Headline Verdana Bold How to become and stay
Headline Verdana Bold How to become and stay licensed in Belgium? Fin. Tech Belgium Digital Classroom 06/10/2020
Introduction The Fin. Tech tree Possible fintech-related regulatory approaches and policy responses: 1. Adjusting or re-interpreting the regulatory perimeter of existing legislation and/or directly targeting fintech activities. 2. Adjusting existing regulations to add technologyspecific elements in existing laws, regulations or guidelines. 3. Providing the foundations for a digital infrastructure. KEY RISKS AND CHALLENGES © 2020 Deloitte Belgium § § Consumer Protection Data privacy and protection Impact on financial stability Cyber-security CONSIDERATIONS FOR REGULATORS § § § Fin. Tech sector support vs. consumer protection – avoid regulatory capture Data privacy and protection Operational resilience Impact on financial stability and resilience in a recession cycle Competition and consumer choice How to become and stay licensed in Belgium? 2
How to become and stay licensed in Belgium? Table of contents 1. Offering regulated services/products and becoming licensed • Understanding the regulatory perimeter • Building blocks of a license file 2. The challenge of compliance • The 3 Lines of Defence • Internal control • Challenges 3. Relevant developments in the regulatory landscape © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 3
Understanding the regulatory perimeter Belgium’s Twin Peaks supervisory model Two main supervisors National Bank of Belgium (NBB): responsible for the supervision of banking, insurance and other financial institutions Financial Services and Markets Authority (FSMA): responsible for the supervision of financial markets and consumer protection © 2020 Deloitte Belgium Other supervisors FPS Economy Data Protection Authority CTIF – CFI Belgian Competition Authority How to become and stay licensed in Belgium? 4
Understanding the regulatory perimeter National Bank of Belgium (NBB) Competences: • Micro-prudential supervision of certain financial institutions: ensuring individual financial institutions comply with authorization, organisational and capital requirements • Macro-prudential supervision: ensuring the proper functioning of the financial system as a whole • Oversight of financial market infrastructure, card schemes and processors of payment operations and critical service providers • AML/CFT supervisors for obligated entities for which the NBB is the prudential supervisor Supervised entities (micro-prudential) • Financial services groups (“Financial Conglomerates”) • Credit institutions • Insurance and reinsurance undertakings • Stockbroking firms (a type of investment firm) • Clearing institutions • CSDs/settlement institutions, depository banks and support institutions. • Payment institutions and electronic money institutions © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 5
Understanding the regulatory perimeter Financial Services and Markets Authority (FSMA) Competences: • Surveillance of the financial markets and supervision of listed companies in the area of information and disclosure • Supervision of compliance with conduct of business rules that apply to the financial institutions • Product supervision • Supervision of financial intermediaries (i. e. agents and brokers) and micro-prudential supervision of certain financial institutions • Supervision of supplementary pensions • Contribution to improving financial education • AML/CFT supervisors for obliged entities for which the FSMA is the prudential supervisor Supervised entities (micro-prudential) • Fund managers and undertakings for collective investment • Portfolio management and investment advice companies • Regulated real estate companies • Crowdfunding platforms • Independent financial planners • Currency change service providers • Consumer Credit / Consumer Mortgage providers • Financial intermediaries in banking, investment services, (re)insurance and credits • Market operators • Institutions for occupational retirement provisions) • (Virtual currency exchanges and Custodian wallet providers) © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 6
Understanding the regulatory perimeter Other supervisors FPS Economy Data Protection Authority CTIF – CFI The mission of the FPS Economy is to create the conditions for a competitive, sustainable and balanced functioning of the market for goods and services in Belgium. The Data Protection Authority (DPA) is an independent body ensuring the protection of privacy when personal data are processed. The DPA is the successor of the Commission for the protection of privacy. The Belgian Financial Intelligence Processing Unit (CTIF-CFI) is in charge of processing suspicious financial facts and transactions linked to money laundering and terrorism financing reported by institutions and individuals specified in the law. Its missions are to: • Advise and approve • Process suspicious financial transactions Among other things, its missions are to • Promote and ensure consumer protection • Regulate financial services such as consumer credit, mortgage credit, and payment services. • Issue opinions • Handle complaints • Inspects and acts as administrative dispute body • Advise and coordinate in the prevention of money laundering and terrorist financing • Link the different players involved © 2020 Deloitte Belgium Belgian Competition Authority The Belgian Competition Authority is an independent administrative authority that contributes to the definition and implementation of competition policy in Belgium. Its missions are to: • Investigates competition restrictive practices in Belgium • adopt interim measures in case of emergency, while also declaring injunctions or fines, and accepting commitments within the framework of an indepth investigation • conduct the preliminary investigation of merger operations that meet the turnover thresholds How to become and stay licensed in Belgium? 7
