www.ifc.org/thoughtleadership NOTE 57 • SEPT 2018 Blockchain Governance and Regulation as an Enabler for Market Creation in Emerging Markets Developing a proper governance and regulatory framework for blockchain-based applications will be essential to providing market participants the stability they need to fully engage with the technology, and allowing innovation to flourish. Given the global, multi-sectoral reach of blockchain, regulators and industry will have to work in a collaborative manner to ensure they can both experiment and learn, and so shape the future of the technology in a way that benefits all parties and society as a whole. Blockchain has the potential to enhance competitiveness responsibility, creating ground rules to protect the and increase connectivity across markets, increase inclusion reputational integrity and the value of the ecosystem. of underserved market segments, boost sustainability and The 2017 exuberance surrounding cryptocurrencies and transparency of global supply chains, and build resilience Initial Coin Offerings (ICOs) has led to greater scrutiny against external attacks—all of which are necessary to the due to the fraudulent nature of many ICOs. This has creation of markets.1 The global regulatory environment has marred the reputation of cryptocurrencies in particular and been slow to adapt to the technology, hindering its growth. blockchain by association, mobilized a defensive response Previous EMCompass Notes (Notes 40, 41, 43, 44 and 45) from regulators against potential risks, and detracted argued that blockchain, a distributed ledger technology, attention from the efforts of serious players developing can create new markets and products across emerging and useful applications. developing economies, and thereby presents an opportunity As a result, some investors will be hesitant to significantly to leapfrog the developmental cycle. finance new blockchain-enabled business models. Moving Blockchain promises to make peer-to-peer (P2P) transactions forward, if blockchain-enabled markets are to mature, more transparent, global, and inclusive. This, in turn could policymakers and businesses must create the rules of empower a sharing economy that challenges powerful digital engagement together. Regulators should provide guiding platforms such as Google, Amazon, Facebook, and Apple, 2 principles to attract private-sector investors, ensure as well as Baidu, Alibaba, Weibo, and Tencent. Market consumer protection and citizens’ rights, and provide incumbents see blockchain as both an opportunity and a safeguards against anti-competitive practices.4 The private threat, and so are moving into the space, as witnessed by the sector can undertake initiatives to ensure industry-wide proliferation of blockchain initiatives by these firms. interoperability and compliance with existing legislation Yet leapfrogging requires a proper regulatory environment and overall public-sector objectives such as the collection of to stimulate competition, investment, and innovation.3 If taxes and the prosecution of illicit activities.5 blockchain-enabled markets are to come to life, regulators For burgeoning technologies such as blockchain, finding a and businesses must work together. Regulators should balance between risk mitigation and innovation will not be think more like innovators and adapt quickly to the fast- straightforward. As long as distributed ledger technology paced nature of the ecosystem, while businesses should (DLT) is applied by businesses to marginally improve strive to think more like regulators and assume governance existing processes, current legislation should suffice, as those 1 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. processes are already subject to regulatory requirements. and wallet providers.14 In contrast, for permissioned DLTs By contrast, highly disruptive use cases springing out of the where access is conditional and the participants are pre- blockchain ecosystem, with new and at times unpredictable screened, the existing regulatory framework should be able technology and business models, will be far more difficult to to provide sufficient oversight since the actors already submit regulate through current legislative frameworks. to regulatory obligations (see EM Note 40 for a description Adopting definitive legislation at this early stage may be of permissioned and permissionless networks). According to premature and hamper future innovation. And yet, legislators international law firm Hogan Lovells, “arguably, supervisory can’t afford to do nothing in the face of blockchain’s growth. oversight is less necessary in regards private blockchains They will need to think outside the conventional legislative (notwithstanding antitrust and competition matters, or toolbox and innovate, as happened in the early days of the powers necessary to supervise possible illegal activities).”15 Internet.6 Collaboration will be key, with participation by Regulatory authorities are thus faced with different public authorities and industry to accommodate the multi- challenges, depending on the sector and their mandate sector, cross-border nature of the technology. (Figure 1), and whether the blockchain is public or private. Regulation and self-governance The paradox is that the same features of distributed ledger technology that can be forces for improvement and efficiency There are two primary ways to regulate a market: can also engender risks, depending on how the technology is regulation and private rule-making or self-governance.7 used. This makes clear-cut