Contemplating 75 years of freedom: a dark story on three Dutch lessons never learnt

First of all I must warn all readers. This is not a happy blogpost. It is not funny. It is a dark and sobering tale of lessons that we should have learnt in the Netherlands. A tale about lessons that we never learnt. Lessons that still hold immense value today. Lessons that we owe it to be taken to heart when we reflect on the 75 years of freedom that we will celebrate next week.

From Rotterdam to Amsterdam: records and track records

This post connects two cities that I lived in for the longest time in my life. First of all; Rotterdam, the place of my birth. It was bombed to ashes early on in WorldWar 2. Except for one place: the city hall. Reason being? That's where the population records were. Cunning Germans, as my dad explained to me. 

Next up is Amsterdam, where the Anne Frank house and her statue form the background against which new children grow up in freedom. Where Stolpersteine remind us of those who lived here before us. Where the elder lady with her dog told us what is was like to grow up here. How the Germans were raiding the houses and pushing their bajonets into the ceilings to discover if people were hiding.

Amsterdam is the city of the 'dot-map'. It is the map that the Amsterdam city administration drew up on request of the occupying Germans, that wanted to know: where do the jewish people live?

It sounds like a simple question: an administrative thing, strange request perhaps, but why not just answer it? Let's cooperate collaborate. So the map says: One dot is 10 jews. Take it in and look history in the face.

The particular situation here in the Netherlands (J.H.Blom - source) was that our government had fled and the Germans put their officials in charge of the Dutch civil servants. This is a marked contrast with Denmark, where they let the Germans enter with the military but stayed in office and controlled their bureaucracy.

There is a lot more to read in the study of Blom but one of the very striking elements is the efficient bureaucracy in the Netherlands, in combination with a tendency to cooperate and answer properly to Authority. Whichever the source of Authority.

The very sad fact of the matter is that after the war we could learn that in Western Europe, the Netherlands turned out to be the country where 75% of its Jewish population died, as compared to 40% in Norway and Belgium, 25% in France and almost 0% in Denmark.

If we look history in the ugly eye, this is (literally) a track record that the Dutch must carry as a scar on and in their souls. A fact that obliges us to honour the deceased and make sure that we learnt something. But do we really?

History is distant and can be easily forgotten
This is all maps and statistics from earlier days. If we wish we can look away and forget. So let me warn you as I bring the lesson closer to home. To this end I draw on a pre-Corona visit that I paid to the excellent exposition covering 300 years of insurer Stad Rotterdam. now ASR. During the visit I stopped by and looked at the part on World War II, where I bumped into someone who turned out to have contributed to that part of the exposition.

He is a commited lawyer who until today still tries to resolve the administrative wrongdoings of the past. His story on what he found in archives, on what he did not find, was very sobering. He had seen files where a fanatic anti-semite employee hammered a J multiple times on the insurance policies of Jewish clients. And he explained how the Germans would start out with simple requests with more serious consequences kicking in later.

A typical example of this is the introduction of a generic duty to register and issue personal ID-s. This was formally introduced in October 1940 in the Netherlands and came info effect in April 1941. And then, one year later, all IDs of Jewish people needed to be stamped with a J. So we see bureaucratic evil of the end made possible by fairly innocent baby steps in the beginning.

Administrative witnesses of the insurance sector: during the World War 2
One of the most well known German tricks pulled in World War 2 in Amsterdam was the take over and manipulation of the Lippman Rosenthal brand by setting up a sort of second bank or branch-office with the same name. This second office was effectively German run and a 'robbery-bank' that sold off assets of Jewish clients. This bank plays a sinister role in the documents that I will be publishing here.

It started out with a request that Jewish people declare to their bank that they are Jewish, as via a specific Regulation, the only bank paying out the life insurances would be the Li-Ro-robbery bank. Here's the snapshot of the regulation and the form to be filled in.

Regulation outlining obligatioo to insurers to pay out
their clients only via the Li-Ro robbery bank

And here is the form and letter that people were sent. Please declare yourself to be Jewish.

Form with request to fill in if you are Jewish or not

Now the involved insurers didn't really all like this idea and they figured out: if we don't know for certain if someone is deceased, we can't really transfer all the money to Li-Ro bank. So the exposition shows a bank writing to the Li-Ro bank on this specific issue. 

