Risks in the Choice Environment of Crypto Apps

VISUAL ANALYSIS SUMMARY Risks in the choice environment of crypto apps

In brief At the end of 2024, the 'Markets in Crypto-Assets Regulation' (MiCAR) will enter into force. In preparation for this, the AFM is exploring potential risks on the crypto market. This research into the choice environment of crypto apps shows, among other things, that guiding and activating elements in these apps carry the risk that users trade more frequently and trade in products that are not in their own best interest. Because MiCAR offers the AFM few points of reference to address these risks, we advise consumers to remain alert themselves: crypto assets remain very risky. The AFM will enter into dialogue with European policymakers regarding the importance of a carefully designed choice environment in crypto apps.

Monday, February 19 Reports 14:39 Top gainers of today ... Invite your friends and benefit now ... Win: enter for a chance to win €250 in A Coin ... Users receive guiding push messages, for example about temporary promotions or large price changes of certain tokens. Real-time tracking of the crypto market is stimulated. The registration process is fast and easy. Rewards make it attractive to also invite friends. Risk 2 Guidance in the use of the app. Among other things: Risk 3 Activation to keep returning to the app. Among other things: Risk 1 Low-threshold access to the app. Among other things: Create an account now and start trading! (3-5 minutes) First and last name Email address Password I understand the risks of trading in crypto Privacy and terms Continue Staking and lending are strongly highlighted. 24.77% €0.2808 €0.2024 1h 24h 1m max Buy Sell €0.2204 B Coin Few steps needed to make a purchase and trading with high amounts is made easy. Guidance towards trading in certain cryptotokens, such as trending or rising tokens. Enable Lending Earn more with lending your coins! Enable Staking Receive yield by staking your favorite coins! € € € € € Buy Confirm 1 2 3 4 5 6 7 8 9 , 0 €25 €250 €2,500 All-in C Coin € 0.00 A Coin D Coin B Coin Trade now Trending Gainers A-Z Buttons for immediate trading are present everywhere in the app.

Risks in the choice environment of crypto apps 2 ANALYSIS REPORT Summary The Markets in Crypto-Assets Regulation (MiCAR) will regulate crypto services - such as crypto applications (apps) - more strictly. After the entry into force of MiCAR on 30 December 2024, crypto asset service providers active on the European market must, among other things, ensure good information provision to consumers and non-misleading advertising. The AFM intends to act as a critical supervisor. MiCAR aims to better protect consumers, but not all risks are addressed by the new regulation. The AFM is conducting research to map the consumer risks that will remain after the entry into force of MiCAR. At the end of 2023, an exploration of the online choice environment of the crypto apps of three Dutch service providers was carried out. The design of the choice environment influences how people consider their options and which choices they ultimately make. MiCAR will not impose requirements on the design of the choice environment of crypto apps. In this research, an estimate was made of the presence of guiding elements in the apps examined that influence users' choices and may carry risks. The three main risks identified relate to:

1. A large public has low-threshold access to the crypto market. The crypto apps examined are all very accessible due to an easy-to-complete registration process. By offering referral rewards, existing users are also stimulated to invite friends. Friends can thus be strongly influenced to - partly driven by feelings of Fear of Missing Out - also start trading in crypto. The low-threshold access and the offering of referral rewards carry the risk that also consumers for whom crypto is not a suitable product enter the crypto market. This could concern, for example, consumers who cannot afford to lose the money they trade with, who are not well informed about the risks of crypto, or for whom the risk of crypto does not fit their risk preferences.
2. Users are guided towards trading (with high amounts) in certain cryptotokens and activating additional services. Users are guided in all apps examined towards trading and towards trading in certain cryptotokens, under other things by trending lists and news articles. A buy or sell order is completed within 3 to 4 clicks and there are few barriers that lead users to pause and consider the choices they make. This carries the risk that users make impulsive choices and spend (more) money on cryptotokens they might otherwise not have chosen. In all apps examined, the emphasis is on staking and lending, with no attention paid to what these services mean and what risks are associated with them. The ease with which the services can be enabled carries the risk that users stake or lend cryptotokens without being properly informed that they are doing so or what this precisely entails.
3. Users are encouraged to return to the app and take action repeatedly. Inside and outside the apps, users are activated to return and take action (continue to take action). Through short-term quotes and real-time changing numbers, users are encouraged to follow the crypto market closely. Push messages tempt users to return to the app and often guide towards taking certain actions, such as trading in hard rising or newly added cryptotokens. The offering of temporary promotions also stimulates users to act quickly. All these elements carry the risk that users are very active in the app, trade more and trade in cryptotokens they might not have chosen themselves.

