• Targeting global financial inclusion, Libra is a project aiming to .

• As per their latest whitepaper, Libra lists three core pillars thereof:

  • A distributed ledger (i.e., a blockchain) referred to as the Libra Blockchain.

  • A set of stablecoins (Libra Coins) which are backed by collateral held in the Libra Reserve. It consists of traditional assets: cash, cash equivalents, and short-term government debt securities.

  • A governance system by a Switzerland-based independent organization (Libra Association) and its subsidiary (Libra Networks) who develop and operate the network.

• Differences with the first version of Libra include a different mission statement and overall narrative, a clear attempt to comply with applicable regulation, a better description of the various parties in the Libra universe, and the set of currencies (multiple single-currency and a multi-currency pegged stablecoins). Conversely, the technological system (e.g., the Libra Blockchain, LibraBFT) remains consistent with the original design from the technical papers from 2019.

• Libra’s envisioned global payment system could do to the payment industry what SpaceX did to the space industry: shake the foundations of a well-established sector with high entry barriers. The mere advantage of issuing widely-available programmable money would already initiate manifold efficiency gains1.

• Libra and its stablecoins would not compete with the use-cases of existing stablecoins as it did not compromise on its long-term goal of financial inclusion. Instead, the Libra team made short-term trade-offs that will starkly decrease its initial impact, as open access to Libra (via “Unhosted Wallets”) has been postponed due to regulatory concerns.

• If Libra manages to both open access to third parties and maintain a user-friendly interface, benefits to financial inclusion could be significant, and ultimately reshape the global payment industry.

• Libra is unlikely to impact the monetary stability of developed countries, but could lead to currency substitution from local currency to ≋LBR whenever Libra’s stated collateral requirements would exclude a dedicated fiat currency. Libra did, however, mention to open a dialogue with respective central banks under these circumstances.

• Libra’s currency pegging system is unique, with collaterals being subject to sovereign risk and redemption risk. Despite the system being overcollateralized, it would mostly be backed by short-term fixed-income instruments denominated in fiat currencies, which may raise questions regarding money creation.

Created by a consortium led by Facebook, Libra’s proclaimed mission has been to enhance financial inclusion across the globe.

Following its release in June 2019, the Libra project seems to be evolving from a network centered around one unique multi-currency stablecoin (“libra” or “≋LBR”) into a new global payment system and financial infrastructure.

In the following analysis, the respective changes of Libra’s core features are discussed. These are contrasted with the original features from the first whitepaper (June 2019) and complemented with an in-depth analysis of the potential rationale behind some of the design changes.

Finally, we shine some light on questions surrounding (i) whether this proposal would impact global monetary stability, (ii) regulations and the stablecoin ecosystem, (iii) financial inclusion, and (iv) the pegging mechanism with the Libra Reserve.

1. Core features of Libra

Libra’s mission is to .

To achieve its goal of improving global financial inclusion, this project relies on three pillars:

1. A distributed ledger (i.e., a blockchain) referred to as the Libra Blockchain (and Libra network).

2. A set of stablecoins (Libra Coins) which are backed by the Libra Reserve composed of real-world assets: cash, cash equivalents, and short-term government securities.

3. A governance system by a Switzerland-based independent organization (Libra Association) and its subsidiary, which develops and operates the network (Libra Networks).

1.1 A distributed ledger: Libra Blockchain

The Libra Blockchain is a programmable distributed ledger, with an open-source infrastructure, that focuses on scalability to serve its mission of powering transactions “for billions of people”.

To achieve this goal, this backbone of the payment system must allow for (i) settlement finality (ii) high-transaction throughput, (iii) low latency, and an (iv) efficient high-capacity storage system. It further needs to be (v) interoperable and (vi) upgradeable.

The Libra Blockchain relies on the following six characteristics:

For some of the technical details about its dedicated programming language Move (and smart contracts), please refer to our previous report. The testnet is available here.