Now beware of the answer which dates to January 1943.  I will translate it here:

Through the contact that we have with the relevant authorities we have been informed that Jewish people that have been deported by government order will be totally taken out of the society and nothing will be ever possibly heard of them. As a result they are, sort of automatically, also completely annihilated in respect to your administration but we note that, if no further measures are taken, their remaining insurances would continue to exist.

It will be clear to you that the circumstances in which the aforementioned Jewish people find themselves in society - but with respect to you as well - have lead to a situation that is equal to that where an insurance policy ends due to the death of the insured, which means that we need to find a way to bring those insurance to a pay-out.

We invite you, the pay to us the relevant reserves that you have amassed to this end, while deducting a considerable reward for the risks that you have taken.We look forward to your proposal.

Administrative witnesses: after the war
Imagine that you survived this World War 2. And that you want to claim the insurance funds that you are entitled to. And the response being: please can you prove that the person you are referring to is actually dead? Survivors of the war atrocities had to endure long and terrible administrative procedures to restore their rights.

Here is a witness that matters. It is a letter dating from 1950 and it is a declaration by a Red Cross official. It specifies the dates of deportation as well as the names of three survivors who have had to make a personal declaration to the Red Cross. It says that

... it is clear from the declaration of those three people (out of 33.000 deported to Sobibor), who stayed of a longer period in time in the camp, that almost all people that came to Sobibor were almost immediately being suffocated by gas and cremated afterwards. Given that nothing has ever been heard since the conclusion is that the person in question has died on 11-6-1943 of the consequence of suffocation.

No happy ending.... 
There is no happy ending to this story.

Survivors had to fight administrative wars and it took until 1999 before some sort of settlement was made between representatives of the Jewish community and the Dutch Insurance Industry. Part of the settlement is that a Foundation for individual claims SJOA has been set up. And until today the foundation is still actively assisting and doing research to do justice.

Which brings me full square back to my neighbourhood in Amsterdam. There are not just the silent physical reminders of history, the Stolpersteine in the streets. We also find reminders on the web, in this list of holders of insurance premiums. If I type in the names of the streets around me, their names come back to help me remember what happened.

Three lessons to heed...
We, society in general but the Dutch in particular, owe it to all of those who gave their lives during the war, hoping for true freedom, to heed three lessons we appear to have never really learnt:

1- we must better understand the mechanics, the workings of records, administrations and bureaucracies and the ease with which what looks like a legitimate government action can turn into an evil one that starts a persecution on illegitimate grounds,

2- we must remember that it is the atrocities of World War 2 that made us formulate the Human Rights Declaration, which formulates the fundamental rights that protect us,

3- we must cherish and protect our fundamental right to privacy as one of the most important defenses against bureaucracies turning evil.

FATF as in: Facebook As The Foe or Facebook As The Friend ?

Dear Mr Billingslea, dear Members of the FATF and dear civil servants in the room,

As you are nearing the end of a very productive year I wish to commend you on your very hard and wise work of the last year. If we look back on the objectives that the President laid out for 2018-2019 we can see the many accomplishments of this year. It has been a very productive year and one that will be remembered for many years to come. Because you will define what FATF truly stands for. 

Of course there are some commentators that challenge the legitimacy of your work on virtual assets. They outline that your so called open-ended mandate is by definition constrained by the boundaries set by Human RightTreaties, UN Resolutions, Fourth Amendments or rulings of the EU court ofJustice (Tele2) or the US Supreme Court (Carpenter). And they outline that effectively the FATF Standards are leading to a privacy infringement under those Human Rights agreements. I leave those comments aside for now. Historians and judges may be the judge for that.

For now, I wish to draw your attention to a practical dilemma that you will be facing the upcoming week. The dilemma is: does FATF stand for Facebook As The Foe or Facebook As The Friend? 

The answer depends on your own view: which society do you wish to leave behind for your kids?

FATF: Facebook As The Foe
While you were looking out of the frame of libertarian misuse of virtual currencies for all kinds of criminal purposes, you may have forgotten to look out the other window: at bigtech players such as Facebook and Google. Widening your view is of particular relevance now that you are about to endorse a virtual asset recommendation that obliges names of citizens to be sent along with virtual asset transfers (one way or the other).

Let's take a closer look at Facebook. They have thrown the privacy hundreds of million people under the bus. They opened up their systems to developers and allowed mass scale harvesting of personal data to other companies. They have come under severe criticism for this. And they changed a lot of operations, moved people out and such, all in other to counter the criticism about their harvesting of data. Bottom line: they need to remove personal data or ensure that they have proper consent from citizens that are properly informed on the whereabouts of their personal data.

