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Digital RMB Cross-Border Flows: Drivers, Challenges and Institutional Responses




The digital RMB has been piloted in China, and its cross-border flow is also an inevitable trend. Compared with traditional currencies, the digital RMB not only has the advantages of higher safety, higher efficiency and lower cost, but also can optimize currency management, promote the RMB's internationalization and establish a fairer international monetary system. However, as a new currency form, the digital RMB also faces multiple challenges, including the weakening of monetary sovereignty, the immaturity and incompatibility of technologies, the incompatibility with existing infrastructure, and circulation risk.

Status Quo


Central Bank Digital Currencies (CBDC) are risk-free currencies that can provide a more resilient, innovative, and competitive payment system.


China's central bank has been studying CBDC since 2014, and the CBDC (i.e., digital RMB) in China is based on the core element of "one currency, two banks, and three centers" and follows the binary system of "central bank-commercial bank." Although it is still in the domestic pilot stage, this is by no means the ultimate goal, but the cross-border application of digital RMB is the direction of its development. From a practical point of view, China is promoting the international circulation of digital RMB.


The establishment of the Financial Gateway Information Services Limited in January 2021 indicates SWIFT's intention to "join hands" with the digital RMB to explore future digital currency cross-border payment and liquidity solutions jointly.


The Hong Kong Monetary Authority is working with the Digital Currency Research Institute of the Central Bank of China to conduct technical tests on digital RMB cross-border payments.

The Hong Kong Monetary Authority is conducting technical tests on cross-border payments of digital RMB with the Institute of Digital Currency of the Central Bank of China, and the Guangdong-Macao Cross-border Financial Cooperation (Zhuhai) Demonstration Zone also intends to pilot digital RMB in cross-border scenarios.


It can be said that the digital RMB cross-border flow is not only in line with the global trend of promoting CBDC cross-border flow but also a powerful initiative for China to compete internationally in this field and occupy the high ground of CBDC.


It is also a decisive step for China to compete internationally in this area and capture the high ground of CBDC. However, before doing so, we must identify the positive impact digital RMB cross-border flows can have and determine whether it is necessary to promote them.


On this basis, examining and overcoming the challenges of digital RMB cross-border flows is essential. Any financial innovation has two sides and will not be smooth in the early stages of development.


Real-world motivations for cross-border flows of digital RMB


Overcoming the shortcomings of traditional cross-border currency flows


The operation of financial markets has always revolved around the three main objectives of security, efficiency, and cost. Yet, traditional cross-border currency flows have safety, efficiency, and price shortcomings. CBDCs have the potential to solve this problem and contribute to the management and regulation of currencies. The CBDC has the potential to solve this problem and contribute to the management and regulation of currencies.


The traditional cross-border payment settlement, with the U.S. dollar as the core and correspondent banks as the primary model, and relying on SWIFT and the New York Clearing House Interbank Payment System (CHIPS), has many shortcomings.


First, there is insufficient security due to transactions' asynchronous settlement and non-traceability. This is manifested in two aspects; one is the settlement risk in foreign exchange transactions. Due to the inconsistent business hours in different countries, transactions cannot be completed synchronously, and after one party irrevocably pays for currency, but may not receive another currency due to the counterparty's bankruptcy, etc.


Second, the risk of crime. The inability to distinguish between two traditional electronic currencies and the complete anonymity of cash transactions, and thus the untraceability of transactions, facilitates crimes such as cross-border money laundering. Correspondent banking and regulatory differences lead to inefficiencies and high costs. In cross-border payments, it usually takes several days to complete a cross-border transfer and is costly. The reasons for this are, first, that in cross-border payments, commercial banks mostly need to find correspondent banks to complete the settlement.


Third, the banking payment infrastructure and regulatory requirements are inconsistent across countries, with each bank having a different system data language and format and facing multiple compliance reviews.


CBDC, as a new form of currency, can systematically solve the above problems, CBDC is based on the core of distributed bookkeeping technology, and each commercial bank is a participating node in the distributed ledger. Each fund of CBDC has "uniqueness" and will be credited to the distributed ledger after the transaction is completed.


