E-Money and virtual currencies


17 Jul 2017 | Possible disruption in bitcoin payment system

The bitcoin.org website announced the possible disruption in bitcoin payment system starting from July 31. On Tuesday, August 01, from 02:00 CEST bitcoin blockchain will start running alternative core clients with ability to increase number of transactions in bitcoin payment system. Bitcoin nodes, users who run the core bitcoin software, vote on which version of softwere will implement into blockchain. The old version and the new versions of bitcoin software will compete for primacy over main bitcoin blockchain. On August 1, a portion of bitcoin’s nodes will run software that another portion of nodes are not fully compatible with. This may create problems for bitcoin users.

Users are advised to refrain from payments in bitcoin from July 31st until this is settled out. Transactions in 'losing' version of core software might render invalid and founds will be lost. Two versions of proposed bitcoin scalability which compete with current solution, differ in approach. The ‘SegWit’ solution (aka BIP141) is developed by core bitcoin developers, and tested extensively over past months. It implements 'User Activated Soft Fork' approach, allowing changes to happen when 95 per cent of network power signals that is ready to change. This proposal will not increase the 1MB block size. Another version of core software: SegWit2X (aka 'The 'New York Agreement') is a proposal of major bitcoin companies and mining pools (mostly from China). It is not developed by core bitcoin contributors, and will require 80 per cent of network power to signal that is ready for change. This solution envisaged the change of the block size to 2MB.

Looking at the statistics from nodes that already actively vote in this events, bitcoin will almost sure enact changes in its network.

The bitcoin.org originally registered and owned by Bitcoin's first two developers, Satoshi Nakamoto and Martti Malmi, is now an independent open source project with contributors from around the world.

6 Jul 2017 | Discussion Paper on the Consumer Protection Code and the Digitalisation of Financial Services

In order to address consumers protection issues and their adequacy to digital enviroment Central Bank of Ireland published Discussion Paper on the Consumer Protection Code and the Digitalisation of Financial Services. Even though consumers protection code is technology neutral and applicable to all industries, this paper should examine how effective is its application on digitized financial services. Paper is open for comments until October and after eding public consultations Bank will present the outcome of this analysis and if there is a need for specific set of rules for protection of consumers in digital environment.


16 Jun 2017 | Iran is drafting a proposal for the digital currency regulation

Iran’s National Center for Cyberspace will finalise the draft proposal after reviewing work of regulatory commissions. These commissions will be looking at the financial and security issues. The future strategy is still to be decided but according to the officials, it will be developed toward digital currency implementation. Central Bank of Iran, Security and Exchange Organization, Telecoms Ministry and the police department, worked together providing inputs for the National Center for the Cyberspace. The proposal should be finalized within the next four months.


The digital currencies story is a continuation of the long-running saga of economics, markets, and commodity exchange in human society. With the constant rise of the global network, we have witnessed many global services becoming widely accepted and in a way changing (by adding to) our experience of mutual interaction. Looking back in history of the Internet we can conclude that public-key cryptography and digital signatures make e-money possible.



E-money can either be centralised (with the control point of money supply) or decentralised, where the control over the supply can come from various sources or network of sources (Bitcoin and/or other virtual currencies). The main difference between e-money and virtual currencies is that e-money does not change the value of the fiat currency (euro, dollar, etc), but virtual currency is not equivalent to any fiat currency. In other words, all digital currency is electronic money, but e-money is not necessarily digital currency.


Electronic money or e-money in short is the money balance recorded electronically on a stored-value card or remotely on a server. The Bank for International Settlements defines e-money as ‘stored value or prepaid payment mechanisms for executing payments via point-of-sale terminals, direct transfers between two devices, or even open computer networks such as the Internet’. E-money is usually associated with so-called smart cards issued by companies such as Mondex and Visa Cash.

Electronic money is a floating claim that is not linked to any particular account. Examples of e-money are bank deposits, electronic fund transfer, payment processors, and digital currencies.

The term ‘stored-value card’ means the funds and/or data are 'physically' stored on the card, in the form of binary-coded data. With prepaid cards, the data is maintained on the card issuer's computers. Typical stored-value cards include: prepaid calling cards, gift cards, payroll card, loyalty cards, travel cards.

E-money can also be stored on (and used via) mobile phones or in a payment account on the Internet. Most common and widely used mobile subsystems are Google Wallet and Apple pay.

