The ultimate objective of cryptocurrencies is to become a payment system substituting, complementing, or competing with the conventional payment systems. Irrespective of whether such an objective could be accomplished, the functional similarities between certain cryptocurrencies and fiat money has persuaded competent authorities of certain EU Member States to grant payment institution licenses to cryptocurrency exchanges. At first blush, granting such an authorization would seem to be a step forward as it would bring otherwise unregulated cryptocurrency exchanges within the scope of the existing payment regulatory framework. However, this authorization effectively applies payment laws to new payment infrastructures that rely on volatile settlement assets with probabilistic finality. Since the volatility and finality risks cannot be fully addressed under the existing payment laws, an alternative policy option would be granting a special license to cryptocurrency businesses or introducing ring-fencing mechanisms to protect the conventional payment systems from the risks of cryptocurrency payments.

中文翻译：

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将加密货币交易所许可为支付机构的阴暗面

加密货币的最终目标是成为替代、补充或与传统支付系统竞争的支付系统。无论这一目标能否实现，某些加密货币和法定货币之间的功能相似性已说服某些欧盟成员国的主管当局向加密货币交易所授予支付机构许可证。乍一看，授予此类授权似乎是向前迈出的一步，因为它会将原本不受监管的加密货币交易所纳入现有支付监管框架的范围内。然而，该授权有效地将支付法应用于依赖于具有概率终结性的不稳定结算资产的新支付基础设施。