First, security is improved. In terms of CBDC issuance and repossession, the security of currency issuance and repossession can be greatly improved by transporting the currency through electronic transmission and keeping it in the cloud computing space. There is no settlement risk in the settlement of cross-border currency transactions. Moreover, the decentralized, network-wide bookkeeping and distributed features of CBDC can naturally resist hacking and help limit data manipulation and eliminate single points of failure, thus making the financial system more stable.


Second, lower costs and higher efficiency. The withdrawal of correspondent banks means lower operating costs, compliance costs, and reconciliation costs among commercial banks, and the time to settle funds can be significantly reduced. Digitization of money can reduce the cost of printing, custody, and distribution of cash.


Third, CBDC helps in currency management and supervision. CBDC's unique codes can accurately trace currency transaction records, which helps central banks strengthen currency circulation supervision and combat currency crimes through penetrating supervision, as well as improve central banks' macro-prudential management and micro-financial supervision capabilities and cross-border capital flow management in international cooperation.


Accelerate the internationalization of RMB


Currently, the RMB has become the fifth largest payment currency in international settlements, but it is about 20 times less than the top-ranked U.S. dollar and about one time less than the fourth-ranked Japanese yen. In order to enhance the RMB's international status, the RMB needs to circulate outside of China and become an internationally recognized currency for valuation, settlement, and reserves. The digital RMB can help achieve this goal.


On the one hand, the competitiveness of the currency is strongly influenced by economic factors, mainly by people's confidence in the future value of the currency, the liquidity of currency transactions, and stability of the currency's value, the currency's trading network. And relying on a technology-driven digital RMB can enhance the RMB's international competitiveness.


First, it can expand the scope of use and enhance international credit by virtue of its security, efficiency, and cost advantages. When the digital renminbi is the first to demonstrate these advantages in the financial market, it will be extremely attractive and quickly recognized and used by more countries, companies, and individuals, which will help expand the use of the renminbi and improve international credit.


Second, CBDC can enhance the effectiveness of central bank regulation of currency circulation. By analyzing the scale, speed, and areas of digital RMB circulation in society, central banks are able to know the weaknesses and problems affecting the global circulation of digital RMB and address them in a more targeted and efficient manner. The liquidity and value of the currency will be more stable. The digital RMB's loosely coupled bank accounts are designed to make it easier for overseas market players to use the RMB for payment and settlement, making the RMB more liquid internationally and minimizing the possibility of exchange rate crises.


At the same time, as a more convenient means of payment, the digital RMB will be frequently exchanged with bank deposits, which can reduce the currency multiplier of commercial banks to a certain extent, thus helping to keep the value of the RMB stable.


In addition, with the advanced detection capabilities of the digital RMB system, the central bank can develop an early warning system for RMB exchange rate risk and tailor a response plan in advance to stop the fluctuation of the RMB currency.


Finally, the currency transaction network is more powerful. Through the distributed ledger, the digital RMB can improve the functions of RMB registration, custody, trading, payment, clearing, and settlement systems and extend the quotation, transaction, clearing, and transaction information release functions of the RMB trading system to financial institutions in various countries, so as to accelerate the formation of a globalized RMB payment system that supports multi-currency settlement and clearing.


Moreover, this distributed bookkeeping technology has greater system resilience, contributing to a more stable, compatible, and attack-resistant currency transaction system.


On the other hand, digital RMB cross-border flows can enhance China's leadership and voice in the field of CBDC and set rules and standards conducive to RMB internationalization. In the field of information technology, whoever holds the standards and rules will have the right to speak.

Digital currencies are based on information technology, and taking the lead in setting standards and transaction rules for globally circulating CBDCs and winning the recognition of most countries in the world is an important factor in the competition for CBDCs The first to set the standards and transaction rules of CBDC in global circulation and win the recognition of most countries in the world is an important factor to occupy an advantageous position in CBDC competition.


Promoting a fair and stable international monetary system


In the current Jamaican credit monetary system, as the United States relies on its strong political and economic power to lay out currency trading networks and control the supply and circulation of money around the world, countries have long formed a dependence and inertia on the use of the U.S. dollar, which has become the dominant global currency. However, the U.S. dollar has failed to fully assume the responsibility of maintaining and coordinating the international monetary order.