1.2. A network composed of real-world currencies: Libra Coins and Libra Reserve

1.2.1 Single-currency stablecoins and Libra Reserve

Diverging from its original design, the Libra Network now strives to also offer single-currency stablecoins (e.g., ≋USD, ≋EUR, ≋GBP, etc.) and incrementally increase the number of supported currencies.

Each of these stablecoins will be fully backed by collateral held in the Libra Reserve, an off-chain reserve composed of two types of high-quality liquid assets (HQLA):

• Short-term government debt securities constitute at least 80% of the face value of every Libra stablecoin in circulation. Eligibility constraints are a maximum maturity of three months, a minimal rating of A+ from S&P, respectively A1 from Moody’s, and sufficient liquidity on secondary fixed-income markets.

• Cash, cash equivalents, and short-term money market funds constitute at most 20% of the Reserve. These assets would range from cash to overnight sweeps into money market funds that invest in short-term (up to one year’s remaining maturity) government securities with similar risk and liquidity profiles as short-term government debt securities.

Various risks such as currency risk from fluctuating foreign exchange rates, as well as spillover, interest, and credit risks, might be mitigated by requiring every issued single-currency stablecoin to be fully collateralized with dedicated assets. The Libra Network thus appears to be primarily collateralized on an individual and not an aggregate level.

The Libra Network will manage the associated reserves and already stated a strong interest to directly incorporate CBDCs (Central Bank Digital Currencies2) as a single-currency stablecoin within the Libra blockchain, whenever possible.

1.2.2 Multi-currency Libra Coin (≋LBR)

While the single currencies on the Libra platform would be thus also available as products on their own, some of them would be pooled together into a currency-basket, Libra Coin or “≋LBR”. This was already envisioned in the initial layout of Libra.

The multi-currency Libra Coin would be similar to the Special Drawing Rights (SDR) of the International Money Fund (IMF) and thus have fixed nominal weights.

While it is thus not yet known which currencies will be included and what their respective weight will be, Libra made an example of composing LBR out of “≋USD 0.50, ≋EUR 0.18, ≋GBP 0.11, etc.”. The Association further stressed the intent to work together with regulators, central banks, and international organizations (e.g., IMF) under the FINMA “college” to define a commonly acceptable basket composition.

From a technological point of view, the ≋LBR is expected to work as follows:

• Composability: every stablecoin is issued as an individual token and fully backed by Reserve assets, making ≋LBR highly composable.

• Deployed in an approved smart contract: the exact composition would be defined in the ≋LBR smart contract.

• Parameter changes(e.g., weights, the addition of new stablecoins) would be submitted for approval by network validators.

Graph 1, below, conceptualizes the interaction and distinction between reserve assets, single-currency stablecoins, and ≋LBR.

Graph 1 - Conceptualization of reserve assets, stablecoins, and ≋LBR

Finally, it is intended that ≋LBR could be used for two distinct purposes:

• As a cross-border settlement asset3: this border neutral currency could be used on a B2B basis to settle payments of multinational trade agreements, or on a C2C basis to improve the process of sending and receiving remittances.

• As a neutral & low-volatility currency for people and businesses in countries that do not “have a single-currency stablecoin on the network yet”.

1.3 Libra Association and its functions

The Association is an independent membership organization headquartered in Geneva, Switzerland. It is governed by the Libra Association Council with one representative per Association Member.

The Association’s declared purposes are:

• Governance: the Libra Association aims “to coordinate and provide a framework of governance decision-making for the Libra network and Reserve”. This is the primary function of the association.

• Operation oversight: the Association would oversee the operation and evolution of the Libra payment system, through its subsidiary (Libra Networks).

• Provision of compliant services: the Association aims to “facilitate the provision of services on top of the Libra Blockchain in a safe and compliant manner”. For instance, it would include the approval of new smart contracts by third parties.

• Social impact grantmaking: the Association wants to “establish social impact grantmaking in support of financial inclusion”.

