How Far Can Digitalisation End Paper-based Trade Finance? To What Extent is it Happening Now? Presentation by Geoffrey Wynne Partner, Sullivan & Worcester UK LLP on 27 October 2016 At Pinners Hall, 105-108 Old Broad Street, London, EC2N 1EX
How Far Can Digitalisation End Paper-based Trade Finance? To What Extent is it Happening Now?
Presentation by Geoffrey Wynne
Partner, Sullivan & Worcester UK LLP
on 27 October 2016
At Pinners Hall, 105-108 Old Broad Street,
London, EC2N 1EX
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What areas this talk will cover ICC and others have raised focus on the subject
E-documents › Electronic warehouse receipts (eW/R) › Electronic bills of lading (eB/L) › Electronic letters of credit › Bank payment obligations (BPO)
E-signatures
Blockchain
The legal challenges each of the above creates and faces
Conclusions and the Way Forward
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E-documents: how did we get here? Some historical pointers:
1990s Citibank launches electronic scheme for customers only 1995 the Bolero Association was created central “registry” for all trade related documents of title 1996 Bolero partners with SWIFT creating a joint venture company to build, market and support the Bolero infrastructure 1999 Bolero service goes fully live 2005 essDOCS is established 2008 bitcoin is established 2016 Misys and essDOCS join forces
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Electronic trade finance Potentially wide ranging applications of technology in the trade finance world:
Electronic Letters of Credit
MT798 messaging
Electronic Bills of Lading (eB/L)
Electronic warehouse receipts (eW/R)
Bank Payment Obligations (BPO)
Distributed Ledger Technology (DLT)/blockchain
Integration of blockchain technologies
Bitcoin and other electronic currencies
Electronic platforms for receivables
the internet of things (IoT) – digital transfer of ownership – utilisation of established cloud technology to instantaneously share info around the world
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Why use e-documents in trade finance?
Many stakeholders are partnering up, investing time and money into developing usable technologies to improve trade finance.
Is technology the answer?
Current issues: increasing complexity of today’s supply chain
Processing paper documents is a time consuming/costly manual process › Tech such as MT798 can reduce complexity, allowing companies to buy from
multiple parties more easily › Reduction in transaction costs, increasing access to new customers › Potential safeguard against duplicate invoicing and increased security › Streamlining of processes, avoidance of transmission delays, facilitates faster
document checking, increased efficiencies, reduced likelihood of human error › Reduced processing time for LCs – improvements in “days sales outstanding”
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Why use e-documents in trade finance: KYC and compliance Host of trade finance regulations becoming more comprehensive,
exposing banks to reputational risk and fines
Checking non-standard paper documents can be cumbersome and carries a higher level of compliance risk
Human error could miss breaches of compliance
Technologies currently being used can lead to high “false positives”
Artificial intelligence could make filtering more effective
Cryptographic technology allows for mathematic proof a document has not been compromised – this has a potentially huge impact for KYC and other regulatory requirements
Automatic screening of content/OCR can facilitate compliance checks
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How are e-documents currently being used? Several banks and institutions have adopted disparate digital
systems to date › According to essDOCS, since 2013 banks have signed up to CargoDocs at an
average rate of one per month
Adoption of digital technologies and systems has not reached critical mass
Huge parts of the supply chain exist where no digital technology is in use
Most is bilateral – ie private arrangements between parties known to each other
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E-documents: some examples of issues
Electronic Warehouse Receipts (eW/R) › Mercuria v Citigroup [2015] EWHC 1481 (Comm) demonstrated the need for safe
storage of goods and accurate databases of receipts › Electronic warehouse receipts are currently utilised for many purposes,
including: collateral for loans from banks and other lending institutions intra-company transactions transferring ownership through the delivery process at exchanges
› Eliminates the need to store, file, safeguard and track used and unused warehouse receipts
› eW/R can be controlled and monitored centrally › Potential to cut costs and speed up process of overnight delivery or physical
transportation of paper warehouse receipts to and from lenders › May remove need to make custodial arrangements › How to develop further?
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E-documents: more issues Electronic Bills of Lading (eB/L)
› Idea has been around since eighties › eB/L allow quick transfer when cargo sold during transportation – can be sent
around world instantaneously › Reduction in administrative burden and amendments can be made at reduced cost › Electronic payment system more traceable and more secure than paper › Shortens payment cycle and improves working capital position of seller › Until 2010 the Rules of the International Group of P&I Clubs (the Group)
specifically excluded liabilities in respect of the carriage of cargo under all electronic/paperless, trading systems where the liabilities under such systems would not have arisen under a paper system
› The Group now covers some of the risks provided that the electronic system had first been approved by the Group.