On the one hand, the U.S. dollar is not a reliable monetary benchmark "anchor," and the U.S. will consider monetary policy based on its own power rather than the real demand for a global currency, so it is extremely easy to form artificial intervention of monetary over-issuance and excess liquidity. This makes it extremely easy to create artificially intervened monetary over-issuance and excess liquidity. This makes it possible for global financial markets to be greatly affected once the price of the dollar changes. On the other hand, the U.S. uses the dollar's status as an international currency not only to obtain minting taxes from other countries by issuing dollars and using them as foreign exchange reserves but also to dominate international exchange rates, manipulate global asset prices, and exploit and seize surplus value from countries.


For this reason, other countries have been seeking to establish a fair and stable international monetary system that is free from the control of the U.S. dollar. The CBDC provides just such an opportunity.


A fair and stable international monetary system should be a system with unified authority and responsibility, stable exchange rates, and appropriate international reserves under the participation and decision-making of multiple parties. With the advantages of openness, sharing of account and database systems, distributed data storage, and decentralized transactions, distributed bookkeeping technology can establish a global unified currency transaction by issuing and circulating across borders through a CBDC union established among central banks. The CBDC Union, established between central banks for cross-border issuance and cross-border circulation, can establish a global unified currency transaction network, thus helping to establish a fair and stable international monetary system.


First, this network is not controlled by developed countries. In the peer-to-peer currency transaction model, transactions are completed by the consensus mechanism of distributed bookkeeping technology, with each country acting as a validating node in the transaction process, participating equally in each country participates equally as a validation node in the transaction process and jointly manages and decides on the settlement of currency transactions. Second, in this network, the authority and responsibility of each country are unified. First, there is no one absolute controlling body in the peer-to-peer transaction network that relies on consensus mechanisms, nor is there a dominant or intermediate currency.


Two, each country has the right to validate currency transactions but also has the obligation to undertake prudential validation.


Third, the international status of the currency relies on the stability of the currency's value and circulation and is not based on monetary hegemony. Second, in this network, the exchange rate between currencies is determined by the market performance of the currencies and is not affected by the quantitative easing policy of the U.S. dollar. In terms of specific mechanisms, exchange rates can be determined through the automatic matching of best rates, direct quotes, negotiated rates, and platform foreign exchange rates.


Finally, in terms of international reserves, since countries can trade currencies in the trading network at any time, they can choose among the most widely used and stable currencies in the trading or multiple currencies that are most widely used in transactions and have the most stable value, without having to rely on the U.S. dollar.


As a major trading nation and a key player and builder of the global economy, China's digital RMB is also an important pole of the global CBDC and a global leader. Therefore, the promotion of cross-border flows of digital RMB will certainly help establish a more equitable and stable international monetary system.


The Challenges of Cross-Border Flows of Digital RMB


The cross-border flow of currency is a very important and complex issue involving multiple issues such as currency sovereignty, foreign exchange management, infrastructure, and legal and regulatory rules. In addition to the lack of payment infrastructure and basic legal rules for cross-border digital RMB flows, cross-border digital RMB flows face huge challenges. The challenges of cross-border digital RMB flows are enormous.


Monetary sovereignty crisis


Monetary sovereignty is the first issue for CBDCs to consider for cross-border flows. In the age of digital currencies, monetary sovereignty faces a more serious crisis.

First, cross-border CBDC flows threaten monetary sovereignty.


CBDC payment networks are naturally transnational in nature and have high circulation efficiency and security, low cost, wide scope, and rapid scale change. When CBDC from other countries are applied to cross-border payments and foreign exchange transactions, citizens and When CBDCs are used in cross-border payments and foreign exchange transactions, it is easy for citizens and enterprises to directly purchase and save in other countries through distributed payment networks and digital wallets, bypassing the national currency payment system and foreign exchange management system. CBDC can be purchased in advance without incurring fees and unfavorable exchange rates, thus breaking the traditional inseparable pattern of cross-border and foreign exchange transactions so that the country's currency is included in the competitive foreign exchange market.


This will not only cause the actual foreign currency size of the national market to be larger than the official foreign currency size, which will affect the monetary and foreign exchange management of the country and cause an imbalance in the balance of payments but will also reduce the use of the national currency and even create currency substitution.


Second, the import of CBDC technology threatens the sovereignty of national currencies.

CBDC is a cryptocurrency, a credit currency, an algorithmic currency, and a smart currency. The technology dependency is such that only a few countries in the world have the financial and technological capacity to develop CBDCs independently. However, if they do not issue CBDCs, they will lose the opportunity for currency development, and their currencies will be impacted by CBDCs from other countries.