In addition, according to the whitepaper, major policy decisions require the consent of two-thirds of the Council representatives (i.e., the same supermajority of the network). It is also required in the Libra Byzantine Fault Tolerance (LibraBFT) consensus protocol.

Members of the organization consist of “businesses and nonprofit organizations” from around the world. As of writing, 8 of the 28 original founding members have already left the Libra association. One of the leaving members, Visa, explicitly stated regulatory concerns as a motivation to leave. Graph 2, below, shows the original composition of the Libra association and which members already left.

Graph 2 - Active members of the initial Libra Association

However, three new members (Tagomi, Shopify, and Heifer) have joined since its inception. The process of how new members might join the Association is clearly specified and envisions a “market competition” that supposedly replaces the initial ambition of Libra to - over time - become a permissionless network. The competition would center around the following capabilities:

1. The provision of payments and financial services to businesses and consumers.

2. The ability to operate independent validator nodes that increase the security and reliability of the Libra consensus protocol by having non-correlated failure risks.

3. The ability to actively participate in the governance and evolution of the Libra project.

1.4 Description of network participants

According to the whitepaper and other working documents, multiple parties would be involved in the network operations:

• Members of the Association are the core of the Libra network and may decide over network-wide governance.

• Designated Dealers act as intermediaries between the Libra network and other for-profit entities.

• Regulated Virtual Asset Service Providers(“VASP”)4 are a second layer of intermediaries that interact with Designated Dealers and offer services to the general public.

• Certified VASPs are non-regulated VASPs that comply with internal regulations.

• Unhosted Wallets are unknown third parties that operate within the Libra network.

Table 1 - Overview of network participants

The below graph illustrates a conceptual structure that displays how these various players are interacting. The respective tiers indicate differences in terms of (i) conditions of participation (unlimited to limited), (ii) relationship to the Libra Association (defined to undefined), and (iii) regulatory burden (decreasing).

Graph 3 - Description of the conceptual network architecture

2. What are the differences and similarities with Libra v1?

Table 2 - Overview of the main changes between Libra v1 and Libra v2

3. Assessing its potential implications

While Libra was careful to highlight their intent to comply with concerns raised by global regulators, it is unclear whether some of the implemented changes would mark a radical difference with the previous proposal.

The initial whitepaper was very careful to stress the fact that Libra was a “cryptocurrency” and seemed to be particularly retail-oriented in the terminology6. One potential interpretation is that Libra deliberately tried to label itself as a cryptocurrency to mark itself as one out of several solutions dedicated to everyone’s daily use. Even though this notion has fully disappeared, with the new whitepaper wording being more transparent and technical, it still remains fairly similar in design: Libra Coins are stablecoins, i.e., cryptocurrencies running on a permissioned blockchain.

3.1 Could Libra impact monetary stability?

Libra does state, for example, their desire to cater towards feedback presented by the G20-composed Financial Stability Board (FSB). More explicitly, the FSB’s most recent consultation paper on stablecoins mentions that Libra might substitute sovereign currencies and therefore impose risks on the monetary stability of various countries. Libra itself pointed out that the Association would “work with the relevant central bank and regulators” to make a dedicated stablecoin available and thus mitigate the risk of currency substitution.

This hinges on the premise that Libra is narrowly overcollateralized. However, the reserves of Libra constitute out of two different elements, short-term government debt securities and fiat currencies. Additionally, Libra made it clear that only short-term government debt with a rating of at least A+ (i.e., Standard & Poor’s) would be acceptable.

As of now, only 37 countries have such a rating. Displayed below in Table 3, the predominant number of countries have a lower rating. Most notably, most of the countries with ratings below A+ are also at higher risk of having their currency “substituted”. As such, there seems to be an inherent conflict between collaborating with central banks to ensure their monetary stability and maintaining a high quality of collateral.

If all stablecoins were to be partially reflected in the Libra composition, there might be a spillover risk from poor collateral of a single stablecoin onto the basket-currency ≋LBR that acts as the network-wide settlement asset.