Becoming more widely used – Baltic and International Maritime Council (BIMCO) included eB/L clauses in new New York Produce Exchange form – and International Group of P&I Clubs have approved three systems
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E-documents: more issues eB/Ls ability to function as document of title is not supported
universally
Present rules and laws cannot support eB/L
Who takes the risk? › ICC notes that regulators are imposing tighter restrictions and controls – will this
help to answer the above question? › Trade partners are required to sign a bilateral agreement with the platform
provider – does this make it clear who is responsible for the risks?
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E-documents: Letters of Credit Electronic Letters of Credit
› eUCP released in April 2002 and last updated in 2007 › Been in use for quite a long time
What does it allow? › Electronic use of letters of credit
Who is responsible for checking the presentation? › Who is carrying the risk if a presentation is not correct? OCR becoming more widely used, emphasis on “matching” not scrutinising
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E-documents: BPOs Bank Payment Obligations (BPO)
› URBPO launched in June 2013 › Bank assisted open account – irrevocable payment undertaking from one bank
to another following a data match › Use electronic data matching platforms – emphasis on matching of data rather
than scrutiny of data
Potential issues with BPO: › No examination of the documents › Automation and fraud risks – who carries the risks? More onerous requirements on banks to carry out due diligence on
underlying transactions and counterparties? › A promise to pay between banks only not the applicant and beneficiary Can you assign the benefit of a BPO?
› ICC suggest slow uptake because the URBPO does not apply to all parties – lack of certainty
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E-documents: where are we now? Demand for electronic trade finance
One of the barriers is that processes currently in place are difficult to break/adapt
Even if this is sorted, what about legal issues?
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E-documents: barriers to adoption Variety of participants in the process mean many parties need to invest
in and adopt processes to make e-trade finance work seamlessly › Smaller parties lack the incentive to change their processes and invest in the
technology › Market participants likely to have fears since digitalisation in trade finance not
sufficiently tested – need for international standards › EssDOCS say that they have developed systems which can be used by other parties
who have not signed up to or integrated their processes
Offering is not always better › Some still prefer “security” of an LC compared with cost savings of BPO › Higher fees associated with LC business compared to BPO – but more flexible?
Inflexibility of legacy processes › Adoption costs associated with new governance, marketing, risk management and
operational expertise › Some systems need all parties to adopt them or each to adopt a full suite of
processes, for example parties on each side of a BPO must be “BPO enabled” › eB/L not currently treated in the same legal manner as their paper equivalent
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E-documents: changing attitudes and what the future holds Are the best innovations in trade finance coming from Fintech companies?
› Desire to create “open networks”
› Increased collaboration between traditional institutions in trade finance and tech companies: R3 CEV – a blockchain tech company leading a consortium of 50+ financial
institutions working together on blockchain usage in the financial system Standard Chartered and DBS Group Holdings Ltd are developing an electronic
ledger of invoices using a parallel platform to the blockchain employed in bitcoin transactions
London Metal Exchange and Kynetix launched LMEshield, an eW/R system in April Barclays’ accelerator programme partnered with start-up Wave on eB/L solution
using blockchain Wells Fargo have pilot trade scheme with Cargill
Risk that non-traditional entrants might gain attractive elements of the value chain if banks fail to act
World Trade Board met in June 2016 and put digitalisation down as one of the three key areas of focus on the global trade agenda.
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E-documents: the risks Digitalisation in trade is happening but we have not ironed out the
risks yet
Who takes the risk if a presentation is incorrect: › the technology provider; or › the party using the technology?
