Enhancing Trust 

and the Integrity of 

Crypto-Asset Markets

VCA Virtual Commodity Association 
Overview 

of Remarks

The Need for a Thoughtful 

Regulatory Framework

Background of Founding Members

The Origins and Mission of the VCA

The Benefits of Self-Regulatory 

Organizations and Global Case Studies

The Road to SRO Designation in 

Crypto-Asset Markets
When regulation is done right it can pave the way to healthy and 

sustainable markets.

Regulation is the pathway to building trust and broader market 

adoption.

Industry has an important role to play in helping to build safe, fair, 

and efficient markets.

Thoughtful Regulation in Cryptocurrency is a 

Win-Win for the Market and Regulators
Gemini is a regulated, New York Trust 

licensed, cryptocurrency exchange and 

custodian.

First crypto exchange and custodian to 

obtain a SOC 2 Type 2 report providing the 

highest level of transparency into security, 

confidentiality and availability. 

First crypto exchange and custodian to 

obtain meaningful amount of insurance

and launch a captive insurance company.

Background of Founding Members 

bitFlyer is a globally regulated 

cryptocurrency exchange with operations 

in Japan, USA, and EU.

One of the first recipients of the New York 

Bitlicense.

Founding member of the world’s first 

officially designated crypto SRO, the Japan 

Virtual Currency Exchange Association 

(JVCEA).

@ GEMINI ••• b. Fl 1• 1t yer 
Established to become a designated self-regulatory organization (SRO).

Multi-phased journey that begins with basic organizational capacity-building.

Responsive to concerns from regulators and government officials. 

Important to promote market integrity, build trust, and enhance 

investor protection.

Learn from experience of well-respected SROs such as FINRA and NFA.

The VCA
Convening subject matter experts to drive organizational capacity-building, 

including through six committees:

Examination/

Enforcement

BSA/AML Custody and 

Security Insurance

Tax Market Integrity

The Organization - Members and Advisors

SULLIVAN TO PSI D E CR O UP 

~ N :VIGANT • !I• bitFlyer @ GEMINI & • EXIGER CROMWELL ' A Guidehouse Company 

SEWARD& MAYER EVERSHEDS PeRKINSCOie All ALVAREZ & MARSAL 

, lf ~f2M~1:!;;'fI KISSELLLP BROWN SUTHERLAND 
Global Case Studies

JVCEA -Japan Virtual Currency Exchange Association 

X 

Financial r ices gency 
A Virtual Commodity 

SRO in the United States

Government Industry

I want the United States to lead 

because whoever leads in this 

technology is going to end up 

writing the rules of the game.

—Chairman and Chief Executive, CFTC, Heath P. Tarbert

“

”
Industry Capacity Building

The IOSCO SRO Consultative Committee[1] identified the following elements 

that might be considered in a model template for an effective SRO:

Internal rulemaking procedures

Authorization and access to a marketplace, 

including fitness/qualification standards for 

market intermediaries

Establishment and enforcement of financial, 

operational and sales practice standards

Surveillance of market activity

[1] IOSCO SRO Consultative Committee Report on “Model for Effective Regulation” published May 2000, available at https://www.iosco.org/library/pubdocs/pdf/IOSCOPD110.pdf

Investigation, prosecution and adjudication of 

rule violations

Administration of a dispute resolution forum

Development and implementation of education 

programs for market participants and public 

investors

Sharing information and cooperating with other 

SROs and statutory regulators 
NFA Case Study

Enhancing Derivatives Markets

The creation of NFA was a historic 

event—one that gave the futures 

industry the regulatory framework 

on which its markets could 

continue to grow and succeed . . . 

—NFA History, https://www.nfa.futures.org/about/nfa-history.html

“

”

• 
Industry Bridge Building -

Thought Leaders and Associations

CHAMBER OF 

- •

, DIGITAL 

l •• c • MMERCE 

.. ,-,., ·------ ~ ---

ADAM 

Association for Digital Asset Markets 

Cl BLOCKCHAIN 

c=J ASSOCIATION 

@)) COIN CENTER 

CRCCrypto 

Rating 

Council 

GLOBAL 

DIGITAL 

FINANCE 
VCA Committee - Examination/Enforcement

Collaborate with other crypto industry associations

Adoption period of rules for VCA exchange members

Examinations of VCA exchange members

Leverage and localize best practices and standards to inform rule-making

! 

~ 

•. j ........ .,,,,. > 

··-.. ::: .. -==· 

@j 
 VCA Committee - Market Integrity

Information sharing agreement between member crypto exchanges 

Multi-purposed data file format for input into a cross-market surveillance 

platform and consolidated audit trail

Implementation of a centralized cross-market surveillance platform

Centralized cross-market alerts and investigations 
Role of Government

Catalyze industry action

Explore avenues to designate an SRO in the virtual commodity space

Designate an SRO with oversight and enforcement authority
Thank You VCA Virtual Commodity Association