Understanding the regulatory perimeter The different regulated statutes in the financial sector Banks (Credit Institutions) Payment Institutions and Electronic Money Institutions Companies Stockbroking Firms Portfolio Management and Investment Advice Companies UCITS Management Companies, selfmanaged UCITS and AIFM’s CSDs/Settlement and Clearing Institutions and support institutions Consumer Credit / Consumer Mortgage Providers Currency Exchange service providers Regulated real estate companies Independent financial planners (Re)Insurance intermediaries (Re)Insurance Banking and investment intermediaries © 2020 Deloitte Belgium Market operators Crowdfunding platforms Institutions for occupational retirement provisions Virtual currency exchanges and Custodian wallet providers How to become and stay licensed in Belgium? 8
Understanding the regulatory perimeter 1) Payment services Services enabling cash to be placed on a payment account (+ operations required for operating payment account) Services enabling cash withdrawals from a payment account (+ operations required for operating payment account) Execution of payment transactions, including transfers of funds on a payment account with the user's payment service provider or with another payment service provider • Execution of direct debits, including one-off direct debits • Execution of payment transactions through a payment card or a similar device • Execution of credit transfers, including standing orders Execution of payment transactions where the funds are covered by a credit line for a payment service user (idem as 3) Issuing of payment instruments and/or acquiring of payment transactions Payment initiation services © 2020 Deloitte Belgium Money remittance Account information services How to become and stay licensed in Belgium? 9
Understanding the regulatory perimeter 2) Issuance of electronic money Electronic money’ means electronically, including magnetically, stored monetary value as represented by a claim on the issuer which is issued on receipt of funds for the purpose of making payment transactions, and which is accepted by a natural or legal person other than the electronic money issuer. Electronic money (e-money) is a digital alternative to cash. It allows users to make cashless payments with money stored on a card or a phone, or over the internet. © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 10
Understanding the regulatory perimeter 3) Investment services and activities (incl. ancillary services) • Investment services: ‒ Reception and transmission of orders in relation to one or more financial instruments. ‒ Execution of orders on behalf of clients. ‒ Dealing on own account (when execution orders on behalf of clients) ‒ Portfolio management. ‒ Investment advice. ‒ Underwriting of financial instruments and/or placing of financial instruments on a firm commitment basis. ‒ Placing of financial instruments without a firm commitment basis • Investment activities: ‒ Operation of MTF or OTF ‒ Dealing on own account • Ancillary services ‒ Safekeeping and administration of financial instruments for the account of clients, including custodianship and related services such as cash/collateral management ‒ Granting credits or loans to an investor to allow him to carry out a transaction in one or more financial instruments, where the firm granting the credit or loan is involved in the transaction; ‒ Advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings; To trigger an authorization obligation, the services and activities involved must provided or carried in relation to financial instruments. Virtual assets (such as tokenized securities) can classify as financial instruments. ‒ Foreign exchange services where these are connected to the provision of investment services; ‒ Investment research and financial analysis or other forms of general recommendation relating to transactions in financial instruments; ‒ Services related to underwriting. ‒ Investment services and activities as well as ancillary services related to the underlying of the derivatives where these are connected to the provision of investment or ancillary services © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 11
Understanding the regulatory perimeter 3) Investment services and activities Investment services Credit institution Stockbroking Management firm company UCITS company AIF Company for investment advice & portfolio management Reception and transmission of orders in relation to one or more financial instruments X X Execution of orders on behalf of clients X X Dealing on own account X X Portfolio management X X X Investment advice X X X Underwriting of financial instruments and/or placing of financial instruments on a firm commitment basis X X Placing of financial instruments without a firm commitment basis X X Operation of an MTF X X Operation of an OTF X X © 2020 Deloitte Belgium X X X How to become and stay licensed in Belgium? 12