answers on regulation extremely The first occurs through public regulators enacting legally difficult. While deliberation on these issues is taking place binding statutes, also known as “hard law.” The second is through private actors that self-regulate or co-regulate, or “soft law.” National and supranational entities exercise 1 Anonymity reduction through KYC, AML and CFT Directives statutory oversight with a wide or specific mandate in their jurisdiction. Actors may prefer “soft law”8 or rulemaking 2 Legal nature of DL including territoriality and liability by private parties, as a more flexible approach to dealing with uncertainty and finding compromise among different 3 Recognition of DL as immutable tamper-proof sources of truth actors.9 In the finance industry, an example of the latter is Visa’s Core Rules, where the rules govern the actions 4 Conciliation of “Right to be forgotten” and DL immutability of participants using the Visa payment system.10 A hybrid example is the Basel Committee on Banking Supervision 5 Legal validity of documents stored in a DL as proof of possession or existence and the Financial Stability Board bringing policymakers from around the world to reach accords that can be 6 Legal validity of financial instruments issued on a DL translated into legislation in specific jurisdictions.11 Public policy perspective: 7 Real-world enforceability, territoriality and liability of smart contracts Key regulatory challenges Until early 2017, actors in the blockchain ecosystem 8 Treatment of shared information in DL from the perspective operated with little regulatory oversight.12 The second half of cross-border flow of data and data protection of that year saw an exponential rise of dubious ICOs and 9 Use of DL as a valid ruling register for the IoT bitcoin speculation, forcing regulators to take action due to the possibility of cryptocurrencies being used for tax evasion, fraud, and other illicit ends. Although regulators 10 Regulatory reporting information standards definition on the blockchain have become more vocal, issuing warnings to industry players as well as investors, blockchain’s terminology is still 11 Definition of a regulatory sandboxes approach to test evolving, complicating the legal classification of its assets.13 Attempting to regulate a permissionless system like bitcoin, FIGURE 1Distributed Ledgers’ Main Regulatory where there is no controlling legal entity, is a complicated Challenges task. Consequently, regulation so far has targeted Source: BBVA Research, 2016. CIT = Combating Financing Terrorism; cryptocurrency business applications such as exchanges DL = Distributed Ledger; IoT = Internet of Things. 2 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. in many forums, a consensus around some key guiding directive requires interconnected registries to record principles has yet to emerge. Nevertheless, there are cross- beneficial ownership of companies and trusts, and to share cutting challenges that require guidance and potentially with local tax authorities (OECD-BEPS Action 12).19 Japan regulatory oversight. These include (but are not limited to): has also amended its primary anti-money-laundering law to Cross-jurisdictional harmonization. Distributed ledger bring virtual currency exchange services within scope. 20 technology has by its very nature a global, cross- Scalability and interoperability. Setting technology standards jurisdictional deployment. It requires regulators and could provide genuine interoperability between nascent lawmakers to collaborate across national borders to protocols and legacy computer systems, thus promoting the harmonize legal and regulatory regimes, while managing scalability of distributed ledger technology. To this effect, the potential risks, including issues of monopolies and market International Standards Organization, with the participation manipulation.16 Addressing these would require significant of 33 nations, is already working on standards for legal and organizational changes and a mechanism for distributed ledgers that might remedy some of these issues. collaboration to ensure alignment. While scalability is not an issue of regulatory oversight, it Security and data privacy. The distributed nature of public addresses concerns that the sustainability of the system is in blockchains provides greater safeguards against potential question and could lead to market failure in the long run.21 external attacks and promises enhanced security. However, Risk to fair competition. The development of blockchain- regulators fear that the system’s anonymity for users could enabled applications, in particular by consortia in a encourage illicit activities such as money laundering and permissioned system, could potentially give rise to concerns terror financing. Another concern is the compatibility about unfair competition issues in a number of areas. 