Their latest project is a cryptocurrency / virtual asset programme, with the naam Libra. It leads to the creation of a world currency, backed by a combination of assets. And Facebook will cooperate with other bigtech and Fintech players to make it happen. As the Wall Street Journal outlines:

FATF-virtual asset rule: cryponite to send and harvest personal data without caring about consent 
I am wondering if you have thought trough your recommendation on standards for virtual assets sufficiently. Are you aware that Facebook itself will become a huge Virtual Asset Service Provider? Are you aware that it is now soliciting other big tech companies to become verification nodes in their virtual asset programme? And are you aware this means they don't have to ask any consent from the users who use their coins, to add name information in or with the transaction (whichever way they see fit, as long as they oblige). And this information must also be shared with counterparts (if any) meaning that if I operate a verification node, I am sitting on the information as well? 

The unintended consequence of what you are doing with the virtual asset rules is that, in times of personal data as the economic fuel for society, you are handing out cryptonite to all kinds of private sector players that want to have a free pass for passing on and harvesting personal information. All kind of other companies may follow suit as the FATF-rule is really an easy tool in the box of companies that actively seek to engage in regulatory arbitrage to avoid privacy rules as much as possible. 

Facebook as the Friend....?
The other alternative is that the FATF effectively sees Facebook as a friend. You are aware of the above consequence and view it as a necessary consequence that will be very helpful in capturing the criminals of the future. That would mean that with the FATF-rule you have deliberately chosen to marry with bigtechs.

Now if I Imagine the biggest data-harvesting company in the world marrying the world-wide law enforcers in the world I must say I am sort of afraid to imagine what their kids will look like. This would be too big a confluence of private and public sector roles and it will have a desastrous impact on the world. Some may argue that we were already living in Orwells 1984, but with this rule you will have definitely sealed the deal. 

What you may just do when agreeing to this virtual asset rule, is outlaw all the citizens of their world. Their data are free for all to harvest and in the process you will ride along to see if you capture a terrorist every now and then. 

Historic data does show, by the way, that all the virtual transaction data will not really help as evaluations of the impact of the travel rule indicate that the number of crooks preventively caught in 15 years of its use can be counted on one or two hands. It is always other law enforcement info that gets you to detect them beforehand, never the transaction data.  

What will FATF stand for: wich kind of society do you leave behind?
Will FATF stand for Facebook as the Foe and will you reconsider virtual asset article 7b?
Or will FATF stand for Facebook as the Friend and will you outlaw all personal data of world citizens?

Next week the choice is up to you. I have a hunch you will be going for the Facebook is my Friend model. Because in your groupthink you may be driven to annihilate all kinds of perceived criminal evil even when the tools for doing so are ineffective. Or just beause your are inclined to do as is told and answer to call of your bosses as they said to approve the virtual asset rules. 

Thereafter, you may end up seeing your choice annulled by judges. This may be the result of lengthy procedures or otherwise geopolitical incidents in which one of the kids of the marriage of FATF and Facebook will have turned evil. And then, each one of you in the room will have to answer towards its citizens, politicians, children and grandchildren: how did you not see this coming? 

Don't finalise the paragraph 7b text
I call upon you to consider the above with an open mind and an open heart.
Do the right thing: vote to re-consider or postpone finalisation of the pragraph 7b text. 

Postponing allows for more time to explore all impacts and consequences and have a further debate on what you wish the true acronym FATF to stand for.

Simon Lelieveldt

From DNB Coin to ECB Coin...?

About a year ago, it became clear that the Dutch central bank, much like other central banks, was actively experimenting with blockchain technology to further establish pros and cons of distributed ledger technology. It had developed a so-called DNB-coin - a private fork of the bitcoin blockchain - which further reinforced a whole discussion on central bank issued bitcoin-like currencies (Fedcoin as outlined by the blog of JP Koning).

Fast forward to the EU parliament, where last week, rapporteur Cora van Nieuwenhuizen presented a draft Fintech report, that calls on the European Commission to draw up a Fintech Action Plan. And in this plan, under item number 6, the ECB is recommended to launch experimentations with a 'virtual Euro'. I think we may dub this as the call for an ECB-coin.

