the requisite civil and criminal penalties available to deter misconduct.

1.51The Bill also includes clear definitions of ‘digital assets’, ‘digital asset exchanges’ and ‘stablecoins’, to provide regulatory clarity and certainty.

Support for the bill

1.52The Bill has been described by Blockchain Australia as a ‘foundational start towards a comprehensive digital asset regulatory framework.’[27]

1.53RMIT Blockchain Innovation Hub Researchers noted that the Bill is ‘the first attempt at regulatory certainty for crypto assets in Australia.’[28] It noted:

[The Bill] seeks to address important policy issues that Australia must face in its transition from an industrial economy to a digital economy. The emerging technology stack (including blockchains, smart contracts, and artificial intelligence) presents an unprecedented opportunity to build a modern digital Australian economy — providing consumer and societal benefits including employment opportunities. The role of Parliament is to craft a regulatory framework that embraces and facilitates the digital economy … To be entirely clear: if Australia fails to adapt to and enable digital business models, these platforms will still be built—they will simply be built in other jurisdictions, or remain in dark parts of the economy, leaving consumers and investors exposed.[29]

1.54FinTech Australia stated in its submission to the Committee:

It is clear a broader regulatory approach is now required, and this Bill appears designed to address some of the more specific issues this industry faces.[30]

1.55There was vast agreement by stakeholders that the Bill’s approach was correct in two important ways: In creating a principles-based framework that can be flexible to development in the sector; and in focusing on the gate-keepers of the industry.

1.56Ms Joni Pirovich, Principal at Blockchain & Digital Assets told the Committee:

[The framework] needs to be more principles based to keep up with the dynamism of the industry … that gives clarity, that gives a perimeter and that gives the agencies a better pronunciation of their mandates in the sector.[31]

1.57Mr David Chung, Director of Creo Legal, told the Committee that the approach of trying to regulate the gatekeepers was ‘the most practical one.’[32] Similarly, Mr Simon Callaghan, Chief Executive Officer at Blockchain Australia, said that ‘the bill is a sensible approach in regulating the intermediaries.’[33]

1.58There was broad agreement with the stated outcomes of the licensing regime and many of the licensee obligations. BTC Markets told the Committee:

BTC Markets agrees with the stated outcomes of a licensing regime – “a fair, orderly and transparent” digital asset market. Similarly, we agree in theory with a minimum capital amount; the regulation of exchange participant conduct and protection; market monitoring; asset segregation; and reporting and disclosure obligations.[34]

1.59BTC Markets elaborated:

We agree with the need to segregate client assets; adhere to prudent capital requirements; and currently submit ourselves to regular auditing. We fundamentally agree that the key persons with custody over Australian client assets, needs to be based within Australia. Recent and repeated examples have demonstrated that need along with real impacts in cases where there was insufficient duty of care.[35]

1.60Kraken Exchange offered a similar account:

Cryptoasset regulation is accelerating globally, and we are at a critical juncture for determining the future regulatory treatment of cryptoassets and centralised service providers in cryptoasset markets. We agree that Australian consumers and investors should benefit from safeguards when investing in cryptoassets, and that now is an appropriate time to be considering the role of regulation in delivering those safeguards.[36]

1.61Coinbase agreed that the licensing regime would provide critical consumer safeguards:

It's always important to ensure consumers are well protected from scams, misleading marketing and other elements that could lead to consumer detriment. A licensing regime for centralised exchanges is a vital step in this journey, as are robust rules for the safekeeping of client assets.[37]

1.62Moreover, stakeholders gave evidence that the Bill had an appropriate focus on international coordination:

Ripple is supportive of the proposal to recognise foreign licenses in the Digital Assets Bill … we also believe such recognition will make Australia an attractive destination for global firms, thereby supporting the growth and development of the Australian digital assets and payments ecosystem.[38]

1.63Kraken stated:

We are also supportive of the Bill’s focus on international coordination. As a global business we note the operational and business impacts of multiple jurisdictions around the world setting their own rules and local subsidiarisation requirements.[39]

Proposed amendments

1.64As noted by FinTech Australia in its submission,[40] many stakeholder recommendations to previous iterations of the Bill were implemented following an informal consultation in 2022.