22 of blockchain with the ‘right to be forgotten’ in the EU These include: (i) the prospect of market dominance by General Data Protection Regulation (GDPR), given the some participants, with negative consequences for cost immutability of data on a public blockchain. and quality of services; (ii) a gating effect that may exclude These are some of the frictions emerging between the new entrants; (iii) the adoption of technical standards potential benefits and risks associated with the technology, that prevent participation by competitors; and (iv) the for which there is no immediate policy recommendation. risk of collusion and market manipulation between In private blockchains, accessibility can be controlled by participants. Companies collaborating with competitors design and participants can ‘opt in’ to the desired level though a consortium will have to consider the nature of the of disclosure and shared access. Hyperledger Fabric and information they make available to competitors through a R3’s Corda, both examples of permissioned DLTs, allow shared ledger, to avoid potential price fixing and exposing participants to control who can see what information about participants to potential antitrust liability. transactions submitted to the ledger.17 Early responses from policymakers Anti-money-laundering and illicit financing. Well-designed A result of this fluctuating environment is that regulatory distributed ledgers could improve compliance with anti- reactions have varied widely across different jurisdictions. money-laundering (AML) and know-your-customer (KYC) The only consistent reaction has been that no jurisdiction requirements, provided they include a secure identity has recognized bitcoin as legal tender.23 A few have taken the system.18 However, given that false identities can hide step of enacting relevant legislation. For example, the U.S. behind the anonymity of open blockchains, and their past state of Arizona passed legislation that qualifies blockchain- use for illicit activities, authorities in 2015 began to provide enabled signatures secured as valid electronic signatures. specific anti-money-laundering guidance and crack down Similarly, Delaware voted to allow blockchains for corporate on illegal activity linked to digital currencies. record-keeping. Russia has created a legal framework to The U.S. Financial Action Task Force (FATF) has urged legalize initial coin offerings, while France has authorized virtual currency exchanges to comply with AML legislation debt-based crowdfunding recorded on distributed ledger by recording customer identities and conducting enhanced technology. Most jurisdictions, however, have maintained due diligence. European governments, in coordination a wait-and-see approach to the underlying technology and with the Organisation for Economic Co-operation and have avoided comprehensive legislation. This approach Development, are pushing for global coordination on this gives regulators time to observe how blockchains develop. issue. The European Union’s fourth anti-money-laundering Experts are advocating for regulators to focus on regulating 3 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. specific use cases of blockchains rather than the technology Private sector governance challenges: itself, a practice that has been adopted with other disruptive The case of consortia technologies such as the Internet and digital platforms. Technology industry analyst Gartner predicts that the value Public authorities around the world have adopted different added for blockchains will grow to more than $176 billion approaches: by 2025, and exceed $3.1 trillion by 2030.35 To capitalize on the opportunity, industry players are forming consortia Europe: The European Union has opted for a balanced to co-develop applications with innovators, while finding approach. 24 The European Commission is actively ways to minimize costs and potential risks. Blockchain monitoring related developments, and in February 2018 technologies have a major impact when network effects can launched the EU Blockchain Observatory Forum to gather be realized and consortia provide a vehicle to leverage them. information from EU members on use cases and engage experts and practitioners before formulating concrete A blockchain consortium is a hybrid, semi-private blockchain policies. 25 Also, the European Central Bank formed a task that allows organizations to establish ‘compartmentalized force on distributed ledgers and launched a joint research trust’ relationships and to condition access to the network project with the Bank of Japan. 26 For financial services, the accordingly. “A consortium platform provides many of the European Securities and Markets Authority has recognized —  benefits affiliated with private blockchain  for example, the need to strike a balance between ensuring safety in efficiency and transaction privacy  — without consolidating transactions and preventing unnecessary complexity, so as power with only one company.”36 Participants involved in not to discourage participation by new entrants. 27 a blockchain consortium may have different priorities and may even be in direct competition with each other. Consortia United States: The response from regulators has been can have a functional objective, such as solving a specific fragmented since regulatory authority crosses agencies business problem. They can also be technical, seeking to (the Securities Exchange Commission (SEC), the develop universal interoperable and modular blockchain Commodity Futures Trading Commission, and the platforms across multiple industries. At present, there are Treasury Department, among others), as well as federal over 40 blockchain consortia across the globe, which have and state jurisdictions. While the tax authorities treat attracted significant funding, mostly from the financial virtual currencies as property, the SEC has refrained sector (Figure 2).37 from providing a legal definition for bitcoin and virtual currencies, 28 preferring to consider developments on a Governance is critical to running an effective consortium, case-by-case basis, a “facts and circumstances analysis.”29 given the volatility of blockchain innovation and the divergent The SEC Chairman has