GFIN cross-border testing

Global Financial Innovation Network invites firms to participate in cross-border testing

Friday, 30 October 2020

The Global Financial Innovation Network (GFIN) is inviting applications from firms to test innovative financial products, services, business models or regulatory technology across more than one country or jurisdiction.

Twenty-three regulators across five continents are participating in this initiative, which builds on lessons learned following the GFIN’s 2019 cross-border testing pilot.

Cross-border testing 1.0

To facilitate the application process, the GFIN has developed several tools and solutions to improve the cross-border testing framework for a new cohort of firms, including:

  • a single-entry application form for firms;
  • a cross-border testing FAQs to help firms understand the process;
  • an evolved ‘Regulatory Compendium’ clarifying the remit and interests of participating regulators and the types of innovation services available; and
  • an extension of the application window to 9 weeks to allow firms more time to consider and prepare their applications.

Firms interested in applying to take part in cross-border testing should review the list of participating regulators and their respective Regulatory Compendiums and submit an application via the GFIN website before the 31 December deadline.

Participating Regulators

The following regulators are participating in cross-border testing.


Regulatory Authority



Australian Securities and Investments Commission (ASIC)



Central Bank of Bahrain (CBB)



Bermuda Monetary Authority (BMA)



Alberta Securities Commission (ASC)

Alberta, Canada


British Columbia Securities Commission (BCSC)

British Columbia, Canada


Ontario Securities Commission (OSC)

Ontario, Canada


Autorité des marchés financiers (AMF)

Quebec, Canada


Guernsey Financial Services Commission (GFSC)



Hong Kong Insurance Authority (IA)

Hong Kong


Hong Kong Monetary Authority (HKMA)

Hong Kong


Hong Kong Securities and Futures Commission (HKSFC)

Hong Kong


Magyar Nemzeti Bank (Central Bank of Hungary, MNB)



Jersey Financial Services Commission (JFSC)



Astana Financial Services Authority (AFSA)



Capital Markets Authority (CMA, Kenya)



Bank of Lithuania (LB)



Monetary Authority of Singapore (MAS)



Financial Services Commission Taiwan (FSC Taiwan)



Abu Dhabi Global Market (ADGM)

Abu Dhabi,

United Arab Emirates


Dubai Financial Services Authority (DFSA)


United Arab Emirates


Central Bank United Arab Emirates (CB UAE)

United Arab Emirates


Financial Conduct Authority (FCA)

United Kingdom


Consumer Financial Protection Bureau (CFPB)

United States of America

Cross-border testing pilot

Tuesday, 21 January 2020

One of the early priorities for GFIN was to develop cross-border testing, previously known as the “global sandbox” concept. As part of this new initiative, GFIN were looking for firms to apply to participate in a pilot to test innovative financial products, services or business models across more than one jurisdiction.

The pilot was as much a trial for GFIN members as it was for firms. Regulators looked for firms who could be flexible and agile in their participation and could provide GFIN regulators with feedback on their experience. Firms benefited from the opportunity to test and compete in these regulated spaces, and their tests helped inform the future work of the network. Over time, trials could inform regulatory authorities about potential areas of regulatory convergence, although it was stressed this was meant as a longer-term opportunity.

In total, 44 unique applications were submitted across the 17 participating regulators. Every regulator participating in the pilot was the subject of at least one application. Each regulator has considered whether a proposed test meets its individual screening criteria, areas of interest, and they have considered their ability to support the activity.

Results of cross-border testing

After this initial screening of 44 applications, GFIN members continued working with 8 firms. The next phase was for firms to develop testing plans with the relevant regulators for their cross-border trial, some of which would involve live transactions. Firms that developed a testing plan satisfactory to each jurisdiction’s criteria would take part in the pilot testing phase.


Proposed test

Current regulators   involved


Software company   offering products built on   public and private blockchains that support   the requirements for issuance,   custody and trading of digital assets   with liquidity across multiple   exchanges.

Bermuda Monetary Authority   (BMA), Bank of   Lithuania (LB)

Ascent RegTech

AI-driven RegTech   solution that automatically   maps a customer’s specific regulatory   obligations and ongoing rule changes,   while also enabling end-to-end   compliance management. The product helps firms   see similarities and   differences in regulatory obligations across regulators   and countries.

