 Sorry, so I will go through the reading of the Linux Foundation and Trust policy. Linux Foundation meetings involve participation by industry and pastels, and it's the intention of the Linux Foundation to conduct all of its activities in accordance with applicable and trusting competition laws. It is therefore extremely important that attendees adhere to missing agendas and be aware of and not participate in any activities that are prohibited under applicable U.S. State, Federal, Foreign, and Trust and competition laws. Examples of types of actions that are prohibited at Linux Foundation meetings and in connection with Linux Foundation activities are described in Linux Foundation and Trust policy. If you have a question about these matters, please contact your company council or if you are a member of the Linux Foundation, feel free to contact and re-op the growth of the firm of Gastonauts with Grove LLP, which provides legal counsel to the Linux Foundation. Hyperledger is committed to creating a safe and welcoming community for all. For more information, please visit our Hyperledger code of conduct. So welcome everybody to this new meeting. Today we have a few new guests and I'm honored to have them both here. We are joined today by Ms. Luca Castellani from Uncetron and we also have Kate. I think both of them, you know, for joining us, Dave will give us their time. I would like to start first from Luca and would love to hand it over to him to have part of the speech. Luca, please. Thank you. Thank you, Andrea and many thanks to you for organizing with me. Any thanks to Kate for joining here. We have a very close cooperation with Singapore's IMDA. So it's a pleasure to have this conversation. I prepared a set of slides. I will do my best to try to share them now despite one year plus of these current situations that we were doing still, what best we can cope with. My name is Luca Castellani. I work in the Uncetron secretariat and I am the secretary of the working group that has prepared the model low on electronic transfer records. I would like to, I don't know if someone has, I see, I can get an echo in my headset so maybe one can mute. Everybody's muted Luca. I don't know. I'm trying to look if everybody please mute yourself. Only the speaker should be able to mute. Thank you. So I will try to keep this introduction as short as possible because I believe that we are all here in an informal meeting that is made of, I saw many names of distinguished experts in this field so I would prefer to have an open conversation about these issues when to have like a one-way illustration of what is going on. But first of all, just to be on the same page, Uncetral is the United Nations Commission on International Trade Law. It is a body of the United Nations system. I personally work for the Office of Legal Affairs of the United Nations secretariat. Uncetral has been established in 1966, has been active for more than 50 years. Its main task is to prepare legislative texts that promote the harmonization of commercial law, especially international business transactions law. And I would say also now modernization in the beginning that the mandate was more about harmonizing existing treaties, but now in many cases Uncetral is trying to set bigger standards for new issues. Many of you may have come across Uncetral when dealing with arbitration, maybe also sale of goods. In the field of electronic transaction, Uncetral started working already in the 1980s. And what is important is that we have four legislative texts, three are model laws, that is to say they work as a source of inspiration for national legislators. And so we encourage the national legislator to use them as closely as possible to the original model, because that of course does help to keep uniformity. But it's of course always possible to make some variations and sometimes with models where there are choices that help to make it fit better the legal tradition of that jurisdiction. There is also one treaty from 2005, the United Nations Convention on the use of electronic communications and international contracts. What is important here, the main takeaway is that altogether these four texts have been enacted in about 100 states. So we are talking about laws that are already enforced in half of the world. What is important is that these laws cover different aspects, we are complementary, but we are all based on the same fundamental principles. And this does open the door to broader adoption of the newborn, which is the model law on electronic transfer records. Now already at three getting four. This is of course the topic of today's discussion. You will see a lot of what I will say has to do not only with the function of this model law to enable, legally enable the use in electronic form of transfer documents or instruments, such as bills of lading promissory notes, but also because of reason the way it was enacted in Singapore. It is the keystone of the new vision that implements the concept of data pipeline in paperless trade. It is also comparable, all anti-trial texts are technology neutral, but this one it addresses specifically its implementation with distributed ledgers in the explanatory note. You can get these booklet in electronic form, the text of the model law and explanatory note in all six languages of the United Nations on the ANSTRA website ANSTRA.UN.WORK. So the core issue, as you know, certain commercial documents and instruments incorporate the right to delivery of goods or payment of sums of money. Of course, as I am a lawyer, I will not say that we give the title to the goods or to the money, but they are documents that represent the goods of the money and they give a good approximation of who could be entitled. And because we are very convenient, there have been centuries of commercial practice about them and they are widely used depending, of course, on the business case. So we are talking about visa relating and warehouse receipts when it comes to goods, visa of exchange, promissory notes, checks. And I see also interest for letters of credit, although whether they are transferable or negotiable, it depends on national law. And there's also some insurance certificates that can come in this list. At the same time, these documents also contain interesting information about the commercial transaction. And of course, for the for the visa relating and the warehouse receipts were very important as collateral in trade finance. What the common element of all of these documents is the fact that they circulate with delivery or with delivery and endorsement, which means that in the business practice, there is an assumption that they exist on paper. They can be possessed. Possession requires a tangible object. So in particular, Ancetral has worked on the issue of electronic visa relating. These electronic visa relating have been something that has been has been pursued for some time. Already, Ancetral is working also on substantive maritime law issues. So we'll see some elements in the Harbing-Hamburg rules, which is a treaty from 1978, but deals with the rights and obligations of the parties to a contract of carriage