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Banking and Fintech

Advised InfiniGold, which is in the process of launching the world’s first gold-backed stable coins with the gold held by a government guaranteed custodian, The Perth Mint (wholly owned by the government of Western Australia). Regulatory treatment of cryptographic tokens is complex and not yet well settled in Australia. Stable tokens, and their trading on global markets, create additional layers of complexity.
Served as regulatory counsel to a nonfungible token issuer and marketplace. Worked closely with the client as it built its service and products and counseled them on money transmitter laws, Financial Crimes Enforcement Network/anti-money laundering obligations, and securities issues.
Advised Invoice Interchange on the launch of an online peer-to-peer financing platform that will allow Australian businesses to raise short-term finance by offering their trade receivables for sale and will allow Australian investors to obtain fixed-interest returns by providing trade-receivable financing through the platform.
Provided guidance to a company located in Singapore and Melbourne in relation to the regulatory and licensing implications for the introduction of an enhanced payments offering into over 30 jurisdictions around the world. The market for the payments product is focused on the travel and leisure industry, and as a result, many of the jurisdictions were developing countries and atypical financial centers.
Advised Immutable, a developer of blockchain applications in the online gaming space. The game assets purchased are represented by tokens on the ethereum blockchain, and can be bought, traded, given away, or sold by players. Immutable’s current flagship title, “Gods Unchained,” has generated millions in revenue through the sale of virtual collectible cards to players that can then be bought and sold through an online marketplace. Individual “cards” have been sold for tens of thousands of dollars as the innovative use of the blockchain allows the creation of verifiable scarcity in a digital world. We leveraged our experience in blockchain technology and the regulation of cryptocurrencies to provide detailed analysis and advice on regulatory compliance issues that were identified as potential risks in the investors’ due diligence. We advised on the treatment of game assets as a digital currency, anti-money laundering and counterterrorism financing compliance resulting from the sale of game assets and the trading of game assets on the marketplace, and the regulation of online gambling in connection with a proposed feature allowing players to bet on the outcome of their games.
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