Taking stock

Dear friends,

Here is a quick "stock taking" before the start of the lazy period of the year, summer holidays!

Why did we come together?
We came together freely, to experiment and learn. Learn about the possibility of collaborating and creating value in a new formula: we are a non-profit with a twist - we have a token that could (in theory) serve as incentive for ... collaborating and creating value, of course

To make things more concrete, we also agreed on a compelling objective:

• offering the 1st MiCA-compliant token in Luxembourg.

What have we done to this date?
Quite a bit, I'd say!

1. Legal person
   Art. 4§1 of MiCA states:
   A person shall not make an offer to the public of a crypto-asset other than an asset-referenced token or e-money token in the Union unless that person:
   (a) is a legal person;
   OffChain Luxembourg a.s.b.l. has been incorporated as a "non-profit" in Luxembourg under the Law of 7 August 2023 (a mighty fine law, by Golly!) on June 4th, 2024 and we have declared the UBOs within one month, by July 3rd 2024, so we are well positioned.

2. Token issued
   We have set out the main tenets of the crypto economic system envisaged and on this basis issued the OCLT token on Hive / Hive Engine.
   Several milestones have been reached:
   we have paid and accepted payment in OCLT,
   exported and imported services in OCLT and HBD
   we have an order book and an LP allowing people to trade OCLT and indeed even people from outside the community have engaged in trading

3. CASP account
   Art 10§3(b) of MiCA states:
   Offerors of crypto-assets other than asset-referenced tokens or e-money tokens that set a time limit on their offer to the public of crypto-assets shall have effective arrangements in place to monitor and safeguard the funds or other crypto-assets raised during the offer to the public. For that purpose, those offerors shall ensure that the funds or crypto- assets collected during the offer to the public are kept in custody by one or both of the following:
   (a) a credit institution, where funds are raised during the offer to the public;
   (b) a crypto-asset service provider (CASP, n.ed.) providing custody and administration of crypto-assets on behalf of clients.
   As we aim to be a bankless association (for now at least), offering OCLT to the public was contingent upon our securing an account with a CASP. Our application with bitFlyer Europe S.A., a MiCA-compliant CASP, has been approved last week, so whenever we launch our offer, we'll be able to collect the crypto funds being raised on our bitFlyer account.

We have also organized a nice event on Tuesday 25th explaining this and talking about exciting developments in the Bitcoin ecosystem, we'll have our first virtual event Monday 8th July and we plan to export OffChain Luxembourg to Bucharest on July 18th.

What remains to be done?
A lot remains to be done though!

1. Internal regulations
   Internal regulations is a critical document because it has to describe in detail how we patch together the Moebius band - bringing the centralized dimension of law and the decentralized dimension of crypto into ONE dimension.
   I have started writing some proposals in Discord and some others in WhatsApp, I'll keep working on it to come up with a coherent system. You are more than welcome to contribute. The rules that the internal regulations will capture are going be the basis for the White Paper

2. White paper
   Art. 4§1 points (b),(c),(d) require a offeror to draw, notify and publish a crypto-asset white paper
   ESMA has just published on Thursday the draft format that we have to respect. I expect the draft to be adopted by the Commission without modification.

3. Marketing communications
   Art. 4§1 points (e),(f) require a offeror to draft and publish marketing communications
   I think we haven't started on those yet

4. Financial statement
   This is not urgent but I've heard that the sooner we start, the easier it will be: in order to comply with the Luxembourg law on non-profits, we'll need to be able to present a financial statement.

Your thoughts?
Let me know your thoughts on all this, whether you want to contribute (being a passive member is absolutely ok too, just say so), how do you think you can contribute (in case you want to) and when do you think you might be able to chip in (in case you want to).
Any questions are also welcome

Best regards
@sorin.cristescu
President
OffChain Luxembourg