© Global Digital Finance 2020

GDF Presentation to CFTC Technology Advisory Committee

Jeff Bandman, Board Member, GDF

February 26 2020
© Global Digital Finance 2020

GDF: Our Mission & Mandate

To promote greater adoption of market standards for the use of global crypto and digital assets, 

through the development of best practices and conduct standards for industry adoption, 

in a shared engagement forum with market participants, policymakers and regulators

GDF Code Of Conduct

GDF has delivered a Code of Conduct to establish 

crypto and digital asset best practice and governance standards, to 

promote higher professional standards in the crypto and digital 

asset industry, to better enable its successful growth and future 

innovation

Global Regulator & Policy Maker Outreach

GDF supports the industry through advocacy, outreach 

and the development of educational materials and 

work streams

GDF 

Mission

GDF 

Mandate

GDF 

Activities

§ Industry expert, community-led working groups who author 

Code of Conduct modules 

§ Industry expert thought leadership and 

promotion of The Code through events, 

blogs and intra-industry working groups

§ Open Memorandum of Understanding engagement with other 

industry-supporting associations and member bodies

§ Bilateral previews with policy makers of GDF work streams -

e.g. new draft code modules, registration, certification 

framework preview

§ Support ad hoc requests from policy makers 

for GDF research, education programs or 

expert sessions

§ Quarterly policy maker update calls and monthly regulatoronly webinar sessions to educate on industry trends and 

other policy developments

§ Oversee a Registration scheme for cryptoassets firms to attest 

their adherence to The Code

GDF 

Vision

Create an industry membership body that drives the acceleration and adoption 

of digital finance technologies to support the next era of digital commerce
© Global Digital Finance 2020

Global 

Regulators

Governments & 

Industry Bodies

Academia Investors

Financial & NonFinancial 

Institutions

Start-ups & High 

Growth Firms

Foundations

Subject 

Matter 

Experts

GDF convenes the entire digital asset ecosystem to set and deliver its proposition

GDF engages with a global ecosystem of influencers
© Global Digital Finance 2020

Context for GDF launch

February 2018 Letter to G20 from Finance Ministers and Central Bank Governors of France and Germany:

The need for a common understanding on the nature of tokens

Monitoring the implications of the increasing exposure of market participants to tokens in terms of financial 

stability and market integrity

Offering better protection to potentially vulnerable investors

Adopting a common approach in Anti Money Laundering and Counter Terrorism Financing. 
© Global Digital Finance 2020

GDF continues to deliver Codes of Conduct whilst delivering advocacy and community value

Deliver GDF Code of Conduct

§ Continue to expand The Code developing 

a principle-based framework for the global 

crypto and digital asset sector through 

member-led working groups and public 

consultations

§ Oversee a Code Attestment Programme 

for crypto and digital assets firms to 

certify their adherence to The Code

§ Build out the Code Attestment 

Programme to include 3rd party 

certification and evaluate on-chain / other 

regtech solutions 

§ Engage the global community through 

quarterly summits, roundtables and 

meetings

Priority 1

Deliver Advocacy & Outreach

§ Deliver global regulator & policy maker 

advocacy through regulator only observer 

channel engagement and responding to 

industry and public consultations

§ Communicate industry thought leadership 

and promotion of The Code through 

speaking at and conducting events with the 

community, including webinars, blogs and 

media placement

§ Build out and support the network of global 

members associations, NGOs and standards 

bodies to promote the harmonisation of 

global policy and the use of global 

standards and codes

Priority 2

Deliver Community Value

§ Ensure membership priorities are reflected in 

the Annual Programme and delivered at pace 

through membership and community survey, 

feedback, and engagement with the Patron 

Board and Advisory Council members

§ Build a core team of professionals and a 

network of partners with strong relationships 

in crypto and digital assets, the financial 

services sector and possessing the highest 

levels of credibility within the global 

community

§ Run a lean and efficient membership 

Executive which collaborates closely with the 

member led and run Advisory Council and 

Patron Board to oversee the development 

and management of The Code and Code 

Modules

Priority 3

GDF Priorities
© Global Digital Finance 2020

Patron 

Board

Advisory

Council

Working

Members

Partners

GDF Membership & Partners

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© Global Digital Finance 2020

Extended GDF Community

200+

Industry Community 

Participants

(community sample)

35+

Global Regulators & 

Policy Makers

Ongoing Outreach
© Global Digital Finance 2020

Driving Community Led Standards

§ Road map for Code Principles are identified 

by GDF Community

§ Working groups are led and driven by 

GDF Community

§ Prior to ratification, Code Principles are:

§ Member-led governance model

§ Member-led oversight of Code Registration compliance

§ Member-led collaborative responses to 

regulator consultations

§ Stocktake may be performed prior to code development.

