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CMS Global Fintech update - August 2021

Fintech in Belgium

Cryptoassets

Virtual asset service providers soon to be subject to FSMA supervision

Description

On 18 June 2021, the Council of Ministers approved a draft law and a draft royal decree, on the status and supervision of providers of exchange services between virtual and FIAT currencies and of providers of custody wallet services.

As regards the draft law, it pursues two objectives (i) to give the Belgian regulator (the FSMA) the power to supervise all ATMs installed on Belgian territory that allow the exchange of virtual currencies against FIAT currencies and (ii) to prohibit persons governed by the law of a third State from offering services related to virtual assets on Belgian territory.

The draft Royal Decree aims to establish (i) the rules and conditions for registration with the FSMA of providers of services related to virtual assets established in Belgium, (ii) the conditions for the exercise of such activities, and (iii) the rules of supervision applicable to such providers. As it stands, the draft Royal Decree sets out the following requirements for registration: expertise, professional integrity, no professional ban, and a shareholder base that guarantees sound and prudent management of the company. During the exercise of this regulated activity, service providers will be required to comply with the Belgian AML law.

Impact

We note two main impacts of these two drafts: firstly, the prohibition on third country persons to offer services related to virtual assets in Belgium, and secondly, virtual asset service providers must comply at all times with the provisions of the Belgian AML.

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Fintech in Romania

Cryptocurrency

Romania regulates the cryptocurrency transactions

Description

On April 30, 2021, Law no. 101/2021 approving Government Emergency Ordinance no. 111/2020 entered into force; the Government Emergency Ordinance transposes into national legislation the European Directives 2015/849 and 2018/843 related to the regulation of cryptocurrency transactions (the “Law”).

The volume of cryptocurrency transactions is on the rise in Romania. This Law regulates the cryptocurrencies for the first time in Romania.

In this context, the providers of exchange services between virtual and fiduciary currencies, as well as the digital wallet providers have the obligation to be registered and authorized in order to carry out their activities.

In accordance with the Law, the term “virtual currency” is defined as a digital representation of value that is not issued or guaranteed by a central bank or public authority. It is not necessarily linked to a legally established currency and does not have the legal status of currency or money, but is accepted by individuals or legal entities as means of exchange and may be transferred, stored and traded electronically.

Moreover, the term “digital wallet provider” means an entity that provides services for the secured storage of private cryptographic keys on behalf of its customers for the holding, storage and transfer of virtual currency.

In order to carry out activities related to cryptocurrency, the legal entity must be established in accordance with Romanian legislation and meet certain conditions or to be authorized / registered by the competent authorities in a Member State of the European Union, or in the signatory states of the Agreement on the European Economic Area or in the Swiss Confederation.

Providers of networks and electronic communications services (e.g. providers of internet services, fixed or mobile telephony services, radio or TV services and cable services) are required to comply with the decisions (of the Romanian Commission for authorizing the foreign exchange activity) regarding the access restriction to the websites of:

  • providers of exchange services between virtual currencies and fiduciary currencies; and
  • unauthorized digital wallet service providers.

Impact

The authorization and/or registration of entities involved in cryptocurrency transactions are performed by the Romanian Ministry of Public Finance, through the Commission for authorizing the foreign exchange activity.

In order to prevent money laundering and terrorism financing, such entities have the obligation to identify suspicious transactions and report them to the National Office for Prevention and Control of Money Laundering if a legal risk could be raised.

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Fintech in Spain

Startup’s Ecosystem - FinTech 

A specific regulatory framework is established to support the creation, growth and evaluation of start-ups in Spain

Description

On Tuesday 6 July 2021, the Spanish Cabinet passed the Report of the Draft Bill on Startup’s Ecosystem Promotion. This project advocates the development of the Spanish startup ecosystem, the stimulation of investments and the interrelation between companies, funded agents and territories.

Impact

The Goals set are clearly ambitious, particularly standing out: (i) the promotion and creation of new startups in the Spanish territory; (ii) talent and foreign capital seeking in order to boost and innovate in our entrepreneurial ecosystem; (iii) the establishment of an specific framework for these kind of companies. Throughout these measures it is aimed to regulate and increase flexibility on all the activities that this kind of beginning companies carry out, also in the Fintech area.

