The rapid growth of mainstream attention toward cryptocurrencies has forced the hands of numerous governments to create their digital alternatives. Over the past few years, interest from various jurisdictions has been pointed towards central bank digital currencies (CBDCs) — digital versions of government-issued fiat.Given their capacity to use blockchain technology to facilitate a simplified fiscal policy — not to mention calibrate privacy features and even provide cross-border banking services to the unbanked — CBDCs continue to gain even more attention from various governments worldwide.Already, surveys show more than 80% of central banks are researching CBDCs, with some working on proofs of concept that could eventually lead to the introduction of fully functional CBDCs. Out of the surveyed central banks, 10% plan to offer a retail version of a CBDC in the next three years, with another 20% set to make the move in under six years. In Asia, these efforts have been compounded by China’s release of the world’s first CBDC after setting up a task force as early as 2014. By 2016, the People’s Bank of China (PBoC) had already established a Digital Currency Institute, which developed a prototype CBDC.Major Asian banks have shown great interest in CBDCs as reports show collaborative efforts by Thailand’s, Hong Kong’s and China’s central banks to create a digital ledger technology (DLT) for a CBDC prototype designed to bridge cross-border gaps. In this article, we give you a brief look at some developing CBDC projects on the Asian continent.ChinaChina ranks among the world’s top economies to embrace digital currencies with the release of the digital yuan — a CBDC project issued by the PBoC. Dubbed the Digital Currency Electronic Payment (DCEP) China’s digital yuan (e-CNY) is set to completely replace cash payments and has been rolled out in the country’s major cities since April 2020. China’s DCEP, while sporting some anonymity features, is controlled, tracked and registered on smartphone apps by the Chinese government, giving them the ability to freeze accounts at will. Perhaps one of its advantages is the fact that users on China’s DCEP network can reverse or correct erroneous transactions, which is one of the features that is non-existent on decentralized digital currencies like Bitcoin (BTC). As China’s CBDC takes shape, various countries (especially the United States) have grown increasingly concerned that the new CBDC initiative will help China tighten increased surveillance on its citizens and private companies. The move is also seen as an attempt to supplant the dominance the U.S. dollar enjoys in international trade. Even so, China’s e-CNY remains highly localized with no significant attempts by the Asian nation to take its CBDC international.Hong KongJust recently, the Hong Kong Monetary Authority (HKMA) released a white paper discussing plans to experiment on the benefits of retail CBDCs for the city’s cross-border markets. Hong Kong is now governed under a one-country, two-system framework where it maintains its own financial and judicial system separate from mainland China. However, HKMA is working with China’s central bank to explore the infrastructure development of its digital Hong Kong dollar (e-HKD).According to the white paper, “The architecture proposed in Hong Kong’s e-HKD features a flexible and efficient two-tier distribution model of a CBDC that enabled privacy-preserving transactions, traceability and cross-border synchronizations of ledgers.”The white paper is the result of CBDC research by Hong Kong’s major financial authority that has been ongoing since 2017 under the aegis of “Project LionRock.” The HKMA considered the opinions of academic and industry experts and plans to conduct more trials to ensure the readiness of both a retail and wholesale CBDC.South Korea South Korea’s latest move towards a CBDC has seen the Bank of Korea (BoK) make calls for a technology partner to help pilot a CBDC program set to run till the end of the year. In a report published by BoK in February this year, the central bank announced plans to test and distribute a digital won while outlining the legal challenges that accompany a state-issued digital currency.Apart from selecting a technology partner to help with the project, BoK has also announced that its CBDC will first operate in a limited test environment in order to analyze the functionality and security of the CBDC.According to previous remarks by a BoK official, South Korea’s cash transactions are on the decline, and the central bank is only taking steps in preparation “for the expected changes in payment settlement systems [worldwide].”The PhilippinesIn the summer of 2020, the central bank began to consider the creation of a CBDC by forming a committee task force to study the issue.Bangko Sentral ng Pilipinas had confirmed in a virtual briefing that a committee was set up to look into CBDCs. In the briefing, Governor Benjamin Diokno explained that a feasibility test and an evaluation of the policy mechanisms of issuing a CBDC were underway. Like most governments and traditional financial institutions, the officials in the