Beneficial Ownership title

The Land Registry privatisation public consultation notes that 13% of land and property title is not registered and that could undermine lowest cost identity verification due diligence, credit scores and increase non-compliance rates to maintain the People with Significant Control register.

The Land Registry privatisation debate could progress open data and risk management with total registration and purchase options and — I am not familiar with the dataset — perhaps price first advertised by each agent, unique landlord reference and compulsory purchase reference.

Anyway, one response to the public consultation, prompted by the Open Data Camp in Bristol:

openmindedly-response

 

 

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Interim Unilateral Beneficial Ownership Option

Could an interim unilateral beneficial ownership option accelerate #anticorruption summit aspirations?

The beneficial ownership debate is about lobbying and policy statements and legislation and registers and incorporation systems.  By the end of the year, jurisdictions could have a public register or a private register or no progress on a register.

On 4th April 2016 OpenCorporates announced a Global Beneficial Ownership Register project with more context in a blog post from the Open Contracting Partnership and the ONE campaign policy director.

I have already established a proof of concept on declaration of beneficial ownership on a public register, it required an internal legal opinion from Her Majesty’s Attorney General chambers because deeds on a public register were assumed to be between two parties and that a declaration of beneficial ownership by definition only included one party:

https://openmindedly.wordpress.com/2014/10/05/country-growth-hacking/

Of course, ideally, the Isle of Man Deeds Registry would be online with public blockchain technology.

Does anyone actually have a register classification scheme to reference?  GOBR will support self-reporting to bypass any delays in specific jurisdictions or specific corporate entities (business names, charities, foundations, trusts) but a draft scheme would be helpful to prompt discussions.  For example:

Level	Classification	Notes
0	unregulated agents	nothing on client file
1	regulated agents	legal requirement to hold beneficial ownership details
11	Private 1 star	reference to centralised corporate register to contact declared officers or the regulated agent
12	Private 2 stars	reference to centralised corporate register to contact officers or the regulated agent legal power to require beneficial ownership declaration by officers or disclosure by the regulated agent (without tipping off clients)
13	Private 3 stars	centralised beneficial ownership register with meta data to decentralised beneficial ownership data (similar to IATIregistry.org) legal requirement to update contemporaneously
14	Private 4 stars	centralised beneficial ownership register
15	Private 5 stars	centralised beneficial ownership register a Service Level Agreement (for example, 24 hours) or perhaps cross-border law enforcement  logins with specific user audit trail and unique case references
15	Private 5 stars	centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to IATIregistry.org)
16	Private 6 stars	decentralised beneficial ownership register
17	Private 7 stars	decentralised consolidated corporate register with beneficial ownership data (i.e. government only private blockchain to support tax information exchange agreements)
21	Public 1 star	centralised corporate register with optional beneficial ownership declaration (i.e. self-reporting)
22	Public 2 star	centralised beneficial ownership register
23	Public 3 star	centralised beneficial ownership register aggregated analytics on public interest trends
24	Public 4 star	centralised beneficial ownership register open data API to support projects such as GBOR
24	Public 4 star	centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to IATIregistry.org)
25	Public 5 stars	centralised beneficial ownership register open data API to support projects such as GBOR legal requirement to update contemporaneously
25	Public 5 stars	centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to IATIregistry.org) legal requirement to update contemporaneously with randomised regulator audits
26	Public 6 stars	decentralised consolidated corporate register with beneficial ownership data i.e. public blockchain operated by governments, the media, stock exchanges, universities, charities, etc.
27	Public 7 stars	decentralised consolidated corporate register with beneficial ownership data i.e. public blockchain operated by governments, the media, stock exchanges, universities, charities, etc. legal requirement to update contemporaneously

I have relentlessly encouraged the Isle of Man to progress in the annual Open Knowledge open government league table from top 100 (rebased) to top 40 to top 20 and hopefully top 10 in Q3 2016.

On 6th May 2016 the Isle of Man Government announced new functionality with an online incorporation and demonstrates that new functionality is an option.  An important factor though is that smaller governments typically outsource the incorporation system and therefore any new functionality requires a prioritised business case in an increasingly complex (i.e. slower) cross-government procurement process or approval of an unplanned external cost (i.e. higher) prompted by global macro factors as either an upgrade by the existing supplier at backloaded commercial rates or a securitisation option that would increase fees that may not then be internationally competitive.