Understanding the regulatory perimeter 3) Investment services and activities Ancillary services Credit institution Stockbroking Management firm company UCITS company AIF Safekeeping and administration of financial instruments for the account of clients, including custodianship and related services such as cash/collateral management and excluding maintaining securities accounts at the top tier level X X Granting credits or loans to an investor to allow him to carry out a transaction in one or more financial instruments, where the firm granting the credit or loan is involved in the transaction X X Advice to undertakings on capital structure, industrial strategy and related matters and advice and services relating to mergers and the purchase of undertakings X X Foreign exchange services where these are connected to the provision of investment services X X Investment research and financial analysis or other forms of general recommendation relating to transactions in financial instruments X X Services related to underwriting X X Investment services and activities as well as ancillary services related to the underlying of the derivatives where these are connected to the provision of investment or ancillary services X X © 2020 Deloitte Belgium Company for investment advice & portfolio management X X How to become and stay licensed in Belgium? 13
Understanding the regulatory perimeter 4) Crowdfunding platforms Alternative financing platform refers to any natural or legal person whose ordinary professional activity consists of supplying alternative finance services on Belgian territory, even if this activity is not it's main activity and that is not a regulated undertaking. The only investment services that can be included in alternative finance services are: • investment advice; • reception and transmission of orders Alternative finance services mean the marketing, by means of a website or any other electronic medium, of investment instruments issued by issuer entrepreneurs, financing vehicles, or starter funds. Authorization is not required for: • Donation-based crowdfunding platforms • Crowdfunding platforms on which payment can be made in exchange for a benefit in kind © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 14
Understanding the regulatory perimeter 5) Virtual currency exchanges and Custodian wallet providers Virtual currency exchange platform (VCEP) • Providers engaged in exchange services between virtual currencies and fiat currencies • Fiat currencies are defined as “coins and banknotes that are designated as legal tender and electronic money, of a country, accepted as a medium of exchange in the issuing country” © 2020 Deloitte Belgium Custodian wallet provider (CWP) • “An entity that provides services to safeguard private cryptographic keys on behalf of its customers to hold, store and transfer value” How to become and stay licensed in Belgium? 15
Building blocks of a license file Licensing process Application for license © 2020 Deloitte Belgium Consultation of the FSMA/NBB Decision Possibility of appeal Final decision How to become and stay licensed in Belgium? 16
Building blocks of a license file Key components of a license file The following building blocks apply to companies for investment advice and portfolio management and are displayed here as an example only. Requirements for license files may slightly differ in case other type of financial services are provided. Depending on the topic, a form needs to be filled in or documentation needs to be provided. Identification data Scope of application Clients and AUM Business model Internal control General organisation Investment services organisation Other services organisation Regulated functions Shareholders Governance Anti-money laundering (AML) © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 17
Key components of a license file Identification data, scope of application, clients and AUM, and business plan Identification data • Company identification: • name • company number • legal form • head office • website • Person in charge of the file preparation: • name • phone number • email address © 2020 Deloitte Belgium Scope of application Clients and AUM Business plan • Description, by type of products, of the investment services or ancillary services the firms intends to provide • Description of other services the firm intends to provide (e. g. crowdfunding) • Description of the expected number of clients and the expected volume of assets under management (for the first three years) • Distinction between retail and institutional clients • Forward-looking balance sheet and income statement for the first three years, based on at least three assumptions: ‘favourable’, ‘neutral’ and ‘unfavourable’ • Description of the firm’s revenue model (incl. nature and method of calculating expected revenues) How to become and stay licensed in Belgium? 18
Key components of a license file Internal control: first line • General description or the internal control organisation • Control procedures (in general and by service line) © 2020 Deloitte Belgium Internal control: second line compliance Internal control: second line risk management Internal control: third line internal audit • Compliance charter • Initial risk analysis • Integrity policy • Internal code of conduct • Policy and procedures on: • private transactions of relevant persons, including market abuses • retail clients complaints • compensation • conflicts of interest • Action plan (incl. relevant Mi. FID topics) • Procedures on the functioning of the compliance function • Internal procedures for reporting infringements of the rules monitored by the FSMA • Risk management charter • Initial risk analysis • Policy and procedures on: • market risk management • credit risk management • liquidity risk management • operational risk management (incl. fraud and legal risk) • business continuity (‘business continuity plan’) • Action plan • Procedures on the functioning of the risk management function • Internal audit charter • Initial risk analysis • Action plan (incl. relevant Mi. FID topics) • Procedures on the functioning of the internal audit function How to become and stay licensed in Belgium? 19