How we work

§ Peer reviewed in open, global plenary sessions

§ Shared with regulators for bi-lateral review and 

comment

§ Posted for open public consultation

§ Ratified or returned to working group 

for further edits

§ Code of Conduct is written by its own 

industry participants

§ Consensus attained through working group model and review 

process

§ Community able and willing to comply with Code 

due to vested interest and ability to influence

§ Holistic community input through plenary sessions and open 

consultations

§ Code and Registration are self-governed 

by community

§ Network effect of sea change in business operating standardsestablishing best practices

§ We communicate with one clear and consistent industry voice, 

engendering credibility with National and International policy 

makers

Result
© Global Digital Finance 2020

GDF Code of Conduct Pipeline

Ratified

§ Part I: Overarching Principles for Crypto 

Participants

§ Part II: Principles for Token Sales and Token 

Sale Service Providers

§ Part III: Principles for Token Trading Platforms

§ Part IV: Principles for Crypto-asset Funds and 

Fund Managers

§ Part V: Principles for Token Comparison and 

Rating Websites

§ Part VI: Principles for Stablecoins and 

Stablecoin Issuers

§ Part VII: Principles for Security Token Offerings 

& Secondary Market Trading Platforms

§ Part VIII: Principles for Know-Your-Customer 

(KYC) & Anti-Money Laundering (AML)

In Development

§ Part IX: Principles for Custody and 

Custodians

§ Part X: Principles for Market Integrity

§ Part XI: Principles for Tax

§ FATF R16 Steering Committee

§ AML/KYC/CTF Best Practice Guide

§ Digital Asset Market Practices (Survey) for 

Financial Institutions

In Pipeline

§ Part XII: Accounting & Audit Standards

§ Part XIII: Valuation

Call for Input

§ Identity

§ AI / ML and Digital Assets

§ Sustainable Finance and Digital Assets

[ ] 

,..____ __ ____, .....___ _____. .....___ _____. ~0 
© Global Digital Finance 2020

How do GDF Codes relate to law and regulation?

1. Fills gaps - there are many evolving areas

2. This is a global market

3. Can serve as models for law and regulation

4. These do not supersede applicable law.

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© Global Digital Finance 2020

GDF Code Registration

GDF Code Self-Attestation Registration – launched in 2019

What is it?

GDF manages a Code of Conduct Self-Attestation Registration framework for crypto and digital asset firms and companies providing 

products and services within the industry to attest their adherence to the GDF Code of Conduct. Through Registration, our members 

demonstrate their commitment to governance best practices to foster transparency, establish credibility, and promote professional 

standards to enable responsible growth and innovation.

Why is Self-Attestation Registration Important?

Code adherence signals to market participants, and global authorities that the registered organization is committed and operates

within the highest standards of compliance, professionalism, and accountability.

GDF Registry

The Registration framework is a publicly available resource of companies who have self-attested their compliance with the GDF Code 

of Conduct. GDF members who register their self-attestation adherence to the Code are entitled to use the GDF logo on their website 

and in marketing materials.

Over 50% of GDF’s entity members have completed the self attestation since its launch in 2019.
© Global Digital Finance 2020