Australian   Securities & Investments   Commission (ASIC), Autorité des marchés   financiers (AMF Québec), Dubai   Financial Services Authority (DFSA),   Financial Conduct Authority (FCA), Hong   Kong Monetary Authority   (HKMA), Ontario Securities Commission (OSC)


Digital   securities platform offering primary issuance of digital   shares &   debentures, secondary trading and optimized post-trade, with   automatic   clearing, settlement and custody.

Central Bank of   Bahrain (CBB), Monetary   Authority of Singapore (MAS), Jersey Financial   Services Commission (JFSC), LB


Platform that   uses blockchain to allow users to invest in real   estate shares as   securities and develops fractional ownership schemes’.

British Columbia   Securities Commission   (BCSC), BMA, JFSC, LB, MAS


Platform that   uses DLT and machine learning to   facilitate cross-border transactions   of multi-currency payments, assets and   commodities via tokenisation,   smart contracts and escrows.’

Astana Financial   Services Authority (AFSA),   plus others to be confirmed


A technology   provider that has developed a proposition to allow   consumers to   securely control their verified identity Digital ID and   share/transfer   that verified identity across financial services organisations   for the   purposes of KYC checks.


Starling Trust

Applied   behavioural sciences technology company that has developed a     Predictive Behavioural Analytics platform using machine learning and     electronic communications data to allow users to measure, manage and mitigate     culture and conduct risks. They will be partnering with a select group   of   global banks, with an initial focus on the three lines of defense   risk   framework.



A   blockchain-based KYC and onboarding platform   that uses AI, IoT and   cloud to help financial institutions meet regulatory   obligations for   SMEs, Corporates, Capital markets, Wealth Management, Retail   and   Unbanked customers and helps regulators provide guidance and supervision     for their markets. They will work with GFIN on self-executing   cross-border   KYC policies.

Abu Dhabi Global   Market (ADGM) and FCA

In January 2020, GFIN made the decision that they were unable to take forward any of the eight firms to begin testing as the firms did not develop a testing plan that satisfies each jurisdiction’s criteria (e.g. the firm’s business is still in development and not ready to test; lacking formal partnerships). GFIN is exploring how it might be able to assist these firms in other ways, either outside the GFIN framework or inviting them to re-engage with the Network when they are closer to being ready to test.

Lessons learned and next steps

The cross-border testing pilot provided GFIN members with valuable experience and feedback which will help the network continue to evolve the framework for future cohorts and ensure that firms are ready for testing.

In October 2019, GFIN met in Montreal to reflect on the pilot and consider the future of cross-border testing, including how processes and structure should change as a result of our experience. In the year since the GFIN launched the cross-border testing pilot they’ve continued to hear that industry is enthusiastic about the support and coordinated services GFIN could provide. Members agreed there is merit in continuing the work on cross-border testing given market demand and the chance for further regulatory learning and collaboration. The EY Fintech Australia Census 2019 highlighted access to international markets and expansion continues to be an important issue for firms, including among developed economies. At the same time, global fintech investment was at an all-time high in 2018 increasing 120% from $50.8 billion USD in 2017 to $111.8 billion USD. Anecdotally, GFIN members continue to have conversations at the domestic level with firms who are strongly supportive of regulators finding more efficient ways to provide coordinated services.

For these reasons, GFIN is committed to developing further the framework of cross-border testing and is now launching several solutions as part of cross-border testing 1.0, or the post-pilot phase. The Network is launching these new solutions ahead of the planned opening of applications for a new cohort in H1 2020.

As part of the Network’s commitment to having an open dialogue with industry, the GFIN has prepared the “Cross-border testing: lessons learned” report to reflect on the pilot period from January 2019, including its achievements and the challenges it faced. The report also includes next steps and solutions to improve cross-border testing for the next phase. GFIN is excited to implement these solutions, continue supporting firms and create an environment to allow the testing and scaling of new technologies in multiple jurisdictions.

Download the "GFIN Cross-border Testing: Lessons Learned" report

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Last updated: 30/03/2021 09:23