For example, a card-based payment ecosystem can process around 65,000 transactions per second, while blockchains such as the one underpinning bitcoin do not usually support more than seven in their most basic configuration.27 Finally, their decentralised governance together with the realization of potential cyber threats could give rise to instances of fraud that end up compromising agents’ confidence both in digital assets and in other areas of the ecosystem. The consequences of such a scenario would be compounded owing to the lack of safeguards protecting customers’ interests and property rights. Given its potential scope, this scenario could become a serious problem. For example, a recent Chainalysis study shows that up to $ billion was stolen from digital wallets and platforms during the first quarter of 2022. Nearly three-quarters of said amount pertain to DeFi activity, a rise of 72% compared with the previous year.28 Bearing in mind there are an estimated 200-300 million crypto-asset users across the world, it is fair to call this a nonnegligible impact.29  The regulatory response In view of the extent of the challenges I have outlined, a number of regulatory initiatives are taking shape. It combines public warnings on the risks of buying and/or holding virtual currencies, and both national and international regulatory initiatives that are of the most importance, given the global nature of crypto-assets. Regarding the international initiatives, what started out with the regular monitoring of such initiatives became, in 2020 and at the behest of the G20, a multilateral regulatory response from the FSB30.

1  According to the results of the Funcas survey of 7 April 2022 on the use of banking services, access to digital banking services and financial and digital education. 2  https://g20.org/documents/  1  However, the commonalities end there. With over 16,000 existing tokens3 (around ten new crypto-assets are estimated to be launched every day on average) the digital asset space exhibits sheer amplitude and a gigantic functional and operational disparity. When analysing crypto-assets, one practical approach is to classify them in accordance with what apparently is their declared main purpose. As a result, broadly speaking, three different groups may be distinguished. The first one comprises those assets whose primary objective is to serve as a medium of payment or exchange. These are loosely labelled as “virtual currencies”, and they frequently fall outside the prevailing regulatory framework, except where specifically referenced in new or existing provisions, such as the case of Germany or France.4 The second group covers instruments designed to help raise capital from investors. Specific procedures are organised to this end, known as Initial Coin Offerings.5 Investors receive tokens substantiating their legal claim to participate in any potential increase in the future value of, or returns on, businesses or specific projects. Alternatively, these may be structured to confer rights equivalent to those of other financial instruments. As they largely overlap with marketable securities, usually sectoral regulations which are already in place apply.