of goods by sea. When there were two articles, Article 16 and 17 of the modern law on electronic commerce, they have been enacted sometimes in some jurisdictions like Columbia or Guatemala, but they have never been implemented actually, as far as we know. And then the Rotterdam rules from 2007, this is actually a medium-neutral treaty. So based off relating under the Rotterdam rules, maybe it should equally on electronic or paper support. But the Rotterdam rules have not yet entered into force. There are five states parties and it needs 20 states parties to come into force. So this regime is not yet there. And in 2011, when we started working on the model of electronic transfer records, MLTR or also Melita, we looked around for existing laws. And in some cases, we found that these laws, they demanded the use of a specific technology somewhere based on registries and the PKI. They were specific to one type of transferable document or instrument. So for instance, one registry for promissory notes. And in some cases, we also created a special type of electronic transfer record. What does it mean? It means that they said this is an electronic promissory note, but it's not the equivalent of the paper promissory note. It has a special name. For instance, in Japan, where is the electronic recorded monetary claim, which is different. In some cases, we were successful. In some cases, it was less successful. But in all cases, there was a multiplication of IT solutions and there was the creation of a data style. Another issue was the creation of so-called electronic bills of lading based on contractual rules. And I think many of you are familiar with that. But these are not real electronic bills of lading. These are contract based commercial documents that mimic between the parties certain effects of the bills of lading. They are not opposable to fair parties and the law of bills of lading doesn't apply to them. When it comes to the MLTR, the fundamental issues are, first of all, this is not a regulation. So some people, they think that, you know, we deal with the regulatory matters we don't, which is purely enabling. It aims at removing legal obstacles to a specific problem, which is the use of an electronic form of these transferable documents and instruments. As I said before, it is technology neutral. So it's compatible with registries, tokens, DLTs, but it doesn't favor or mandate the use of any of that, which promotes interoperability. When it's based on functional requirements rules, which means the same substantive law applies to electronic and paper based documents, which means the law of bills of lading, for instance, would apply to an electronic bill of lading that is issued under the MLTR. This is particularly convenient when there is a conversion between electronic and paper. It's rare whether it is the other change of medium between, but usually it's because someone does not or cannot use electronics or requires the change of medium to paper. But there is no change in applicable laws. That's particularly convenient. And another very good outcome is that of course, because the substantive law applies, all the interaction with third parties, including the user's collateral, remains just the same as if it were on paper. Then of course, there is the additional dimension, which is the inclusion of dynamic information metadata, especially data originating from Oracle's smart contracts. All of these things can be included, of course, in the electronic transfer. One of the key issues in preparing this model was the need to prevent double spending, of course. Obviously, the starting point is the paper document is issued in a single original, but we all know, and I will not need to indulge in this place, in this forum, on the risks of this assumption that has more to do with practice and the ability to assess risk based on past practice. Although we have seen, especially this year, last year, that sometimes we are not so good at controlling this kind of risk. In the MLTR, this is achieved with two notions, control and singularity. VET makes sure that only one electronic transfer record is issued and VET transfer record is kept under control from the time of the issuance to the time of presentation and the termination. The outcome is one electronic transfer record means one claim for performance. Of course, it's possible to add additional safeguards, for instance, by using Oracle's, so that it is possible to link directly the cargo and a bit of lading, for instance. Technology gives us the possibility to do this. This is something we cannot do on paper. It's just a matter of implementation. As I always say, when it comes to electronic matters, normally we expect governance to be better because we have more data and we have a possibility to have better analysis. It is true. Of course, implementation is key. So requirements for an electronic transfer record, I will not get in the details here, but of course, because the same substantive law applies, the electronic transfer record must contain all information, mandatory and optional, which is needed for the paper document. It does not need to be presented visually in the same way, but it has to be there. And then there is the need to have a reliable method to identify the record as an electronic transfer record as opposed to an electronic record, which is not transferable. As I said before, to make it subject to control for the whole life cycle and also to retain integrity of the electronic transfer records. That means all the information regarding what happens to the transfer record after issuance has to be recorded regardless of its legal significance. That's why the use of blockchain and DLT may be advisable because we know in that environment it is more difficult to reverse changes to electronic records. Everything should be recorded probably. Of course, this doesn't mean that it's not possible to reverse the legal effect. The legal effect may be reversed by taking the appropriate action. But historically, what happened is recorded. And more generally, obviously, all of these that has to do with the reliable method is implemented in practice by using trust services such as electronic signatures and time stamping and assurance of integrity and so on and so forth. As I said before, the key problem here was finding what is possession in an electronic environment because possession is a notion, is a factual notion that refers to the ability to control physically an item. In a virtual environment, there is this functional requirements rule that says the equivalent of possession is control and the electronic transfer record management system must establish exclusive control over the record and also identify the person in control. Now we're not getting in the details of what identification means. But it is important just for the specialists where it is possible to make transfer of document instrument circulate, for instance, only by delivery to the bearer which is possible also electronically. So there may be different issues here. Identification for KYC has to be carried out, of course, to comply with this type of rules. But at the same