1.65Two further amendments, however, have arisen out of the Committee’s inquiry.

I. The definitions

1.66Stakeholders recommended that the definition of ‘regulated digital assets’ be narrowed to exclude NFTs. Piper Alderman submitted that this amendment would exclude assets such as ‘digital art, collectibles, in-game items and tickets and ensure technology neutral regulatory treatment.’[41] Blockchain Australia noted that this was important to support ‘Australia’s ability to innovate in other industries, such as video gaming and entertainment.’[42]

1.67FinTech Australia noted a concern among its members that the definition of ‘stablecoin’ may capture tokens that may not typically be classified as stablecoins, such as asset-based tokens.[43]FinTech Australian raised examples of Gold and Silver Standard and the BetaCarbon Token.[44]

1.68It is appropriate that NFTs be excluded from the definition of ‘regulated digital assets’, and that certain asset-based tokens be excluded from the definition of ‘stablecoin’.

II. The transition period

1.69Stakeholders conveyed a concern about the length of the transition period. At present, the Bill specifies a commencement date of 6 months from the date of Royal Asset, with a 3 month transition period.

1.70To ensure businesses and regulators can effectively comply with a new regime, it is suitable that the transition period be extended from 3 months to 9 months.

Conclusion

1.71The Committee Inquiry has demonstrated that the Government’s approach to digital asset regulation is hurting Australian consumers and investment. The Digital Assets (Market Regulation) Bill is the first serious step towards implementing a comprehensive digital asset regulatory framework. The Government has junked the ambitious crypto agenda of the former Liberal Government, and Australians will pay the price.

Senator Andrew BraggSenator Dean Smith

Deputy ChairMember

Senator for New South WalesSenator for Western Australia

Footnotes

[1]Swyftx, Australian Digital Assets Survey, August 2023, https://swyftx.com/wp-content/uploads/2023/08/Australian-crypto-survey-2023.pdf.

[2]Swyftx, Australian Digital Assets Survey, August 2023, https://swyftx.com/wp-content/uploads/2023/08/Australian-crypto-survey-2023.pdf.

[3]Aleks Vickovich, ‘EY tips crypto economy to hit $68b, create 200K jobs’, Australian Financial Review, 14 December 2021, https://www.afr.com/policy/economy/ey-tips-crypto-economy-to-hit-68b-create-200k-jobs-20211214-p59hgq.

[4]Aleks Vickovich, ‘EY tips crypto economy to hit $68b, create 200K jobs’, Australian Financial Review, 14 December 2021, https://www.afr.com/policy/economy/ey-tips-crypto-economy-to-hit-68b-create-200k-jobs-20211214-p59hgq.

[5]Select Committee on Australia as a Technology and Financial Centre, Final Report, October 2021, pg. vii.

[6]The Australian Government at Treasury, Transforming Australia’s Payments System, December 2021, p. 12, https://treasury.gov.au/publication/p2021-231824.

[7]The Hon. Stephen Jones MP, ‘Work underway on crypto asset reforms’, Media Release, 22 August 2022.

[8]RMIT Blockchain Innovation Hub, Submission 4, p. 3.

[9]RMIT Blockchain Innovation Hub, Submission 4, p. 3.

[10]UK Parliament, Financial Services and Markets Act 2023, News, 28 June 2023, https://bills.parliament.uk/bills/3326/news.

[11]HM Treasury, Rocket boost for UK economy as Financial Services and Markets Bill receives Royal Assent, Media Release, 29 June 2023, https://www.gov.uk/government/news/rocket-boost-for-uk-economy-as-financial-services-and-markets-bill-receives-royal-assent.