The fast introduction of e-money has lead to governmental regulatory activities. Hong Kong was among the first jurisdiction to regulate e-money, by allowing only licensed banks to issue stored-value cards. Since 2001, the European Union has implemented a directive on the taking up, pursuit and prudential supervision of the business of electronic money institutions (E-Money Directive - 2009/110/EC).

Electronic currencies can be divided into soft currency and hard currency. Hard electronic currency is one that only supports non-reversible transaction. Reversing transaction, even in case of a legitimate error is not possible. They are more oriented to cash transactions. Examples for hard currencies are: Western Union, KlickEx, or Bitcoin. On the other hand, soft electronic currency is one that allows reversal of payments in a case of fraud or disputes. Examples are PayPal and credit cards.

Digital currency

Simple intention drives this technological avalanche, based on financial and commercial competition (as is the case of regulated economies). In this struggle, the regulated market and the privacy of the affairs of financial actors are crucial. Fair and constructive financial institutions acting as intermediaries are the safeguards of these principles.  In most cases these are state regulatory agencies. But something has changed in the digital era. Regulation is taking a new form of teamwork and networking.

The European Central Bank defined in 2012 virtual money (virtual currencies) as a ‘type of unregulated, digital money which is issued and usually controlled by its developers, and used and accepted among the members of a specific virtual community’. This Internet based medium of exchange have properties similar to physical currencies, however allows for instantaneous transaction and borderless transfer-of-ownership. Banks and customers use their keys to encrypt (for security) and sign (for identification) blocks of digital data that represent money orders. A bank ‘signs’ money orders using its private key and customers and merchants verify the signed money orders using the bank’s widely published public key. Customers sign deposits and withdraw using their private key and the bank uses the customer's public key to verify the signed withdraws and deposits.

In 2014, the European Banking Authority defined virtual currency as ‘a digital representation of value that is neither issued by a central bank or a public authority, nor necessarily attached to a fiat currency, but is accepted by natural or legal persons as a means of payment and can be transferred, stored or traded electronically’.

Both virtual currencies and cryptocurencies are types of digital currencies.

Cryptocurrencies are set to take the online world by storm, as their popularity and use, and understanding of their advantages and limitations increases. Giant companies like Apple, Dell and PayPal have already indicated their plans to integrate cryptocurrencies as a payment method, and more are likely to follow, with Bitcoin emerging as one of the most popular virtual electronic currencies. The main invention of this cryptocurrency is to present the central ledger of all transactions, known as blockchain. This open source software allows all peers in a network to verify every transaction ever made in the Bitcoin system and therefore serve as guardians to this central ledger.

There are signs that central banks are also paying more and more attention to virtual currencies. As an example, in early 2016, the People's’ Bank of China announced that it was looking into the possibility of launching its own virtual currency, considering that this would contribute to making economic activities more transparent, while also reducing money laundering and tax evasion.

The main issues

There are many comparative advantages of this system of money creation and payments compared to the usual form of online financial transactions. Using one source (the Internet) to connect to a unique global financial system sounds like possible futuristic idea, but with virtual currencies, it is not far away.

At the same time, there are also many warnings that virtual currencies could be misused for illegal goods and services, fraud, and money laundering. The anonymity associated to the use of virtual currencies (such as bitcoin) transactions increases the potential of possible misuse. A US government-funded report on the 'National Security Implications of Virtual Currencies', published at the end of 2015, noted that ‘non-state actors’, including terrorist and insurgent groups, may exploit virtual currency by using it for regular economic transactions.

Government regulation is still the key to virtual currencies attracting more users, as well as to potentially address the risks of misuse. States around the world are currently considering its regulation. This will not only increase consumer confidence in the technology, it will also involve more companies and investors in the growing business. While some are arguing that unregulated virtual currencies are safe haven for money laundering and illegal flow of money, others present this as an ultimate tool in fighting identity thefts and leakage of personal financial information.




The IMF is exploring the implications of new technologies for financial services.


The IMF is exploring the implications of new technologies for financial services. A January 2016 paper on ‘Virtual Currencies and Beyond: Initial Considerations’ points at different challenges related to the regulation of virtual currencies and outlines the need ‘to calibrate regulation in a manner that appropriately addresses the risk without stifling innovation’. The organisation has an Interdepartmental Working Group on Finance and Technology and a High Level Advisory Group on Fintech, which study the economic and regulatory implications of developments in finance and technology. A June 2017 paper explores the possible impact of fintech on financial service and possible regulatory responses.