time, this does not affect the ability to limit commercial consequences by circulation to bearer or anonymously. So basically, also on this point, the substantive law as it is enforced in that jurisdiction will apply also to the online environment. Now, getting to the policy aspect, I don't need to here to preach to the choir by saying why we want to have paperless trade. Sometimes I make the example of bank payment obligations, which I find very interesting, although we have different level of uptake there. One issue that is interesting for trade financing is that, of course, if the electronic transfer record is identical to the paper-based document, it also does not affect the capital requirements for the lending institutions. But when we go beyond that, and here comes the vision, and I think that's what Kay will discuss more in detail. We get down to the fundamental question. We have one commercial transaction and we have a multitude of commercial documents and regulatory documents. Now, of course, we have to do on paper because the information on paper is very static. But do we need that when we have dynamic information in electronic form? Do we need to replicate this multitude of documents or can we rethink this process so that we move out of this fragmentation and into something which gives us additional advantages? So the idea here is to put all this information in a single electronic transfer record. And then, of course, we will share this information with all business partners. To the extent that, of course, it is relevant for that business partner to a extent that we can do so. This is the implementation of the data pipeline concept. And the huge advantage of this is that that single electronic record, which is also transferable, of course, if we want to have it transferable, has the best data quality. So it's complete, it's accurate, it's up to date, it's authentic. So let's say if there is a problem, like, for instance, the ship cannot go through the Suez Canal, then automatically the information is updated in that record and that record will update the information for all business clients. As I said, it's okay to give details of how trade trust is trying to implement that concept, but trade trust is not the only example of implementation. So why enacting the MLETR? Reduction of compliance costs, better governance, less errors, less also inconsistencies across documents. I would say very important it can give significant additional safeguards against fraud if it is well designed and implemented. It is meant to operate across borders. It has specific provisions. So it does help international trade. So we have a long list of benefits and the only disadvantage is, of course, that it's new and so people may be risk averse and they need a little bit more of explanation about. With respect specifically to COVID-19 recovery, which is a very relevant topic and it's a good illustration. If we go generally on paperless trade, we know that paperless operations minimize personal interaction, which means, of course, less risk for the individuals because there is less exposure, but at the same time also less risk for the business process because there is less human physical human input. Very important for certain goods like now vaccines, of course, if it's implemented a blockchain, it would be possible to give certain high standards of origin traceability, business being looked into seriously by several players. Obviously, if in this vision, we have complete control over logistics, financing as well, but also customs because we can integrate the single windows for customs operation in the supply chain. So we know exactly where the shipment is and we also know how to prioritize what we want to prioritize. In the medium term comes the other aspect of the financing aspect because if we have lower costs, of course, we are able to have better access, especially for SMEs because we do have more information about pet clients and we are able to provide a better service, both in terms of collateral and also in terms of the credit worthiness of the client. So the MLTR has been adopted in Bahrain first in Singapore and in the Abu Dhabi global market. It's a specifically reference in the digital economy agreements where Singapore has concluded with Australia, New Zealand and Chile so far, more are in the works. It is in bills that have been introduced in parliament in a couple of more countries and we do expect a few more enactments this year. Of course, the big discussion about this is going on in the UK and it's promoted by ICC UK but there's also a significant engagement of the Law Commission of England and Wales and this so you may find quite a bit of information there. I will stop here. I tried to do my best to give you this overview at the same time. I do appreciate that. I took a bit of your time. Apologies for that. Thank you so much, Luké. It was a really, really interesting presentation. Lots of insights that I would like to keep for the question and answer time for the debate. As you said, you were right. Let's give an interactive feel to the whole meeting. So I will hand it over to K. We'll have him to step in and to have his presentation. Thank you. Thank you. Just give me a second whilst I load the PowerPoint. Okay. I guess everybody can see my screen. Perfectly. I can see it perfectly. Okay. Okay. Wonderful. Great. All right. Great. Greetings to all from sunny Singapore. So my name is K and I work in the trade team under the sectoral transformation group within Singapore's Infocom Media Development Authority. The team's director, Mr. Law Sinyong, is also in the event today. And I think he is one of the primary inventors of the trade trust framework and we'll talk a bit more. So this is an initiative called Trade Trust that we started conceptualizing some two years back and it's reaching a certain level of maturity. So who's the Infocom Media Development Authority? Well, we are a statutory board within the Singapore government under the Ministry of Communications and Information. As a regulatory body, we oversee and implement policies relating to the ICT media and postal industries in Singapore. We also run the PDPC, the Personal Data Protection Commission and POPMA, Protection from Online Falsehoods and Manipulation Office. Now, in addition to our regulatory role, IMD is also responsible for driving Singapore's digital transformation through the use of ICT technologies. We work closely with organizations in industries such as trade, logistics, transportation and trade finance to promote the adoption of ICT technologies in order to enhance our company's competitiveness in the global marketplace. So let's zoom into trade. Well, as we all know, international trade involves many parties exchanging a lot of information using more often than not silo systems that are not integrated with one another. Unfortunately, a lot of this takes place over then paper, a lot of this data information exchange then takes place over paper, which is at last count, 2000 year old technology. This medium is of course inefficient and in an often cited analysis by MERSC and IBM, this cost can be as