Regarding the measures adopted to prevent the brain drain and in order to make Spanish startups shine, it was decided to both include tax benefits, able to promote the establishment of digital hubs in Spain and reduce the tax rate of Corporate Tax (IS) Corporate Taxes of non-residents (IRNR). Reducing the standard rate of 25% to 15% in the first period, in which the tax base is positive, and in the three following ones as far as it remains under the Startup qualification. Along with these measures, it is considered on the one side, the deferment of tax debts of both IS and IRNR in the first tax year in which the tax base is positive and the next one, with no need of guarantees and without delay interests, for a period of 12 and 6 months respectively; and, on the other hand, not only elevate the yearly exemption of €45k to startups, but also increase flexibility on the treasury stocks of LLC’s.

In order to stimulate investments, it has been established that the maximum tax base reduction will be raised from €60k to €100k yearly; increasing also the reduction from a 30 to a 40% and the “recent launch” to 7 years in general terms, being able to extend to up 7 years in certain industries. Along with that, to accelerate bureaucracy and entrepreneurial activity, the obligation to pay splits of IS and IRNR in the 2 years after the tax base turns positive has been suppressed; non-resident investors will be able to obtain their NIF without needing the NIE; and in case a company should desist from its activity they may finish the bureaucracy electronically.

Some other point to be raised is the unified regulation on the prominent Sandbox, testing regulated ecosystems of the financial sector that aim at evaluating the viability of different tech projects; along with the novelties included regarding the “digital nomads”, that is those workers who develop their activities remotely, as they ought to be applied a particular tax regime so that they are imposed the non-residents tax rate, softening their requirements.

The raise of Spanish entrepreneurship based on innovation and the great success that the Spanish startups have acquainted, constitutes the main cause to develop such regulation. Also, job creation, reactivation of rural areas thanks to work-from-home and the educational improvement of the youth in the digital environments. This has placed the digital emerging companies (startups) in the cornerstone of our economy, as it aims at placing innovation at its base.

Last, the aforementioned Act, an unprecedented milestone for the Spanish entrepreneurial ecosystem, is held under the Recuperation, Transformation and Resilience Plan and also covered on the 2025 Spanish Digital Agenda; particularly on Reform 2 of Component 13, regarding the proliferation and promotion of emerging, tech-based companies, which also includes social values as important as gender equality and non-discrimination.

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Fintech in South Africa

Cryptoassets

Position paper on crypto assets

Description

The South African Crypto Assets Regulatory Working Group (WG), consisting of representatives from various regulatory and supervisory bodies, published on 11 June 2021 its position paper on crypto assets. The WG believes that crypto assets cannot remain outside of the South African regulatory purview and recommends that South Africa employs a staged approach to bring crypto assets within the regulatory remit through the regulation of crypto asset service providers (CASPs).

According to the WG, the regulations should focus on:

  • the implementation of an AML/CFT framework by making CASPs an accountable institution under Schedule 1 to the Financial Intelligence Centre Act 38 of 2001 (FIC Act):
  • creating a framework for monitoring cross-border financial flows by including regulation under foreign exchange control regulations; and
  • the application of financial sector laws to crypto assets, initially by declaring crypto assets a financial product through the provisions of the Financial Advisory and Intermediary Services Act 37 of 2002 (the FAIS Act) and in the medium term by including financial services provided in relation to crypto assets under the Financial Sector Regulation Act 9 of 2017 (the FSR Act).

The WG described in its paper six principles that should guide the approach on regulating CASPs in South Africa:

  • Principle 1: CASPs must be regulated appropriately.
  • Principle 2: An activities-based perspective must be maintained, and the principle of ‘same activity, same risk, same regulations’ must continue to apply and inform the regulatory approach.
  • Principle 3: Proportionate regulations that are commensurate with the risks posed must apply (i.e., a risked-based approach to crypto asset regulation must apply).
  • Principle 4: A truly collaborative and joint approach to crypto asset regulation must be maintained.
  • Principle 5: Continue to proactively monitor the dynamic development of the crypto assets market, including maintaining knowledge on emerging international best practices.
  • Principle 6: Digital literacy and digital financial literacy levels must be increased amongst consumers and potential consumers of crypto assets.
Impact

Currently the trade in crypto assets is not subject to particular regulation. The implementation of the proposals set out in the Position Paper would result in the CASPs having to obtain a licence, initially under the FIAS Act, and in the medium term under the FSR Act.  They would furthermore become subject to AML/CFT regulations in connection with transactions involving crypto assets. Where cross-border transactions are involved, the CASPs involved may need to be registered under the foreign exchange regulations and the transaction themselves will become subject to reporting requirements.