This means that if most countries choose to issue CBDC, they need to import other countries' financial technology support system, which is not only dependent on the hardware but also the implantation of other countries' complex monetary algorithm systems, thus risking the loss of their monetary sovereignty.


For our country, the aforementioned currency sovereignty crisis means both a boycott of the digital RMB and a threat to our currency sovereignty from other countries. For China, the aforementioned monetary sovereignty crisis means both that the digital RMB will be boycotted by other countries and that our monetary sovereignty is threatened by CBDC. On the one hand, we hope that the digital RMB will be accepted by more countries and become an international currency. Still, given the threat to monetary sovereignty, other countries may boycott the digital RMB and take legal, administrative, and other measures. On the one hand, we hope that the digital RMB will be accepted by more countries and become an international currency. This will inevitably hinder the cross-border flow of digital RMB. This will certainly hinder the cross-border flow of digital RMB.


On the other hand, the "positive externality" and "winner-takes-all" characteristics of CBDCs may result in strong competition among countries for CBDCs. This may have two negative effects on the cross-border flow of digital RMB. First, suppose the digital RMB is at a disadvantage in the international CBDC competition. In that case, China's monetary sovereignty will be affected by a large number of foreign CBDCs and even private digital currencies. The first is that if the digital RMB is at a disadvantage in international CBDC competition, China's currency sovereignty will be threatened by the massive entry of foreign CBDCs and even private digital currencies.


Second, the digital RMB faces competition with other countries' CBDCs. The current international monetary system is dominated by the U.S., and the cross-border flow of digital RMB will certainly form a substitute and crowding-out effect on the international status of the U.S. dollar. It will certainly be hindered and suppressed by the U.S. The U.S. will certainly hinder and suppress it. Other countries are also expanding aggressively in this area and are bound to compete with the digital RMB in the international market.


The digital renminbi will be competing in international markets. Given that the RMB is not yet used internationally enough to compete with currencies such as the U.S. dollar and the euro, and given the low level of openness of China's financial markets, this may hinder the cross-border flow of digital RMB. This may hinder the cross-border flow of digital RMB and may even trigger a sovereign crisis of our currency.


Technical immaturity and incompatibility


Digital RMB is strongly technology-dependent, and the adoption of technology should be based on technology security, transaction security, and data security. Technology self-security requires that the underlying technology must not have a significant adverse impact on the issuance, circulation, repatriation, and management of the digital RMB.


Transaction security requires that the technology can achieve uniqueness and validity of transactions and ensure that the digital RMB cannot be "double-spent" or counterfeited; data security requires that the technology can ensure reasonable use of data and balance transaction tracking and privacy.


At the same time, the choice of technology for digital RMB should also consider compatibility with other countries. The technology choice for digital RMB should also consider compatibility with other countries' CBDC. However, the technology for digital RMB is not yet mature, and compatibility is a challenge.


The development of digital RMB does not have a pre-determined technology path, nor does it rely on one technology alone. While this leaves flexibility in the choice of the underlying technology, this leaves room for flexibility in the choice of the underlying technology, it also indicates that the digital RMB is currently facing technical challenges.


First, there is no very mature underlying technology. Blockchain technology is the mainstream technology for private digital currency. Blockchain technology is the mainstream technology for private digital currency, which can realize the flow of value under anonymous conditions, ensure the traceability of transactions, and support centralized management. Still, the problem is that blockchain technology can support limited transaction capacity and scalability, is vulnerable to arithmetic attacks, and cannot guarantee the certainty of transactions. And Other technologies cannot also have the features of distributed storage and traceability to support the good operation of digital RMB.


Incompatible infrastructure


In order to break the cross-border payment and settlement system centered on the correspondent banking model and the US dollar, as well as the monopoly of CHIPS in the international settlement, the cross-border flow of digital renminbi must get rid of this system and take an independent internationalization path. However, at this stage, China's international payment infrastructure construction cannot meet the needs of the cross-border flow of digital renminbi.


In addition to relying on CIPS, my country can also consider building an independent digital RMB global payment and settlement system, but this also faces obstacles.