much as 20% of the cost of actually transporting the actual cargo. And furthermore, silo systems arrive in the trade ecosystem and these silo systems are not interoperable and conventionally extremely costly to make them so. This was a point that was also brought up by Luca just now. So we do see a lot of pockets of digitalization efforts. One of those, you know, government establishing direct connections to governments, but that type of effort is really inadequate. The world needs a better way to digitalize that is fast, easy and cheap and enable the thousands of digital silo systems out there to interoperate. Hence, in trade trust, we focus on the two key problems in trade. Number one, the inefficient processes because of paper and number two, the silo ecosystems. So on the paper front, we have to have digital assets that are functionally equivalent to their paper counterparts. On the silo ecosystems front, it isn't as easy as it sounds. Because international supply chains today involve many parties with many documents that are handed from one to another over along the value chain. And we have to cater for the varying degrees of digital maturity and technical ability as well. So we need interoperability, not just between digital systems, but even between hard copy and soft copy. So what is the end vision that we are driving towards? To solve all these problems, what do we need to do? So we need to effectively digitalize two categories of documents that are used in international trade. So normal documents, well those are the ones that are just used to convey information, not too particularly difficult to digitalize, but we don't just stop there at just digitalizing it. We don't just stop there. We use technology to assure all the trade players that no matter how they obtain a document, regardless how many hands it had passed through before, that it hadn't been tampered with since it was created. So that's authenticity. Now of course, trade players also need to be assured, as you heard Luka talked about the need for identity, about knowing who. Trade players also need to be assured of who really created that document as well. So that's source. And lastly, the other category is that of transferable documents. So these documents, I'm sure you have gotten a very good brief from Luka in the previous section. So you know that they are a special class of documents which have the legal ability to affect performance obligation transfer from party to party. Now the paper medium is slow to transport amongst all the different players and necessitate risky practices such as the use of letters of indemnity. So on top of assuring authenticity and source of the document, we use technology to effect title transfers electronically, info compliance to the requirements of the law. So let's talk about trade trust then. Trade trust is not a platform. It is a framework. This framework comprises of globally accepted standards all so that we can connect governments and businesses to a public blockchain to enable trusted interoperability of the electronic trade documents used in trade across digital platforms. And it is offered as a digital utility. I'll talk about that. So to achieve this cross border vision for paperless trade, we don't just need the technology. We also need to address the change management, the legal and business considerations. So to do this, we develop four tracks. You can see them in front of you. Legal harmonization, standards development, accreditation and software components. So let's talk about legal harmonization first. So legal harmonization looks to not only enable electronic negotiable documents to be legally valid, to be legally recognized, but to do so toward a standard that the world can get behind. And that's the ML ETR or Melita as Luca likes to coin the phrase. This model law, you heard a lot about it just now. And so you would also know that Winsutral is also responsible for the model laws on electronic commerce and electronic signatures, which I think we can thank to be able to shop on the internet today. So if you now look at the other track, the second track of standards development, this deals with the creation and enhancement of technical and process standards at international bodies, such as UNC FACT, that's the United Nations Center for E-Business and Trade Facilitation. And the International Standards Organization ISO, where we do all this in collaboration with experts from all over the world. And these are then baked into the trade trust software components. Track three, accreditation is an optional feature within the ML ETR. And number four, these software components, these are designed, number one, these are released on open source licensing terms. And they are designed to be able to be easily integrated into backend solutions and deployed on the different trade players' existing IT infrastructure so that they can extend its operability beyond their own digital community, their own digital work model. So if you now look at the picture in front of you, that's what trade trust looks like from a technical perspective. The application layer is where systems and platform providers continue to thrive by providing value to their users. This is one reason why we try to emphasize trade trust is not a platform. Now, of course, we do have a website and things that we look at. But in its purest form, trade trust actually has no interface. But we had to build something in order for people to actually see something. So that's why we call it our reference implementation. The URL will be on a slide that's later on. But where trade trust really is is at the services layer. And this design ensures minimal coupling and provides the flexibility to cater for changes in technologies in the future. For example, when a quantum resistant cryptography technique is invented and applied to a distributed ledger, well, trade trust can be adapted to plug into that. So it is really an adapter to be able to plug the applications into the various blockchains. Now, last year, we actually used this software components to accomplish a transfer of ownership of a ETR between two separate systems, one in Singapore, one in Netherlands, over the public Ethereum blockchain network. So completely separate systems, completely separate platforms. Now, what would be of extreme interest to this community, I think, are the trade trust design principles. Now, because it is offered to the world as a public good, it currently uses public Ethereum, which is a public and permissionless blockchain, so as to ensure that no one party has undue influence over the rest. This is particularly relevant if you were talking about trying to connect governments to this blockchain via the system, via this framework, how sovereign nations can get. So if you're not looking at the second bubble, sorry, the second principle, data is not kept on the blockchain, so that data confidentiality, commercial confidentiality is preserved. The third principle is that it's payload agnostic. This is so that the parties can make use of whichever formats or standards they have already engineered their systems to work with, whilst having