Revenue In-game currencies In-game currencies Financial regulation may not be the game developer is carrying most developers’ first consideration on certain activities in relation to in the context of video games. the tokens such as selling tokens or However, there are a number of arranging transactions in tokens. ways that a token, in-game As some games have sought to currency, or other in-game asset monetise by selling tokens within can fall within either crypto- the game which give their holders specific regulations or the wider a say in future development and financial services regime. We (crucially) governance of the game, have highlighted some of the key the characteristics of tokens will areas of UK and EU regulation that need to be scrutinised. Tokens developers should consider that may qualify as security tokens and future trends in UK regulation. include those providing dividends, Player one tutorial: current voting rights, or are sold with the UK and EU regulation expectation of profit from the efforts of others. Security tokens E-money tokens Some tokens or assets may be regulated under the Financial E-money tokens are those which Services and Markets Act 2000 fall within the definition of e-money (FSMA) and supporting legislation if: under the Electronic Money Regulations 2011 (EMRs). Where a they provide rights and obligations game incorporates e-money tokens, that are similar to ‘specified the game developer will be required investments’ such as shares, debt to have the right permissions and instruments and units in collective comply with the relevant rules. There investment schemes are exclusions which may apply to some games, however the scope of 67