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Fintech in Switzerland

Distributed Ledger Technology

Description

On 1 August 2021, the new Swiss DLT-Act fully entered into force. Drawn up as a blanket act providing for selective adjustments in a total of nine Swiss federal laws, it has, in particular, introduced the following:

  • Civil law:The parts of the Swiss DLT-Act that amend Swiss civil law entered into force on 1 February 2021 and enable the introduction of ledger-based securities, which are represented on the blockchain. The so-called register uncertificated securities are created when entered in an electronic register that meets certain requirements regarding functional safety and integrity, as well as transparency of information for the parties involved. The legal innovation is that the entries in the electronic register have the same functionality and entail the same legal protection as negotiable, paper-based securities. These civil law changes generally increase legal certainty regarding the transfer and holding of digital assets in Switzerland and, thus, foster the general adoption of DLT as a new way of issuing financial instruments.
  • Financial market infrastructure law:A new financial market infrastructure authorization type has been introduced, the so-called DLT trading facility, which allows the multilateral trading of digital assets also by unregulated end-users. The introduction of the DLT trading facility will mark an important milestone in creating a unique, sustainable and functioning infrastructure for digital assets in Switzerland.
  • Insolvency and banking law:The DLT-Act has introduced significant clarifications to Swiss insolvency and banking law, setting out the requirements for digital assets to be segregated from the bankrupt's estate of the custodian. In bankruptcy, segregation will, in particular, take place, whenever the digital assets can be individually allocated to a client. Off-chain segregation will be deemed sufficient, thus, allowing the on-chain pooling of digital assets, which can be seen as a further milestone for the industry.

Impact

With its blanket law approach, the Swiss legislator consciously refrained from creating a specific technology law for digital assets, a path taken by Liechtenstein, Gibraltar or Malta, for example. In fact, the Swiss technology-neutral and principle-based approach can be deemed an advantage in that it can easily accommodate to the ever-changing technology.

All in all, with the introduction of its DLT-Act together with the Swiss Fintech license (which was already introduced back in 2019 and is especially useful in the DLT space, for innovative payment services and crowdfunding platforms), Switzerland remains at the very forefront of legal and regulatory developments in the digital assets space around the world, allowing it to continue to develop as a leading, innovative and sustainable location for the issuance (e.g. equity tokens and NFTs), trading and safe custody of digital assets.

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Fintech in Ukraine

Developments in Payment Services Market

Description

On 30 June 2021, the Ukrainian parliament adopted draft law No. 4364 “On Payment Services”, which represents long-awaited regulatory reform in Ukraine's payment services and FinTech markets. The Payment Services Law essentially relies on the regulation of the EU, in particular, the Second Payment Services Directive (PSD2), E-Money Directive and other instruments. Except for certain provisions, this Payment Services Law will go into effect in 12 months upon its publication, giving market stakeholders time to prepare for the anticipated changes. Below is the outline of major novelties introduced by the Payment Services Law:

