A few days ago, Ouke Cloud Chain Research Institute released a blockbuster report, which attracted widespread attention from the banking industry and financial regulatory agencies. By dismantling the cryptographic layout of more than 70 banks around the world, the report believes that with the increase in global adoption and the maturity of related technologies, cryptoassets have become an issue that cannot be ignored by the banking industry. There are also areas of innovation that cannot be missed.
As a senior practitioner in traditional financial institutions,Mr. Chen Zhitang not onlyhas decades of banking experience, He also has in-depth research and unique insights into Web3 and encrypted assets. And coincides with the European Keyun Chain Research Institute, Mr. Chen Chi-Tang also believes that crypto-assets are an unavoidable market for banks, and Hong Kong can become a testing ground for crypto-asset innovation and continue to play the role of a bridge between the East and the West.
Based on the continuous research and thinking on virtual assets, Web3.0 and banking industry, Mr. Chen Zhitang recently completed the projectThe article "Thinking about Digital Transformation: Web3.0 and Banks". Mr. Chen Zhitang said in the article, Compared with virtual asset investment and RWA direction, stablecoins are most suitable for the nature of banking business and have the clearest entry path at present< /span>. . Hong Kong banking entities can provide stablecoin-related services to individual customers by participating in the stablecoin business, and provide bank settlement services to qualified virtual asset service providers (VASPs). When the customer base increases, they can establish a quasi-SEN with reference to Silvergate bank. Payment and settlement system
In Mr. Chen Zhitang's view, banks' participation in virtual asset layout can not only achieve brand promotion effects, but also improve customer structure and enrich revenue sources. More importantly, the introduction of virtual assets will completely reshape the bank's product system. . These thoughts are similar to the conclusions of the Ouke Cloud Chain Research Institute in the "Global Banking Industry Encryption Landscape 2023" report.
This article is published in a special edition for the benefit of readers.
Author | Chen Zhitang
The following is Mr. Chen Zhitang’s article (with deletions). If you want to get the complete text, please click "Read the original text" to download.
A review of the Hong Kong government’s Web3 policy context
The Hong Kong government is promoting the construction of a world virtual asset center with an unusual speed and attitude.
According to PANews, the Hong Kong government has launched policy guidelines related to virtual assets since 2018. However, before 2023, the relevant policies did not attract a lot of attention from the market. After 2023, due to the Hong Kong government’s regulations on virtual assets and Web3 .0 Positive changes in policies. The Hong Kong government and institutions at all levels, including the regulatory agencies the Hong Kong Monetary Authority and the Hong Kong Securities and Futures Commission, have intensively launched various declarations and policies of practical significance, and promoted the implementation of virtual asset businesses at the practical level. These This initiative has greatly attracted the attention of Web3.0 industry participants around the world.
Hong Kong’s policy on promoting virtual assets is particularly prominent in the context of China’s strict ban on crypto asset trading and the United States’ strict supervision of virtual asset exchanges. Therefore, it is inevitable to speculate whether the Hong Kong government has communicated with the central government on the development of virtual assets. Furthermore, in the historical context of decoupling between China and the United States, can Hong Kong continue to be an international financial center and rely on virtual assets to break the situation?The Hong Kong government’s concerted policy advancement at least demonstrates the courage of those in power. and determination, and it is very unexpected by traditional financial institutions and Web3 institutions. This has also led to the Hong Kong Monetary Authority’s rare call on banks to open accounts for crypto asset service providers, but there are still few responders< a i=2>.
In the shadow of the policy, there are also cryptocurrency or stablecoin exchange shops in Hong Kong. The nature of the business of these money change shops is indistinguishable from the regulatory scope issued by the Hong Kong Monetary Authority and the Hong Kong Securities and Futures Commission, but I have never heard of money change shops needing to apply with the above regulatory agencies. This may have something to do with the fact that the regulatory agency for traditional currency exchange shops is the Hong Kong Customs and Excise Department.
Reactions and actions of different institutional entities towards virtual assets
Given China’s strict virtual asset management policies, let’s first look overseas. Even after years of development, foreign institutions' participation in virtual assets is still considered outside the mainstream. The three most famous institutions before 2023 are, Grayscale Trust, and Tesla. MicroStrategy
MicroStrategy, Grayscale Trust, and Tesla were regarded as the vane leading Bitcoin investment in the last bull market, especially under Musk’s huge personal influence. The price fluctuations of cryptocurrencies such as Bitcoin and Dogecoin are often closely related to Musk's Twitter content.
In 2023 , the voice of cryptocurrency from traditional financial giants has once again attracted people’s attention to the cryptocurrency market.