What do I mean by an interim unilateral system?

Something that would address reasonable concerns on competitor jurisdictions.

Consider a legal requirement that a specific beneficial owner must:

• adopt a unique anonymised beneficial owner reference (similar to the global legal entity identifier) in a specific jurisdiction
• consistently apply that unique beneficial owner reference to any corporate activity in a specific jurisdiction
• declare that a unique beneficial owner reference has been applied on key documents such as incorporations, annual returns, share allotments and share transfers.

The largest impact is likely to be when agents discover they do not actually have an “exclusive” relationship with a beneficial owner (i.e. they lied) and technically they are not eligible for discounted management fees on corporate structures.

Unilateral actions could prompt a multilateral network effect.

Feedback welcome.

Funding offers welcome too!

 

 

Anti-Corruption Summit in London

11th May 2016:  updated to include nominal cost draft UK #anticorruption guarantee scheme forwarded to Open Knowledge session lead Mor Rubenstein and highlighted via Twitter (I guess the next blog post should be insights on the real world path to beneficial ownership public registers):

a draft UK #anticorruption guarantee scheme

Governments typically take a long time to progress anything meaningful and individuals rarely have the self-funding to sustain significant efforts year on year and civil society funding mechanisms are largely undeveloped or very conservative in the sub-national jurisdictions likely to be discussed the most.

Undoubtedly, some non-standard open government experts and open data hacktivists could add a lot to the pubic and private discussions at the Anti-Corruption Summit in London next week.  Unfortunately, they are the ones least able to add a lot to an offshore bank account or a credit card lol:

I have helped push an offshore jurisdiction in the Open Knowledge open government league table from top 100 (rebased) to top 40 to top 20 and potentially to top 10 in Q3 2016 but nonetheless I very reluctantly had to ask several times not to be nominated in the recent Open Government Partnership International Expert Panel round precisely because of the unsustainable commitments requested of anyone in the open data community determined to self-fund via debt if required rather than risk independence given the requirements to travel potentially to the other side of the world, the implied requirements stop paid work to progress unpaid work, etc.

Fix the open data funding mechanisms and fix everything faster.

In the meantime, I have milestones and deep insights on bitcoin and blockchain and the Isle of Man gambling regulator is expected to legalise bitcoin transactions in July 2016 so I would welcome an open data CSR fellowship, an advisory board role or project specific consultancy!

 

Incorporations in Google Maps

Google Maps front end to OpenCorporates

http://incorporations.openmindedly.com

The open data community often talks about how open government programmes let volunteer developers and civil society funded projects help end users such as citizens, taxpayers and voters but the largest end users of open data are typically governments, financial services companies, international charities and even gambling companies.

Chris Taggart was a speaker at a British Computer Society Isle of Man open data unconference in early 2011.

I originally configured a map in late 2011 to help less digital end users at the Isle of Man Government in Income Tax, economic development, foreign aid and regulators leverage other government open data as an opportunity to demonstrate value and to build momentum on an open government programme.  It helped visualise incorporations to non-technical end users and helped end users without English to access the data:

Corporate Register: Isle of Man

With previous expertise as a legal compliance officer in an offshore companies registry and as a group IT manager in global wealth managers and, prompted by email threads with Chris Taggart, James McKinney and others, I realised that Incorporations League Tables could visualise expertise by SIC code and year on year market share trends but it also surfaced issues such as free text registered office addresses, free text officer names, aged shelf companies, excessive directorships and client dumping in SAR frameworks:

Incorporations League Table: Isle of Man

I recently noted 31 extra jurisdictions since early 2015 and updated the map:

• Australia
• Bahamas
• Belgium
• Canada: New Brunswick
• Canada: Newfoundland and Labrador
• Cyprus
• Hong Kong
• Latvia
• Myanmar
• Tajikistan
• Uganda
• USA: Alabama
• USA: Arkansas
• USA: Colorado
• USA: Delaware
• USA: Hawaii
• USA: Indiana
• USA: Kansas
• USA: Kentucky
• USA: Minnesota
• USA: Nebraska
• USA: Nevada
• USA: New Hampshire
• USA: New York
• USA: North Carolina
• USA: North Dakota
• USA: South Carolina
• USA: Utah
• USA: Virginia
• USA: Wisconsin
• Viet Nam

Is there a prioritised list of extra jurisdictions and is it reshaped by events such as #PanamaPapers or just limited by volunteer efforts?