Philippine government were not shy to admit to the significance of blockchain technology. Diokno said, “Cryptocurrency for us has always been beyond the asset itself but more on the blockchain technology that underpins it.” In line with these remarks, the Philippine Bureau of the Treasury, in partnership with the Philippines’ Digital Asset Exchange and UnionBank, had launched a mobile application built on blockchain tech for distributing government-issued treasury bonds.A few months later, however, saw the Philippines’ central bank reject the possibility of issuing a CBDC any time soon. Citing the need for ongoing research and study, the country’s central bank noted that its CBDC research so far could benefit from looking at established use cases of digital currencies in the private sector as well as other industrial applications.Singapore From as early as 2016, the Monetary Authority of Singapore had been looking into CBDC initiatives and is now seeking commercial partners to help develop the currency.By setting up challenges and competitions to discover and develop a retail CBDC, Singapore was able to establish a healthy diversity of solutions with the participation of more than 300 individuals.Singapore’s move to launch a CBDC began as a joint project with an institute dubbed “Project Dunbar” that mainly focused on building an in-house retail CBDC for the country. Soon after, the Singaporean central bank announced cash prizes for participants issuing digital currency ideas. Finalists in the challenge included ANZ Banking Group, Standard Chartered Bank, Criteo, Soramitsu and HSB Bank Limited, to mention a few. Throughout 2021, the Singaporean authorities have maintained a crypto-friendly stance with approvals given to crypto exchange platforms to operate similar to other digital payment token services. CambodiaCambodia’s “Project Bakong” is probably one of the few fully operational retail CBDCs out there. The country’s blockchain-enabled money transfer project was originally launched in October 2020.By June 2021, the project was reported to have amassed over 200,000 users with an overall indirect outreach of over five million users. What’s more, the first half of 2021 saw Cambodia’s CBDC project hit a transactional throughput of 1.4 million transactions valued at $500 million. Developed on a hyper ledger platform, the Cambodian CBDC features mobile connectivity that allows users to connect to financial institutions and make payments without a centralized clearing entity. Apart from the declared goal of using the CBDC to wean off dependence on the U.S. dollar, officials also disclosed that plans are underway to explore a cross-border transaction capability through a partnership with Thailand’s central bank and Malaysia’s largest bank.JapanIn Japan, the country’s central bank joined hands with a group of other seven central banks in October 2020 to publish a report that examined CBDCs. Since then, the Bank of Japan (BoJ) has begun a proof-of-concept to test the core CBDC functions. While the testing phase was scheduled to end by March this year, officials from Japan’s panel on digital currencies have said that the digital yen should be compatible with other CBDCs and that the BoJ is still ironing out its key functions.An offline capability of the CBDC is one of Japan’s core considerations as it strives to establish a digital currency that is resilient to disruption given Japan’s vulnerability to natural disasters, earthquakes, floods and tsunamis. At the start of 2020, Japan’s parliamentary vice-minister for foreign affairs said that Japan’s digital currency could be a joint venture with public and private partners to align Japan’s goal with global changes in fintech.ThailandSince 2019, Thailand has joined forces with Hong Kong’s HKMA to test the use of a CBDC that would be used in cross-border payments between financial institutions in both countries. According to a press release by the Bank of Thailand, “The development of a CBDC is a key milestone with the potential to alter the financial infrastructure and ultimately the financial landscape which could cause many changes in the roles of many stakeholders.”Similar to other CBDC initiatives, the Bank of Thailand will seek out consultations and feedback with the general public as well as with the private and public sector on the “development and issuance of retail CBDC.”The Bank of Thailand plans to start pilot tests for the usage of its CBDC in the second quarter of 2022.VietnamPreviously, the Vietnamese government had requested the State Bank of Vietnam to investigate blockchain-based currencies. It appears that Vietnam has joined the growing list of jurisdictions looking into CBDCs despite its previous harsh stance on cryptocurrencies. In May 2020, the country’s ministry of finance announced plans to research and formulate a regulatory law for the crypto industry, even as the country experienced high levels of growth in digital currencies. In July, the Vietnamese government decided to investigate CBDCs with plans to issue a pilot CBDC, given its utility for a small country in a global financial system that is dominated by the U.S. dollar.