Risks in the choice environment of crypto apps 3 ANALYSIS REPORT MiCAR offers no points of reference for supervising the design of the online choice environment. Consumers active on the crypto market must therefore remain alert themselves. Crypto assets are very risky products that seem suitable only for a very small group, and this will remain the case under MiCAR. It is important that consumers only trade with their own money that they can afford to lose and that they make informed choices by educating themselves about the nature of the products they buy, including the associated risks. The AFM will enter into dialogue with European policymakers to bring to attention the importance of a careful design of the choice environment of crypto apps.

Risks in the choice environment of crypto apps 4 ANALYSIS REPORT

1. Background 1 In the rest of this report, we refer to crypto assets when the term crypto is used. When referring to specific crypto assets, the term cryptotokens is used. 1.1 What is crypto? Crypto assets1 are a digital representation of value or rights that can be traded and stored via a distributed ledger. What distinguishes crypto assets from traditional currency is that they are decentralized. This means they are not controlled by central authorities such as (central) banks. Instead, transactions are verified and recorded on a distributed ledger known as the blockchain; this technology is also called Distributed Ledger Technology (DLT). In addition to serving as a form of digital money and value storage, crypto is also used for various other purposes, such as enabling other decentralized (financial) services. Crypto exists in various forms and differs in the underlying technology used, each with its own characteristics, risks, and value. The value attributed to crypto is mainly based on the extent to which crypto is used and the potential technological utility. The speculative nature associated with crypto causes prices to fluctuate strongly. Furthermore, the pseudonymity of issuers and holders of crypto and the possibility of international trade without intermediaries makes it difficult for consumers and supervisors to assess the integrity of crypto and crypto services. Risks regarding crypto affect both the sound and stable operation of crypto markets and the protection of consumers. The integrity of crypto markets is an important risk for crypto. Think here of the lack of rules for asset segregation, the risk of market abuse (insider trading, market manipulation) and the risk of money laundering and terrorism financing and circumvention of sanctions legislation. Crypto markets also pose a potential risk to financial stability when the size and interconnection with the traditional financial system increase. Furthermore, there are significant risks for consumers; crypto assets are in fact very risky products that seem suitable only for a very small group. These risks can be exacerbated by the low-threshold offering of crypto to consumers and the offering of crypto via unclear, incomplete, and (deliberately) misleading information. Crypto and underlying technologies can drive innovation in financial markets. The possible benefits mainly concern the underlying blockchain technology. Due to the decentralized, global nature of blockchain technology, crypto is not dependent on individual platform providers or traditional financial intermediaries. This offers the possibility of low transaction costs and almost immediate settlement of transactions. However, the degree of innovation and possible benefits varies per crypto. 1.2 What is the legal framework? Currently, crypto and crypto services generally do not fall under the supervision of the AFM. Financial products or financial services based on crypto may fall under our supervision. Examples of this include: managing an investment fund that invests in crypto, issuing a share or bond using blockchain technology, and issuing crypto-based derivatives. Providers of crypto services wishing to become active in or from the Netherlands must apply for registration in the public register of De Nederlandsche Bank (DNB). To do so, they must demonstrate compliance with legislation on the prevention of money laundering and terrorist financing and the Sanctions Act. However, consumers are not currently protected as they are with other financial products or services.