 

Style of Open Government

A response to an #opendata movement exchange between Tom Steinberg (founder MySociety UK) and John Wonderlich (director Sunlight Foundation USA) about the importance of outrage from someone that struggles to push and to collaborate on open government at the same time in parliament, in government and in large corporates:

http://civichall.org/civicist/over-politeness-is-the-fatal-flaw-in-the-open-data-movement/

http://sunlightfoundation.com/blog/2016/04/27/the-false-choice-between-criticism-and-collaboration/

https://medium.com/@TomSteinberg/a-response-to-the-false-choice-between-criticism-and-collaboration-by-john-wonderlich-360abcdada54

https://medium.com/@JohnWonderlich/there-should-certainly-be-more-adversarial-advocacy-daf648928a68

 

It has taken 10+ years effort to earn the trust to successfully identify and cajole the *right* career civil servants and the *right* politicians to go to an open data bootcamp.

The efforts are certainly built on outrage.

I believe I am the only person in the Isle of Man to go to court over the code of practice on access to information with the Companies Registry and one of the reasons I ended up helping Chris Taggart at opencorporates to webscrape Liechtenstein, Gibraltar, Cyprus, etc.  In a small and, more importantly, offshore jurisdiction that is usually very career defining (a.k.a. limited to the private sector).  That is outrage.

I have allocated 80% annual leave for years and “volunteer” for anything that earns time in lieu (no paid overtime anyway) to attend TransparencyCamp in Washington DC for the masterclasses or RISE in Hong Kong to help push harder on #blockchain.  I have explored how to help get cash directly into the hands of beneficiaries with the bitcoin XBT currency code in the global aid flow database and then just did it because no-one else would in my timescale.  That is outrage.

I have been on that cold train station platform late on a Sunday at the end of an exciting but draining unconference when a career civil servant  says they are looking forward to the next 2 days time in lieu to recover and you have to go to the day job.  That is outrage.

Yes, the funding mechanisms are broken and the Open Contracting Data Standard will probably not help fast enough to help the early stage open data generation.  I have made some difficult decisions already in 2016.  I have had 2 direct debits bounce and my credit reference is impacted.  That is outrage.

I was at the Open Knowledge bootcamps in London, Warsaw, Helsinki, Geneva and Berlin but increasingly only the handfuls that ended up with some government funding were still able to afford or to justify self-funding from other consultancy.  Tech startups know or eventually learn that fundraising is increasingly a full-time role and only successful if you have a CTO co-founder to help the fundraising.  The rightest and brightest ideas needlessly slip through the fingers of society every month and I am powerless to stop it.  That is outrage.

Just last night, I hosted a parliament session with a small group of 16+ year olds in care to debate a motion for the government to substantially fund driving lessons as they do not have parents to subsidise or to practice driving at weekends.  A quiet girl had exhaustively researched driving lesson costs (average GBP 28 per hour) and average lessons (47) and costs.  A young mother with a baby had powerful points and the director of childrens services agreed in principle to amend the department policy.  I was humbled.  I recognise channelled outrage.

I have made the right decision.  Collaboration and hacktivist.  Open data, when do we want it, now! ;O)

 

bitcoin milestones: XBT

XBT

I’ve blogged before about the pipeline of pending bitcoin milestones and country growth hacking so I should highlight progress on XBT as a currency code.

I attended the open data summit in Ottawa in May 2015 and prompted by some hardcore Q&A I decided to unblock the stalemate on BTC as a currency code.

I discovered that the United Nations and World Bank supported global aid flow database already includes a mechanism to include politically sensitive currency codes.  X is used as a prefix to the established currency code BTC and truncated to 3 characters, i.e. XBT.