Nonetheless, this risk is likely addressed by merely restricting the number of stablecoins that compose “≋LBR” to the ones with the best-rated collateral.

Table 3 - Using the rating of government debt securities to identify countries with eligible stand-alone stablecoins

Source: Binance Research. Data from Worldbank, Standard & Poor’s.

3.2 Regulation and the broader stablecoin ecosystem

Generally, Libra uses a three-tiered design to stay compliant with applicable regulations. Regulation occurs at the (i) level of the Libra Association, (ii) protocol-level, and the (iii) VASP level. The first two are internal, whereas the last - and arguably most demanding - level is externalized to the VASPs.

The Libra Association applied to the Swiss regulator, FINMA, for a Payment System license. In order to process the application, the FINMA has initiated a “College” where they involve “more than 20 supervisory authorities and central banks from around the world”. As such, a payment system may very likely qualify as being “systemically important”7 and would have to comply with even more stringent criteria laid out by the BIS. It is important to note that there are very few payment systems, and most of them are operated by a central bank and of only regional scope. Libra could thus do to payment systems, what SpaceX did to the space industry.

Additional regulation at the Association level is internally imposed and governs (i) due diligence for all parties in the Libraverse (including association members), (ii) the creation of a risk-based compliance program with a supervisory body, the Financial Intelligence Function (“FIU”) and (iii) risk-based conditions of participation.

The protocol level is implemented as an automatic regulation that governs all on-chain activity. It imposes limits on transactions and balances of select addresses and prevents sanctioned addresses from sending or receiving currency. Furthermore, wallet addresses located in select jurisdictions (e.g., North Korea and Iran are on the FATF’s blacklist) may be identified by their IP address and subsequently blocked from participating in the Libra network.

The protocol level also addresses Unhosted Wallet users and their higher risk profile. Unhosted Wallet users do not undergo the same onboarding process as other users and thus pose a higher threat from an AML/CTF perspective. While the intention is to manage this risk with particularly stringent oversight and lower transaction/ balance thresholds, users could conduct some sort of "Sybil attack” on the Libra Blockchain and simply create multiple wallets. Such behavior would be identified and prevented on the protocol level.

The last relevant piece of Libra’s effort to stay compliant involves the VASPs. VASPs will be forced to comply with the so-called “travel rule”. The travel rule is applicable to cryptoassets since January 2020 and requires the regulated entities to pass on information about the asset owner. The association will provide an “off-chain protocol to facilitate compliance with Travel Rule and record-keeping requirements”. Most interestingly, Libra Networks may force Unhosted Wallet Users to also provide equivalent information whenever requested.

Libra highlighted that it intends to move to its mainnet “within the next months”. Simultaneously, the previously mentioned recommendation from the FSB urged regulators to roll out local, respective regulation before Libra was to launch. As this regulation would not only be applicable to the stablecoins of Libra, but more generally to all stablecoins, existing projects would also likely need to comply with such regulation.

Yet, pressure on existing stablecoins is not only originating from stablecoins moving into the spotlight of regulators, but also from increased competition on non-trading functions of stablecoins (e.g., remittance, payment).

The existing stablecoin market is currently dominated by Tether and several additional, smaller players, such as Paxos, Centre, and Trust Token. The use-cases of such stablecoins rely primarily on the existing crypto-industry and facilitate trading on exchanges, arbitrage across multiple trading venues (e.g., BTC/USDT trading pairs), and a more broadly usage in various centralized- and decentralized applications (e.g., DeFi).

On the contrary, Libra’s use-case is very different as it would focus on use-cases that are not related to trading. As stated before, Libra’s focus is on financial inclusion and establishing a retail and corporate financial infrastructure for payment applications across its global ecosystem, composed by its network of partners. One particular noteworthy use-case relates to the benefits of improving the technical functionality of currency, i.e., making it programmable. Features like Hashed time-locked contracts (HTLCs) could bring great efficiency improvements to the current payments landscape. As discussed in a previous report on HTLCs, there are many conceivable benefits from atomic delivery-vs-payment (DvP) and payment-vs-payment (PvP).

