Since the catalogue of financial instruments in the German Banking Act was expanded by the introduction of crypto assets, the question arises if blockchain-based e-money units qualify as crypto assets at the same time. If so, e-money tokens would not only be payment units but also financial instruments and therefore could trigger authorization obligations according to the German Banking Act.
The global, political protest against the planned stablecoin Libra is growing and governments are threatening with prohibiting the project even before its start. But is a prohibition of stablecoins in Europe even legally possible?
Can e-money be issued on a blockchain? And is it possible that in individual cases, blockchain coins or tokens must be qualified as e-money in the sense of the European E-Money directive 2009/110/EC? A topic rarely discussed so far but with great potential for disruptive payment business models.