Bitcoiner Allan Flynn has settled his first complaint with the Australia and New Zealand Banking Group (ANZ) over being unilaterally debanked in 2018 due to his occupation as a Digital Currency Exchange (DCE). The settlement comes 20 months after the Canberra resident first filed complaints with the ACT Civil and Administrative Tribunal against ANZ.In the settlement, the ANZ noted that it closed his accounts due to the risk of money laundering and terrorism funding (ML/TF) that it perceives among exchanges. It also acknowledged that the act of unbanking Flynn could “have amounted to unlawful discrimination contrary to sections 7(1)(p) and 20 of the Discrimination Act 1991.”However ANZ denied any liability saying that if it had “discriminated against Mr. Flynn by closing his accounts, that discrimination was reasonable in the circumstances and thus lawful.”The statement by the ANZ also admitted that it closed his account upon detecting DCE activity without contacting Flynn for further information about his activities. Flynn argues that such discrimination is unlawful per Canberra law which states that, “It is against the law for someone to discriminate against you because of your profession, trade, occupation or calling.”Although this first battle is complete, he will take Westpac bank to the tribunal next Thursday over a second complaint.Westpac closed his bank account in 2019 citing the same ML/TF concerns over him being a crypto trader.Flynn told Cointelegraph the case was an important one as it will be the first time banks will be forced to say definitively whether they will serve Bitcoin traders. “All I’m asking for is a fair go,” he said.Flynn plans to cite human rights violations by banks for discriminating against him and his occupation. He feels that this is the right path to take over calling for more regulations and hopes that a win could force policy changes nationwide or perhaps even internationally.“A win against the banks could have wider implications for discrimination against occupations.” He said that a ruling by the Tribunal will enjoy widespread public scrutiny, while a settlement beforehand could help change policy due to a partial admission of guilt. He worries, however, that a loss could see more Bitcoiners unbanked.Related: New Australian crypto legislation likely in 2022, Senator Bragg tells NFT FestHis case is far from unique. Just last month, Rebecca Schot-Guppy, the CEO of Fintech Australia told the Senate that up to 91 members of her organization had been debanked without apparent cause or means to appeal.The Australian Transaction Reports and Analysis Centre (AUSTRAC) has issued increasingly specific regulations since 2015 about how DCEs must operate and be treated by the law. Importantly, AUSTRAC has made it clear that the AML/counter-terrorism laws do not obligate banks to close the accounts of crypto traders.Flynn believes the behavior of ANZ and Westpac suggests “the banks do not want competition,” and that if DCEs were allowed to function unimpeded, they would “break the speed limit and surpass traditional banks.”
The International Monetary Fund (IMF) thinks crypto has the potential to put pressure on the banking sector.
In a new report, the IMF says technological innovation is changing financial services. The report notes that the banking sector could lose market share if the crypto ecosystem grows to become a mainstream alternative to bank deposits or current lending options.
Bank of America released their latest crypto report this week, as Bitcoin returns north of $50K. BofA strategists Alkesh Shah and Andrew Moss described the crypto market as “too large to ignore” and that “there could be more opportunity than skeptics expect.”
Let’s take a bird’s eye view on key findings from the 140+ page report.
As BTC hangs tough above $50K, both BofA and our team’s internal perspective on Bitcoin inflows reflect strong institutional interest.
Additionally, beyond simply traditional financial institutions, Bank of America also cites the potential for further integration of blockchain technology in daily life. “In the near future, you may use blockchain technology to unlock your phone; buy a stock, house or fraction of a Ferrari; receive a dividend; borrow, loan or save money; or even pay for gas or pizza,” the report states. Of course, many different projects are already working on tools for some of these exact use cases, and a whole lot more.
Outside of existing economies ripe for reinvigoration, the report also calls out projects and firms that are becoming inherently native to the digital asset ecosystem. There has been ample growth across both of these categories, exemplified by the below chart showing mentions of digital asset language on earnings calls:
If there is one thing that is abundantly clear, it’s that digital assets are on major corporate radars, and as BofA states – “corporations aren’t risking being left behind.” These earnings calls included companies in information technology and finance, but also included consumer staples, real estate, health care, and more.
All The Rest: DApps, NFTs, And The Regulatory Battles
It’s hard to justify bucketing the immense growth of DeFi, Dapps, and NFTs all in one place while still giving the respective categories their fair shake. Nonetheless, that’s what we’ll do here to provide a brief recap on Bank of America’s thoughts on everything that isn’t a fungible token or straightforward blockchain project.