While, as discussed in section 1.3, several of the most prominent partners have opted out (e.g., Paypal, Mastercard, Visa8) since June 2019, we expect multiple new partners to join (back into) the Association once the new roadmap and regulatory environment provide increased clarity on what to expect from Libra.

If ≋LBR were to become widely used with products directly quoted in ≋LBR, we could imagine new stablecoins, both fiat-backed (e.g., collateralized stablecoin) and crypto-backed (e.g., Maker), replicating its peg on multiple permissionless networks like Ethereum. This optimistic long-term vision could also entail a future where Libra Coins would be added onto multiple crypto exchanges once the networks further matured and became even more commonly adopted. If so, Libra could act as an alternative to existing stablecoins, hence increasing the competition on existing market participants. However, in this scenario, benefits could be massive to the rest of the crypto-industry, pushing the adoption to the masses.

In short, Libra Coins (LibraUSD, LibraEUR) would compete with existing cryptocurrencies on non-trading use-cases such as remittances, programmable currency, and other applications. Yet, the permissioned component of the Libra network, with smart contracts requiring a pre-approval from validators to be deployed, would prevent its adoption in emerging sectors like decentralized finance (DeFi) where anyone can deploy a new protocol and applications with full network composability. Subsequently, Libra Coins and stablecoins are unlikely to be direct competitors.

3.3 Will Libra help to bank the unbanked?

As indicated earlier in Chapter 3.1, the stated eligibility criteria for collateral would de facto exclude most of the countries from having their currency added to Libra. If these rules were to be enforced, more than 70% of the global population would be excluded from having a dedicated stablecoin. While this could thus be perceived as negative for users, the opposite is true. The alternative of having a dedicated single-currency stablecoin is for Libra to provide its multi-currency asset, ≋LBR, to these (relatively) low-rated countries.

Conversely, this could - theoretically - allow roughly 70% of the global population to get exposure to a stable currency. Before, however, being able to use Libra, users must set up a wallet, which is theoretically possible via three different wallet providers: (1) Unhosted Wallets, (2) certified VASPs, and (3) regulated VASPs.

However, Libra already pointed out that Unhosted Wallets and certified VASPs might only become available in the future, leaving regulated VASPs as the only gatekeeper to the Libra universe.

Notably, all regulated Virtual Asset Service Provider entities must be registered or licensed in 1 of the 38 FATF member jurisdictions, effectively excluding local organizations from poorer, less developed countries. To further understand this dimension, it is necessary to point out that the current financial institutions (e.g., JP Morgan) are the candidates most likely to participate as a VASP. Since these VASPs would continue to carry most of the regulatory burden - as discussed earlier in chapter 3.3 - profits from the user’s activity must exceed the costly on-boarding and compliance process. In addition, some of these financial institutions are already working on proprietary distributed ledger technologies (e.g., JP Morgan on its “JPM Coin” and the Quorum blockchain), which may potentially make them not eager to collaborate.

Even though a risk-based AML approach allows VASPs to exercise some flexibility, the most straightforward question to ask is why the existing global financial institutions would go through the costly process of onboarding customers to Libra, but not to their own platform. From a financial perspective, this would only make sense if transaction fees and other user-generated revenue are higher in Libra than within the current banking system.

Naturally, this is a simplistic take, as the boundaries between financial inclusion and access to a stable currency have been blurred. Out of the ~5.5 bn people living in countries with an S&P rating below “A+”, “only” ~1.7bn people do not have access to financial accounts. Furthermore, barriers to financial inclusion exist not only in the form of on-boarding costs, but must be complemented with, for example, insights from the latest WorldBank & BIS report on “Payment Aspects of Financial Inclusion”. This report identified the following elements as the main drivers for financial inclusion:

“Fintech offers opportunities [to improve financial inclusion via]: (i) transaction account and payment product design; (ii) access points; (iii) awareness and financial literacy; and (iv) large-volume recurrent payment streams.