Emphasis is on verification/matching not scrutiny
Coding and transaction mistakes happen
ICC paper says need to establish clear legal/regulatory framework to remove uncertainty around digitalisation
ICC want to develop initiatives to give digitalisation a legal framework acceptable to banks and counterparties
Incoming EU data protection regulation regulating data/privacy/requiring data to be ‘redactable’
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E-signature: legal framework The legal framework was recently amended and is now
underpinned by the Electronic Identification Regulation (EU/910/2014) (the Regulation) most of which came into force on 1 July 2016
The Regulation repealed the E-Signature Directive (1999/93/EC), which was the basis for the previous regulatory regime (incorporated in English law by the Electronic Communications Act 2000)
In the European Commission's view, the E-Signature Directive had failed to make online authentication an acceptable alternative to hard copy documents and written signatures in transactions requiring identification
On 25 July 2016, the Law Society published a practice note endorsing the use of electronic signatures (the LS Note)
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What is an e-signature? Article 3 of the Regulation defines an electronic signature in broad
terms as: “data in electronic form which is attached to or logically associated with other data in electronic form and which is used by the signatory to sign.”
It can take many different forms, including: › typing a name into a contract or into an email containing the contract’s terms; › clicking an “I accept” button on a website; › pasting a signature (in the form of an image) into an electronic contract; and › using a web-based electronic signature platform to generate: an electronic representation of a handwritten signature; or a digital signature using public key encryption technology and backed by a
digital certificate from the provider (or a trusted third party) verifying the identity of the signatory.
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Trust services and trust service providers
The Regulation seeks to address the fragmented nature of trust services across the EU
It therefore replaces the role of certificate service providers (CSPs) (as they were under the E-Signature Directive) with the concept of trust service providers (TSPs)
A TSP is an entity providing one or more "trust services", which are electronic services, normally for remuneration, consisting of: › the creation, verification, and validation of electronic signatures, electronic seals
or electronic time stamps, electronic registered delivery services and certificates related to those services;
› the creation, verification and validation of certificates for website authentication; and
› the preservation of electronic signatures, seals or certificates related to those services.
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Qualified trust services Regulation also introduces the concept of qualified trust services
and qualified TSPs
Qualified TSPs can provide qualified certificates and are subject to a more comprehensive and harmonised regulatory regime than that which existed for CSPs issuing qualified certificates under the E-Signature Directive
The introduction of this harmonised regime is intended to ensure that qualified TSPs across the EU meet the same high-level security standards
Member States are required to designate a supervisory body with responsibility for supervising TSPs (Article 17)
In the UK, the government has designated the Information Commissioner's Office as the supervisory body for TSPs
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Trust mark Qualified TSPs are permitted to use the new EU trust mark from
July 2016 to identify their services in a simple, recognisable and clear manner (Article 23):
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Liability Article 13 of Regulation provides that all TSPs (qualified and non-
qualified) are liable for damage caused intentionally or negligently due to a failure to comply with their obligations under the Regulation
However, only qualified TSPs will be assumed to have acted intentionally or negligently unless it can prove otherwise
The burden of proof in relation to non-qualified TSPs remains with the person claiming damage
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Legal effect of e-signatures The Regulation maintains the position established under the E-
Signature Directive: an electronic signature should not be denied legal effect and admissibility as evidence in legal proceedings just because it is electronic or fails to meet the requirements for a qualified electronic signature meaning, an advanced electronic signature that is created by a qualified electronic signature creation device, and which is based on a qualified certificate for electronic signatures.
However, only a qualified electronic signature is automatically granted the equivalent legal effect of a handwritten signature (Article 25)
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Legal effect of e-signatures Article 26 provides that advanced electronic signatures must be all
of the following: › uniquely linked to the signatory; › capable of identifying the signatory; › created using electronic signature creation data that the signatory can, with a
high level of confidence, use under his sole control; and › linked to the data signed therewith in such a way that any subsequent change in
the data is detectable.
A qualified electronic signature based on a qualified certificate issued in one Member State now benefits from mutual recognition in all other Member States
However, if Britain exits from the EU the Regulation might: › automatically cease to apply; or › continue to apply through the EU law principle of mutual recognition.
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Mercury v HMRC [2008] EWHC 2721 (Admin)
In Mercury the parties to a (lawful) tax avoidance scheme had created documents, purportedly executed as deeds, by inserting signed pages from earlier drafts in to a final version
The court held that the documents had not been properly executed as deeds
Mercury does not allow a signature page to be produced independently and then bound into a "deed", where that signature page has never been part of the whole (concluded) deed
The Mercury decision however caused widespread concern about the process of signing and completing legal agreements under English law.