The report soberingly acknowledges the emergence of DeFi, despite it being seen as a continual threat to traditional financial firms like Bank of America themselves. BofA described Dapps as having the potential to bring financial services to nearly 2B unbanked individuals across the globe. What many crypto advocates and loyalists have been thinking and working towards is now becoming widely acknowledged by some of the biggest traditional institutions in the game.
When it comes to NFTs, the short stroke is that the sentiment reflects digital assets in general: Bank of America is bullish. The firm describes NFTs as “changing the way creators connect with fans and receive compensation.” Indeed, as BofA acknowledges, NFTs have immense potential in demonstrating ownership without any sort of middleman fee – and that this is substantial demand for this across a wide variety of verticals.
Finally, regulatory uncertainty was cited in the report as the largest near-term risk in the firm’s view, and understandably so. That regulatory risk may be exacerbated with stablecoins, however the report noted that despite less liquid reserves (which could lead to heightened regulatory scrutiny), stablecoins are “a waiting zone between fiat currencies and digital currencies, which could further accelerate adoption of the latter.” The report adds that central bank digital currencies (CBDCs) are a “when, not if” situation.
Bank of America only began it’s crypto division earlier this year, however the banking behemoth has already released a bullish report on the crypto market. | Source: NYSE: BAC on TradingView.com
Related Reading | Grayscale Report Shows The Good, The Bad, And The Ugly Of The Cardano Network
Close The Curtain
In summary, we’re watching it all unfold in real time. The report states that over 20M U.S. adults own digital assets (roughly 14%) while an additional 19M+ plan on buying digital assets sometime this year. However, rising interests are just limited to individuals, but also live within corporations.
Furthermore, growth in ownership, interest, etc. doesn’t stop or start with Bitcoin. Bitcoin has amassed one of the largest market values on the planet, and in this case is the rising tide that is lifting altcoin boats. The BofA report dives into Twitter mention analysis, which showed that Bitcoin mentions decreased year-to-date (as of August) while many altcoin mentions increased. In the meantime, Bitcoin volatility has decreased relative to the early years, as increased adoption leads to more “diamond hands.”
Additionally, CBDCs are on the horizon. Bank of America approximates that countries encompassing roughly 90% of global GDP are reportedly exploring CBDCs. Meanwhile, engagement in NFTs and DeFi products are increasingly rapidly as well.
While acknowledging regulatory hurdles that the market will need to overcome, the BofA report doesn’t shy away from difficult topics either. Illicit activity with crypto has been a staple for bears, however BofA notes that digital assets associated with illegal activities have been cut in half compared to 2019.
In all, BofA is admittedly optimistic looking forward. As more traditional finance operations come to terms with crypto’s role across a variety of industries, adoption is only set to increase. Fasten up and hold on to your seats.
Related Reading | SEC Chair Gensler: SEC Will Not ‘Ban’ Crypto
Featured image from Pexels, Charts from TradingView.com
Resistance is mounting to U.S. President Joe Biden’s reported plans to tap a staunch banking and crypto critic to run the Office of the Comptroller of the Currency (OCC).The proposed nomination of law professor, Saule Omarova, to head the federal bank regulatory agency has raised eyebrows in political and financial circles as she is widely seen as anti crypto and anti big banks. Texas Republican Senator Ted Cruz has become the latest crypto ally to speak out, claiming that her decisions, if nominated, could change the future of the industry in a tweet on Sept. 28.“Not only is Saule Omarova, Biden’s pick to lead the OCC, a threat to our traditional economy, she also wants to regulate crypto into oblivion. Crypto faces future-defining government regulations. This nomination needs to be stopped.”A number of big banks and banking associations are also against the nomination with the American Bankers Association debating whether to publicly fight the decision. ABA President and CEO Rob Nichols said “we have serious concerns about her ideas for fundamentally restructuring the nation’s banking system,” in a statement on Sept. 24.Ranking Republican on the Senate Banking Committee, Pat Toomey, also spoke out in opposition of the nomination last week stating that he has “serious reservations” given her “extreme leftist ideas.” President and CEO of the Independent Community Bankers of America, Rebeca Rainey, said that Omarova “would displace locally-based community banking and restrict economic growth in local communities,” according to reports.The OCC oversees America’s banking giants such as Goldman Sachs, JPMorgan, and Citi Group and would also encompass aspects of the crypto industry.Omarova, who has previously said she wanted to “end banking as we know it,” is expected to enforce stricter rules. She has also claimed that the rise of cryptocurrencies is “benefiting mainly the dysfunctional financial system we already have.”She shares views with anti-crypto lawmakers such as Senator Elizabeth Warren in that digital assets threaten to destabilize the economy, according to Bloomberg. For her part, Warren stated that the nomination was “tremendous news,” and looked forward to heavier regulations.Related: New OCC head requests review of cryptocurrency rulesThe OCC has morphed from one of the Treasury’s most crypto-forward agencies into one that changed direction under subsequent leadership. Former head of Coinbase’s legal team, Brian Brooks, joined the OCC in March 2020 and paved the way for legislation allowing banks to custody crypto. In January, the banking regulator told national banks that they could run independent nodes for distributed ledger networks such as stablecoins. However, then the tone changed. On Sept. 21 acting head of the OCC, Michael Hsu, warned that decentralized finance products are similar to those that catalyzed the global financial crisis in 2008.