Source: Bank of International Settlements, World Bank.

Arguably, this payment system, with its strong ties to Facebook, is well-suited to create an intuitive product design that is highly user-friendly. For example, Calibra, the wallet developed by Facebook, would be directly integrated into popular services like Whatsapp and Facebook Messenger. As such, the Libra project could immediately address two out of the four main drivers of financial inclusion.

In the long-term, network effects and the addition of Unhosted Wallets would greatly improve “access points”. Once these access points are there it is likely that Libra is also going to be used for remittances or “large-volume recurrent payment streams”. Consequently, Libra could not only completely reshape the global payment system but vastly increase the levels of financial inclusion. (If they find a way to minimize the Unhosted Wallet User’s burden to comply with regulation such as the travel rule, which seems challenging with their currently pursued approach).

For instance, a store in Manila could sell its goods to a party located in Argentina with greater facility, transacting in a single stable currency for both of them. The transaction types without Unhosted Wallets are conceptualized in the below graph.

Graph 4 - Conceptualized overview of transaction types in Libra

Contrary to Unhosted Wallets with balance and transfer restrictions, crypto-collateralized stablecoins (e.g., Dai on Ethereum) represent an alternative already available that can be used by anyone on the planet, without any restriction, and transferable without any limit in a fairly short amount of time at a low transaction cost.

Libra’s edge is, of course, the promise to scale this payment network far beyond the scope of what projects like MakerDAO could achieve in the foreseeable future. Such a global payment network would have implications in bilateral trades across countries and could ultimately lead to capital efficiency gains worldwide9.

3.4 Is Libra’s Reserve design compatible with a stable pegging system?

Unlike most stablecoins, the Libra Reserve would mostly own non-cash assets. Instead, it would rely on short-term securities (80%) and other money market instruments (20%).

As stated, there are two primary risks relating to the redemption process of the Reserve:

• Liquidity risk: Designated Dealers could fail to meet their obligation to provide a low-spread market for customers to buy/sell Libra Coins to domestic currency.

• Interest and credit risk: abrupt changes in interest rates might depreciate the collateral value. As seen in the recent market movements, there is a possibility that the capital component of the short-term securities would depreciate in the event of an interest rate shock, leading to depreciation of the collateral (aka the value of the instrument). Relatedly, yet more unlikely, is a scenario within which the collateral issuer is entirely defaulting.

To prevent these scenarios, the two suggested solutions are:

• Pre-determined arrangements with third-party administrators: it would rely on a “pre-existing arrangement with a third-party administrator or dealer to assist, in an administrative capacity, in burning Libra Coins for end-users and liquidating assets comprising the Reserve to make payment as appropriate.”

• Capital buffer: the Libra Reserve will feature a “loss-absorbing capital buffer” to cope with credit, market, and operational risks of the payment system. In short, the system would be overcollateralized to prevent adverse events.

However, emergency operations would occur if the system were to become temporarily undercollateralized. These operations would occur under the guidance of relevant regulatory authorities. According to the multiple whitepapers, it would include:

• Delayed redemptions: Libra Coin redemptions could be postponed to allow additional time to liquidate some of the Reserve’s assets during a larger window of time to avoid selling at a significant discount. As collaterals are backed by short-term high-quality maturity instruments, it would expire at face value. Hence, this strategy would not lead to a financial loss (unless the issuer would default10) with a redemption time capped to the maximum maturity allowed (i.e., 3 months).

• Penalty (i.e., “haircut”) for early redemptions: in the most adverse circumstances, a redemption penalty could be applied for instant redemptions for users not wishing to wait until redemptions resume. Such users would also need to bear the spread between the face value and the market price of the asset.

• “Global settlement”: Libra Networks, the Swiss subsidiary of the Association, would further have the option to temporarily suspend redemptions to liquidate its remaining assets over a window of time deemed sufficient to minimize market impact. If Designated Dealers were operating, they would be expected to receive, on behalf of consumers, funds in exchange for Libra Coins based on the liquidation of a portion of the Reserve’s balance.