suggested that ICOs30 seem to fall interests of participants. Trust is introduced through an in the realm of securities.31 He also sent a clear message to market participants: “those who would use distributed 26 Financial services ledger technology to raise capital or engage in securities transactions must take appropriate steps to ensure 10 Cross-sector compliance with the federal securities laws.”32 Life sciences & 3 health care Singapore: Singapore is a major player in Asia’s innovation ecosystem. The Monetary Authority of Singapore is 1 Energy & resources taking a collaborative, “risk proportionate”33 approach 1 Technology, media & to blockchains, and has launched a regulatory sandbox telecommunications where fintechs, banks, and regulators work together. The 1 Public sector regulator is collaborating on an international scale with Consumer & other regulators, including the Hong Kong Monetary 0 industrial products Authority, to develop a cross-border blockchain-based trade 0 5 10 15 20 25 30 finance system. It has issued a public notice to qualify token sales as securities and has announced that it would develop FIGURE 2 Consortia Distribution a new payments service framework to ensure anti-money Source: Deloitte analysis; see also Gratzke, Peter, David Schatsky and Eric laundering compliance for companies involved in the Piscini. 2017. “Banding Together for Blockchain - Does it Make Sense for dealing or exchange of virtual currencies.34 Your Company to Join a Consortium?” August 16, 2017. 4 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. entity, acceptable to all, that exercises control over access engagement from both policymakers and industry to work and makes decisions about membership and management of on specific use cases. the alliance. As the size of consortia increase, however, so do Initiatives for engagement can be advanced by either party, the governance challenges of each group, which essentially such as regulatory “sandboxes” (see below) from public consist of classic organizational problems of cooperation and authorities or industry-led public private partnerships. An coordination. A 2017 CoinDesk survey on digital innovation industry-led example is the U.S.-based Blockchain Alliance, in financial services found that over 70 percent of respondents which brings together stakeholders from the blockchain considered industry consortia as vital to the development of industry with law enforcement agencies from the United solutions.38 Yet a similar percentage had serious reservations States and around the globe. The European Commission about the format, from the system of incentives to the lack has launched two initiatives, the EU’s Blockchain of control. Smaller, use case-focused consortia start to Observatory and the European Blockchain Partnership, to emerge and even large consortia are segmenting into different coordinate the actions of Member States in the context of a working groups to facilitate governance. digital single market.43 Establishing clear rules for engagement, decision- Regulatory sandboxes: making, and accountability is critical. Participants must Toolkits for public-private dialogue address how rules will be changed in the future after the distributed ledger technology is implemented. An important Sandboxes and similar government-backed initiatives are consideration for participants is the question of intellectual useful approaches that allow startups and regulators to property, particularly if one or more of the participants learn together in practice and in a controlled “safe space,” come to the table with pre-developed technology, as there so that they may make more informed decisions about might be a risk of vendor lock-in (although open source the boundaries of their respective responsibilities. These is most likely the appropriate route for many consortia).39 are also a way to attract innovation to one’s jurisdiction During the early stages, most of the focus will be on without committing a priori to a binding legislation. converging around a technical solution. But as the business Sandboxes typically have the following features:44 rationale adapts to changes in market conditions, decisions • Customizing rules for each firm/business proposal, will have to be made about which course to pursue and how rather than a one-size-fits-all approach. to effect changes to the code. Dispute resolution, sanctions • A small number of customers/clients, testing for a for violations, and appropriate enforcement mechanisms limited time-period, and safeguards for consumer need to be foreseen to address potential conflicts.40 protection (such as requirements of informed consent). Self-governance and regulation: • Restricted authorization/licensing, individual guidance, The importance of public-private collaboration waivers/modifications to rules for that project, and no While computer codes by default are self-regulatory, they enforcement action letters. should not operate in isolation from a legal framework.41 The model is already being tested in various jurisdictions. Regulations create legal certainty, allowing entrepreneurs The UK Financial Conduct Authority (FCA) was the first to to innovate without fear of breaking the law. Blockchain- introduce a sandbox specific to blockchain. While the most based systems need robust governance mechanisms even experienced and firm-focused sandbox, its attractiveness though regulators are hard-pressed to keep up with the may diminish with Brexit, a potential loss of a “passport” technology’s unpredictable nature. ICOs exploded onto