Key components of a license file General organisation • Organisation chart and number of employees • Schematic overview of the order flow, mentioning : • the tools used (software; communication channels) • the components of the company's own organisation • the external parties that play a role in this framework • Policy and procedures on: • staff training • data storage • (Project of) company statutes • Overview of insurance policies concluded • Policy and procedures regarding the coverage of risks by insurance policies © 2020 Deloitte Belgium Commercial organisation • Commercial organisation (incl. possible use of intermediaries, customer referrals, and recruiting of clients online) • Policy and procedures regarding off-site contracting Organization of outsourcing, delegation, and collaboration with critical service providers • List of outsourced services • Policy and procedures regarding the outsourcing, delegation, and collaboration with critical service providers • List of depositaries of client assets with whom the firm will collaborate • Policy and procedures regarding the selection of custodians for client assets with which the firm will collaborate • List of order executors with whom the company will collaborate • Policy and procedures regarding the selection of order executors with which the firm will collaborate Financial organisation – reporting process • Policy and procedures on: • Annual statements • Periodic statements IT organisation • Description of IT organisation (incl. the infrastructure and software used for the front office, middle office, back office, and accountancy) • Overview of the contracts to be concluded with IT services providers • Overview of the sources of information • Policy on logical and physical IT security • Policy and procedures regarding online services How to become and stay licensed in Belgium? 20
Key components of a license file Organisation of investment services and other services Investment services organisation • Policy and procedures on the approval of new products and services (‘product approval process’) • Questionnaire on appropriateness assessment • Questionnaire on adequacy assessment • Model contract of retail client portfolio management • List of financial instruments used in the context of providing investment services (indicating the category) • Policy and procedures on: • appropriateness assessment • adequacy assessment • financial instruments categorisation • client order processing • client order best execution/selection • client reports • client acceptance • client categorisation • client information (incl. advertising rules) • client files content • inducements • product governance © 2020 Deloitte Belgium Ancillary services organisation • Policy and procedures on: • investment research and financial analysis • advising companies on capital structure, industrial strategy, mergers and takeovers • services related to the underlying market for investment services derivatives Other authorised regulated activities • Policy and procedures on • financial planning advice • alternate finance services (crowdfunding) • insurance intermediation services How to become and stay licensed in Belgium? 21
Key components of a license file Regulated functions and shareholders Board of directors • Name • Executive director? • Member of the steering committee? • Senior executive in charge of AML? • Independent director? © 2020 Deloitte Belgium Other effective directors • Name • Function Independent control functions • List of the persons in charge of: • the compliance function • the risk management function • the internal audit function • AMLCO Shareholders • List of shareholders with qualifying holding (physical persons and legal entities) How to become and stay licensed in Belgium? 22
Key components of a license file Governance and AML Members of the board of directors Shareholders with qualifying holding • ‘XXXX’ questionnaire completed and signed • Copy of the ID • Extract of criminal record (less than three months old) • Questionnaire ‘XXXX. 2’ completed and signed by the company • Questionnaire ‘YYYY’ completed and signed • Schematic presentation of the group to which the undertaking belongs (if applicable), mentioning (if applicable) the status of the regulated undertakings in the group and the competent supervisory authority © 2020 Deloitte Belgium Governance AML • Governance memorandum • Policy and procedures on the terms of directors, effective officers and persons responsible for independent oversight functions • Policy and procedures on: • anti-money laundering and antiterrorist financing • client acceptance • identification of the characteristics of the client and of the purpose and the nature of the business relationship • periodical client review • customer and transaction due diligence • internal reporting of atypical operations to the AMLCO • reporting to CTIF of atypical transactions known or suspected to be related to ML/TF • compliance with binding provisions on financial sanctions and embargoes and other restrictive measures How to become and stay licensed in Belgium? 23