Risks in the choice environment of crypto apps 5 ANALYSIS REPORT By the end of 2024, crypto services - such as crypto apps - will be more strictly regulated by the Markets in Crypto-Assets Regulation (MiCAR), but it is not a solution for all risks on the crypto market. MiCAR was published in June 2023 and will enter into force gradually from mid-2024. MiCAR aims to support innovation and fair competition while ensuring better protection for individual holders and integrity on the crypto markets. MiCAR does not address all risks surrounding crypto to the same extent. For example, unlike the Markets in Financial Instruments Directive II (MiFID II)2 , MiCAR does not impose requirements in the field of product development and distribution. This also applies to the design of the choice environment in crypto apps. Furthermore, in the area of market abuse, MiCAR goes less far than existing legislation in this area. Moreover, in supervising crypto asset service providers (CASP)3 , there is the limitation that this is primarily allocated at the member state level, while crypto markets are by nature cross-border. Crypto service providers with a license in another European country may also serve Dutch consumers, for example via apps. For the supervision of these parties, the AFM is largely dependent on the foreign supervisor where the crypto service provider holds a license. 1.3 What consumer risks remain? The AFM is currently preparing for the entry into force of MiCAR and the supervision of crypto markets and crypto service providers. The AFM uses a risk-based approach in its supervision. This means that when granting licenses to crypto parties, the AFM will focus on the significant risks regarding the design of business operations and management. In ongoing supervision, the AFM will focus on the main risks regarding business operations, integrity, transparency, and service provision. This 2 MiFID II applies to investment firms and trading venues. This regulation aims to make European financial markets more efficient and transparent and to increase investor protection. 3 In the rest of this report, (crypto) service providers are referred to. 4 In April 2023, a survey was conducted on various financial topics among 1,163 Dutch consumers who are part of the LISS panel. The LISS panel is managed by Centerdata, an independent research institute. The panel is selected to form a representative reflection of the Dutch population. When extrapolating the data to the number of Dutch users, it should be noted that this is survey research and that this number is subject to uncertainty. 5 See e.g. Understand, Guide, Measure (AFM, 2021); Johnson et al. (2012); Münscher et al. (2015); Sunstein (2014); Szaszi et al. (2018); Thaler et al. (2013) means that crypto service providers must meet various requirements such as asset segregation, preventing money laundering and conflicts of interest, and providing correct, clear, and non-misleading information to consumers. As noted, risks remain unaddressed under MiCAR. The risk-based crypto supervision of the AFM will therefore also focus on mapping which risks for consumers remain after the entry into force of MiCAR. In this context, the AFM has conducted various studies to gain insight, among other things, into the characteristics of current crypto holders and the environment in which they trade. A survey among a representative panel in April 2023 showed that 11% of respondents owned crypto at that time or previously. This amounts to approximately 1.95 million Dutch (former) crypto holders. Of these, 4% stated they had previously owned crypto but did not own it at that time. Crypto ownership is more common among men, younger age groups, and those with middle and higher education (see figures in Appendix 1. Characteristics of crypto holders).4 To get a better picture of the environment in which crypto holders make choices, an exploratory study was also conducted into the choice environment of applications that service providers use to offer crypto (crypto apps). The design of the choice environment influences how people consider their options and which choices they ultimately make.5 This design can have both a positive and negative impact on the choices one makes; from stimulating prudent financial behavior to encouraging purchases that are not in the consumer's interest. It is not possible to design a 'neutral' choice environment, as a decision will always have to be made regarding the manner in which options are presented. Crypto service providers

Risks in the choice environment of crypto apps 6 ANALYSIS REPORT can design the choice environment in such a way that it primarily focuses on promoting commercial interest rather than customer interest. In this context, an exploratory study was conducted at the end of 2023 into the choice environment of crypto apps from three Dutch and one foreign crypto service provider. The results of this study are central in the rest of this report. Chapter 2 discusses the main findings. Chapter 3 forms a conclusion based on this regarding potential risks for consumers on the crypto market.