the regulatory approval into other EU markets. Other countries market with such speed that regulators were unprepared for have followed the UK’s example: Singapore, Abu Dhabi, the outcome. Australia, Canada, Denmark, Hong Kong, Switzerland, Michele Finck of the Max Planck Institute proposes a Malaysia, and South Africa have all launched some form of collaborative effort between regulators and innovators a sandbox. to account for the specificities of the technology and The main drawback of regulatory sandboxes is that they provide stability.42 Given the still experimental phase of are limited to a single jurisdiction and do not accommodate blockchain, businesses and regulators alike are struggling the global reach inherent in the technology. While a to learn quickly and define regulatory boundaries. At this global process of multi-stakeholder co-regulation has been stage, it is important to maintain flexibility and encourage proposed, it is unlikely to emerge any time soon. 5 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. An intermediate step could be the creation of a multi- funds by breaking the immutability of the code splintered jurisdictional sandbox. The FCA has proposed a global the community of developers/shareholders and undermined regulatory sandbox, uniting regulators from several trust in the system and in the concept of “Code is Law.” jurisdictions and firms with multi-market ambitions to work This reputational damage of blockchain was compounded together on policy and regulatory challenges. As a first step, by the fraudulent use of ICOs, in the absence of clear rules. the initiative proposes to create an international “college” of The model of “crowd” blockchain governance is being regulators, each with its own mandate or sandbox models, tested. The question becomes whether the technology giving firms access to multiple regulators. It is a pragmatic, can and should fully replace a transparent democratic go-to-market approach that aims to provide firms with debate on governance, essentially a political process, with some guiding principles rather than a full-fledged set of a technical rule-making system defined by elite developer standards across participating jurisdictions. Other experts communities.48 The more distributed ledger technology have put forth a long-term vision of a full multilateral penetrates business use, the more it will be confronted sandbox, perhaps under the mandate of a global multilateral with existing legislation. Blockchain will need to evolve institution such as the World Bank Group or the IMF. and provide a clearer governance structure to guarantee Entities like the European Commission may be in a position transparency, accountability, and the protection of to encourage and coordinate such projects among member investors and shareholders. It will also need to recognize states. The recently signed European Blockchain Partnership the socio-political context in which it operates and ensure is a promising start “to exchange expertise in technical and that technical solutions do not have unintentional effects in regulatory fields and prepare for the launch of EU-wide marginalizing segments of participants or undermining the blockchain applications across the Digital Single Market.”45 freedom of individuals. Corporate governance disrupted: In response to these pressures, the corporate governance The impact of blockchain on the role of the firm of companies stands to be disrupted as much as their Blockchain’s distributed trust mechanism has far-reaching business models, as they attempt to adopt and adapt implications for governance. Yet there has been limited to the technology. Traditional structures are already research on how new crypto-corporate governance models experimenting with blockchain and smart contracting may emerge and challenge the board-centric existing model. applications to take advantage of potential efficiency Decentralized Autonomous Organizations—also known gains from its auditability, immutability, and digital as DAOs—operate without a corporate hierarchy. identification. Specifically, blockchain initiatives are The evolution of smart contracts has the potential to underway to address some of the procedural flaws and revolutionize economic activity, displacing the firm as the costs for small shareholders of the Annual General Meeting primary organizational vehicle. A DAO promises to self- by facilitating voting and registration of shareholder lists. govern, with bylaws and decision-making codified into The Nasdaq announced a successful pilot for e-voting in algorithms, and potentially little or no human mediation. Estonian Annual General Meetings in 2017 and similar Such a structure may be able to address an inherent initiatives have been undertaken by the Abu Dhabi agency problem in existing governance structures, where Securities Exchange, the Russian National Settlement the interests and risk preferences of board members and Depository, and the Toronto Stock Exchange Group. shareholders may diverge.46 DAOs are organized around the Eventually, corporate actions such as the payment of concept of a “town hall,” with the potential to give voice to dividends and coupons could be distributed through a fully all investors.47 The original DAO, which was launched by automated process. This could result in lower costs for Slock.it in 2016 on the Ethereum platform and raised $150 trading, faster transfer of ownership, and greater accuracy million, was the first example of a such a structure. It had and transparency throughout the process.49 At