How to become and stay licensed in Belgium? Table of contents 1. Offering regulated services/products and becoming licensed • Understanding the regulatory perimeter • Building blocks of a license file 2. The challenge of compliance • The 3 Lines of Defence • Internal control • Challenges 3. Relevant developments in the regulatory landscape © 2020 Deloitte Belgium 24
The challenge of compliance The 3 Lines of Defence = Systematic approach to enhance communication and clarify roles & responsibilities between the different functions within an organisation 1 st line T R A N S V E R S A L © 2020 Deloitte Belgium Other operation al functions: Legal, HR, … 4 th line 5 th line External auditor Supervisory Authorities Line - Business / Operational services 2 nd line The risk management function: facilitate and supervise the implementation of the risk control measures taken by the operational management, assist the operational management at identifying the risks of the financial institution. The risk management function cannot perform compliance function tasks. The compliance function: judge the compliance risk of the institution, observe that the institution complies with the laws, regulations and codes of conduct which are part of its work domains. 3 rd line The internal audit function: judge the appropriateness of the internal control measures, including the risk management function and the compliance function. The internal audit function can not preform compliance function tasks. • All transversal functions: align activities, make sure that there is a fitting exchange of relevant information, inform each other about relevant findings. • In general: every institution must have a sound governance structure and must comply with the legal organisation requirements. How to become and stay licensed in Belgium? 25
The challenge of compliance The 3 Lines of Defence Internal control in the operational services Compliance & risk management function Internal Audit function Transversal functions: • Are responsible for identifying and managing the risks in the operational services in collaboration with these services • Should align their activities and see to an adequate exchange of relevant information • Communicate findings which are relevant to another function to that function Each institution must have an appropriate policy structure, which refers in particular to: • A coherent and transparent organisational structure, providing for an appropriate separation of functions • A well defined, transparent and coherent system for the assignment of responsibilities • Appropriate procedures for the identification, measurement, management, tracking and internal reporting of any significant risk incurred by the institution due to activities in which it engages or intends to engage • A remuneration policy and culture which are consistent with and contribute to a sound and effective risk management It is strongly recommended that the legal function will not to carry out any compliance assignments. © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 26
The challenge of compliance Internal control refers to the set of measures which, under the responsibility of the management of the institution, should with reasonable certainty allow for: • Orderly and prudent management of the institution, with clearly defined objectives • Efficient and economical use of the employed resources • Identification and sufficient management of the risks in order to protect the institution's funds • Sound and reliable financial and management information • Compliance with the laws and regulations, as well as with the general policies, plans and internal rules © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 27 27
The challenge of compliance Internal control • Physical controls, manuals, safety orders, IT security etc. • Internal control is effected by people. It’s not merely policy manuals and forms, but people at every level of an organization. • The ultimate responsibility of functioning internal control lies with the top management and board of the organization • Manage & operate internal control system => Management & employees • Oversight of internal control system => Board Misconceptions: Internal control is… … a set of rules on paper to comply with regulations … a lot of administrative work … something that is only required in the finance department … not necessary because we all know each other … something to punish us with when we underperform … a waste of time © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 28 28
The challenge of compliance Internal control COSO = Committee of Sponsoring Organizations of the Treadway Commission - The COSO Framework was designed to help businesses establish, assess and enhance their internal control It is built around 5 components and 17 principles © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 29 29
How to become and stay licensed in Belgium? Table of contents 1. Offering regulated services/products and becoming licensed • Understanding the regulatory perimeter • Building blocks of a license file 2. The challenge of compliance • The 3 Lines of Defence • Internal control • Challenges 3. Relevant developments in the regulatory landscape © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 31