On Wednesday, speaking at a meeting of the Exchequer Club — which is a group of senior economic and financial policy professionals headquartered in Washington, D.C. — Acting Comptroller of the Currency Michael Hsu delivered remarks on the topic of safeguarding trust in banking.In the speech, Hsu named reducing inequality, adapting to digitalization, acting on climate change and guarding against complacency as the main priorities of his office.Speaking on the regulatory challenges emerging as a result of digitization of the financial system, the head of the Office of the Comptroller of the Currency (OCC) listed rising cryptocurrency-related and decentralized finance (DeFi) activity among the innovations driving changes in banking, disintermediating it in novel ways.Hsu attributed previous failures of U.S. financial regulators — such as those that had made the 2008 financial crisis possible — to the “siloed” nature of various regulatory bodies’ operations. The OCC boss further touted the collaborative effort by the UnitedTreasury, the Federal Reserve, the Securities and Exchange Commission, the Commodity Futures Trading Commission, the Federal Deposit Insurance Corporation, and his own office aimed at coordinating regulatory policies around digital assets.However, the OCC head did not mention any specific results of the working group’s activity beyond the report on stablecoins expected later this fall.Notably, Hsu said that it is necessary for regulators to “Ensure that crypto/DeFi activities that take place within the banking system or are facilitated by banks are trustworthy.” Given that the bulk of the decentralized finance activity takes place outside of the regulated banking system, it is unclear whether Hsu’s remarks can be interpreted as reflecting OCC’s aspiration to extend its purview over DeFi platforms.The OCC is an independent bureau within the U.S. Department of the Treasury that is tasked with supervising all national banks and federally licensed branches of foreign banks in the country. Michael Hsu became the acting Comptroller of the Currency in May this year.
Avanti Bank and Trust CEO Caitlin Long has posted a rebuttal to a recent New York Times article claiming that crypto and decentralized finance is “disrupting the banking industry” so fast regulators can’t keep up.Disrupting traditional finance is exactly what crypto and DeFi aspires to do, but the piece titled “Crypto’s Rapid Move Into Banking Elicits Alarm in Washington” published on Sept. 5 had a number of inaccuracies and omissions according to Long.The primary argument of the piece — using DeFi startup BlockFi as an example — was that crypto derivatives and highly leveraged products have become a nightmare for regulators which are scrambling to catch up. High-stakes speculation is leaving investors vulnerable to major losses according to the NYT. But Long stated that the issue is not black and white and suggested that “anti-crypto forces” are constantly trying to paint the entire industry with the same brush. “Bad actors deserve to be called out, but the article ignores the fact that regulatory-compliant firms exist,” she added.1/ @NYtimes story on #crypto/#banking deserves a thoughtful reply. Issue isn’t black & white: anti-crypto forces try to paint us all w/ a broad brush. Bad actors deserve to be called out, but the article ignores fact that regulatory-compliant firms exist. https://t.co/IUYTctBGfV— Caitlin Long (@CaitlinLong_) September 5, 2021Long took particular issue with the fact that the article failed to mention that fully regulated crypto banks already exist, such as her own Wyoming-based Avanti, which launched in October 2020.She stated that Wyoming’s special bank charter does not allow “cryptocurrency deposits.” Regulated banks can provide custody services for crypto, she continued to explain, but cannot take deposits in anything except fiat currency.“Article misses that critical point — it’s a firewall protecting Fed’s payment system from exposure to anything other than $ [USD].”The article also pointed out that many crypto intermediaries have introduced some of the “bad behavior” from traditional finance such as extreme leverage without requiring a capital buffer. These are fair criticisms, according to Long, who has previously cautioned about leverage, adding that very fe crypto intermediaries, such as brokers or third parties acting between the bank and the blockchain, disclose information about their reserves.Related: ‘Bitcoin is not an asset that is designed to be leveraged,’ says Caitlin LongLong stated that DeFi platforms in particular do a far better job with transparency than crypto intermediaries or traditional banks which remains one of its best attributes. Banks settle their books once a day while crypto is settled in minutes, and for that reason, the Avanti Bank CEO concluded:“Regulated banks that handle crypto need to be in a straightjacket. That’s the only safe & sound way to integrate the crypto & traditional systems.”Vehemently anti-crypto U.S. Senator Elizabeth Warren was still on the warpath this week when she labeled the entire cryptocurrency industry the “new shadow bank” as reported on Sept 7. She expressed particular concerns over stablecoins and their apparent lack of transparency regarding reserves.
