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国际货币基金组织报告.pdf

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1、 January 2016 SDN/16/03 I M F S T A F F D I S C U S S I O N N O T E Virtual Currencies and Beyond: Initial Considerations Dong He, Karl Habermeier, Ross Leckow, Vikram Haksar, Yasmin Almeida, Mikari Kashima, Nadim Kyriakos-Saad, Hiroko Oura, Tahsin Saadi Sedik, Natalia Stetsenko, and Concepcion Verd

2、ugo-Yepes VIRTUAL CURRENCIES AND BEYOND 2 INTERNATIONAL MONETARY FUND INTERNATIONAL MONETARY FUND Monetary and Capital Markets, Legal, and Strategy and Policy Review Departments Virtual Currencies and Beyond: Initial Considerations Prepared by an IMF Staff Team1 Authorized for distribution by Jos Vi

3、als, Ross Leckow, and Siddharth Tiwari DISCLAIMER: Staff Discussion Notes (SDNs) showcase policy-related analysis and research being developed by IMF staff members and are published to elicit comments and to encourage debate. The views expressed in Staff Discussion Notes are those of the author(s) a

4、nd do not necessarily represent the views of the IMF, its Executive Board, or IMF management. JEL Classification Numbers: G00, G10, G18, G20, G23, G28, E42, E5 Keywords: Virtual currencies, cryptocurrencies, payment technology, distributed ledger, blockchain, financial innovation, financial efficien

5、cy, financial inclusion, AML/CFT, consumer protection, tax evasion, exchange controls, capital flows management, financial regulation, financial stability, monetary policy, international cooperation Authors E-mail Address: dheimf.org; khabermeierimf.org; rleckowimf.org; vhaksarimf.org; nkyriakossaad

6、imf.org; tsaadisedikimf.org; yalmedidaimf.org; mkashimaimf.org; houraimf.org; nstetsenkoimf.org; cverdugoimf.org; 1 The IMF staff team comprised Dong He, Karl Habermeier, Ross Leckow, Vikram Haksar, Yasmin Almeida, Mikari Kashima, Nadim Kyriakos-Saad, Hiroko Oura, Tahsin Saadi Sedik, Natalia Stetsen

7、ko, and Concepcion Verdugo-Yepes. Inputs are also gratefully acknowledged from Victoria Perry, Federico Diaz- Kalan, Silvia Iorgova, Jonathan Pampolina, Nadia Rendak, Anna Strandquist, Herve Tourpe, and Christophe Waerzeggers. Sonia Echeverri, Rosemary Fielden, and Kajal Jagatsing provided valuable

8、support. VIRTUAL CURRENCIES AND BEYOND INTERNATIONAL MONETARY FUND 3 CONTENTS EXECUTIVE SUMMARY _ 5INTRODUCTION _ 6A. Overview _ 6B. What are Virtual Currencies? _ 7ARE VIRTUAL CURRENCIES MONEY? _ 10A. Perspectives from Theory and History _ 11B. Legal Perspectives _ 16C. Economic Perspectives _ 17DI

9、STRIBUTED LEDGERS _ 18A. What Are They and How Do They Work? _ 18B. Emerging Uses of Distributed Ledgers _ 21REGULATORY AND POLICY CHALLENGES _ 24A. Regulatory Challenges and Responses _ 24B. Financial Integrity: AML/CFT _ 27C. Consumer Protection _ 28D. Taxation _ 30E. Exchange Controls and Capital

10、 Flow Management _ 31F. Financial Stability _ 31G. Monetary Policy _ 33THE WAY FORWARD _ 35SELECTED BIBLIOGRAPHY _ 38BOXES 1. Public and Private Provision of Money: History and Theory _ 122. Design of Distributed Ledgers _ 213. Smart Contracts _ 23FIGURES 1. Taxonomy of Virtual Currencies _ 82. Vola

11、tility of Bitcoin Value _ 183. Distributed Ledger System: How Does It Differ from Centralized Payment System? _ 20VIRTUAL CURRENCIES AND BEYOND 4 INTERNATIONAL MONETARY FUND TABLE 1. Characteristics of Currencies: A Comparison _ 14ANNEX 1. Policy Responses to Virtual CurrenciesSelected Countries _ 4

12、2 VIRTUAL CURRENCIES AND BEYOND INTERNATIONAL MONETARY FUND 5 EXECUTIVE SUMMARY New technologiessupported by advances in encryption and network computingare driving transformational change in the global economy, including in how goods, services and assets are exchanged. An important development in t