One can only guess what exactly would be meant here, but my best guess would be that this means the ECB can now freely choose to experiment with methods for distributing digital euro's using advanced blockchain or distributed ledger technology. So would they design it themselves, or involve themselves into market initiatives such as R3, Hyperledger?

Anonymous ECB-coins or not? 
Time will undoubtedly tell how this experiment with ECB-coins will evolve. We should note however that, there is also a European legislative initiative to limit the use of cash. So it appears logical that the cash-limiting initiative could reinforce the development of central bank issued virtual currencies (i.e. euro's on a blockchain).

Those will not be truly anonymous ECB-coins, if you ask me. Close reading of this last legislative proposal, I noticed that anonymous digital currencies (such as the good old digicash) are not truly desired:

In view of the development of cryptocurrencies and the existence of other means of payments ensuring anonymity, an option could be to extend the restrictions to cash payments to all payments ensuring anonymity (cryptocurrencies, payment in kinds, etc.) 

The end of anonimity and begin of pseudonimity 
In sum we will be watching the end of anonimity, but this may not be its true end. I think it would be fairly easy to device new business and payment models where one slices off the good-reputation of a payer/payee (not blacklisted, no terrorist etc) into a pseudonomous, tokenised system that allows payer, payee and all involved financial institutions not to know each other but still transact securely and within the legal parameters as set by society.

Which most likely brings us back to square one: the blockchain.

A new FAQ for PSD2 would be very useful to harmonise interpretations across Europe

Summary

The second Payment Services Directive, published end of December last year, is an important and welcome next in the further integration of payment services in Europe. In order to achieve a true European level playing field ‘on the ground’, a clarifying FAQ for those who prepare its implementation today would be very welcome.

A FAQ that explains how the PSD2 definitions will apply in all Member states to the variety of business models and transaction mechanisms observed, will enhance the purported level playing field. This harmonised guidance is just as important as the FAQ/guidance provided for the first PSD. Both regulators and the market have further developed since PSD1 and it is essential to recognise some of the underlying dynamics and developments of the payments market.  

1. Out of scope, limited network or regulated?

At present, member states use the harmonised PSD-rules to determine whether or not a certain business model defines as a payment activity or can be categorised as an exemption. Both in terms of content and process, the approaches vary considerably between supervisors. The feedback of supervisors varies from an elaborate argumentation to merely the brief outcome of an internal review process. 

Also in terms of content, the approaches vary. Business models that are out of scope in one member state may be exempt or require a license in others. The lack of a central register of supervisory statements on those matters makes this hard to identify, but the PSD2 will change this. All business activity exempted under article 3k and 3l, must be notified and the exemption decision will be published in a central register.

The practical consequence is that market participants can more easily determine which business models are exempted in which countries. This means that the supervisors must ensure that their qualifications are well-grounded and harmonised. One of the major challenges in this respect is to take into account the technological and market developments.

2. Technological developments: open and device-agnostic

Just one look at a user’s technical environment demonstrates that the major trend in payment technology development is the move from closed, bespoke systems and standards to more open structures. Whereas previously payment providers would control (sometimes own) all technological instruments to be used in a payment transaction, this is no longer the case.

The future infrastructure setting is one in which consumers and merchants will use their own technical device, and providers need to ensure that it can be used safely. We can now see card-based payments, where no plastic is used anymore, as the payment is made via a virtual card application in the mobile phone or PC. At the same time, in the back-office, the systems are opening up to the outside world via Application Programming Interface’s (APIs). Rather than having one instrument that operates as a shopping and a payments tool simultaneously, we can see that the value chain of search, shop and pay can be arranged via modularized interfacing of channels and technologies.

Therefore, when assessing the qualification of the technologies in todays payments, an open and functional approach is required. The classical approach, in which one tries to find the main device (such as a card) that services as the payment instrument and then builds the further classification of a system around that instrument, will no longer work. There will be all kinds of devices and technical tools and while some may classify as payment instruments, others may not.

Fortunately, the definition of payment instrument in the payment services directive enables this functional approach. The definition mentions both ‘a personalized device’ and/or a ‘set of procedures’ to be viewed and defined as the payment instrument:

"payment instrument" means a personalised device(s) and/or set of procedures agreed

between the payment service user and the payment service provider and used in order

to initiate a payment order;

3. Where is the commerce and where is the payment transaction?

As technology slices up the commercial value chain, we should note the relevance of the last element of the definition of payment instrument: ‘to initiate a payment order’. There is a clear difference between the commercial use of devices for purchases (apps, shopping carts on the web, nfc-identification devices) and the later moment in which aggregated purchases are actually being paid. This can be compared to the difference between the shopping cart/button on a website and the payment button.

