WEBVTT

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Narrator: Tanya, a tax manager, has a dependent son that wants to

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purchase cryptocurrency. He is very excited about a particular

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cryptocurrency and wants to make the purchase right away. Tanya

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knows that there are independence rules related to cryptocurrencies

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and is unsure how to proceed. She weighs her options. She can tell

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her son that he can’t make the purchase until she has a chance to confirm

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whether it is permissible, or she can let him go ahead and buy it, just

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this once. In the interest of avoiding an independence violation, she

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decides to reach out to Risk Management - Independence for assistance

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in determining whether the cryptocurrency purchase is permissible.

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Let’s listen to the conversation.

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Tanya: My son would like to purchase a cryptocurrency. I know there are

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independence rules on cryptocurrencies, but I’m not sure where to start.

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Independence: It’s good that you called. First off, there are several

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cryptocurrencies and digital assets that have already been identified as

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“safe” for independence purposes. The list can be found on the KPMG

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Independence Safe List on the Independence portal - Bitcoin, Litecoin,

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Ethereum and Verge are some examples. You can purchase these digital

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assets on the Safe List through a digital wallet custodian, like Coinbase,

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and they don’t need to be reported in your KICS account.

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Tanya: That’s good to know, but he’s interested in a different one.

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Independence: Got it. If it’s not one of the cryptocurrencies included

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in the Safe List, then you would need to check the restriction status of the

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cryptocurrency or digital asset in KICS before he makes the purchase.

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Your dependent son would not be permitted to purchase any cryptocurrency

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or other digital asset that is restricted. Any permitted cryptocurrency or

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digital asset that you hold - other than those on the KPMG Independence

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Safe List - will now need to be reported in your KICS account.

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Tanya: So I would need to check KICS before he purchases the

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cryptocurrency, just like I would before making an investment?

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Independence: That’s right. Before purchasing a cryptocurrency

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or other digital asset, you should always check KICS to determine its

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restriction status. There’s a large number of cryptocurrencies listed in

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KICS, and as long as it’s not a restricted option, you can purchase it.

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Tanya: Ok, but what if I can’t find the cryptocurrency in KICS?

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Does that mean it’s not restricted?

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Independence: No, that just means additional research is needed. If you can’t

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find it in KICS, reach out to Risk Management - Independence via the

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Independence Inquiry Submission Form found on the Independence portal,

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so that we may research and confirm the restriction status. And make

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sure your son holds off on making the purchase until you receive

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a response and have conclusive evidence that it’s not restricted – otherwise,

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you may end up with an independence violation if it turns out to be restricted.

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Tanya: Okay, I think I’ve got it. Is there anything else I should be thinking about?

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Independence: Well, yes. You’ll need to consider where your son

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is planning to hold the cryptocurrency. Using a digital wallet custodian or

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exchange could impact your independence, since the balances may be

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subject to the independence rules that apply to brokerage account balances.

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If the custodian or exchange is an SEC restricted entity and you are

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a Covered Person, you can’t hold accounts with that entity if the digital

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asset custodian or exchange doesn’t provide insurance coverage under SIPC.

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Tanya: Ok, it sounds like we have a lot of options. I’ll be sure to do

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my research before we make any purchases and will monitor Risk

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Management – Independence communications for

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updates on this evolving topic.

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Narrator: The conversation with Risk Management - Independence

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helped Tanya recognize and evaluate the independence considerations

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before allowing her son to make the purchase. They informed her of the

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steps and research that must be undertaken before purchasing

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cryptocurrency or other digital assets. By discussing the matter with

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Risk Management -Independence first, Tanya acted in an ethical manner

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and was able to decide on the best course of action to avoid an

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independence violation.

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