Many businesses are now, as a result, still organising physical signing meetings to conclude a transaction that could otherwise have been concluded electronically
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LS Note – deeds Deeds:
› deed can be validly executed by a company: by each of two directors signing the deed (using an electronic signature or
another acceptable method) either in counterpart or by one director signing, followed by the other adding his or her signature to the same version (electronic or hard copy) of the deed; or
by a director e-signing with another individual genuinely observing such signature and that witness subsequently signing an adjacent attestation clause (it is noted that best practice would be for the witness to be physically present, rather than witnessing through video conferencing or other live medium).
› an individual can validly execute a deed by e-signing under the “genuine observation” of a witness in the same way as described above for a director
› delivery of a deed can be achieved through e-signing, however, as with wet-ink signatures, parties should explicitly address when delivery takes place if it is not intended to be at the time of signature
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LS Note – documents in writing Documents subject to a statutory requirement to be in writing
and/or signed and/or underhand (e.g. statutory requirements for bills of exchange, guarantees or promissory notes): › a contract executed using an electronic signature (and which may exist solely in
electronic form) satisfies a statutory requirement to be in writing and/or signed and/or under hand
Board minutes and written resolutions can be validly e-signed if they are subsequently: › sent or supplied in hard copy form by or on behalf of the person who signed it;
or › sent or supplied in electronic form, provided that the identity of the sender is
confirmed in a manner specified by the company or (where no such manner has been specified by the company) if the communication contains or is accompanied by a statement of the identity of the sender and the company has no reason to doubt the truth of that statement.
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LS Note – other points There is no reason why a document cannot be signed using a
combination of e-signatures and wet-ink signatures
It should be noted that some authorities or registries (e.g. the Land Registry) still require a wet-ink signature on certain documents
Where an overseas company is to sign an English law document electronically, or the document is not governed by English law, parties should seek advice from foreign counsel
The LS Note provides only non-binding guidance on execution and completion practices
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What is blockchain? Blockchain is a database operating through ‘distributed ledger
technology’ – i.e. an online ledger which allows two or more entities that do not necessarily know each other to agree that something is true without the need of a third party to certify ownership and/or clear transactions
Users agree that something is true by way of pre-agreed consensus algorithms in the applicable participating network
It records ownership by taking a number of inputs and placing them into a ‘block’. Each block is then 'chained' to the next block using a cryptographic signature
This allows ‘blockchains’ to be used as a safe ledger accessible by anyone with permission to do so
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Open or closed? Blockchain-based distributed ledgers may be customised along a
spectrum of decentralisation: › public ledgers – fully decentralised among its servers, with transactions that are
transparent but pseudonymous (i.e. users are given a cryptographic identity for which it is up to them to either declare their personal details or keep the transaction private)
› partially decentralised ledgers – the ledger, servers and users may be subject to certain constraints imposed by e.g. a consortium of entities that controls all changes to the ledger, or controls user permissions
› private ledgers – a single trusted entity controls all changes to the ledger, or controls user permissions
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Digital currencies More than 500 cryptocurrencies are in use today, but bitcoin is the
most used
The idea of bitcoin as a ‘currency’ is a misconception
It is a digital commodity which can traded on blockchain – it is “both a piece of the ledger and an asset on the ledger”
Regardless of its definition, bitcoin is a “disruptive” technology – displacing established market leaders – that can facilitate cross-border transactions: › it can be sent anywhere in the world at nearly zero cost › it is nearly impossible to counterfeit › it can be divided into smaller parts than a cent/pence
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Blockchain applications in trade finance
Some blockchain properties arguably lend themselves extremely well to trade finance programmes, such as: › immutability and timestamping › provenance of goods › streamlining settlement › peer-to-peer transfer of ownership of digital assets › smart contracts (i.e. electronic contracts than can be executed automatically
once certain conditions are satisfied) › secure distribution of ‘single source of truth’ (i.e. the practice of storing data
exactly once)
Relevant to secondary loan trading, supply chain finance, commodities trading
Put together, these properties could create the framework for an automated supply chain with a potential to improve: › supply chain logistics › management and supply chain finance
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Reducing risk (and related costs) Each transaction in the ledger is openly verified by a community of
networked users, arguably making the distributed ledger tamper-resistant (e.g. duplicate invoices and malicious parties can be detected and reported much faster)
A searchable historical record of all transactions is created, enabling, it is said, effective monitoring and auditing by participants and regulators (e.g. AML/anti-terrorism regulations and KYC requirements)
Almost any intangible document or asset can be expressed in code (‘tokenised’) which can be programmed into or referenced by a distributed ledger such that: › ownership can be proven › transfer of title would be real-time and peer-to-peer
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Real-world example: buyer-led receivables
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Supplier (Seller)
Service Provider/ Financer
Debtor (Buyer)
Supply Contract
1. Purchase Order
2. Supplies goods/services and invoice
5. Request for financer to purchase receivable
6. Payment of discounted purchase price in exchange for assignment of receivable
8. Payment of face value of receivable on maturity date
7. Notice of assignment of
receivable
Steps 1 to 8 are performed
through a single shared platform
Financer
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Real-world example: buyer-led receivables
Buyer’s inventory management system detects it is running low on steel
Step 1 – once steel inventory drops below a certain level, a purchase order is automatically sent to the Seller (via e.g. a smart contract)
Step 2 – the Seller ships the correct amount of steel and automatically issues an invoice for the goods to the Buyer
Steps 3 and 4 – the Buyer performs a three-way match and automatically approves payment with a cryptographic signature. The signature confirms to the Seller the approval and a promise to repay on the due date
Steps 5 and 6 – the Seller sells the receivable and receives early payment from the Financer. Another option would be to sell receivables automatically based on e.g. - › discount rate › seller’s current cash balance
35 Source: GTR guide to blockchain for trade finance
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LC transaction using multiple platforms
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Manual pre-screening.