A draft strategy emerged in the corridors at a fringe unconference on Saturday and fermented at a micro brewery in Gatineau (Quebec) on Saturday night:

• shortlist charities already accepting bitcoin donations
• register a wallet with a bitcoin operator based in the same country as the charity
• process a cross-border bitcoin transaction
• handcode the bitcoin transaction as cross-border aid flow in an XML aid flow transaction file to include XBT as the currency code
• leverage an Isle of Man login to the global aid flow database to upload the cross border aid flow transaction file — ok, the system was developed to process millions of dollars/pounds/swiss francs/etc but millibits sounds like millions
• request that the IATI technical support team add an XBT currency code to the official code list to stop validation errors in thousands of aid flow management systems and apps linked to the IATI API

With due diligence on shortlisted charities and previous bitcoin transactions via Blockchain Luxembourg, firstly I selected a German charity Amani Kinderdorf with projects in Africa to support AIDS orphans and secondly I selected a German bitcoin wallet operator cubits based on personal recommendations.

Disclosure: I subsequently accepted an advisory board member role for 3 months to research bitcoin mass adoption.

On 5th June 2015 I uploaded the transaction file.

On 11th September 2015 IATI started a private consultation on XBT as a currency code within the IATI Technical Advisory Group.

Disclosure: I am a member of the IATI TAG.

On 1st October 2015 it was confirmed that XBT had been added as a currency code to the IATI global aid flow database system emdorsed and supported by the United Nations, the World Bank, etc.

So what?

I have accumulated extensive relevant expertise via 2 years on the Bank of England currency tracking system, the Open Bank Project (the first batch at Level39), a 1 year open banking placement at the Treasury in the Isle of Man Government and bitcoin milestones, so I have had some interesting discussions on possibilities with potential partners in Dublin, Zurich, Luxembourg, New York, Melbourne, etc.

Obviously I have followed the Barclays project with Safello and they are expected to support bitcoin charity donations in Q4 2015 or Q1 2016.

Disclosure: I applied to the Barclays Techstars fintech accelerator.

I had previously discussed a large opportunity in wealth management with Cayman National Bank and, prompted by the announcement of the HM Treasury Open Banking Working Group chaired by Barclays and the Open Data Institute, more recently with Barclays Isle of Man.  Cayman National Bank didn’t have the right existing client profile but I think Barclays will need to do the London thing before it has enough internal momentum to progress something more ambitious offshore.

I defined and requested that Jersey, Guernsey and Gibraltar corporate register and charity regulator reference codes should be added to the global aid flow database system.  Jersey and Guernsey have been added but Gibraltar does not presently meet all the technical requirements.

On 10th November 2015, I flagged a hidden issue at an excellent Wragge Lawrence Graham fintech event with a great keynote by Bob Ferguson from the FCA and “ask me anything” fintech VC panel — actually lots of fintech milestones are self-funded so a mechanism to fund or to refund hacktivist research could accelerate progress in any jurisdiction.

The regulatory sandbox at the UK FCA with a government umbrella company and representative appointment risk management mechanism is real world help to support fintech startups and to let large operators dip their toes in the water and even fail small.

On 1st June 2015, in the UK, the International Development (Official Development Assistance Target) Act 2015 means that 0.7% of spending will be allocated to aid flow each year so transparency on budgets such as £11.4 billion in 2014 are increasingly important.

A little reported response to the Paris attacks was to increase aid flow to fragile states from 30% to at least 50% — the jurisdictions at highest risk of diversion.  So the need to maximise financial reporting at lowest cost, the need to visualise soft power dynamics and ultimately the need to demonstrate sustainable social impact will support a shift to blockchain technology, daily micropayments direct beneficiaries and perhaps even a BIP to automatically allocate some bitcoin ecosystem processing to the nearest direct beneficiary mobile phone as an income stream.

At the RISE conference in Hong Kong I arranged to follow up on key points with Bobby Lee.  Downstairs at the Facebook developers bootcamp I noted that Facebook had hired talent from Ripple etc and that, for example, mainstream bitcoin apps would be ok.