First, due to many issues related to the research and development of the underlying technology of the system, the design of the system language, the formulation of system operation rules, and the manufacture of physical equipment, the system is difficult to go online in the short term, which means that the digital renminbi may lose its first-mover advantage.


Second, there are obstacles to the access and authority of overseas financial institutions. The realization of digital RMB peer-to-peer settlement requires the establishment of a distributed ledger system that enables direct transactions between financial institutions such as commercial banks. In this system, any two commercial banks can directly conduct payment and settlement. This means that my country needs to expand the authority of foreign financial institutions in my country's payment and settlement system and at the same time, provide foreign financial institutions with payment interface services in my country's digital currency system. However, on the one hand, due to the uneven economic strength, technical level, and anti-risk ability, not all financial institutions are willing and able to provide digital RMB services, and there is currently a lack of standards and rules for foreign financial institutions to access the digital RMB system.


On the other hand, the degree of openness of my country's financial market is limited, and foreign financial institutions do not have sufficient participation and access rights to participate in digital RMB cross-border transactions.


Digital RMB circulation risk


The digital renminbi not only lacks legal protection, but its cross-border flow involves two interconnected and mutually influencing domestic and international markets, which brings huge circulation risks to the digital renminbi.


First, the digital renminbi law is absent. On October 23, 2020, the central bank announced the "People's Bank of China Law (Draft for Comments)." Although it was written in the digital form of RMB, there were no more specific regulations, and it has not yet been reviewed and approved. my country's existing banks, foreign exchange, and other related.


The law lacks regulations on the digital renminbi and cannot be directly applied. The issuance basis, legal compensation, ownership transfer, anti-counterfeiting, and personal information protection of digital renminbi all face challenges. These problems create legal obstacles to the issuance and circulation of digital renminbi in China, and international circulation will face more problems.


Second, the number and proportion of digital renminbi issued may not be able to meet the needs of circulation. Domestically, legislation can determine the digital renminbi as a legal tender, and no unit or individual may refuse to accept it. However, in the international community, the risks of the digital renminbi may not necessarily be widely accepted. When financial institutions in some countries only provide traditional renminbi exchange services, since the issuance, circulation, and withdrawal of digital renminbi and traditional renminbi belong to two sets of currency systems, the two currencies cannot be exchanged in time, or the exchange cost is too high. The international community There will be a contradiction between too much digital renminbi and too little traditional renminbi in the circulation of renminbi in China. At this time, the frequent issuance of the traditional renminbi will cause currency devaluation and inflation. Therefore, how to determine the issuance scale and proportion of digital renminbi will become one of the difficulties in its cross-border flow.


Third, there are obstacles to foreign exchange management and exchange rate risks. On the one hand, foreign exchange management becomes more difficult. Digital renminbi supports point-to-point value transfer away from bank accounts, which means that domestic and foreign entities can conduct transaction settlement through digital wallets, and anonymous payments can be made when the amount is small. As a result, there may be large-scale circulation and entry and exit of digital renminbi internationally. And it may bypass the central bank and flow directly into society so as to be free from supervision. In addition, peer-to-peer payment and settlement will greatly enhance the correlation between changes in my country's monetary policy and the cross-border flow of global funds. The speed of response will also be greatly improved. For example, when the United States implements monetary easing or monetary tightening policies, the transfer of global funds between countries will accelerate, and my country's balance of payments will also face faster and more severe shocks. When the value of RMB fluctuates, it is easy for the public to transfer funds irrationally and on a large scale across borders by buying and selling digital RMB. This risk will be more obvious during the period of capital hedging. On the other hand, the difficulty of exchange rate control has increased. First of all, as mentioned above, the issuance quantity and proportion of digital renminbi are not easy to grasp, which may lead to a surplus or shortage of digital renminbi and traditional renminbi, resulting in large fluctuations in the exchange rate of renminbi. Second, the small anonymous transaction ofdigital RMB will also affect exchange rate management. The scale of the digital renminbi is much higher than that of paper money, which may prevent the central bank and foreign exchange management agencies from discovering the imbalance between the scale and demand of the digital renminbi's domestic and foreign circulation in a timely manner, resulting in fluctuations in the renminbi exchange rate. Finally, the digital characteristics of digital RMB may lead to free exchange between it and various encrypted digital currencies such as Libra and Bitcoin, which may lead to the formation of a dual-track system of the RMB exchange rate, increasing exchange rate risks and difficulties in foreign exchange management.