2023 Year 6 Month 15 On the 5th, BlackRock, the world’s largest asset management company, applied to the U.S. Securities and Exchange Commission(SEC) for spot Bitcoin ETF; 2023 Since 8 A large U.S. financial institution submitted a Bitcoin spotETF to the U.S. SEC Apply.
2023 Year 8 Month 7 On the 5th, the American payment giant Paypal announced the launch of its stable currency PayPal USD (PYUSD), < /span>”. century Pillars 21 hopes to become the payment system of our Possibly"< /span>if issued under a clear regulatory framework(This is a clear signal that stablecoins issued a statement saying, Patrick McHenryChairman of the U.S. House of Representatives Financial Services Committee became the first technology giant to issue a stable currency.
The choice between the asset management giant and the payment giant demonstrates the attraction of virtual assets to the traditional financial industry. In the banking industry, both traditional commercial banks and modern technology banks have pioneers in active deployment.
2020 DBS Bank announced the launch of "DBS Digital Exchange"(DBS Digital Exchange)< a i=3>, to create a comprehensive digital asset ecosystem for corporate and institutional customers and qualified investors. Services include:Security token issuance ,digital currency transactions, anddigital custody services, etc.
In terms of technology banks, Silvergate bank and Signature bank Even though this year's U.S. dollar interest rate hike cycle failed, the two companies' successful experiences in the crypto-asset industry are still an important model for the banking industry to participate in the virtual asset industry.
Take Silvergate Bank as an example. The company did not start in the field of cryptocurrency. In fact, it started as a company specializing in < a i=3>A bank engaged in real estate financing. 2014 year 1 month, Silvergate Bank sees that most banks are unwilling to provide opportunities related to virtual assets, and the situation is very similar to the current situation in Hong Kong:
At that time, most banks were not willing to touch virtual assets, and they would even close individual customers' accounts if they were found to be transferring funds to or from cryptocurrency exchanges .
Buying and selling cryptocurrencies in U.S. dollars is a global activity 7*24 hours, but buying and selling U.S. dollars requires the use of traditional financial systems. Very slow speeds and the need to adhere to the official working hours of the clearing system.
Silvergate Bank Therefore created a real-time payment system "Silvergate Exchange Network" (SEN) to facilitate cryptocurrency transactions, allowing easy transactions between bank accounts around the clock, and the ability to settle payment activities for both parties immediately and at any time, which is not possible with traditional banks after hours. Handling cross-border business is completely different, attracting a large number of institutional traders and cryptocurrency exchanges.
SEN The system allows customers to voluntarily deposit tens of billions of dollars without any requirements Silvergate Pay interest, bringing a large amount of zero-cost and low-cost deposits. Since 2017 , Silvergate Bank ’s customer deposits have grown by nearly a> billion US dollars. 110 exceeds times, 7
Signature Bank has also developed a similar real-time payment system Signet.
Even if the above two banks declare bankruptcy in 2023 , the low-cost capital accumulation and profits that crypto-friendly banks can bring , is an attractive cake for every bank.
In the Hong Kong local market, According to Bloomberg, Hong Kong’s largest virtual bank ZhongAn Bank(ZA Bank) Exchange services for cryptocurrencies and fiat currencies are being promoted. Yao Wensong, Chief Executive Officer of Zhongan Bank4month11day stated in an interview that Zhongan Bank will act as a settlement bank, allowing customers to deposit cryptographic tokens on licensed exchanges and then withdraw them in Hong Kong dollars, US dollars and other currencies.
This business model is already used inHashKey andOSL Running on Hong Kong, these are currently two of the most well-known licensed cryptocurrency exchanges in Hong Kong. ZhongAn Bank will also provide the same services to other exchanges after they obtain licenses.
The direction of participation that Hong Kong banking entities can choose
From the perspective of Hong Kong’s policy orientation and the business direction of large overseas entities, virtual asset investment, stable currency business, real world asset tokenization(Real World Asset,RWA) are three main business directions. From the perspective of banks, compared with virtual asset investment and RWA direction, Stablecoins are most suitable for the nature of banking business and have the clearest entry path at present.
There are currently three mainstream development methods for stablecoins, namely USDT and USDC < Asset-backed stablecoins represented by /span>, cryptocurrency-backed stablecoins represented by < /span> is an algorithmic stable currency represented. UST DAI , cryptocurrency-backed stablecoins represented by
Each stablecoin design has its own unique flaws. In the industry, these trade-offs are often referred to as the Stablecoin Impossible Triangle" a i=4>, because it is impossible to achieve all three characteristics at the same time in one design: peg stability, decentralization, and capital efficiency. The current situation is that stablecoin projects can only give priority to two of the three characteristics. In other words, stablecoin projects must be successful in two To gain advantage in one aspect, one must make compromises in the third aspect. In summary:
Asset-backed stablecoins such as USDC and USDT, known for its stability and capital efficiency, with 1:1 mortgage backing but all Being centrally controlled brings dependency risks, as we saw with USDC ’s exposure to Silicon Valley Bank and Opacity of USDT .