Extracts from the GDF Code 

Overarching Principles

1. Compliance with Existing Laws

2. Legal and Organisational Requirements

3. Ethics, Conflicts Management and Market Integrity

4. Treatment of Customers and Customer Assets

5. Compliance with the Code

Principles for Token Sales and Token Sale Service Providers

1. Compliance with Existing Laws

2. Content of Whitepapers

3. Token Sale Service Providers involved in the drafting

of Whitepapers and in the Token Distribution process

Principles for Token Trading Platforms

1. Compliance with Existing Laws

2. Legal and Organisational Requirements

3. Token Due Diligence

4. Market, Liquidity and Credit Risk Management

5. Operational Risk Management

6. Settlement

7. Safekeeping

8. Market Access

9. Timeliness

10. Transparency
© Global Digital Finance 2020

Extracts from the GDF Code 

Principles for Cryptoasset Funds and Fund Managers

1. Compliance with Standing Laws

2. Ethics and Conflict of Interest

3. Relationship with External Service Providers and

Counter-parties and Customer Asset Safekeeping

4. Accounting, valuation and NAV calculation

5. CDD, KYC and AML

6. Insider Trading & Market abuse

Principles for Token Comparison and Rating Websites

1. Compliance with Existing Laws

2. Independence and Impartibility

3. Consumer Experience and Engagement

4. Transparency 

5. Accuracy and Data Integrity

Principles for Stablecoin Issuers

1. Compliance with Existing Laws

2. Pricing and Valuation

3. Issuance and Redemption

4. Market Integrity & Liquidity Risk

5. Disclosures; Terms and Conditions

6. Customers

7. Governance 
© Global Digital Finance 2020

Extracts from the GDF Code 

Principles for Security Token Offerings & Secondary Market 

Trading Platforms

1. Token Development and Issuance

2. Exemptions

3. Regulatory Permissions

4. Token Arranging, Marketing, Offering & Selling

5. Secondary Markets & Trading Platforms

6. Market Integrity, Preventing Abuse and

Insider Dealing

7. Financial Crime Preventions and Know-Your-Customer

8. Investor Disclosure

9. Conflicts of Interest

10. Issuer Governance

11. Funds , 12. Secondary Market Considerations

Principles for KYC / AML

1. Definitions and Scope

2. Compliance with Existing Laws

2. Governance

4. Training

5. Risk-based Approach

6. Due Diligence

7. Ongoing Monitoring

8. Suspicious Activity Reporting

9. New Technologies

10. Reliance on Outsourcing

11.Record Keeping
© Global Digital Finance 2020

GDF 

• Today is GDF’s 2 year anniversary.

• GDF is holding its 8th Summit 

• Approximately 200 people are in attendance at 10 global locations.

• The agenda includes the presentation of the final draft of the Custody code before consultation, community calls 

for input on the next working groups we convene, and a GDF Advisory Council update.

GDF 
© Global Digital Finance 2020

Regulators such as CFTC are engaging with GDF as “Observers” and participate in bilateral previews of GDF work streams.

• Quarterly policy maker update calls 

to educate on industry trends and 

other developments

• Transfer knowledge of industry trends 

and sentiment

• Bilateral previews with policy makers 

of GDF work streams and code drafts

• Cross pollinate content across policy 

maker jurisdictions 

• Open invitations to GDF Summits

• Constructive responses to consultations

Influence Sentiment & Inform Trends Increase Engagement outside the G20

• Leverage existing engagement with 

OECD and IMF to expand GDF reach further into more 

non-G20 emerging economies /regions

• Become a ‘centre of excellence’ 

resource for emerging markets

• Support ad hoc requests from policy makers for GDF 

research, education programs or expert sessions

Regulatory Outreach & Advocacy
© Global Digital Finance 2020

Progress and Challenges Ahead

Challenges and priority areas highlighted by the community – 2019 Year-End Global Community Survey: 

Biggest Regulatory Challenges

Inconsistent/unaligned cross-border regulatory guidance

Lack of clarity on regulatory perimeter

Not all market actors are regulated, creating commercial challenges to partner/collaborate

Priority Areas for Codes

Blockchain platform interoperability

Digital identification

Custodial insurance

Audit standards

Potential evolution to third-party certification framework

Biggest Challenges to the Industry

Lack of regulatory clarity/government restrictions

Financial institution infrastructure/readiness

Access to banking facilities (priority for non members)
© Global Digital Finance 2020

Please Stay in Touch with GDF

Sign up for our newsletter and summits at Hello@gdf.io

Web site www.gdf.io

Follow us on twitter @GlobalDigitalFi

Linked In https://www.linkedin.com/company/global-digital-finance/
© Global Digital Finance 2020

Disclaimer

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matters relating to investments (being "investment professionals" within the meaning of Article 19

of the Financial Services and Markets Act 2000 (Financial Promotion) Order 2005 (the "FPO")) [,

][or (ii) persons falling within Article 49(2) ("high net worth companies, unincorporated

associations etc") of the FPO [, (iii) persons falling with Article 48 (“certified high net worth

individuals”) of the FPO, or (iv) persons falling with Article 50 (“certified sophisticated investors”) of

the FPO] (all such persons being "relevant persons"). Any investment or investment activity to

which this presentation relates is available only to relevant persons and will be engaged in only

with relevant persons. This presentation must not be acted or relied upon by persons who are not

relevant persons.

Reliance on this presentation for the purpose of engaging in any investment activity may expose

an investor to a significant risk of losing all of the property invested. Any person who is in doubt

about investing should consult an authorised person specialising in advising on investments of the

kind in question.

Prospective investors should not construe the contents of this presentation as legal, tax or

investment advice. Investors should consult their own competent lawyer, accountant or business

adviser as to legal and related matters concerning any investment. This presentation does not

purport to be comprehensive or contain all the information that a prospective investor may

require. Prospective investors are advised of the need to conduct their own thorough

investigation and legal, tax and accounting due diligence before making an investment.

In particular, but without prejudice to the generality of the foregoing, any forecasts, estimates and

projections contained in this presentation are provided for illustrative purposes only. Such

forecasts, estimates and projections involve known and unknown risks, uncertainties and other

factors which may cause the actual results to be materially different from any future results,

performance or achievements expressed or implied by such forecasts, estimates and projections.

Accordingly, no representation or warranty (express or implied) is or will be made or given in

relation to, and (except in the case of fraud) no responsibility or liability is or will be accepted by

GDF in respect of such forecasts, estimates and projections or their achievement or

reasonableness. Recipients must determine for themselves the reliance (if any) that they should

place on such forecasts, estimates and projections.
© Global Digital Finance 2020

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