On 18th November 2015, Facebook launched the non-profit donations option but I would expect the most progressive social impact via the internet.org initiative.

Next week, I will progress a bitcoin milestone in London that should indirectly progress Banknotey, a platform to finally extend ebusiness to cash customers so they can have a better life too.

Best regards,

Graeme Jones

bitcoin policy advisor (Isle of Man)

open government hacktivist (global)

co-founder, Banknotey Technology Limited (UK)

http://www.linkedin.com/in/jonesIOM

 

Nepal, interim data and IATI engagement

IATI ENGAGEMENT

Prompted by the news coverage of Nepal, the IATI TAG unconference in Ottawa next week and an open data superhero like Bibhusan Bista, I thought I would look at the world class UK Government open data and the level of IATI engagement.

I assumed that IATI would become the natural hub to share real time open data and to help map official requests and responses to an unfolding crisis such as the Nepal earthquake.

Matched donations are a very successful policy but most donors still like to click through to see the matched donations, data visualisations on allocation efficiency and inspirational images and video clips to see the positive impact of donations.

So interim data should be an IATI focus.

NEPAL PRESS RELEASE

I read the latest news on the UK Government Department for International Development dated 20 May 2015:

https://www.gov.uk/government/news/nepal-earthquake-uk-aid-response

Nepal earthquake: UK aid response

The UK’s humanitarian response now stands at more than £33 million and includes:

£10 million to rebuild vital health services in the worst affected districts;

£5.3 million for UN agencies in Nepal to coordinate the international relief effort and provide clean water and shelter for affected families;

£3 million released under the Rapid Response Facility (RRF) to six charities and NGOs already working on the ground: Save the Children, Mercy Corps Scotland, Care International UK, ActionAid, Oxfam and Handicap International;

£2 million for the British Red Cross;

£5 million to match public donations to the Disasters Emergency Committee’s appeal, which will support NGOs on the ground;

a £5 million package to provide a further team of 30 trauma medics, logistical support and equipment to ease congestion at Kathmandu Airport and humanitarian experts in water, health and sanitation. DFID also deployed a team of more than 60 UK International Search and Rescue (UKISAR) responders and specialist rescue dogs;

£2.5 million for the UN Humanitarian Air Service to enable organisations already on the ground to deliver aid to isolated areas; and

more than £300,000 for Mission Aviation Fellowship (MAF) to provide two Airbus 350 helicopters to get help to more remote regions

I noted that the updated infographic by Ricci Coughlan/DFID has had 4880 views.

I looked at the UK Government DfID publisher page on the IATI website — 127 files but strangely only 1 follower for a leading national publisher:

http://iatiregistry.org/publisher/dfid

I looked at the specific file on Nepal but strangely 0 followers:

http://iatiregistry.org/dataset/dfid-np

DFID Activity File Nepal

I downloaded the dataset (all transactions in CSV format):

http://tools.aidinfolabs.org/csv/direct_from_registry/?xml=http%3A//iati.dfid.gov.uk/iati_files/Country/DFID-Nepal-NP.xml

I reviewed the 2560 rows, focused on column Q (transaction-value_value-date) and sorted the dataset into ascending date order.  I filtered the dataset to rows dated 2015.  The dataset includes 1 commitment in 2015 Q1, 1 commitment in 2015 Q3 and the 2015 Q1 transactions.

I then sorted the dataset on column V (receiver-org).  The dataset includes 3 rows with aggregated small transactions in 2014 Q4 (deleted), 2 rows with commitments (deleted), 1 row with negative expenditure such as an overpayment (deleted), 12 rows marked “correction” with a transaction and reverse transaction (deleted) and 37 rows perhaps unexpectedly marked “supplier name withheld” in a transparency database (retained).

total transactions value = GBP 8,609,560

BENCHMARKED DATA

I downloaded the Open Nepal dataset on commitments and aid flow and filtered UK transactions:

http://earthquake.opennepal.net/aid-type/2

http://earthquake.opennepal.net/aid-csv-file

total transactions value = GBP 32,862,438

19x rows

I then downloaded and filtered the source dataset at the UN OCHA FTS (Financial Tracking Service) on the Nepal appeal site:

http://fts.unocha.org/pageloader.aspx?page=emerg-emergencyDetails&appealID=1100

total transaction value = GBP 33,897,941

19x rows but with an extra GBP 295,858 to UN Agencies (GBP 739,645) and an extra GBP 739,645 to UNICEF National Committee/UK (GBP 2,218,935)

However, the IATI dataset is significantly lower due to quarter end reporting.

total transactions value = GBP 8,609,560

AID MATCH

Our hugely successful Aid Match scheme has helped boost the British public’s own generous donations to different charity campaigns.

