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The GDF Code of Conduct: FAQs

Discover the why, who, and how of the GDF Code of Conduct 

Contents: 

What is the GDF Code of Conduct? 

Why did GDF create the Code of Conduct?

How was the GDF Code of Conduct developed?

What is GDF’s role in the Code of Conduct?

What is the scope of the GDF Code of Conduct?

How does the Code of Conduct remain relevant?

Why self-certify to the Code of Conduct?

What type of firm has certified to the Code of Conduct?

Who sees that my firm has self-certified?

How can my firm self-certify?

  1. What is the GDF Code of Conduct?

The Global Digital Finance (GDF) Code of Conduct is designed to establish a common understanding of the best practices and governance policies for the global digital asset market. 

Divided into 10 parts, the Code addresses each component of the digital finance value chain. It is complemented with the Taxonomy for Cryptographic Assets, which sets out a consistent and reliable framework for defining tokens, their lifecycle, and the market actors who engage with them. 

Both the GDF Code of Conduct and the Taxonomy for Cryptographic Assets are written from the perspective of general global regulatory frameworks. Given the borderless nature of digital assets the Code defines best practices on a global scale. 

  1. Why did GDF create the Code of Conduct?

Global Digital Finance (GDF) was set up to drive the adoption of global best practices and demonstrable governance policies, developed in a shared engagement forum with the industry, policy makers, and regulators, to enable the digital asset market to thrive.  

GDF believes the ability to rapidly deploy networks of tokens at low cost represents a massive opportunity for the financial services ecosystem and broader society, creating new asset classes, enabling new business models and improving the liquidity and transparency of both new and existing markets. 

However, the absence of a framework for mapping this growing variety of topics and an understanding of what constitutes best practice in the deployment and management of tokens posed risks to their creators, holders, and the broader ecosystem in which they operate. 

With this in mind, the GDF Code of Conduct was written to establish a shared understanding of the best practices for a new generation of token markets. Alongside this, GDF published the Taxonomy for Cryptographic Assets to establish a consistent language for describing the new activities being explored, as well as debating their implications. 

  1. How was the GDF Code of Conduct developed? 

The Global Digital Finance (GDF) Code of Conduct is created by the community for the community. To establish a strong shared understanding of these best practices, GDF convenes industry participants across financial services, law, and cryptographic industry practitioners to write the Code. 

For the Taxonomy and first three parts of the code (Part I: Overarching Principles, Part II: Principles for Token Sales and Token Sale Service Providers; and Part III: Principles for Token Trading Platforms), the drafts of the documents were published on the GDF website for a 60-day open public consultation period, and received 640 comments from 160 individuals and companies across the globe. During this time, GDF actively sought feedback from industry participants, subject matter experts, regulators and global policy makers, and held in-person roundtables in Paris, London and New York and two virtual roundtables.

The consultation review process itself concluded in October 2018, following GDF community meetings held in ten locations in Asia, Europe and North America. Consultation feedback was reviewed and assessed, and the Code of Conduct (Parts I-III) and Taxonomy were revised in response to this feedback, before being published on the GDF website. 

Since then, GDF workstreams have evolved, meaning that Parts IV-X were developed by dedicated Working Groups. GDF Working Groups are co-chaired by two or more GDF Advisory Council members. You can read more about past and open Working Groups here. 

The number of participants in the Working Groups contributing to the original draft of each code grew to in excess of 100 participants. As a result, there are now fewer responses in the public consultation process as the views of the broader community have already been collected and considered before the draft reached public consultation.

Nevertheless, the process remains the same: 

  • The draft of the Code is published for public consultation 
  • Feedback is received and considered by the working group 

This may lead to edits in the draft. If it is made clear that there are significant new areas to consider which would warrant their own part of the Code, it may lead to the creation of new Working Groups. 

The Code is then approved by the GDF Advisory Council, before being published and made available for self-certification. 

  1. How is the GDF Code of Conduct used? 
  • Demonstrate alignment with customers: GDF members use the Code of Conduct to demonstrate to their customers, investors, and the wider value chain that they are aligned from a technical, legal, and governance perspective. 

“We have used Code Certification in our marketing. It gives us a competitive edge.” – GDF Advisory Council Member 

  • Engagement with regulators: The GDF Code of Conduct provides a resource and engagement tool for discussions with regulators and policy makers across the globe. 