Letter of credit.
Shipping arranged.
Manual checks.
Paper-based verification to be completed.
Contracts manually
completed.
Manual KYC and due diligence is
time consuming.
Limited access to data means many
SMEs cannot access finance.
Lack of transparency
over exact condition of
goods in transit.
Process of manual checks is costly and creates
a higher turn-around time.
Unavailability of authorised
signatories to sign the paper
requests.
Main points:
Source: Santander InnoVentures – Fintech 2.0 Paper
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LC transaction using a single platform
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Real time capturing of trade data.
Letter of credit.
Shipping arranged.
Real time monitoring.
Real time verification and digital
submission.
Smart contract auto
filled.
Better underwriting
and credit decisions.
Authorisers can approve requests remotely.
Better knowledge of the condition of goods.
End customers can track their goods improving
trust.
Verification of goods is more reliable and in
real time.
Elimination of documentation speeds process
and reduces costs.
Main points:
Source: Santander InnoVentures – Fintech 2.0 Paper
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Blockchain: the long view (2022) Application of the concept of ‘just-in-time, automated financing’ to
the entire supply chain and trade networks = › Increases in efficiency and utilisation of working capital in global commerce
Adoption of a large blockchain-based lender network including top financial institutions and trade finance programmes = › Drop in title ownership and transfer risks for lenders that are part of the network
Collection of granular data in a searchable and continually updated blockchain network = › Creation of a global trade finance index or rating helping inform credit decisions.
Blockchain could displace some or all of SWIFT’s current role in banking
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Blockchain: the reality (2016) We are still living in the late 1990s ‘internet’ stage of blockchain
Overall, blockchain has only been tested by market participants on a small, focused scale – nowhere near the degree of scale needed to realise the benefits of blockchain in trade finance
Over the last year R3 CEV claims 45 financial institutions have joined a consortium aiming to develop universal standards and a shared protocol for blockchain networks
Blockchain promises to reduce banks’ operational and compliance costs that come with paper-based trade financing by: › 10-15% according to the R3 CEV consortium › $15-20 billion per annum by 2022, according to Santander
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Blockchain: the reality (2016) Interest is certainly increasing:
› BoE and the EC have conducted studies on the utilisation of cryptocurrencies and blockchain technology
› Santander UK to use blockchain for B2B and consumer international payments through a new app
› Citigroup to use its own blockchain and cryptocurrency Citicoin › Emirates NBD and ICICI Bank have partnered with a subsidiary of Indian tech
giant Infosys on a pilot blockchain solution for trade finance › Dun & Bradstreet is testing a blockchain distributed ledger for offering its
proprietary corporate data to business customers › In September 2016, Barclays announced “the first blockchain LC transaction”
between Ornua and the Seychelles Trading Company part of a regular flow of LCs between the two parties, but relatively small in
amount (under $100,000) documentation handled on the “Wave” platform, with funds sent via SWIFT
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Blockchain: the risks In an imperfect world, who takes the risk if a transaction is
reflected incorrectly on the distributed ledger: › the party(ies) responsible for inputting the relevant block of information? even in the event of fraud?