A good enough reason to upload interim data is so that private donors can click through to matched government donations and any third party data visualisations, infographics, etc.

NEXT STEPS

So could interim data increase IATI engagement?  Could twitter change the world??

#UKaid #Nepal

IATI TAG

http://www.aidtransparency.net/technicaladvisorygroup/tag-governance

obviously Chair John Adams

@johnthegeo

DfID

https://www.gov.uk/government/organisations/department-for-international-development

@dfid_uk

https://www.gov.uk/government/news/dfid-welcomes-new-ministerial-team

DFID welcomes new ministerial team

re-appointment as Minister of State for International Development, Desmond Swayne

@DesmondSwayne

appointment as Minister of State for International Development, Grant Shapps

@GrantShapps

re-appointment as Secretary of State for International Development, Justine Greening

@JustineGreening

appointment as Parliamentary Under Secretary of State Baroness Verma

@Baroness_Verma (only 1 tweet though)

first bitcoin payment into a national government bank account

I received a bill from the NHS dentist but it didn’t have routing details for online banking.  I contacted the NHS dentist reception and they explained that they do not offer the option to pay online.  Mmmm.  Next I contacted the department accounts team and they did not have any routing details but they referred me to the centralised payments section.  I confirmed sub bank account routing details and agreed to forward an email confirmation with a payment reference.  The reason online payments are not encouraged is that they are processed and reconciled manually.  So, the inbound payment from “Cryptopay Limited” was not reversed, lol, and I added a bitcoin milestone to the list:

https://docs.google.com/file/d/0B0fsFbbm75EFeGtGS0R0Y1E4dmM/edit

I have more milestones in the pipeline, of course! ;O)

The minimum days and focus on meaningful Continued Professional Development in the UK Civil Service increases on 01/04/2015 so the next step in the UK national government could be to register and control bitcoin addresses (or another perhaps less contentious crypto currency such as Dogecoin) for one or more exemplar services to build up expertise in crypto currency and underlying technology such as blockchain.

The Isle of Man is well established as a proof of concept accelerator and the UK is a leading financial services centre so ideally leverage the strengths of both jurisdictions with a faster parliament and a bigger regulator so that British companies are world class.  The crypto community is a joined up growth policy, lol.

Graeme Jones

founder

openmindedly

open data | open government | open banking

egovernment, fee transparency, bitcoin and the free 1% public sector pay rise

When is egovernment not egovernment?

When the front office does not include BACS online payment routing details on invoices, the back office is not able to support manual requests to confirm routing details and the internal financial system does not have the fractional cost online payments option installed?

A look at Lloyds Bank transaction fees gives us some numbers as a starting point:

cash = 60p per £100 excludes 70p per paying in slip

cash exchange = £1.65 per £100

cheque or postal order = 31p

incoming BACS credit = 15p

So, “openmindedly” with numbers that do not reflect any volume discount etc, in the 2014/15 financial year, with cash transactions averaged out at £20 and card transactions averaged out at £50, if a government processed incoming retail transactions without online banking payments (excludes bank account and hardware monthly fees and excludes fraud):

£10m in cash transactions @ £60,000

£0.5m in cash exchange for floats etc @ £8,250

£30m in cheques @ £186,000

£45m in debit card payments (15p) @ £135,000

£15m in credit card payments with 2% fee (£1) @ £300,000

£0m in online banking BACS payments @ £0

However, benchmarked with fintech platforms such as BACS online banking payments, digital currency and banknotey (TM):

£9.5m in cash transactions @ £54,000

£0.5m in banknotey (TM) cash transactions @ £6,000 – £1,250 signup/revshare commission

£0.25m in cash exchange for floats etc @ £4,125

£10m in cheques or postal orders @ £62,000

£45m in debit card payments (15p) @ £135,000

£10m in credit card payments with 2% fee (£1) @ £200,000

£1m in bitcoin with 1% fee (50p) @ £10,000

£24m in online banking BACS payments at 15p fee @ £72,000

Ok, that equates to £689,250 with older ratios and £541,875 with newer ratios or nearly -22% in cost savings.  An interesting headline number in an era of government budget reviews and pressures to rebalance whole economies.