The main question to ponder is therefore: does the technology service allow the user to make a payment to any other payee in Europe (under the SEPA-rules) and is the transaction actually a payment order, or is it merely a shopping transaction, with payments being arranged later on.

I wouldn’t be surprised if in the next years, we will witness a shift away from devices as the actual payment instrument. It may be more suitable to put the (user) accounts centre stage as the actual payment instrument. When applied by retailer organisations, such a choice will enable them to build a multi-channel sales-channel in which the device used is irrelevant. The sales channel aggregates purchase transactions towards the user account at the retailer. In cases where the retailer merely aggregates these purchases and initiates a direct debit for the total sum to be paid, this remains an administrative account as the actual payment account in the process is that of the bank. Only in cases where actual payments orders are initiated from such an account, it would become the payment account as well as the payment instrument for the commercial transactions.

It is crucial to distinguish the commercial from the payment process domain when evaluating apps and identification tools on the market. The actual payments can be expected to become the afterthought of commerce, rather than a primary service. These can flow via a payment account in the background, which is provided by retailer, bank or payment service provider. It is that account that will then function as the payment instrument in the commercial transaction and not the purchase device/application used. Supervisors should thus not immediately label ‘the card’ or any specific technical tool in a commercial business model as the payment instrument.

4. Areas and definitions of interest for the application of the PSD2

We’ve seen that the democratisation of technology allowed non-bank payment service providers to enter the payment space. Among those will also be retailers that can leverage the technology to provide a better customer experience. If those retailers are to use a services and customer contract with a monthly SEPA-direct debit agreement in the background, the payment services directive will not be relevant for them.

Similarly there is the question whether the payments services directive would have to apply to intermediary web-based platform companies that help users transact among themselves. Such business models could be in or out of scope based on the interpretation whether:

- the payments are seen as a regular occupation or business activity (art 1,2b),

- the agency model applies,

- the new definition of acquiring applies,

- the limited network exemption applies.

I hope that the collective of regulatory players involved in the transposition and application of the PSD2 will succeed in addressing those scoping and definitions issues early-on. In this respect the publication of a FAQ on those issues, may be a very effective tool to clarify and ensure the level playing field.

Now that the voting on the PSD is done, the real work starts...

The second Payments Services Directive, also known as PSD2, will be officially established today. In the plenary session discussion yesterday all political groups backed the achieved consensus and highlighted the benefits to consumers, the increased security of payments, further innovation in the payments area and lower cost overall.

Some work ahead...
We should realize however, that with the promulgation the real work will start for a whole range of involved players. First and foremost, there is a lot more work ahead for regulators and supervisors in the transposition process, but in particular also for the European Banking Authority. The PSD2 that seeks to open up access to banks and customer bank accounts for new players, leaves quite a bit of work to be done by EBA.

EBA should:
- develop rules on level of guarantee/professional indemnity insurance for payment initiation service providers and account information service providers,
- set up standards for cooperation and data exchange between local supervisor and resolve disputes on different applications of the PSD2,
- set up a central register of payment institutions and agents licensed under the directive,
- develop regulatory standards that define when the appointment of a central local contact point can be demanded by local supervisors and what its functions should be,
- be informed immediately in the case of emergency situations (such as large scale fraud),
- coordinate requirements as to the security frameworks applied,
- specify the requirements of common and open standards of communication to be implemented by all account servicing payment service providers that allow for the provision of online payment services,
- develop guidelines on a harmonised set of information to be provided during the application for a payment institution license,
- publish local exemptions under article 3k and 3l in the public register,

Clarity for industry on EU-application of definitions and scope
When the first PSD was delivered, it turned out that quite some players in the market required timely insights as to the future scope of the directive and how it would impact them. The European Commission then published an FAQ that further outlined how definitions should be understood.

It seems to me that it would be worthwhile to perform a similar exercise right now as there are quite some areas that can give rise to questions. As an example: the recital on the agency exemption leaves open the existence of agents for both buyer and supplier as long as the agent does not enter into posession of the funds. Yet, the definition of acquiring appears to be purposefully wide, meaning that such commercial agents might after all be viewed as acquirers.

The sooner this clarity is provided, the better it is, as the lead time for setting up and getting a license as a payment institution is similar to the lead time that now exists for transposing the PSD2.