the ability to adapt and change as they wish at their own pace. The fourth principle, it is released on open source and its code can be checked by all before they use it. Lastly, the title transfer functionality of the trade trust framework is designed to be ML ETR compliant. Again, this is another view, trying to reinforce the message that it is not a platform. It is an approach to help platforms and systems achieve interoperability and ML ETR compliant title transfer. And as the Singapore government, it is not our intent nor ambition to compete with the private sector or the solution providers out there. We see our role as one to reach where the private sector perhaps find it difficult. So that's why we have conversations at the WTO, at UN, the various events there. And of course we offer the digital infrastructure, the software components as a public good via open source licensing terms. So let's now look at I guess the secret source of the trade trust framework and how it handles transferable records. If you look at the paper transferable instrument, the title ownership and what we call the BL data, that's all on that medium. Now, when you digitalize it, you can actually split the two because we know in the transferable part of the record, the one that changes hands, we call that the title ownership and the rest of it, the BL data, the port of local discharge, cargo description, the part that doesn't change. Let's just call it BL data. Now we deal with those two parts separately. Okay, so how do we actually deal with them separately? The title ownership part that's being maintained in the public blockchain. So let me orient you to this particular figure. This particular figure has two parts. There's the outer ring that tracks the movement of the BL data, the file, and the title ownership information is recorded in the public blockchain. The little green boxes are the software components that are integrated into the various systems. So the carrier, for example, we talk about bill of lading, of course, the carrier would be the one that issues this electronic bill of lading. Perhaps he has a documentation system. He would issue this electronic bill of lading and the title ownership gets recorded in the public blockchain. Whereas the actual file would be sent via conventional means. It could be as simple as email or it could be via file transfer protocol. However, he currently does it in terms of sending electronic files to his business partner. He can use that same method to other people. So in this figure, you have seller one and trader two who happen to be on a blockchain based platform for buyers and sellers who capture the transaction inside that particular platform. However, they capture it, the BL data part gets the file, the .tt file is what gets transported to the various players and using that file, they can look up to know at any one time who is the title owner. Now, the beauty of this approach is that you don't have to secure that BL file too harshly. You don't have to build all your armored walls around that. Anybody can get a hold of that .tt file or that BL because the smart contract is the one that controls who can actually update that title holder. So your same file could be launched with the government authority for customs clearance purposes and you don't have to worry that they will change the title owner and so on and so forth. So this accomplishes that same BL file being able to be interoperable across the various ecosystems. Now, in case you are thinking, okay, well that's well and good, well that will work. Is straight trust really only just for negotiable documents? Short answer is no. As I mentioned, you can use straight trust for two categories of documents, the normal documents and the transferable documents. So here for plain vanilla business documents you can still use straight trust to assure authenticity and the provenance of plain documents. So here I'd like to allude to a trial that was conducted with Australian Border Force and on certificates of origin between Australia and Singapore where they used the straight trust framework to run this trial with very, very good feedback from the private sector participants as well. So this next to last slide is really a slide to show that the amount of interest in trade digitalization is immense and we have I guess the pleasure of working with many international organizations, ICCD, DSI being one of that and I see that Oswald is also part of the meeting. So a shout out to Oswald but we do have other governments working with us on this. We've got Australia, we've got Netherlands and many other international organizations like Swift have also joined us in this journey and of course we want to issue an open call for anybody to come and join us on this journey as well. If you are a trade ecosystem player, feel free to take a look at the links. There's lots of information there and feel free to reach out for any further discussions. And really this problem of digitalizing negotiable documents or instruments is really not a new one but all the efforts that have come before, they do so with some sort of gating mechanism whether it's a platform-centric access or perhaps the registry is a centralized one that is subject to a particular party's control. Well trade trust is different, you can tell it's actually designed to give its users the freedom of choice of application and still prevent lock-in. So with that I thank you for your time and attention and I hand the time back over to Andrea. Thank you. Thank you Kay. That was such a nice presentation. Thanks Luke as well. It was really really insightful one. I mean I would love to open. Julian is fine with it. I mean we'd like to give the words to the attendants today to have questions from their side. Penny, I would love first to start with the UK if you don't mind. I mean it's interesting to see how you manage to let private worlds such as banks, financial institutions and then the administration and the public once joined together in a single environment. That's fine. I mean any questions I mean from the attendants? Andrea it's John Taylor here if it's permitted. Oh sorry I can't hear you. Yeah please go ahead. Oh thank you very much. Well first of all could I just say a very special thank you to those Luca and Kay for excellent presentations. Very clear and congratulations to both of you for your work in this area. I have one specific question as a number of you will know I've been working for some years on the working group of Baft, the bankers association for finance and trade that has created the distributed ledger payment commitment that is an electronic promissory note that I think has all the characteristics that both Kay and Luca have described. My question though is we believe it is satisfying the Milita's criteria. Does Uncitrao provide any guidance as to whether it's the requirements of Milita are being complied with for any producer of an electronic transferable record? So it's really a question for you Luca please. Thank you thank you very much John. Very important question. We don't provide that guidance of course there are two ways of solving