The card companies have not supported any shift to a surcharge process historically because the inevitable customer conclusion is that cash would be a “free” payment method.

If a government amended policy on not absorbing higher cost credit card transaction fees (American Express is not accepted by the Isle of Man Government) but allowing the customer to choose a preferred surcharge on every payment method such as cash, cheque, debit card, credit card, charge card, prepaid card and even points, miles, bitcoin, ripple and banknotey it could contribute the equivalent of a 1% pay rise, offset the living wage and allow credit cards from credit unions as a more flexible payment method on what are typically quality of life public sector services rather than cash from payday lenders or loan sharks.

If a government then progressed legislation to itemise transaction fees outside the public sector at the offline and online point of sale, customers, SMEs and the economy would immediately benefit from more awareness of transaction process costs, more consistent and more competitive commercial rates and open up the opportunities on real time risk based transaction fees.

As someone that reported a fraudulent card transaction to purchase a flight into the UK from online banking in time to catch the criminal at the departure or arrival gate, it is a reasonable assumption that fintech could significantly decrease financial crime with transparent fees, a shift to joined up real time policing of each and every fraudulent transaction and an end to passing a large percentage of the avoidable costs of financial crime to customers.

Graeme Jones

policy advisor, Isle of Man Parliament

project lead, openmindedly @ Isle of Man Government

founder, banknotey

etc

Crypto Businesses Public Register

The Isle of Man does not have a central bank and that is well received by bitcoin believers, of course!

On 10 June 2014, the Isle of Man financial services regulator explained that the policy was to support legitimate businesses within the emerging crypto sector to operate in the jurisdiction without regulation, to support best practice and that a public register would be introduced in new legislation.

On 18 July 2014, the Isle of Man financial services regulator announced guidance notes.

The Crypto Valley Summit prompted extensive discussions and — perhaps not widely enough — I recommended a voluntary public register without a fee pending the compulsory public register with a fee in the new legislation.

The new legislation (explanatory notes) is expected in H1 2015 but will not regulate crypto businesses.  As at 15 December 2014 it has passed the first and second reading in the lower chamber so still requires a third reading in the lower chamber, first, second and third readings in the upper chamber and also (UK) Royal Assent in the joint chamber so it is on the right timescale.

The UK is often cited as the most important onshore jurisdiction to crypto businesses.  I discussed with peer contacts and noted that even the world class UK Government Digital Service has limited public API functionality.

Most regulators and governments struggle to minimise consequential costs but increasingly real time risk management of any business on a public register is a core requirement.

I reviewed the existing Isle of Man public register of regulated banking licence holders and decided to configure a no/low cost public API with import.io as a proof of concept that even an unregulated crypto business would want to be on a voluntary public register that could be monitored with innovative automated services such as alerts (public register ping, highlight a shift to a different jurisdiction) to investors, digital wallet holders, digital currency exchanges, insurance companies, media companies, other regulators and cross-border law enforcement such as Europol and Interpol.

So, what could you do in 2 hours?

• host a group coffee with some local peer contacts to shortlist crypto businesses already active in the local tech community and the inevitable 1 or 2 handfuls of stealth mode tech startups that may or may not want to be included yet (20 minutes)
• draft a voluntary public register and any amendments (30 minutes)
• circulate to highlight any gaps (10 minutes)
• upload the summary, content and link to a holding page on the regulator website (30 minutes)
• draft tweet (10 minutes)
• apologise for making it look easy with import.io (20 minutes)

Best regards,

Graeme Jones

project lead, openmindedly

founder, banknotey

etc.