I therefore hope that, for the sake of a proper EU level playing field, the collective of regulatory players involved in the transposition and application of the PSD2, will seek to address those scoping and definitions issues early-on.

Where and how to look for innovation in payments ?

This week I had the pleasure of joining a panel on retail payments innovation as a part of a seminar by van Doorne and Innopay on the Payment Services Directive and the future changes for the payment industry. Panel chair Gijs Boudewijn challenged me to formulate some thoughts on the future direction of retail payments. I answered that the best place to look would be in places and via perspectives that we could be overlooking right now.

1. Is it access to the account or a traceable id that matters?
There is a lot of discussion on the text of the second Payment Services Directive and on the legal and technical mechanisms that are required to make access to the account work. Due to their origin, these discussions are quite bank centric and the implementation issues surrounding this topic will drain a lot of resources of many players involved.

While being busy with this PSD2 issue, we may overlook the fact that all one really needs is a simple chip-id. In the Netherlands for example, one could use the chip-id of public transport ticket issuer TLS as a basis for use in hip and new proprietary retailer/consumer applications. These would combine the chip-id with an intelligent voucher/billing/customer system that utilises SEPA-direct debits in the back-end. It would provide a smooth customer and retailer experience while the bank only sees regular transactions.

My proposition here is that if we're all looking towards access to the account as the hot spot for innovation, we may be looking in the wrong direction. It might be more about the traceable id.

2. The retailers have landed in an interesting position
In his tomorrows transactions blog Dave Birch referred to an analysis by Peter Jones from PSE on the impact of the interchange fee regulation, published in the Journal for Payments Strategy and Systems. The main conclusion of it was that financially the retailers are the winners by getting a cap on their fees. I agree with that and would be inclined to broaden this perspective.

By tradition banks were the players with the monopoly on payments technology and security knowledge. Even in the 1980s, the collective of retailers in the Netherlands had done a feasibility study to set up their own Point of Sale system. This showed they could set it up for € 5 million euro but they didn't want to take the risk of it failing. So they left it to the banks (to complain about high fees later).

Since that time, the knowledge on processing and payments has become available to a wide range of players, to the extend that banks are now lagging in expertise and capability (while being locked into old technology solutions). The consequence is that retailers will be well able to develop or use in-house apps, customer relation services and payment mechanisms that use the bank infrastructure, without being subject to the rules of the Payment Services Directive.

The main development is therefore that the obliged intermediary role of banks in providing payment mechanisms is gone and will erode. Retailers can regain their customer relationship by themselves or in cooperation with any other ICT-provider that allows them to identify the customer and provide a processing infrastructure. Some interesting innovations can therefore be expected at the outer boundaries of the PSD, as a consequence of the possible exemptions.

I expect both physical and e-retailers to use the non-bank, non-payment space that the PSD defines to achieve exactly what they're after: increased customer retention, increased conversion and a smooth payment experience. Bottom line: we might better be looking outside of the PSD to see innovation in action.

3. On ledgers and tokens
As a final thought I would encourage everyone to try a different mindset for the developments that we are witnessing. Because in essence, anything that happens (in payments/retail) boils down to either tokens (coins, notes, points) or ledgers (private or public). Now let's see what happens if we apply this framework.

We might then appreciate the bitcoin emergence as an innovation in the area of collective ledger provision with distributed trust. We could reposition Linked-In as a privately owned, open and self-administered ledger, that logs individuals achievements that are relevant in the work domain. The same would hold for Facebook and many other e-commerce companies. We would call banks the keepers of the trusted and well protected financial ledgers and would also note that in the public domain, a whole range of ledgers are being interconnected for the sake of security, anti-fraud measures etc.

We could also look at the world of tokens, in its many variations. Tokens of shopping behaviour (saving points), tokens of access (tickets), tokens from government (coins and banknotes), tokens of appreciations (awards, prizes) and tokens that prove identity or personal characteristics. Some of those tokens might be valuable and lead to a change of some of the ledgers, while others would have a role in their own right (voucher for a free coffee).

While it is clear that there are quite a few interesting new developments in the ledger-space, could it be that it is the token-domain where the true action is going to be ?

Payments as an afterthought
In sum: the non-bank, identity-based, non-regulated commercial domain might well be the area where we can see innovations that show us how today's technology can be made to work best so that payments become the afterthought that they are.