13、his process has been the emergence of virtual currencies (VCs). VC schemes are private sector systems that, in many cases, facilitate peer-to-peer exchange bypassing traditional central clearinghouses. VCs and their associated technologies (notably distributed ledgers based on blockchains) are rapid

14、ly evolving, and the future landscape is difficult to predict. VCs offer many potential benefits, including greater speed and efficiency in making payments and transfersparticularly across bordersand ultimately promoting financial inclusion. The distributed ledger technology underlying some VC schem

15、esan innovative decentralized means of keeping track of transactions in a large networkoffers potential benefits that go far beyond VCs themselves. At the same time, VCs pose considerable risks as potential vehicles for money laundering, terrorist financing, tax evasion and fraud. While risks to the

16、 conduct of monetary policy seem less likely to arise at this stage given the very small scale of VCs, risks to financial stability may eventually emerge as the new technologies become more widely used. The development of effective regulatory responses to VCs is still at an early stage. VCs are diff

17、icult to regulate as they cut across the responsibilities of different agencies at the national level, and operate on a global scale. Many are opaque and operate outside of the conventional financial system, making it difficult to monitor their operations. Regulators have begun to address these chal

18、lenges, with a variety of approaches across countries. Responses have included clarifying the applicability of existing legislation to VCs, issuing warnings to consumers, imposing licensing requirements on certain VC market participants, prohibiting financial institutions from dealing in VCs, comple

19、tely banning the use of VCs, and prosecuting violators. These approaches represent an initial policy response to the challenges that VCs pose, but further development is needed. In particular, national authorities will need to calibrate regulation in a manner that appropriately addresses the risks w

20、ithout stifling innovation. More could be done at the international level to facilitate the process of developing and refining policies at the national level. International bodies are playing an important role in identifying and discussing the risks posed by VCs and possible regulatory responses, an

21、d they should continue to do so. As experience is gained, international standards and best practices could be considered to provide guidance on the most appropriate regulatory responses in different fields, thereby promoting harmonization across jurisdictions. Such standards could also set out frame

22、works for cross-country cooperation and coordination in areas such as information sharing and the investigation and prosecution of cross-border offenses. VIRTUAL CURRENCIES AND BEYOND 6 INTERNATIONAL MONETARY FUND INTRODUCTION A. Overview 1. New technologies are driving transformational changes in t

23、he global economy, including in how goods, services, and assets are exchanged. The development of monies and a variety of payments systems throughout history have helped make exchange more efficient and secure. The rapid spread of Internet-based commerce and mobile technologysupported by advances in

24、 encryption and network computinghas driven the development of several innovative technologies. Companies such as Uber and Airbnb have developed radical new business models. Secure online payments systems (for example, PayPal) and mobile payments and transfer solutions (for example, M-Pesa) are chan

25、ging the ways in which payments for goods and services are made. 2. An important development in this process of transformation has been the emergence of virtual currencies (VCs). VCs, in principle, question the paradigm of state-supported fiat currencies and the dominant role that central banks and

26、conventional financial institutions have played in the operation of the financial system. VCs are issued without the involvement or backing of a state. Some VC schemes make use of “distributed ledger” technologies that provide complete and secure transaction records without using a central registry.

27、 These technologies therefore allow for direct peer-to-peer transactions and eliminate the need for central clearinghouses. It is therefore not surprising that private sector interest in these new technologies has been growing, and that attention from regulators and policymakers has not been far beh

28、ind. 3. VCs and their underlying distributed ledger technologies have the potential to generate benefits. VC schemes and distributed ledger technologies can strengthen financial efficiency by facilitating peer-to-peer exchange while reducing transaction times and costs, especially across borders. In

29、 the longer term, these technologies have the potential to deepen financial inclusion by offering secure and lower-cost payments options. Beyond payments systems, distributed ledger technologies have implications for a wide range of markets and financial market infrastructures as a fast, accurate an

30、d secure record keeping system, including for stock exchanges, central securities depositories, securities settlement systems or trade repositories. Technological and regulatory progress will be needed to realize these potential benefits. 4. However, these technologies also pose risks. VCs can be mi

31、sused as vehicles for money laundering, terrorist financing, and tax evasion, and other forms of illicit activity. While risks to the conduct of monetary policy seem less likely to arise, risks to financial stability may eventually emerge as the new technologies come into more wide-spread use. Altho

32、ugh the growing use of distributed ledger technologies outside of the context of VCs pose far fewer risks, it may over time pose a serious challenge to parts of the business model of the established financial system. VCs and distributed ledger technologies will thus continue to attract the attention