very important problems as it is usually the case in this field. There could be you know traditionally we call it we like to call it ex ante and ex post, why this is our legacy. Ex post which is the traditional approach it's really in the specific case up to the judge or the arbitrator to verify whether the method was reliable betting in mind that obviously the key element where often is the agreement of the parties when the parties agree to use a specific method or a specific technical solution they agree that this is appropriate. Now that approach of course is very flexible it's very technology neutral but has the disadvantage of not helping predictability and therefore we often see it complemented by the possibility of having some providers who are recognized by a national authority as reliable. In Bahrain I think this the V system is mandatory so someone who would operate in Provide would have to be licensed first by the oversight authority. In Singapore it's a mixed approach it is possible to use any system it's up to the parties but there is an optional I can call it accreditation system if that makes sense or your recognition or designation system and obviously those who use that channel they benefit from certain presumptions and of course that means that there is a reversal of the burden of proof on the reliability of the method which is very convenient it's always possible to prove that the method is not reliable but of course in practical terms that makes a lot of difference. Thank you very much. Yes, I'm sorry could I ask a question? Sure you can, welcome to see you. I'm also very very glad to be here and I'd definitely like to follow John's John in stating that it was some very very good presentations. Now I wrote a paper on an Ethereum bill relating and the the letter a little while ago and yeah it's a very important legal text and there's a lot happening around it but also because of it so definitely a very very important one. I also think it's very interesting and very cool to see people using the public blockchains as a way of establishing consensus and also precisely Ethereum also because there's a lot happening in the space with the Ethereum 2.0 upgrade so I think there's a lot to be excited about in these coming years but I'd just like to get back to the model law. It's on the kind of control approach for establishing the functional equivalents of possession in the virtual space and this has kind of traditionally been seen as a capitulation to the registry system which in the past was the only way to establish possession in a virtual space but the problem with this is that it in essence gives people a symbolic key to a warehouse rather than actually gives them the ability to to manipulate to the extent that might be desirable for establishing possession but the notion of of control I think that wasn't that wasn't defined anywhere in the in Milita to what extent was this a conscious decision and do you think that there should be a uniform definition Luca thank you. Thanks Nils and it's a pleasure to to hear your appreciation for the model law as you are very involved in these matters. Control is not defined but as a functional equivalence to possession so the legal effects of control are the same as the legal effects of possession this is one of the issues here is we don't want to upset in any manner existing law. Now if your question is what is in the end control in in in technical terms when I think that it is clear that control especially this control which is exclusive which means that the person in control who can be of course a physical person a legal person a multiplicity of persons at the same time whatever is possible in in the real world but should replicate the same type of factual situation that you have in possession so you would have a definition of possession in national law for instance in many Romano-Germanic jurisdictions she would say the exclusion of everyone else from interaction with that item so that would be the same so yes there was a some thinking behind of course. Yeah it's just I think it's quite an interesting kind of legal slash philosophical point when you establish your when you kind of establish a system in order to exclude control but then you know by virtue of establishing a system you already kind of imply an external control which is why maybe a decentralized system is legally a better way of doing it. Thank you for answering. Thank you. Any other questions from the attendants? There's a question in the chat that you may want to look at Andrea. Yes there's a question too there's a question what do you think are the main challenges on adoption and phase what else is missing it seems to solve real problems who would love to answer this one it's about the challenges in the adoption of this model and this approach by single trait trust. I think it's a question for both of us maybe I can go first and Kate can do the current I mean currently we are at the stage where we have very strong support from private sector and all that we need is to have the implementation. Once this is implemented and it's clear how it works and the benefits are clear then it should you know that that would start as noble effect and that's it it's the new normal. There was recently and maybe I can put it in the chat there was a webinar organized by Ancitral it was actually supposed to support a different project but basically one day was only about presentations on MLTR and the second day too also it was about it and I will put now the link in the chat and there was something said which is very interesting by Marina Comininos from ESS docs in that seminar and the recording is available on the Ancitral website she said that they have changed the rulebook and this change was approved by the PNI club so that now they can issue electronic bills of trading under Singapore law and the MLTR. Now this is the kind of thing where in my opinion is missing and the next step to the real implementation of this because where we have a product which is commercial by commercial provider but this is now it it closes the loop because we have everything we have the law we have the technology we have the the service provider we have the we have everything we need and so now we just need to start using it and to to implement it so the next thing would be for another service provider doesn't have to be electronic bills of trading it can be promissory notes it can be bills of exchange it can be warehouse receipts to say yeah now we issue under MLTR out of choice of law and and then we are happy with it and we can do it but a similar thing like because of a decision of the Swedish Supreme Court in Sweden it is already possible to issue electronic promissory notes if they meet 10 requirements which are so that would be another use case so I think that what we are we'll see now we will see people who will say yeah now we will we will start doing this we believe in this we are confident enough we know the risks we know how to do it we just do it and then that's it talking about the private sector Luca what about the public one I mean I saw in case presentation I saw the mention