The team behind Libra stated its intention not to become a monetary issuer, with the rationale being that each Libra Coin would always be fully backed by collateral. To that end, Libra properly addresses the function of banks being subject to reserve requirements and fractional money (i.e., banks print money based on the requirement).

However, Libra would still “print money” based on assets that are not cash. Regardless of their maturities, zero-coupon bonds are typically issued at a discount, as they carry a risk higher than cash. Instead, the system treats short-term money instruments as a commitment to receive cash at maturity, with a similar risk profile. The system relies on positively-yielded instruments to reward validators and other parties in the system, hence implicitly admitting the reward model being dependent on the instruments added to the platform. In general, the higher yield, the higher the risk profile of a financial security. As a result, a basic discounted cash flow analysis would price Libra Coins below face value.

In addition, the system would likely rely on multiple portfolio managers in charge of managing the Reserve, which might raise additional concerns on whether these Libra Coins are indeed fully collateralized stablecoins as they would be subject to human decisions.

Finally, with at least 80% of the assets being backed by short-term government securities, it is possible that the Libra Reserve would become a major buyer of short-term government debt securities if the project were to be widely adopted, hence with possible adverse effects on the traditional fixed-income industry (i.e., an increase on the demand side would lead to lower yields).

Mostly addressing previous concerns, the team indicated its intention to work with central banks to directly incorporate central bank digital currencies (CBDCs) in the network. While this would mitigate risks relating to interest & credit risk and monetary creation, such a scenario requires central banks to view Libra as a monetary platform that is compatible with their own visions and goals for CBDC.

4. Conclusion

Libra matured in its narrative and general conception - instead of simply rolling out a new “cryptocurrency” to its vast user-base, Libra seemingly reacted to the (mostly) negative response from public officials and opted for a much more cooperative approach that centers around building a global, blockchain-based payment system.

However, its core mission remains intact with multi-currency libra being set to co-exist with traditional stablecoins (e.g., LibraUSD, LibraGBP). In that regard, the project has not only re-stated its desire to launch but broadened its product offering towards enabling a global audience access programmable currencies, including a “SDR” currency.

This is already remarkable on its own, as most payment systems are domestic, have not seen real innovation and seemingly lack ambition - an optimistic comparison would be to say that Libra aims to do to the payment system what SpaceX did to the space industry: shaking the foundation of a well-established system with high entry barriers.

While Libra’s approach to release without pre-regulatory approval was criticized, it has forced global regulatory bodies to work on a general framework to work with Libra, hence fast-tracking the public discussion about digital currencies in modern society. Unintended side-effects were the increased development speed of China’s CBDC and the Libra Association losing some of its founding partners due to the strong regulatory pushback.

Nonetheless, one of the core elements for Libra to really become a global settlement system are Unhosted Wallets. Unhosted Wallets would greatly improve the availability of Libra, hence making them the key drivers of financial inclusion. With the intent to quickly go to market, Libra somewhat sacrificed these elements - for now. The team behind Libra has made it very clear that they still see Unhosted Wallets as a core element that is crucial to their mission and will find a way to balance regulatory compliance and intuitive product design.

Despite critical concerns about monetary stability and the associated pegging mechanism, Libra has incorporated various suggestions from public bodies like central banks and other institutional entities and seemingly continues to reaffirm its commitment to its broad mission for financial inclusion.

Overall, Libra still lives to its initial ambition. Despite most commentators considering Libra to have scaled down, in our view, this updated whitepaper reaffirms the ambition of the Libra organization to massively impact and reshape the global payment industry, disregarding the time it might take.