  • One regulator for payment services: unlike previously, only one regulator of payment services will authorise payment service providers for any stage of the payment process and related services. The National Bank of Ukraine became the only regulator of this market;
  • Scope of payment services: there will be nine payment services, seven of which relate to financial payment services and the remaining two constitute non-financial payment services. In each case, the providers of these payment services will be specifically determined;
  • New players: most payment services in Ukraine can currently be provided only by commercial banks (e.g., issuing payment cards and e-money, and opening current bank accounts). The new law contemplates that payment institutions other than banks will be entitled to provide these payment services, which will increase competition in the market. Currently, neobanks have two options: (i) to obtain its own banking licence; or (ii) to use a banking licence of the existing bank. Upon entering into force of the Payment Services Law, we expect an increase of small and mid-sized neobanks operating, based on a payment institution licence, instead of a banking licence. Also, the marketplaces will be able to provide their clients with financing services such as lending and payment by instalment without the engagement of banks.
  • More client accounts and open banking: non-banking payment services providers will be entitled to open and manage payment accounts. Open banking principles are now set out in the Payment Services Law and will allow new participants to access client accounts. Additionally, account information service providers and payment initiation service providers will be authorised to operate in Ukraine. Respective amendments are likely to boost the development of loan application tools, digital wallets, personal finance planners and other services.
  • Easy authorisation for payment business: the authorisation of payment service providers and the introduction of the concept of small payment institutions will simplify the process of operating a payments business in Ukraine. Small payment institutions will be able to operate on the territory of Ukraine only and within the limit of the overall value of payment operations, to be established by the National Bank of Ukraine;
  • No mandatory participation in a payment system:under existing rules, only a financial institution that is a member of a payment system can run a payments business. The new law no longer has this requirement for rendering payment services;
  • Introduction of regulatory “sandbox”: the Payment Services Law introduces basic regulation for the regulatory “sandbox” platform. The NBU will be allowed to create a regulatory platform for the examination of new technologies and instruments in the payment services market by the stakeholders. More detailed regulations and procedures will follow;
  • Transparency:the terms of payment services are expected to become more transparent as the Payment Services Law improves the requirements on the provision of payment services related information to customers; and
  • Security of payment operations and counteraction to fraud: for some types of transactions there will be additional security requirements towards, e.g., strong customer identification. The Payment Services Law envisages stricter liability for illegal actions with payment instruments and access to bank and payment accounts to minimise cyber fraud.

Impact

The Payment Services Law is expected to resolve current regulatory barriers, improve transparency and security in financial services sector and facilitate the improvement of existing and development of new business models for FinTechs. An increase in competition in many segments of the traditional banking sector and among FinTechs will positively affect the payment services market. For the market stakeholders, this is the right time to think about new products and opportunities produced by regulatory developments in Ukraine. During the transition period, we recommend all Ukrainian financial services providers prepare for the anticipated changes.

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Fintech in the United Kingdom

Cryptoassets

 

Development: FCA’s findings into cryptoasset consumer research 2021 – what does the public think of crypto?

Description

On the 17th of June 2021, the Financial Conduct Authority (“FCA”) released a new publication covering insights gathered from research into consumer attitudes towards the ownership of cryptocurrencies.

The main findings from the FCA’s study highlight:

  • An increase in public awareness of cryptocurrencies;
  • A rise in ownership of cryptocurrencies, although the profile of cryptocurrency users remain broadly unchanged since 2020;
  • Users are likely to see cryptocurrencies as an alternative or complement to mainstream investments rather than a gamble;
  • Most consumers continue to use an exchange to purchase their cryptocurrencies and use their own disposable income to pay for it;
  • Half of users intend to buy more cryptocurrencies in the future; and

There are limited signs of enthusiasm or understanding for stablecoins.

Impact

The FCA has stated that it will reflect on the findings to inform their work on cryptocurrencies going forward. For a range of financial businesses from large institutions to smaller FinTechs, these findings highlight that consumers continue to show more willingness to engage with cryptocurrencies as awareness increases and ownership grows. Particularly promising is the fact that more users are starting to  hold them as part of a wider investment portfolio - they are not merely seen as a gamble. The FCA has also seen an increase in cryptocurrency propositions make use of the FCA’s regulatory sandbox.

With the Kalifa Review highlighting that the UK is primed to become a global FinTech leader, there are plenty of opportunities for organisations wishing to become involved in cryptocurrencies going forward. However, it is also important to note that the FCA continues to be proactive in emphasising the risks for retail investors and the general public who may not sufficiently appreciate the volatility, novelty and lack of regulation in the cryptocurrencies space.

Read related Law-Now article


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Pay for your coffee with crypto? In El Salvador you can

Description

On 8th June 2021, El Salvador President Nayib Bukele’s proposal to make bitcoin legal tender was approved by El Salvador’s Congress. Bitcoin will become legal tender in the country, alongside the US dollar, in 90 days’ time. Under the law, bitcoin can be used for purchases or tax payments, and bitcoin exchanges will not be subject to capital gains tax. The government guarantees convertibility to US dollars at the time of the transaction through a trust set up at the Development Bank of El Salvador, with the bitcoin-dollar exchange rate set by the market. 