Risks in the choice environment of crypto apps 7 ANALYSIS REPORT 2. Guidance and activation in crypto apps 6 Auer et al. (2023); Weber et al. (2023) At the end of 2023, the AFM conducted an exploratory study into the online choice environment in the apps of three Dutch crypto service providers. These service providers together serve the majority of Dutch crypto holders. The goal of this exploration was to map the potential risks for consumers by making an initial estimate of the presence of guiding elements in crypto apps that influence choices. Where possible, observations were enriched with results from previous studies and insights from academic literature to make a better estimate of the possible ways in which consumers' choices are influenced. Based on this research, however, we cannot determine what the actual effect is of the design of the choice environment on the behavior of app users. Accounts were opened at the three Dutch crypto service providers for the execution of the research. In addition to the app, the registration process was also examined. The website and other communications such as e-mails from the crypto service providers were excluded. The observations in this report are based on a snapshot in November and December 2023. It is therefore possible that changes have occurred since then. Also, the app of one foreign service provider was examined. Since this concerns only one foreign service provider, these observations are described separately from the other three crypto apps. The results can be found on page 16 of this report in the box 'Observations crypto app foreign crypto service provider'. More information about the research design can be read in Appendix 2. Research Justification. In this chapter, the main observations and associated risks for consumers when using the crypto apps are described. These are divided into three paragraphs based on the different interactions users have with crypto apps: access to the app, using the app, and returning to the app. 2.1 Low-threshold access to the app Over the past few years, trading in crypto has increased strongly.6 This increase was partly made possible by the low-threshold access that crypto apps provide consumers to the crypto market. This low-threshold access carries the risk that also consumers for whom crypto is not a suitable product enter the crypto market. This applies in particular to consumers who cannot afford to lose the money they use to trade or to consumers who do not understand the market and/or do not foresee the risks. In this paragraph, the observations related to access to the crypto apps are explained. 2.1.1 The registration process runs smoothly Prior to and during the creation of an account, consumers are exposed to various marketing messages that emphasize the positive aspects of (trading in) crypto and the benefits of trading with the specific service provider. For example, all three service providers emphasize that they comply with European laws and regulations and/or that they have a DNB registration, that they have a very large offering, and that an account is created quickly. The possibility of generating passive income by 'putting crypto to work' is also mentioned by one service provider. Furthermore, two of the service providers show various visualizations of, among other things, stacks of money and green rising lines. Create an account now and start trading! (3-5 minutes) First and last name Email address Password I understand the risks of trading in crypto Privacy and terms Continue The registration process is fast and easy.

Risks in the choice environment of crypto apps 8 ANALYSIS REPORT Creating an account is an easy process and takes about 3 to 10 minutes. Consumers must share their name, email, funding source, and reason for opening an account with all three service providers. Other information - not covered by all service providers - includes sharing address details, phone number, employment status, and net income. Identity verification is part of the registration process for two service providers, where users must upload a photo of an identity document and a selfie video or photo. For the other service provider, ID verification follows later and is only necessary when one wishes to deposit more than 250 euros or crypto. This makes the registration process with this service provider significantly shorter. One of the service providers makes the registration process personal by interactively addressing the user's entered data. Most consumers will be able to easily complete the registration process. This ensures that the crypto market is low-threshold and quickly accessible to a broad public.7 Possible previous doubts can be alleviated by the displayed marketing messages. The perceived ease and the identity check can also contribute to this by creating a sense of safety and trust.8 During the registration process of two service providers, the risks of crypto are briefly addressed. Consumers are asked - at the beginning with one service provider and in the middle with the other - to check a box in which they declare that they understand the risks associated with trading in crypto and/or that there is a risk of losing (part of) the stake. It is good that users are forced to pause and consider the risks of crypto in the registration process. However, it is unlikely that this will have much impact, because most users will only check the box to proceed in the process and because the risks are not (clearly) described. 7 For people who are less digitally skilled, the registration process and especially the identity verification can form a barrier. This also applies to navigating the application in general. See: Access to Financial Services Not Self-Evident (AFM, 2023) 8 Corritore et al. (2003) 9 Acquisti et al. (2017) With two service providers, an access code must be set by default upon first login via a mobile phone, but with the other service provider, the default setting is that the app can be opened without an access code. With all examined service providers

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