去中心化金融：现况与监管发展

Current Landscape and Regulatory DevelopmentsJune 2024 Contents Pages Foreword2Acknowledgements3Executive Summary4Chapter 1DeFi and its ApplicationsIn a rapidly evolving landscape, DeFi is developing its potential as analternative financial system that actualises the ethos of blockchaintechnology.7Chapter 2Risks and VulnerabilitiesDeFi activities highlight a combination of existing and new vulnerabilitiesthat are attracting the attention of financial authorities.17Chapter 3Regulatory Challenges and International Approaches to RegulationAuthorities in various jurisdictions are adopting diverse approaches to guidethe development of DeFi in the spirit of recommendations made byinternational organisations.26Chapter 4Views of Market Participants in Hong KongOur survey revealed Hong Kong’s growing interest and adoption of virtualassets, despite challenges.43Chapter 5Views and Considerations for Fostering a Healthy DeFi EcosystemEffective regulation and deep-dive research can facilitate the developmentof a healthy and vibrant DeFi ecosystem.56 Conclusion Appendix A:Background of the Virtual Assets/DeFi Survey67Appendix B:List of Abbreviations68Appendix C:Glossary of Technical Terms69Appendix D:References71 Foreword readers’ understanding of the virtual asset ecosystemin Hong Kong, this report also presents the findingsof a survey commissioned by the Hong Kong Institutefor Monetary and Financial Research summarising theviews of local financial services practitioners on thecurrent market landscape and potential challenges ofvirtual asset markets. The survey participants includedtraditional financial institutions (such as banks, assetmanagers, and insurers) as major institutionalcustomers and virtual asset service providers as majorinstitutional providers. The report concludes byproposing some considerations for the healthydevelopment of the DeFi market in Hong Kong. Over the past two decades, the pace of technologicaladvancementhas been accelerating at anunprecedented rate, particularly since the emergenceof the third generation of the Internet (Web3)encompassing individual control of personal data andthe use of crypto-assets and blockchain. Theattractiveness of Web3 is that it is decentralised,meaning that an intermediary is not necessary forvirtual transactions between parties. This representsvast potential to transform existing business models,especially in the financial services industry. Playing a prominent role within Web3, DecentralisedFinance (or DeFi henceforth) is the delivery of financialservices without traditional financial intermediaries,offering a potentially faster and more cost-effective,accessible, and secure alternative to conventionalfinancial systems. As the regulatory environmentsurrounding DeFi is still evolving, a robust regulatoryframework is essential, not only managing thepotential risks effectively but also promoting thesustainability of financial innovations. As Hong Kong is progressively fostering a vibrantvirtual assets industry, we hope that this reportprovides market participants and regulators, locallyand internationally, with an informed perspective onregulatory developments that support DeFi innovationwhile managing the emerging risks with consumerprotection measures in place to promote the growthof the virtual asset ecosystem. Against this backdrop, this report provides theinvestigation of the DeFi’s existing landscape, coveringopportunities, risks and a comprehensive discussionof the international regulatory experience, aiming todraw attention to regulatory developments andhighlight potential areas for collaborations betweenmarket participants and regulators that may beimportant to Hong Kong’s developments. To enrich Mr Enoch Fung Chief Executive OfficerHong Kong Academy of Finance Executive DirectorHong Kong Institute for Monetary and Financial Rsearch Acknowledgements This report has greatly benefitted from the contributionsof various external collaborators. We thank theFinancial Services and the Treasury Bureau, theInsurance Authority, the Mandatory Provident FundSchemes Authority, the Securities and FuturesCommission, and various divisions of the Hong KongMonetary Authority, including the CommunicationsDivision, the Digital Finance Division, the ExternalDivision, the Fintech Facilitation Office, the BankingSupervision (Supervisory Technology) Division, and theMarket Development Division for their comments andsuggestions. We wish to extend our gratitude to DrPhilip Turner of the University of Basel for his inputs toChapters 2, 3.1, and 5.2. We are also grateful for thecollaboration of PricewaterhouseCoopers Limited indesigning and administering the survey entitled‘Current Landscape and Developments of VirtualAssets/DeFi in Hong Kong’s Financial Services Industry’from May to July 2023, and in conducting interviewswith various market participants, including banks,insurers, asset managers, and virtual asset serviceproviders. Finally, we thank the HKIMR Council of