The reasoning behind the move is to make it easier for Salvadorans living abroad to send money home. El Salvador is highly reliant on remittances, or money sent home from abroad. More than two million Salvadorans live outside the country and send back more than $4bn (£2.9bn) each year, an amount which makes up around 20% of the country’s GDP. It is also hoped that the legalisation of bitcoin as tender will open up financial services to the 70% of El Salvador who do not have access to traditional bank accounts.

Impact

The current trend in common law jurisdictions has been to accept that cryptocurrencies are property. The status of cryptocurrencies as property could have significant ramifications, particularly around financial regulation, issues of ownership and seeking legal assistance to recover lost or stolen cryptocurrencies. 

There may also be questions that arise on whether the status of bitcoin as legal tender will attach personal or proprietary rights.  This could have an impact on the remedies available from the Courts. Related to that is the weighty question about whether bitcoin (or other cryptocurrencies) should be treated as money, which has significant implications for contractual and regulatory outcomes. 

There is also the added complication of what happens if various holders of cryptocurrencies decide to go to El Salvador to “cash in” their bitcoins.  This could lead to a significant depletion of El Salvador’s US dollar accounts and in turn lead to a reduction in the value of the cryptocurrencies in El Salvador, leading to price arbitrage. 

Read related Law-Now article


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Risk-weighting cryptoassets: BCBS consults on the prudential treatment of cryptoasset exposures

Description

On 10 June 2021, global standard setter the Basel Committee on Banking Supervision (“BCBS”) published a consultation on the prudential treatment of banks’ cryptoasset exposures, with comments to be submitted by 10 September 2021. This anticipated consultation follows earlier international and domestic statements on this topic, including the Financial Stability Board’s Report to the G20 in July 2018 and a Dear CEO Letter from the Prudential Regulation Authority to UK banks, insurance companies and designated investment firms in June 2018.

Among other things, the BCBS is proposing a new conservative prudential treatment for certain high-risk cryptoassets such as bitcoin, which would mean they carry a high capital charge that may in practice disincentivise investment, and new disclosure requirements for cryptoasset exposures. The BCBS makes it clear that its proposals would represent a minimum standard and jurisdictions would be free to apply additional and more conservative measures if thought appropriate (such as banning cryptoasset exposures altogether).

Impact

The UK is a member of the BCBS and so in due course any adjustments to the Basel Framework should be implemented through changes to the UK’s Capital Requirements Regulation. Forthcoming changes to the UK’s prudential regime for investment firms should not affect the application of the new BCBS treatment to investment firm’s cryptoasset exposures, because under the current proposals certain parts of the UK CRR will continue to apply.

Read related Law-Now article


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UK Fintech

 

Wide range of new initiatives announced for UK FinTech by Chancellor (Part 2)

Description

In his keynote speech opening London FinTech Week, the Chancellor of the Exchequer, Rishi Sunak, announced a series of new policy developments relating to FinTech. In particular:

  1. the launch of a new FCA ‘scale box’ and Centre for Finance, Innovation and Technology (“CFIT”); and
  2. new initiatives relating to the UK’s potential adoption of a central bank digital currency (“CBDC”).

The ‘scale box’ is a new regulatory sandbox for FinTech and RegTech businesses intending to ‘scale’ and collaborate with ‘incumbent’ financial services providers. CFIT will be an industry-led organisation for FinTechs to promote the development of FinTech and support the implementation of certain initiatives.

Last year, the BoE signalled its interest in the possibility of creating a CBDC by releasing a discussion paper which considered how such a system could be designed. The Kalifa Review also endorsed the implementation of a CBDC and indicated that collaboration between HM Treasury and the BoE would be essential to create an effective approach to a CBDC. 

The Chancellor’s announcement of the creation of a new Taskforce and two new forums exploring CBDCs, suggests that he supports this approach, with the creation of a new Taskforce being jointly chaired by both HM Treasury and the BoE.

Impact

The scale box aims to tackle obstacles to partnering between start-ups and incumbent financial services firms. These obstacles include: the complex procurement processes of incumbents which tend to be driven by regulation; a concern by incumbents in relation to potential risks (particularly as the regulatory risk tends to fall on these incumbents); and a lack of opportunity for FinTechs or RegTechs to demonstrate or experiment their solutions in a manner which could reduce the concerns of incumbents in relation to their risk. 