Fourth, the cross-border flow of digital renminbi facilitates international currency crimes. The existing supervision of anti-money laundering and other crimes mainly relies on the "know-your-customer" principle of commercial banks and other financial institutions to trace large and suspicious transactions. Although the digital renminbi can theoretically enable my country's central bank to penetratingly supervise all digital renminbi transactions to control currency crimes, the digital renminbi supports anonymous peer-to-peer transactions, which will generate a large number of transaction entities outside my country's financial supervision system. Moreover, as more foreign financial institutions and transaction entities participate in transaction settlement, the regulatory capabilities of these financial institutions are uneven, which may make the supervision of currency crimes more difficult. In addition, the digital renminbi transaction data of foreign users may be regarded as privacy protected by their own laws, so my country's supervision of the circulation of the digital renminbi is hindered by foreign privacy laws and policies, and the existing anti-money laundering monitoring methods cannot be fully and effectively implemented. As a result, foreign criminal organizations are likely to use foreign financial institutions to conduct money laundering and other criminal activities through digital renminbi.


The innovation of currency form and currency internationalization are major changes that affect the whole body. Strong risk control and response capabilities are prerequisites. In addition, my country does not yet have the open financial market environment and corresponding systems required for currency internationalization. To ensure that the cross-border flow and internationalization of digital renminbi face greater risks, it requires strong risk control and response capabilities.


In this regard, first, my country needs to establish a global vision on the basis of the existing currency cross-border flow system and incorporate the risk management and response of digital RMB international circulation into the scope of work. At the macro-policy level, my country should continuously improve monetary policy and strengthen macro-prudential management, cross-border capital flow management, and foreign exchange management so as to provide institutional guidance and guarantees for the prevention and resolution of financial risks. In terms of the specific division of responsibilities, the central bank and foreign exchange management agencies should assume the main responsibilities, strengthen risk early warning and handling capabilities by establishing big data analysis centers, conducting stress tests, formulating risk emergency response mechanisms and crisis alternative plans, etc. so that risks are generally controllable On the premise, the cross-border flow of digital renminbi will be steadily promoted. The second is to test the risk control and response capabilities of digital renminbi cross-border flows in practice. With my country's implementation of digital renminbi cross-border payment in Hainan and the central bank's fintech and digital currency cooperation with the Hong Kong Monetary Authority, the Bank of Thailand, and the United Arab Emirates central bank, the cross-border application scenarios of digital renminbi are more abundant. my country needs to take this opportunity to test the technical risks, legal risks, and financial risks of the cross-border flow of digital renminbi and continuously enhance risk control and response capabilities.


Utilize national policies to promote digital renminbi through currency cooperation. On the one hand, my country should use the "One Belt, One Road" policy and the China-ASEAN Free Trade Area to promote the digital renminbi. The "Belt and Road" countries and ASEAN countries have inseparable trade networks and trust relationships with China. Many of them support the use of RMB in international trade and even use RMB as a reserve currency. Relying on these countries to promote the digital renminbi has a profound economic and geographic basis.


On the other hand, China should carry out currency cooperation with countries that need to introduce CBDC. According to World Bank statistics in 2018, there are still 1.7 billion adults in the world who are unbanked and unable to access formal financial services. The main reasons include a lack of necessary supporting documents, inability to pay for financial services, and inaccessibility due to distance. Financial institutions and distrust of financial institutions, etc.


The digital renminbi is not limited by bank accounts and distance, and the cost is low. It is very suitable to use the digital renminbi to develop inclusive finance in these countries. Moreover, these countries not only need to introduce CBDC to solve the problems of restricted circulation of domestic banknotes, sharp fluctuations in exchange rates, and insufficient tracking ability of currency investment but also hope to increase cross-border trade volume by popularizing CBDC cross-border payment. my country should take this opportunity to cooperate with these countries and effectively use my country's international influence and digital RMB advantages to promote the cross-border circulation of digital RMB so that digital RMB occupies a favorable position in the international currency.


Disclaimer: Part of the article viewpoints are based on the research project "Research on legal issues of the cross-border flow of legal digital currency" written by Pu Xuemin and Ma Qijia; Monisight, as an information sharing and learning platform, will not share any legal responsibility or lawsuit arising from it.

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