“The Code provides concrete guidance for regulators on what the industry thinks.” – GDF Working Member 

  • Education resource: Regulators and industry participants have used the GDF Code of Conduct and Taxonomy for Cryptographic Assets as an education resource. Whether for newcomers to the space, or from the perspective of developing guidance for the industry, the Code has provided a framework for mapping new asset classes, and the evolving ecosystem. 

“We have referenced the GDF Code and Taxonomy in our conversations on the development of guidance for cryptoassets.” – Member of the GDF Regulators’ Forum 

  1. What is GDF’s role in the Code of Conduct?

Global Digital Finance (GDF) is the leading global industry association, taking direction from its members on the key areas of focus in digital finance. 

When it comes to the Code of Conduct, our role is to convene this global community to determine the focus of the Code, facilitate its continued development, and enable its review and publication. This also includes creating engagement fora in which the principles of the Code can be discussed, and market participants from across the ecosystem can be consulted. 

GDF also enables its members to self-certify to the GDF Code of Conduct. 

  1. What is the scope of the GDF Code of Conduct? 

The Global Digital Finance (GDF) Code of Conduct addresses various aspects of the digital asset ecosystem:

Part I: Overarching Principles 

Part II: Principles for Token Sales and Token Sale Service Providers 

Part III: Principles for Token Platforms 

Part IV: Principles for Funds and Fund Managers

Part V: Principles for Token Comparison and Rating Websites 

Part VI: Principles for Stablecoin Issuers 

Part VII: Principles for Security Token Offerings and Secondary Market Trading Platforms

Part VIII: Principles for KYC/AML 

Part IX: Principles for Custody and Custodial Wallets

Part X: Principles for Market Integrity 

  1. How does the GDF Code of Conduct remain relevant? 

While the existence of digital tokens is not in and of itself new, the speed with which they are being deployed and the scope of value which these tokens represent is unprecedented. Given the pace of development and innovation within this industry, Global Digital Finance (GDF) recognises that the Code cannot remain in stasis and must be reviewed and updated continuously to be effective. 

Part I: Overarching Principles of the Code of Conduct addresses this, setting out that participants will respond to periodic surveys from GDF to enable the Code to remain a living document, in which new principles may be added on an as-needed basis.

As new developments emerge within the industry, certain parts of the Code will be re-opened for discussion and consultation. The KYC/AML Working Group remains open to GDF members, incorporating key industry developments, such as the Financial Action Task Force’s Recommendations, into the Code of Conduct. In autumn 2021, the Stablecoins Working Group will be reopened to look at the required updates to Part VI: Principles for Stablecoin Issuers, as well as the Stablecoin Taxonomy.  

  1. Why self-certify to the GDF Code of Conduct? 

GDF members who self-certify to the Code of Conduct demonstrate their commitment to best practices. 

As the industry grows and new market participants evolve, self-certification is a signal to regulators, policy makers, customers, investors, and the wider value chain that your firm strives 

for transparency, follows sound governance policies, and can be considered ‘the adults in the room’.

The adoption of the Code establishes a degree of trust and predictability across a new and rapidly evolving market. 

  1. What type of firms have certified to the GDF Code of Conduct? 

From established industry participants to new players, GDF members in the Code Certification programme represent the breadth of the digital asset ecosystem. This includes:

  • banks 
  • issuers 
  • advisory firms 
  • asset and fund managers 
  • auditors 
  • Exchanges
  • market data companies 
  • risk and compliance firms 
  • clearing services 
  • custodians and wallet providers 
  • liquidity providers 
  • tax and accounting firms 
  • consultancies 
  • infrastructure and network providers
  • law firms 

Anyone who is a GDF Patron, Advisory Council, or Working Member may self-certify to the Code of Conduct. 

See our Members’ directory here. 

  1. Who sees that my firm has self-certified to the GDF Code of Conduct? 

The members who have self-certified to the Code have their company name and logo listed alongside the specific parts of the Code on the GDF website. 

The Self-Certification Registry is also shared with the GDF Regulators-only Forum on a quarterly basis. 

Members may also choose to list the GDF logo on their website, signalling to customers and associates that they have self-certified to the GDF Code of Conduct and are committed to industry best practices. 

  1. How can my firm self-certify to the GDF Code of Conduct? 

Once a firm has become a GDF Patron, Advisory Council, or Working Member, they may self-certify to the Code of Conduct by completing this self-certification form. 

All GDF members are asked to self-certify to Part I: Overarching Principles, as well as the parts of the Code that are applicable to their line of business or project.