There has been some debate in relation to the implementation of a (retail) CBDC.  The advantages are likely to include a cheaper, more resilient, and more trustworthy mechanism for depositing funds and making payments. It will also foster new business models and could create innovative new ways of implementing monetary policy (e.g. by directly applying interest rates to deposits or more easily and cheaply implementing “helicopter money” strategies). The disadvantages relate to privacy concerns for individual citizens, the potential for misuse of data which can be gathered by government, and the general concern of whether the public sector should be involved in such a project. 

Overall, the approach taken by the government and the BoE will be welcomed by the FinTech industry as a CBDC invites a huge opportunity to innovate and replace existing payments infrastructure with new, cheaper, and more efficient methods.

Read related RegZone article


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Wide range of new initiatives announced for UK FinTech by Chancellor (Part 1)

Description

On 19 April 2021, during his opening keynote speech at a launch event for FinTech Week, the Chancellor of the Exchequer, Rishi Sunak, announced new proposals for UK FinTech, as follows:

  1. A new FCA ‘scale box’ and Centre for Finance, Innovation and Technology (“CFIT”) would be launched;
  2. A new Central Bank Digital Currency (“CBDC”) taskforce would be set up and the implementation of a new sandbox and “omnibus” account; and
  3. Plans for implementing reforms to the prospectus regime and listings were announced.

The ‘scale box’ is a permanent digital sandbox pilot which supports partnerships between incumbent financial services firms and FinTechs / RegTechs to provide support for growing regulated firms. 

The Chancellor has announced the launch of the ‘scale box’ along with the Second Phase of its Digital Sandbox which creates a sandbox for firms to test new products which tackle sustainability and climate change related challenges.

A CBDC is an electronic form of central bank money which, in these circumstances, could be used more widely by households and businesses to carry out payment transactions and store value – effectively acting as a digital version of a traditional bank note. Whilst the government and Bank of England (“BoE”) have made clear that they have not yet made a decision on whether to introduce a CBDC in the UK, the Chancellor’s announcement of a new “Taskforce” indicates the possibility of its introduction has become more likely.

The Chancellor explained how the government would take forward some of the recommendations in the recent UK Listing Review by Lord Hill.

Impact

The CFIT is an industry-led organisation which co-ordinates and fosters growth of the FinTech market by providing a variety of services and creating a collaborative environment. The CFIT is also the body which implements or oversees a number of other recommendations which were set out in the Kalifa Review, such as working closely with newly formed regional hubs to help address their challenges. The ‘scale box’ and CFIT were both ideas recommended in the recent Kalifa Review.  Whilst we await the government’s full response to the Kalifa Review which has not yet been published, the implementation of these two recommendations indicates that the government is likely to have a positive view of the review.

The Chancellor also announced a new sandbox for firms using distributed ledger technology to improve financial market infrastructure, which will be implemented jointly by HMT, the BoE, and the FCA

Developments could offer innovative payment services with the security of central bank settlement. 

The Chancellor’s announcements in relation to the prospectus rules and listings will; result in an adjustment of overburdensome prospectus rules; allow for firms to provide forward-looking financial information; and improve the efficiency of rights issued when existing shareholders purchase new additional shares.

Read related Law-Now article


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Key contact

Sam Robinson
Sam Robinson

Authors

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Benoît Vandervelde
Benoît Vandervelde
Partner
Brussels
Florence Berchem
Florence Berchem
Junior Associate
Brussels
Cristina Reichmann
Cristina Reichmann
Partner
Head of Capital Markets, FIS, and Structured Finance, Romania
Bucharest
Mircea Ciuta
Bucharest
Jaime Bofill
Jaime Bofill
Partner
Madrid
Macarena Sanz
Macarena Sanz
Associate
Madrid
Pieter van Welzen
Pieter van Welzen
Senior Consultant
Financial Markets (Africa)
Johannesburg
Tina Balzli
Tina Balzli, LL.M. (NYU), LL.M. (NUS)
Partner
Head of Fintech & Blockchain
Zurich
Matthias Kuert
Dr Matthias Kuert, LL.M.
Associate
Zurich
Ihor Olekhov
Ihor Olekhov
Partner
Head of Banking & Finance Practice, CMS Cameron McKenna Nabarro Olswang
Kyiv (CMS CMNO)
Sam Robinson
Sam Robinson
Partner
London
Dil-Veer Kang
Dil-Veer Kang
Associate
London