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Supervision is a challenge. Cryptocurrencies are currently not classified as securities, so they fall outside of the remit of market supervision. And when it comes to ordinary bonds and shares, pump and dump schemes are forbidden, and front running and market manipulation are not allowed. However, these things are mainstream in cryptocurrencies. Additionally, all ICOs need to fall under general regulation and adhere to the same rules as other companies. Traditional intermediaries are being replaced by new types of advisors and consulting firms, promoting ICOs to investors. They’re mainly selling hope instead of giving proper advice, resulting in the loss of the duty of care that intermediaries usually have. Tackling these practices is complicated for the AFM, however, because of the way the intermediaries are structured. Referring to Christensen’s comparison with offshore illegality, parts of criminal activities happen outside the Dutch jurisdiction and become a matter of global governance. However, essential questions are still unanswered, namely: should companies issuing security in cryptocurrency be regulated? How can we ensure the intermediary function in investments? Supervisors like the AFM all share the same view on what should be done, yet what is lacking is speed and leadership within the regulating community. Continuous innovation demands fast reactions and, in the end, cryptocurrencies should be regulated just like ordinary payment systems. The roles of public entities in this process should be acknowledged. 16:20 PM Hennie Verbeek – head of the Dutch Financial Intelligence Unit (FIU) – said that she clearly recognizes the public duty of regulation. Verbeek talked about a Harvard case study during which the participants heard stories about the owners of shops, pubs or restaurants being pressured to sell their businesses for a huge amount of money. It also appeared during this Harvard case study that in hospitality, for instance, private loans are often used to finance the business. Yet the source is often unknown, opening the door to criminal investments. As a result, the license application process was being examined and it appeared that mainly the person who was going to run the business was screened. That shifted to: in what way is the business financed? It’s about asking questions. To combat issues like these, public and private authorities should collaborate and exchange data, playing their own roles. For instance, disapproval of loans happens through the identification of sources that are not transparent, yet is only possible with information provided by banks and accountants. The FIU receives, analyses and disseminates information. It uses and exchanges information at both the national and the international level, contributing to combatting crime both nationally and globally. The FIU receives reports from the private sector (gatekeepers are obliged to report to the FIU if they see something unusual), analyses these and adds value by combining data with information from other sources (e.g. the police, real estate companies). The outcome of this analysis is disseminated to law enforcement agencies if needed, so they can act. The FIU also analyses big data so it’s able to predict new trends. In accordance with John Christensen, Verbeek advocated agile cooperation and the expansion of partnerships (public–public, private–public and private–private). New players like cryptocurrency exchange platforms, exchange offices and the GAFA companies (i.e. Google, Apple, Facebook and Amazon) have to be regulated, Verbeek said. However, that will take some time.