Cryptocurrency-collateralized stablecoins like DAI bring stability and decentralization benefits, but they require higher Minting is done at a collateralization rate, making it less capital efficient than other options.
- Algorithmic stablecoins, like UST , have the advantages of decentralization and efficient capital, and have a unique peg maintenance mechanism, But all lack operational history, and their mechanisms have inherent problems, bringing potential risks of price instability.
Because of the above unstable triangle problem, stablecoins are also called the Holy Grail of Web3 , and every stablecoin issuing company is Look for different solutions.
从香港金管局的政策导向来看，目前只有资产支持型稳定币是被允许开展的业务，以保证稳定币与法币之间 1:1 的价格联系机制及避免后续的波动问题。而资产支持型稳定币方面，USDT 作为非受监管对象发行的稳定币势必要被排除在外，因此 Circle、Paxos 等已经获得监管合规牌照的合规稳定币公司将会是银行首选的合作对象。
银行选择稳定币的业务方向和收益分析
银行参与稳定币业务，有如下业务方向：
1、为个人客户提供稳定币相关服务
加密生态系统中最值得开发场景之一是出入金通道。对于个人投资者来说，法币和稳定币之间的汇款和兑换服务是最为需要的，但目前在香港地区除众安银行外，仍未有较大型的银行进行清晰的表态。
实际上，银行可以逐步推进为个人客户提供的稳定币服务。
首先是个人客户与合规稳定币发行公司之间的汇款业务。汇出业务是合规成本最小的，银行根据现行的反洗钱/反恐要求对个人资金来源进行审核，汇出时同样遵守现行的反洗钱/ 反恐要求，属于传统的法币汇出汇款业务。
其次是接收个人客户从合规稳定币发行公司汇入的美元汇款(或将来的其他合规法币)。由于个人客户在合规稳定币公司同样需要进行 KYC/AML 程序，合规稳定币的汇出银行也在汇款时执行 KYC/AML 程序，理论上与现行的法币汇入汇款业务没有区别。
最后银行可以考虑与合规稳定币进行公司合作，为个人客户提供法币和稳定币兑换服务。在此模式中，合规稳定币公司作为银行的对手盘存在。
2、为合资格虚拟资产服务提供商(VASP)提供银行结算服务
目前香港地区银行所面临的市场情况与 Silvergate Bank 当时在美国面临的市场情况一样， 银行对于为 VASP 提供银行账户犹豫不决，甚至在 HKMA 两次召开会议下仍然没有银行愿意明确表态，这在任何一个业务类型中都是罕见的。
银行可以考虑与 Hashkey，OSL 这两家已获得牌照的交易所进行商谈，为其提供银行账户，主要方向是与合规稳定币公司之间的汇款业务，个人客户与两家交易所之间的出入金业务，未来如果交易所自行发行稳定币时的资金托管业务。
3、在客户群体增多的情况下，建立参照 Silvergate bank 的类 SEN 支付结算系统
随银行的加密客户群体增多，银行可以考虑参照 Silvergate bank 建立起类 SEN 支付结算系统。该系统形式上类似银行的清算体系，如果都是行内清算，对于银行来说，初期的开发成本并非巨大的投入。
银行收益方面，则体现在:
1、鲜明的品牌宣传效应
如同众安银行的宣布，在各大媒体的宣传下，敢于定位自己为对加密友好的银行，将会获得巨大的曝光以及流量的追捧。如果是传统中小型银行，将会是一次改革自身形象和提升自身品牌的绝佳机会，即使是碍于合规成本未能开展大规模业务，也会在行业保持鲜明定位和先发优势。
2、改善客户结构的机会
虚拟资产行业投资者大都是年轻人，尤其是 90 年代之后出生的 Z 时代。在目前可选加密友好银行稀少的情况下，提供出入金服务的银行将会强烈吸引这些年轻客户前来开户，对于如果是以中老年客户为主的传统中小银行，是一次非常好的改善客户结构的机会。
对于公司客户而言，以数码港已经落户的 150 户客户为例，宣称对加密货币友好的银行完全会实现以点带面的营销效果，吸引一个行业的客户前来开户。
在跨境客户方面，在中国境内禁止交易虚拟资产的背景下，到香港开立一个能够有机会交易虚拟资产的账户，将会对中国境内居民具有很大的吸引力。毫不夸张的预言，访港旅客的购买标的从以往的奢侈品到现在的保险和定期存款，未来将会变成虚拟资产。
3、潜在的稳定币盈利机会
抛开简单的汇兑点差收入等不谈(实际这部分收益已经非常可观)，稳定币在目前具有绝佳的盈利机会。
以 USDT 发行商 Tether 为例，根据其披露的 2023 Q2 报告，USDT 的总资产规模从年 初的 660 亿达到了目前的 860 亿美元，其中超过 550 亿的美元资产用于投资美债等无风险资产，大部分的盈利都来源于此。
It was reported that Tether achieved in Q2 Profit exceeding 1 billion billion, and even more achieved in Q1 quarter 14.8 Tether is expected to earn< /span> a>Multiple people. 50 employees , which has only Blackrock billion in profits. This is more profitable than global asset management giant 40
Take Slivergate bank as an example again, its SEN The system absorbs large amounts of deposits at zero and low costs, providing a large amount of financial support for its investment in bonds and loans.
