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Jenny Leung

Blockchain & Fintech Attorney

Jenny Leung is a regulatory attorney based in New York, with a background as a former Australian securities regulator. Her expertise lies in blockchain & crypto, fintech, and data privacy. Jenny has a Bachelor of Laws (LLB) and Bachelor of Commerce (BCom) with a focus on Finance and Law from UNSW, along with a Graduate Diploma of Legal Practice from The College of Law Australia. She also participated in a Study Exchange Program focusing on Law at Università Bocconi. Jenny has held various roles including Blockchain and Fintech Attorney at Ketsal, Key Contributor to Australia's National Blockchain Roadmap at the Department of Industry, Science, Energy and Resources, Data Privacy Associate at PwC, Regulatory Attorney at ASIC specializing in Financial Market Infrastructure and Technology, and Immigration Attorney at Sydney Immigration Lawyer. She also gained experience as a Legal Intern at CMS Legal Services.

Highlights

Oct 22 · linkedin

Over a year, multiple drafts and many debates later, we are so excited to finally publish our framework of data-driven metrics that would hopefully bring more meaning to the term "decentralization". Here are some of my favorites that we discuss in the framework 👉

  1. Mining Power Concentration - the only metric in the framework that sits across all three layers of decentralization (computational, economic, political). One only has to look at the recent strike by Filecoin miners to appreciate its importance: https://lnkd.in/evcCJrM

  2. Market Attack Cost - how much would it cost to cause the market price to crash to zero? How many BTC's would I have to sell/short?

  3. Potential Access to Material Non-Public Information (MNPI) - examples include core devs having access to information regarding critical bugs and making decisions before revealing the MNPI to the public.

You may also be wondering where the Bahamas Test is - if you figure out a way to quantify this, do let me know 😋

Many thanks to Nicholas Gans Adam Zarazinski Zach Finzi Diana J. Stern and Lane Rettig for your help and feedback on this!

Do you have a favorite metric?

https://lnkd.in/egfcs_N

Feb 14 · linkedin

International Organization of Securities Commissions (IOSCO) published its Final Report on Crypto-Asset Trading Platforms this week. Despite some changes, its conclusion remains unchanged from the May 2019 version - that it is not appropriate to prescribe new standards or requirements having recognized the evolving nature of crypto-asset markets globally.

Given what we have seen the year, the evolving infrastructure behind tokenized securities, the growing role of transfer agents in the US vs blockchain as the golden source of truth in other jurisdictions, this is not surprising.

What was new in the report was Annex C - IOSCO's responses to the comments it received. One commenter had suggested that CTPs that also hold crypto assets should be subject to the same requirements imposed on licensed custodians or CSDs. IOSCO agreed & updated the report to note that regulators should also consider the Principles for Financial Market Infrastructures (PFMIs) when considering the issues associated with safeguarding crypto assets.

Another comment highlighted the lack of a unified framework and regulatory arbitrage. IOSCO's response was "a uniform approach to regulation is not practical." Looks like we won't be seeing any new Principles for Crypto-Assets from IOSCO anytime soon ...

Jenny Leung
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Location

United States