33、 of policymakers and regulators at both the national and international levels. VIRTUAL CURRENCIES AND BEYOND INTERNATIONAL MONETARY FUND 7 5. Any policy response to VCs will need to strike an appropriate balance between forcefully addressing risks and abuses while avoiding overregulation that could

34、stifle innovation. The initial focus should be on the most pressing concerns related to VCsincluding financial integrity, consumer/investor protection, and tax evasionwhile leaving less immediate risks (for example, financial stability, monetary policy) to a later stage. VCs combine many different p

35、roperties of electronic payment systems, currencies, and commodities that span the responsibilities of several types of regulators at the national level. VCs operate in a virtual world that reaches across borders, increasing potential risks and creating opportunities for regulatory arbitrage. Effect

36、ive policy coordination will therefore be required at the national and international levels. 6. This paper discusses the potential benefits and risks posed by VCs and how financial regulators could approach them. The paper begins by explaining what VCs are, and how they work. It then examines key fe

37、atures and related developments in distributed ledger technologies underlying decentralized VCs, along with their potential use for financial development and financial inclusion. The paper subsequently discusses the policy and regulatory implications of VCs generally and concludes with a brief discu

38、ssion of areas for future analysis. 7. As a starting point, it is important to note that the VC landscape is still new and rapidly changing. It is therefore not possible to fully predict the future direction and importance of these evolving technologies or to identify specific longer-term policy res

39、ponses. The paper is therefore intended as a first step and a platform for further research and analysis. Many of the questions it raises are left for future discussion. B. What are Virtual Currencies? 8. VCs are digital representations of value, issued by private developers and denominated in their

40、 own unit of account.2 VCs can be obtained, stored, accessed, and transacted electronically, and can be used for a variety of purposes, as long as the transacting parties agree to use them. The concept of VCs covers a wider array of “currencies,” ranging from simple IOUs of issuers (such as Internet

41、 or mobile coupons and airline miles), VCs backed by assets such as gold,3 and “cryptocurrencies” such as Bitcoin. 9. As digital representations of value, VCs fall within the broader category of digital currencies (Figure 1). However, they differ from other digital currencies, such as e-money, which

42、 is a digital payment mechanism for (and denominated in) fiat currency. VCs, on the other hand, are not denominated in fiat currency and have their own unit of account. 2 Given the fast evolving nature of the industry, a universal definition has yet to emerge and could quickly change as the VC ecosy

43、stem continues to transform. 3 This type of VCs is backed by the combination of existing tangible assets or national currencies and the creditworthiness of the issuer. VIRTUAL CURRENCIES AND BEYOND 8 INTERNATIONAL MONETARY FUND Figure 1. Taxonomy of Virtual Currencies 10. VC schemes comprise two key

44、 elements: (i) the digital representation of value or “currency” that can be transferred between parties; and (ii) the underlying payment and settlement mechanisms, including the distributed ledger system (see the section on distributed ledgers and Box 2). 11. VC schemes have different levels of con

45、vertibility to real-world goods, services, national currencies, or other VCs. Non-convertible VCs (or closed schemes) operate exclusively within a self-contained virtual environment. Under these systems, the exchange of VCs with fiat currency (or other VCs) or its use in payments for goods and servi

46、ces outside of the virtual domain is significantly restricted. In contrast, convertible VCs (or open schemes) allow for the exchange of the VC with fiat currency (or other VCs) and for payments for goods and services in the real economy.4 The level of contact between convertible VCs and the real eco

47、nomy is much greater than is the case in closed schemes.5 12. VC schemes can operate through a centralized, decentralized, or hybrid model. The operation of VC schemes includes three components: (i) the issuance and redeemability of the VC; (ii) mechanisms to implement and enforce internal rules on

48、the use and circulation of the currency; and (iii) the payment and settlement process. Each area of operation may be managed by a trusted central (and private) party or in a decentralized manner among participants. Hybrid schemes also 4 An additional distinction is sometimes made between unidirectio

49、nal flow and bidirectional flow of convertibility, with the former referring to VCs that can be obtained in exchange for fiat currency (or other VCs), but cannot be converted back to fiat currency (or other VCs)the flow of convertibility being unidirectional (for example, Nintendo Points, some frequ

50、ent-flyer programs air miles)and the latterwhere the flow of convertibility is bidirectional (for example, Bitcoin, Linden Dollar). See ECB (2012). 5 It should be noted that convertible VCs may be subject to illiquid markets, limiting their de facto convertibility. VIRTUAL CURRENCIES AND BEYOND INTE

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