5. References

• Bank for International Settlements (2020). Payment aspects of financial inclusion in the fintech era. Available online at: https://www.bis.org/cpmi/publ/d191.pdf

• Bank for International Settlements (2001). Core Principles for Systemically Important Payment Systems. Available online at: https://www.bis.org/cpmi/publ/d43.htm

• Baudet, M., Ching, A., Chursin, A., Danezis, G., Garillot, F., Li, Z., ... & Sonnino, A. (2019). State machine replication in the Libra Blockchain. Available online at: https://developers.libra.org/docs/assets/papers/libra-consensus-state-machine-replication-in-the-libra-blockchain/2019-09-26.pdf

• Binance Research (2019). First Look: Libra. Available online at: https://research.binance.com/analysis/libra

• Blackshear, S., Cheng, E., Dill, D. L., Gao, V., Maurer, B., Nowacki, T., ... & Zakian, T. (2019). Move: A language with programmable resources. Available online at: https://developers.libra.org/docs/assets/papers/libra-move-a-language-with-programmable-resources/2020-04-09.pdf

• European Central Bank (2014). Regulation of the European Central Bank (EU) No 795/2014 of 3 July 2014 on oversight requirements for systemically important payment systems (ECB/2014/28). Available online at: https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32014R0795

• Financial Action Task Force (2019). GUIDANCE FOR A RISK-BASED APPROACH: Virtual Assets and Virtual Asset Service Providers. Available online at: https://www.fatf-gafi.org/publications/fatfrecommendations/documents/guidance-rba-virtual-assets.html

• FINMA (2020). Libra Association: FINMA licensing process initiated. Available online at: https://www.finma.ch/en/news/2020/04/20200416-mm-libra/

• Financial Stability Board (FSB)(2020). Addressing The Regulatory, Supervisory and Oversight Challenges Raised By “Global Stablecoin” Arrangements. Available online at: https://www.fsb.org/wp-content/uploads/P140420-1.pdf

• Libra. Whitepaper. V1 (2019). Available online at: https://libra.org/en-US/wp-content/uploads/sites/23/2019/06/LibraWhitePaper_en_US.pdf

• Libra. Whitepaper. V2 (2020). Available online at: https://libra.org/en-US/white-paper/

• The Block Crypto (2019). A Technical Perspective on Facebook’s LibraBFT Consensus Algorithm. Available online at: https://www.theblockcrypto.com/post/28194/a-technical-perspective-on-facebooks-librabft-consensus-algorithm

1. Such efficiency gains could refer to functional benefits in Payment vs Payment (PvP) or Delivery vs Payment (DvP) executions, made possible via technical innovation (e.g., Hashed Time-Locked Contracts).↩

2. Central Bank Digital Currencies (CBDCs) are discussed in some of our previous research analysis.
   - Binance Research (2019). First Look: China's Central Bank Digital Currency https://research.binance.com/analysis/china-cbdc
   - Binance Research (2020). Sweden’s Public Digital Cash: E-Krona. https://research.binance.com/analysis/e-krona↩

3. This idea was discussed in our previous report about Libra (v1). https://research.binance.com/analysis/libra↩

4. VASPs are defined by the Financial Action Task Force as gate-keeping entities that must be held accountable to AML/CTF regulation.↩

5. Mentioned only a single time in the first whitepaper (page 2). “ Some projects have also aimed to disrupt the existing system and bypass regulation as opposed to innovating on compliance and regulatory fronts to improve the effectiveness of anti-money laundering. We believe that collaborating and innovating with the financial sector, including regulators and experts across a variety of industries, is the only way to ensure that a sustainable, secure, and trusted framework underpins this new system.”↩

6. From the whitepaper, ↩

7. The European Central Bank, for example, devised the following (simplified) criteria to identify SIPS: (i) average processed value, (ii) market share, (iii) cross-border activity, (iv) connection to other FMIs. ↩

8. https://www.coindesk.com/ebay-stripe-follow-paypal-in-quitting-facebooks-libra-project↩

9. This would be in the long-term assuming Libra’s complete success and global adoption.↩

10. One might argue that if a sovereign country with a rating A+ defaulted on a bond repayment with a remaining maturity inferior to 3 months, Libra Coins’ peg would not be the primary anxiety from the perspective of the financial industry.↩