› the party(ies) providing the blockchain platform and related protocols? even if caused by events outside its control?
Data is permanently/immutably embedded by default › confidentiality and/or privacy rules might not easily be complied with: can the technology secure the financial information provided? If not,
questions of waivers and consents arise new US and EU regulations (e.g. EU General Data Protection Regulation) all
require personal financial data to be redactable — something that is not possible on an immutable platform
› operational errors and illegal or nefarious activities could stand uncorrected › to remove the above risks, previous blocks of information must therefore be
capable of being edited (under extraordinary circumstances) without breaking the chain 41
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Blockchain: the risks In a fully or partially decentralised global blockchain network where parties are
unable to identify a single place on which the data is held, it may be difficult to: › identify the appropriate set of domestic rules to apply to both contract and
property rights › pinpoint which jurisdiction would apply in the event of a breach or fraud within
the network.
Smart contracts present enforceability questions if attempting to analyse them within the traditional ‘contract’ definition (i.e. offer, acceptance, consideration and intent)
The legal status of online entities used to execute smart contracts and record blockchain activities is open to interpretation – questions of ownership and responsibility also arise
Pseudonymous distributed ledger platforms raise transparency and anti-money laundering / compliance issues
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Blockchain: the risks As with SWIFT, the security of the blockchain process is not
absolute and largely depends on the users’ good practice › paper-based trade finance might be inconvenient and costly, but it is relatively
safe from cyberattacks › private or partially decentralised ledgers could be at risk of a focused cyberattack
on the central server(s) that validate transactions
Blockchain could therefore enable fraud and service disruption cyberattacks on unprecedented scales
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Conclusions and way forward How far can digitalisation end paper-based trade finance?
There is increasing development of technology in trade finance
The uptake of digital technologies in trade finance has not been as fast as some may have anticipated › legacy systems › faster adoption in certain regions (Asia)
Questions around which party carries the risk remain key › Would you accept the risk?
Need for coordinated regulations/codes of practice › ICC are currently examining the role they should play in this › new EU regulation on data protection and processing of private information
Developments in distributed ledgers and its immutability may help increase adoption of rules particularly for KYC/compliance
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Dates for your diary
10 November – 3rd Anniversary Party
24 November – next seminar
15 December – last seminar for 2016
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Geoffrey L Wynne Partner Geoffrey Wynne is head of Sullivan & Worcester’s London office and also head of its Trade & Export Finance Group. He has extensive experience in banking and finance, specifically trade and structured trade and commodity finance. He also advises on corporate and international finance, asset and project finance, syndicated lending, equipment leasing and workouts and financing restructuring.
Geoff is one of the leading trade finance lawyers and has advised extensively many of the major trade finance banks, multilateral financers and companies around the world on trade and commodity transactions in virtually every emerging market including CIS, Far East, India, Africa and Latin America. He has worked on many structured trade transactions covering such diverse commodities as oil, nickel, steel, tobacco, cocoa and coffee. He has worked on warehouse financings in many jurisdictions and advised on how to structure involving warehouse operators and collateral managers. He has also advised on ownership structures and repos for commodities and receivables financings.
Geoff sits on the editorial boards of a number of publications and is a regular contributor and speaker at conferences. He is also the editor of and contributor to The Practitioner’s Guide to Trade and Commodity Finance published by Sweet & Maxwell and A Guide to Receivables Finance, a special report from TFR published by Ark.
Sullivan & Worcester UK LLP Tower 42 25 Old Broad Street London EC2N 1HQ
T +44 (0)20 7448 1001 F +44 (0)20 7900 3472 [email protected]
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Awards & Recognition TFR “Best Law Firm in Trade Finance”
Trade & Forfaiting Review (TFR) named Sullivan & Worcester "Best Law Firm in Trade Finance" in its 2014, 2015 and 2016 TFR Excellence Awards GTR “Best Law Firm 2015 Poll”
Sullivan & Worcester UK LLP was top ranked firm in the Global Trade Review (GTR) Best Law Firm 2015 poll The Legal 500 UK 2016
Sullivan & Worcester UK LLP was ranked in the following category in The Legal 500 UK:
› Trade Finance (Tier 1)
Chambers UK 2016
Chambers UK ranked Sullivan & Worcester UK LLP, along with Geoffrey Wynne and Simon Cook in the following area:
› Commodities: Trade Finance (UK-wide)
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