to the certificate of origin I know how maybe tricky how it seems to you to let public institution into this what about the current situation that are they currently into this in going fully digitized well there are some critical areas I mean maybe I'm asking directly to to Kay what were the challenges that they faced in bringing public institution into this yeah hi Andrea I think the difficulties are not restricted or not limited to just the public institutions I think as with everything it's about getting the knowledge and information out there unfortunately you know even blockchain itself is really only gaining a better understanding only in the recent times but the problem that we're trying to solve is a very real one the cost you know the reduction in cost of shipping is just one it's just one of the more visible dimensions that we chose to bring up I think what's more exciting is once every once the information once it is digitalized the unleashing of you know innovation energies by providers by companies would be immense I do not think we have yet uncovered all that is possible once we have trade documents digitalized to a very large degree so that that's definitely one aspect in terms of challenges public institutions I guess you could say that public institutions are more risk averse that certainly is true for some rather than others but I think as you know as as Mr. Luo Xinyong is very often you know quoted to say it's you know if you look at the innovation curve right for innovation adoption curve you will always have the early adopters you will always have the legards and really it's about some of us showing the rest of us the way a way and really taking taking those first steps and showing the rest of the world it is possible it is you know and unfortunately the fact is digital negotiable instruments private sector has had you know the effort started more than 10 years ago and unfortunately there is a lot of industry fatigue in this particular area right so I think one of the first things is to get over that fatigue to to explain why now it's different now it's not a contractual legal framework discussion anymore it's statutory it's it's a it's an open framework and so on and so forth but yes that industry fatigue is a very real thing to get over so these are some of the big challenges I think thanks it's you know I'm thinking also about the you know issues related to this and you know the customers authorities are so reluctant often and they make so much big into this so heavily stuck into paper you were mentioning Kay formally you know that you're creating with Australia with other countries let's see that there are other potential areas what do you target I mean to collaborate with are you open or have you got in the future near future in the future are there any other areas you target to collaborate with um sorry Andrea the connection wasn't so good were you asking what other areas are we looking at in the future yes my apologies you know back connection today maybe no no no problem no problem um of course the fact is you know international trade in itself is a huge domain so you know it really isn't easy just to you know accomplish everything quickly but you know as you saw from Lucas presentation this class of digital negotiable instruments there are more than just the bills of leading right there are other instruments as well so at least for for Singapore we've really you know decided to focus a lot on the bill of leading for now but there is obvious applicability in trade to other instruments as well in terms of other areas to be perfectly frank we we are looking for those who are willing to join us on this journey um governments and and companies alike um you know we're looking for a coalition of the willing and able right uh we are very thankful that we have very um forward-looking governments like China, Netherlands, um you know in Australia who have you know really sought to work with us on real concrete projects and demonstrate that to their to their communities and to the world and yes we continue to look out for such willing and able partners wherever they may be so you have no boundaries actually perfect okay thank you this is a question from our friend Joel on the chat and he's asking can bills of leading which have been created on a proprietary closed EBL platform to the IMDA public blockchain so that they can be transferred to parties which have not been onboarded to the closed EBL platform I think this is for you K of course speaking okay certainly I will take a step at this although I do have other colleagues from the trade team who are also on this channel shout out if they would like to also add on so first of all when you talk about adopting the ML ETR so I think a couple of dimensions we're going to look at this on the first is legal the other is technical if you look at it from a technical perspective what we're talking about is the fulfillment of those particular requirements and now in trade for trade trust we use Ethereum we use ERC 721 a tokenization to achieve the singularity requirement right now we are I guess if you've managed if you've monitored the news we are indeed trying to look into this area with our work with R3 actually so funnily enough you know your your sentence actually just exactly described what we're trying to what we're trying to work out with R3 and quarter EBL that's on the technical aspect now on the other aspect which is the legal aspect that's that remains something that we have to investigate because again you've got to be a bit more specific about what do you mean by a EBL platform adopting the ML ETR subject to Lucas I guess a correction the ML ETR is it's up to a particular jurisdiction to adopt those requirements and that's what gives it that legal recognition I know recognition many lawyers tell me don't use the word recognition but I'm a layman so I guess I get away with it that legal recognition yes but but yeah we are exactly trying to figure that out with R3 as one example yes I don't know whether anybody else from the IMDATry team wants to chime in Sinyong or Marcus thank you Gay thanks for answering there is another question from the attendants about Africa comes from a tank camera he's asking Africa is implemented free trade area the innovation innovation development transformation in the region he's asking for advice I mean how do you tell it to do this to your pets maybe I don't know you are right I'm not too sure what the question is though but you know the trade trust material we actually have a website www.tradetrust.io I flashed it just now in one of my slides all the information all the technical information is there the software components are you know open source yeah so feel free to take that and yes implemented in the African continental free trade area don't forget the legal part of stuff though but yes as in so far as the technology part is concerned yeah you can find all that in our website perfect thank you Gay anybody else who wants to make questions to Gay and to Luca it's a good chance to ask Luca for posting links yeah that's the link I mentioned before with a lot of a lot of