Recent developments in the regulatory landscape MICA proposal Entities in scope: Persons that are engaged in the issuance of cryptoassets or provide services related to crypto-assets in the EEA • A wide range of crypto-asset service providers are in scope such as custodian wallet providers, cryptoasset trading platforms and cryptoasset brokers and advisors • Issuers of crypto-assets • Credit institutions and investment firms can provide services related to crypto-assets without authorization, insofar the provision of these services is compatible with their authorization. © 2020 Deloitte Belgium Virtual assets in scope: A digital representation of value or rights which may be transferred and stored electronically, using distributed ledger technology or similar technology • Utility tokens • Asset-referenced tokens (stablecoin) • E-money tokens (stablecoin) • Other crypto-assets (incl. non. Carve outs stablecoin cryptocurrencies) Crypto-assets that qualify as: • Financial instruments • Electronic money except where they qualify as electronic money tokens • (Structured) deposits • Securitisations How to become and stay licensed in Belgium? 33
Recent developments MICA proposal Licensing and prudential requirements for crypto-asset service providers Crypto-asset service providers will be required to have a physical presence in the EU and they will be subject to prior authorization from a national competent authority before starting their activities. They will be subject to prudential requirements, organizational requirements, rules on safekeeping of clients' funds and rules on mandatory complaint handling procedures and conflicts of interest. In addition, there are specific requirements dependent on the type of crypto-asset services being provided. A passporting regime will be introduced as well. © 2020 Deloitte Belgium Prevention of market abuse The new rules will also prohibit market abuse in relation to crypto-assets that are admitted to trading on a trading platform for crypto-assets operated by an authorised cryptoasset service provider, or for which a request for admission to trading on such a trading platform has been and introduce a requirement for issuers of the above crypto-assets to disclose inside information. How to become and stay licensed in Belgium? 34
Recent developments MICA proposal Offering and marketing to the public of crypto -assets (other than asset-referenced tokens and e-money tokens) An issuer will only be able to offer such crypto-assets to the public in the EEA or seek an admission to trading on a trading platform for such crypto-assets if it complies with certain requirements such as the obligation to be established in the form of a legal person, the obligation to draw up a crypto-asset white paper, and the notification of such a crypto-asset white paper to the competent authorities and its publication. In addition, requirements in relation to marketing communications and conduct of business requirements for issuers will be introduced. After the notification of the crypto-asset white paper, competent authorities would have the power to suspend or prohibit the offering, require the inclusion of additional information in the crypto-asset white paper or make public the fact that the issuer is not complying with the Regulation © 2020 Deloitte Belgium Specific additional requirements for offering asset-referenced tokens to the public and to seek their admission to trading on a trading platform for cryptoassets Issuers of asset-referenced tokens are subject to additional requirements. The main additional requirements include the obligation to be authorized, governance requirements, detailed rules on conflict of interests, ongoing information requirements, the requirement to have a complaint handling procedure, capital requirements, requirements for orderly wind-down, the requirement to have a reserve of assets (and associated investment rules) and additional white paper requirements (incl. supervisory approval). Additional obligations will apply in case the asset-referenced token is considered as “significant” by the EBA. Finally, the Regulation will introduce requirements with respect to the acquisition of issuers of assetreferenced tokens How to become and stay licensed in Belgium? 35
Recent developments MICA proposal Specific additional requirements for issuers of e-money tokens No e-money tokens will be able to offered to the public in the EEA or admitted to trading on a crypto-asset trading platform unless the issuer is authorised as a credit institution or as an electronic money institution and e-money tokens are deemed electronic money. This means that the issuers involved will be subject to the regulatory requirements of the Electronic Money Directive and the rules set out in the Regulation on Markets in Crypto-Assets, which for example means that they must give a 1: 1 claim to the token holders and must publish a white paper. Additional obligations will apply in case the e-money token is considered as “significant” by the EBA. © 2020 Deloitte Belgium Supervision To ensure effective supervision, Member States have to designate a competent authorities for the supervision of compliance with the Regulation. For issuers of significant asset-referenced tokens the supervision is carried out by the EBA. Significant e-money tokens are subject to dual supervision by national competent authorities and the EBA. How to become and stay licensed in Belgium? 36
Recent developments DLT Pilot regime © 2020 Deloitte Belgium How to become and stay licensed in Belgium? 37
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