[12]Kirsten Gillibrand, Lummis, Gillibrand Reintroduce Comprehensive Legislation to Create Regulatory Framework For Crypto Assets, Press Release, 12 July 2023, https://www.gillibrand.senate.gov/news/press/release/lummis-gillibrand-reintroduce-comprehensive-legislation-to-create-regulatory-framework-for-crypto-assets/.

[13]Jason Brett, ‘Congress Creates A Storm of Crypto Legislation’, Forbes, 3 August 2023, https://www.forbes.com/sites/jasonbrett/2023/08/03/congress-creates-a-storm-of-crypto-legislation/?sh=603d45953aa4.

[14]Mr Simon Callaghan, Chief Executive Officer, Blockchain Australia, Proof Committee Hansard, 25 July 2023, p. 5.

[15]Mr Simon Callaghan, Chief Executive Officer, Blockchain Australia, Proof Committee Hansard, 25 July 2023, p. 5.

[16]Mr Matthew Baxby, Chief Executive Officer, Australia and New Zealand, Revolut Payments Australia, Proof Committee Hansard, 25 July, pp. 25-26.

[17]Ms Caroline Bowler, Chief Executive Officer, BTC Markets, Proof Committee Hansard, 25 July, p. 29

[18]Mr Liam Hennessy, Partner, Clyde & Co and Ms Joni Pirovich, Principal, Blockchain & Digital Assets - Services + Law, Proof Committee Hansard, 25 July, pp. 34-35.

[19]Mr Michael Bacina, Partner, Piper Alderman, Proof Committee Hansard, 25 July, p. 35.

[20]Mr Jonathon Miller, Managing Director, Australia, Kraken Exchange Australia, Proof Committee Hansard, 25 July, p. 30.

[21]Jessica Sier, ‘Australia is falling behind Nigeria on crypto regulation’, Australian Financial Review, 15 June 2023, https://www.afr.com/technology/australia-is-falling-behind-nigeria-on-crypto-regulation-20230615-p5dgv0.

[22]IQ23-000092.

[23]Mr Faryar Shirzad, Chief Policy Officer, Coinbase, Proof Committee Hansard, 25 July, p. 2.

[24]Ms Joni Pirovich, Principal, Blockchain & Digital Assets - Services + Law, Proof Committee Hansard, 25 July, p. 33.

[25]Mr Matthew Baxby, Chief Executive Officer, Australia and New Zealand, Revolut Payments Australia, Proof Committee Hansard, 25 July, p. 25.

[26]Associate Professor Chris Berg, Private capacity, Proof Committee Hansard, 25 July, p. 20.

[27]Blockchain Australia, Submission 1, p. 4.

[28]RMIT Blockchain Innovation Hub Researchers, Submission 4, p. 3.

[29]RMIT Blockchain Innovation Hub Researchers, Submission 4, p. 3.

[30]FinTech Australia, Submission 3, p. 2.

[31]Ms Joni Pirovich, Principal, Blockchain & Digital Assets - Services + Law, Proof Committee Hansard, 25 July, p. 33.

[32]Mr David Chung, Director, Creo Legal, Proof Committee Hansard, 25 July 2023, p. 16.

[33]Mr Simon Callaghan, Chief Executive Officer, Blockchain Australia, Proof Committee Hansard, 25 July 2023, p. 7.

[34]BTC Markets, Submission 20, p. 1.

[35]BTC Markets, Submission 20, p. 2.

[36]Kraken Exchange Australia, Submission 13, pp. 1-2.

[37]Mr Faryar Shirzad, Chief Policy Officer, Coinbase, Proof Committee Hansard, 25 July, p. 2.

[38]Ripple Labs Inc., Submission 19, p. 10.

[39]Kraken Exchange Australia, Submission 13, p. 2.

[40]FinTech Australia, Submission 3, p. 3.

[41]Piper Alderman, Submission 10, p. 3.

[42]Blockchain Australia, Submission 1, p. 5.

[43]FinTech Australia, Submission 3, p. 5.

[44]FinTech Australia, Submission 3, p. 5.