One area of work for the EBA is


One area of work for the EBA is payments and electronic money, and activities in this field are aimed at ensuring that payments across the EU are secure, easy, and efficient. In 2014, the Authority issued an ‘Opinion on Virtual Currencies’, outlining a series of requirements that would be necessary to regulate virtual currencies, and advising financial institutions not to buy, hold, or sell such currencies while there is no regulatory framework in place. In 2016, the EBA expressed support for the the European Commission’s proposal to bring virtual currency exchange platforms within the scope of EU’s Anti-Money Laundering Directive.


The Bank has focused on issues related to e-money and e-banking since as early as 1998, when its Basel Committ


The Bank has focused on issues related to e-money and e-banking since as early as 1998, when its Basel Committee on Banking Supervision published a document on ‘Risk management for electronic banking and electronic money activities’ (republished in 2003 as ‘Risk management principles for electronic banking(’. The Basel Committee’s Electronic Banking Group also elaborated a paper on ‘Management and supervision of cross-border electronic banking activities’, in 2003.  Over the years, the Bank has conducted numerous surveys on developments in the field of e-money and e-banking. Digital currencies have also been in the Bank’s attention, through its Committee on payments and market infrastructure.


In establishing its digital single market, the EU has progressively developed a dense 


In establishing its digital single market, the EU has progressively developed a dense copyright legislation corresponding to a set of ten directives, which harmonise essential rights of authors, performers, producers and broadcasters. To ensure EU copyright rules are fit for the digital age, the European Commission has recently presented legislative proposals to modernise the EU legal framework, in order to allow more cross-border access to content online and wider opportunities to use copyrighted materials in education, research and cultural heritage; and have a better functioning copyright marketplace.


In recent years, the FATF has been paying attention to the potential use of e-payment methods as tools for cri


In recent years, the FATF has been paying attention to the potential use of e-payment methods as tools for criminals. The 2013  Guidance for a Risk-Based Approach to Prepaid Cards, Mobile Payments and Internet-Based Payment Services outlines recommendations for countries and the private sector of how to regulate and supervise such products and services and implement anti-money laundering (AML) and counter-terrorist financing (CFT) measures. In 2014, the paper on Virtual Currencies. Key Definitions and Potential AML/CFT Risks proposes a definition and classification of virtual currencies and explores potential risks associated with such currencies.


Ecommerce Europe has an e-Payments Working Committee which deals with issues such as regulatory and legal fram


Ecommerce Europe has an e-Payments Working Committee which deals with issues such as regulatory and legal frameworks, technical standards, technical innovations, and e-identification and trust services for online payments. In April 2017, the Committee published two position papers: one on online payments, containing recommendations for an innovative and competitive cross-border payments landscape in Europe (covering issues such as customer authentication, interoperability of payment systems, and e-identification schemes); and the other one containing recommendations on online payments authentication. In June 2017, the organisation hosted the Global Ecommerce Summit, which focused on issues related to how digital currencies and blockchain could change the e-commerce sector.


Other Instruments

EBA Opinion on Virtual Currencies (2014)


Blockchain Technology and Internet Governance (2017)


Bitcoin’s Creator Satoshi Nakamoto Is Probably This Unknown Australian Genius (2015)
Taxation and Today's Digital Economy (2015)
This is Why Bitcoin Won’t Go Away Anytime Soon (2015)
Tech Giant Microsoft Accepts Bitcoin Payments (2014)
Online Cash Bitcoin Could Challenge Governments, Banks (2011)


Opportunities and Risks Associated with the Advent of Digital Currency in the Caribbean (2016)
Internet Governance Acronym Glossary (2015)
An Introduction to Internet Governance (2014)


Bitcoin: A Peer-to-Peer Electronic Cash System (2008)


One Internet (2016)
Virtual Currencies and Beyond: Initial Considerations (2016)
National Security Implications of Virtual Currency. Examining the Potential for Non-state Actor Deployment (2015)
EBA Opinion on Virtual Currencies (2014)
Risk Management for Electronic Banking and Electronic Money Activities (1998)

GIP event reports

Report for World Economic Forum Annual Meeting 2017 (2017)

Other resources

Revenue and Customs Brief 9 (2014): Bitcoin and Other Cryptocurrencies (2014)
Application of FinCEN's Regulations to Persons Administering, Exchanging, or Using Virtual Currencies (2013)


Session reports

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