the materials were both slides and recording it's about the MLITIA and I wanted I want to apologize because I before I called trade trust the platform Kay correctly said it's not a platform and I would call it an ecosystem but it's not an ecosystem it's a community so you know what Kay why don't you talk about trade trust and I don't talk about because I don't know what I'm talking about but you have a point because now platforms are regulated and and and actually trade trust is the opposite of a regulated it's a very open environment yeah sorry can I sorry can I just quickly jump in with the one question which may be completely irrelevant to this conversation and though I apologize in advance but did you have any communication or feedback from banks who are engaged in international trade I take it that that's directed at myself I'll take a step yes yes actually we have since trade trust's inception we have been you know constantly listening to feedback from banks non-banks you know carriers well everybody who is in that ecosystem and just in case it wasn't clear trade trust is not just a IMDA alone kind of effort the Singapore government is taking trade digitalization as a whole of government affair so actually we work very closely with our maritime port authority which is our I guess maritime community sector agency with the monetary authority of Singapore which of course is our central bank and governs the banks yeah as a sector agency and yes we do work very closely with banks DPS standard charter and we even work very closely with SWIFT I think I I think one of one of the slides had their name there so we work with SWIFT as well who as you know are a cooperative numbering 11 000 banks and corporates so yes we do and I would like to mention also that it's very important for the promotion of the MLP are the contribution of the ICC DSI the digital standards initiative and there's much more there that has to do with both logistics and with trade funds and we're gonna launch a website anytime soon I don't know I saw Oswald before I don't know if he's still here or not but it's a matter of days thank you very much what a great presentation thanks both hi jayce monger of HSBC just a question maybe more for look on the what I mean what what is the the next in line or sorry there's a bit of echo yeah I mean the the next country that will integrate the model low into their their legislation because I mean as much as I mean the the great benefit of this is is really to have the direct enforcement of those of those documents I mean directly into into into the the legal system but then for those that have not adopted this I mean you will still have to rely on some contract to revert to the contract law so what is your views on on on how much this can be used without having the major trade countries that are part or that they have implemented those model low thank you this is a very interesting question and I realize I have to give you an answer on on two or three different points but quickly mindful of time first of all we do promote actively this model law obviously we need the help of the private sector we need the help of governments we need the help of everyone knows that may be passed when we are based on uniform texts they may be passed maybe quicker but where is the need for the the the legislature to be involved and to be told why it's good and and you know and that's that's the kind of work that we see for instance the advocacy work that is being done by the ICC including certain national committees if you just want to know who's gonna who's gonna adopt next I can tell you but the bills to enact the MLTR and not only because these are broader bills on on electronic transaction law have been introduced in Paraguay and in Kiribati but that's a fact with this public information that is available but of course Paraguay and Kiribati are important countries but we are not on top five world traders so the next step is how do we engage these top five or top 10 or top 20 there is a very interesting discussion in the UK as I mentioned before and I think there will be some some evolution there necessarily but bearing in mind also the specific features of the English common law and then there is also a very lively discussion in Germany and actually one opinion is that Germany is already to some extent or to to quite a bit compliant with MLTR and it's a matter of implementation and implementing regulations and so on and so forth so we see things happening it's not just a matter of passing the law it's also a matter of understanding and implementing the law the US has already legislation in this field the US had for many years legislation on electronic bills of lading but it was never used until the end of 2020 and in 2020 was used only for inland waterway commodity shipment but for instance in the US laws on warehouse receipts are being used electronic warehouse receipts and they're also very compatible with MLTR so I would say this is a little bit more of you know a mosaic now we see different things happening there is a convergence where there are countries like Monaco where actually the functional requirements rules of the MLTR has been enacted in the law but it's awaiting implementing regulations and I don't know if there is a market demand but it's possible to implement it tomorrow so it's it's more complex it's very it but then just saying yes the law has been passed and now it's possible to do that but we see a lot of action that we didn't see two years ago there's a huge acceleration because of the effects of COVID there's a huge demand for information and requests for awareness and then of course we're here whoever wants to discuss how to adopt this law tomorrow we are here to assist okay thank you thank you Luca thanks for those final remarks I mean if there is any other anybody else who would like to ask questions to look at and of course thanks for asking so nobody else any questions I think Julian any question from your side no I think we've run over by 27 minutes that just means it was very good and interesting and interactive session we should all be proud or you should be proud I think okay and I try I've done a great job yeah yeah that's it that's it normally people try to get out of these things 10 minutes earlier so extending it over over the projected time is great thank you Bijana thank you you know what now we have to keep up with the level so it's going to be challenging for us to to go on this way but anyway we have excellent collaboration excellence you know speakers so it's pretty easy it was actually but thank you thank you so much so Julian I think you can end up the meeting and you know I think you're having slight problems Andrea with with it was with the voice and connectivity Andrea thanks for setting us up and Luca and Kay thank you for great presentation and and for everyone being involved and turning up here today and let's continue this conversation and I think there was a kind of call to action from Kay and Luca to get involved so please do take care everyone keep safe thank you keep safe and see you in two final thank you all here thank you thank you