For small and medium-sized banks, they have a very big disadvantage in terms of funding sources compared with large banks, such as competition CASA Deposit There are disadvantages of the settlement system in terms of payment, loan pricing disadvantages in competing with large blue-chip customers for deposits, and credit rating disadvantages in the interbank lending market.
Therefore,If a large number of low-cost funding sources can be obtained through the virtual asset industry, it will provide strong support for banks to develop their asset business, and the level of net interest margin will be improved.
4. The introduction of virtual assets will reshape the bank’s product system
The way virtual asset distributed ledgers operate will completely reshape the bank’s product system.
In terms of clearing and settlement, stablecoins based on the Ethereum network do not need to be based on the traditional SWIFT system. The traditional banking system There is a new way to integrate capital flow and information flow in terms of clearing and settlement.
In terms of lending, personal lending based on cryptocurrency mortgages can improve the current personal credit products in the Hong Kong banking market. The personal credit products of Hong Kong banks are mainly personal credit loans and personal housing mortgage loans. It is a personal loan 100% pledged. The process is also cumbersome and complicated, based on DEFI < a i=4> technology or even Web2.0 technology-based cryptocurrency mortgage lending can greatly release the liquidity of personal assets and also bring benefits to banks. Come to new asset classesand sources of income.
Asset tokenization can bring interesting changes to bank payments. Taking time deposits as an example, if they are tokenized, holders can make external payments for part of the time deposits, and the payment comes with accurate interest, making the assets divisible, transferable and infinitely extensible.
In terms of bank customers KYC , if “ soul is introduced The concept of "Bound Token (SBT)" relies on the bank's completed KYC As a result, customers can achieve unified identity authentication within the ecosystem formed by the bank and its partners through SBT .
The most traditional safe deposit box business has also undergone new changes after injecting the concept of virtual assets. For example, banks can provide private key custody services tocustomers.
All of this is because the concept of virtual assets has produced practical needs and far-reaching changes.
Risk and Choice
The banking industry's slow response to virtual assets is certainly due to traditional conservatism under strong bank supervision, but the following risk factors are also the reasons for banks' indecision.
1, combined wind
Virtual assets have higher anonymity than traditional assets. Even for simple remittance business, it is difficult to distinguish the source of the customer's funds. Under the increasingly high pressure of anti-money laundering, , banks are naturally reluctant to take the initiative because of the additional anti-money laundering costs and potential anti-money laundering risks.
In addition to calling on banks to provide account opening services, the Hong Kong Monetary Authority should actively discuss anti-money laundering standards for virtual assets with the industry. Supervisory authorities and the industry should jointly formulate direct, clear, and enforceable anti-money laundering guidelines for virtual assets to facilitate banks’ business operations.
2, science and technology wind
Virtual assets have completely different operating methods, which have put forward new requirements for banks in preventing online fraud, key management, asset custody, etc. At this stage, when bank practitioners generally have not yet formed an understanding of crypto assets, the management of technological risks It is a huge challenge, and it has also caused banks to not easily get involved in virtual assets.
To carry out such business, banks not only need to form a talent reserve within themselves, but also need to form supporting services in the industry, such as technology companies with professional services, systematic asset custody companies, etc.
3, strategy style
The strict ban on virtual assets in China is one of the factors that Hong Kong banks must consider in their actions. Hong Kong banks basically have businesses or branches within the country, and Chinese banks needless to say. Therefore, Hong Kong banks not only need to consider Hong Kong’s local policies, but also need to take into account domestic policy risks.
The Hong Kong government should communicate and report to the central government and clearly convey information to the industry. Hong Kong banks carrying out virtual asset business in Hong Kong must comply with the regulatory framework of the Hong Kong government. It does not violate the relevant policies in China to solve the worries of Hong Kong banks.