present, no directors, managers, or employees and the governance experiments are marginal. But with the prospect of further structure was built with software, code, and smart contracts. automation through smart contracts, the question arises as Yet, the 2017 hacker attack on the original DAO that stole to whether DAOs should have a legal corporate charter and $55 million exposed the vulnerability of the network and what form these should take. raised issues of liability for loss of value. The decision by Corporate governance under a blockchain system can the majority of shareholders to recapture the siphoned profoundly alter the power relations among managers, 6 This publication may be reused for noncommercial purposes if the source is cited as IFC, a member of the World Bank Group. shareholders, regulators, and other stakeholders. ABOUT THE AUTHOR The transition from a centralized world of corporate Marina Niforos is the founder of Logos Global Advisors, a hierarchies to a distributed one still defies our established strategic advisory firm on strategy and innovation, and Visiting notions of economic production around the vertical firm. Faculty of Leadership at the Hautes Etudes Commerciales de Disintermediated corporate governance structures and Paris (HEC), a French business school. In March 2018, she was practices can perhaps offer a more cost-effective and appointed to the Blockchain Policy and Framework Conditions efficient way for management to access market information Working Group of the EU Blockchain Observatory & Forum. and shape strategy. However, efficiency gains may be (marina.niforos@logosglobaladvisors.com) hampered by the ability of the platform and the nodes to extract rent for their efforts, proportionate to their market ACKNOWLEDGMENTS power. In any case, such changes will require significant The author would like to thank the following colleagues reform and legal adaptation of the existing rules as well as for their review and suggestions: Gordon Myers, Chief a shift in the incumbent organizational culture.50 Counsel, Legal Department, IFC; Steven Buck, Manager, Conclusion Operational Risk and Business Continuity, Risk Management, IFC; Andrew Yew, Senior Counsel, Legal Department, IFC; Despite the exuberance surrounding cryptocurrencies, Rachel Alexandra Halsema, IT Officer, Business Management the distributed ledger technology is still at an early I, Technology and Innovation, World Bank Group; Susan stage of development and remains a marginal economic Carevic, IT Officer, Business Management II, Technology phenomenon. Blockchain faces challenges of scalability, and Innovation, World Bank Group; Peteris Zalgalvis, security, and mass adoption. With respect to its Head of Unit, Startups and Innovation, Digital Single governance, the system is struggling to transition from a Market Directorate, Directorate-General Communications techno-libertarian model to one that can accommodate Networks, Content and Technology, Co-Chair, FinTech Task friction with the real economy. Yet for optimal governance, Force, European Commission; Sopnendu Mohanty, Chief the deliberation process cannot take place in isolation. Fintech Officer, Monetary Authority of Singapore; Damien Innovators and regulators need to engage with each other Pang, Head of Technology Infrastructure Office, Monetary to learn and shape the future of the technology in a way Authority of Singapore; Paul Worthington, Innovate / that benefits all parties, and society as a whole. Aware of Strategy and Competition, Financial Conduct Authority, the potential and the magnitude of the challenge, regulators UK and Thomas Rehermann, Senior Economist, Thought in emerging markets, whether in Asia, the Middle East or Leadership, Economics and Private Sector Development, IFC. Africa are actively observing the space and testing policy options (see discussion on regulatory sandboxes above). ADDITIONAL EM COMPASS NOTES AND REPORTS Ideally, a global multi-stakeholder process should be put ABOUT BLOCKCHAIN AND ITS OPPORTUNITIES FOR in place to pursue a uniform, rules-based system across EMERGING MARKETS: national jurisdictions. But as the Internet has shown, Blockchain – Opportunities for Private Enterprises in implementing a global coordination mechanism can Emerging Markets (report), IFC, October 2017; Can Blockchain become mired in geopolitics, making the prospect of a Technology Address De-Risking in Emerging Markets? (Note global arbiter seem distant. Less ambitious scenarios for 38); Blockchain in Development -- Part I: A New Mechanism transnational cooperation are underway to develop public of “Trust”? (Note 40); Blockchain in Development -- Part II: standards for the code, with international agencies working How It Can Impact Emerging Markets (Note 41); Blockchain on some aspects of standards harmonization and for in Financial Services in Emerging Markets - Part I: Current regulatory sandbox coordination. Whatever the process Trends (Note 43); Blockchain in Financial Services in Emerging selected, a purely technological, amoral model cannot Markets - Part II: Selected Regional Developments (Note 44); ensure the governance and sustainability of the blockchain Beyond Fintech: Leveraging Blockchain for More Sustainable ecosystem without acknowledging the real political and and Inclusive Supply Chains (Note 45); Using Blockchain to social pressures surrounding any change as fundamental as Enable Cleaner, Modern Energy Systems in Emerging Markets the one blockchain promises to bring about. 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