Tim Stokely, the founder and CEO of OnlyFans has explained how banks had forced it to drop adult content from the subscription-based content platform. OnlyFans is a popular platform connecting online sex workers to subscribers, but the firm recently changed its policy to prohibit “sexually explicit conduct,” starting Oct. 1 — which has caused backlash from both creators and content connoisseurs alike. Speaking about the change of policy with the Financial Times on Aug. 24, Stokely noted that “we had no choice — the short answer is banks,” as he listed three banking giants who refused to provide services to OnlyFans: Bank of New York Mellon, Metro Bank and JPMorgan Chase. Stokely asserts that the banks pulled services from OnlyFans over the “reputational risk” of being associated with a platform that hosts sexually explicit content. The founder cited JPMorgan in particular, stating that it is “aggressive in closing accounts of sex workers” or any business that “supports sex workers.”Stokely claims that they “flagged and rejected” every wire transfer connected with the firm, which was “making it difficult” to pay creators on the platform.“We pay over one million creators over $300 million every month, and making sure that these funds get to creators involves using the banking sector,” he said.Pornhub has run into similar issues in the past, with Paypal pulling back from the platform in late 2019. In December of the following year, Visa and Mastercard also halted services to Pornhub, over issues regarding videos that allegedly depicted illicit material. Related: JPMorgan Chase reportedly shuts down bank accounts of Bitcoin mining firmPornhub moved toward cryptocurrencies for payments including utilizing Verge (XVG), which it had partnered with back in 2018. Stokely didn’t reveal if OnlyFans would adopt crypto like Pornhub, but did note that he would “absolutely” allow pornographic content on the platform if banks changed their mind. There are also blockchain-based alternatives to OnlyFans, via platforms such as Nafty.tv which is built on Binance Smart Chain and utilizes its native NAFTY token for payments, along with credit and debit cards.
Lloyds Banking Group, the British parent company of Lloyds Bank, is currently hiring a “digital currency [and] innovation senior manager,” according to a recent job listing posted to BYP Network. Lloyds is one of the largest financial services firms in the world with close to $500 billion assets under management (AUM). The new digital currency job advertisement highlights the new employee will work with the firm’s mobile banking network with “over 30 million customers.”
Lloyds Banking Group Is Hiring a ‘Digital Currency and Innovation Senior Manager’
A job listing published on BYP Network explains that Lloyds Banking Group is in need of a digital currency expert. Lloyds notes that the company’s Payments Liquidity & Settlement team is a newly formed venture unit and the group and “global network of bank relationships” details that they “look towards the future, digital currencies.”
The job listing follows the recent surge of Fortune 500 firms that have been looking to hire digital currency experts like Amazon, Apple, and Walmart just revealed it is looking for a cryptocurrency lead as well.
“The outlook for digital assets has shifted markedly as a number of factors have converged to make them ready for the possibility of wider adoption,” Lloyd’s job listing says. “Regulatory clarity is improving whilst central banks are actively exploring digital currencies. 86% are running pilots, and certain geographies, e.g. China, are close to going live.”