Digital transformation greatly impacts financial industry. Banks and other credit institutions in Russia know this first-hand, as they face greater competition and more demanding customers. This compels financial service providers to constantly experiment with new technologies and business models, thus paving the way for a growing interest in fintech. This makes particular sense when you consider how attractive the customer base is in Russia where there are more than 146 million citizens and a high internet penetration rate of 73 per cent.
Overall, Russia can be categorised as a fintech-friendly jurisdiction with no unusually burdensome requirements on companies involved in this field of commerce. There are some obstacles and uncertainties that may impact certain business models, but we expect this to change soon due to recent efforts aimed to upgrade Russian regulatory framework for digital economy (see Sections VIII and IX for details).
The main regulator, the Central Bank of Russia (the Central Bank), also demonstrates an open-minded approach towards new financial technologies and maintains an informative website in English.2 Interested parties may engage with the regulator in several forums, such as Finopolis,3 an annual fintech conference organised by the Central Bank in Sochi, the Association for Financial Technologies Development4 and in various smaller working groups.
Big banks in Russia lead the innovation race by leveraging existing relationships with and data about their customers. For example, the largest banks are building their own financial marketplaces and their own peer-to-peer lending platforms. However, there are also many smaller companies and start-ups trying to challenge incumbents, especially in such areas as point of sale technologies and payment solutions.
Supporting fintech companies with economic incentives would certainly help, as there are currently no specific tax incentives for fintech companies in Russia. Fintech start-ups, however, may take advantage of benefits available for IT companies, such as reduced social security contribution rates of 14 per cent on employees’ wages (instead of 30 per cent for other companies) or even more substantial tax privileges for residents of ‘technoparks’ (Skolkovo, for example).
i Licensing and marketing
‘Fintech’ is an umbrella term that includes several different business models ranging from traditional payments and collective investments to novel areas, such as cryptocurrencies, ICOs and robo-advisers. Each business model is always subject to its specific set of regulations and licensing requirements. Given this fact, there is no universal fintech licence in Russia. Instead, each business model of fintech is regulated separately. Some business models, such as payments, are subject to established regulations that were adopted several years ago, while many others are subject to no regulation at all or operate in the grey area of the law.
The main financial regulator is the Central Bank, which oversees the monetary policy and regulates the financial industry. As of 2013, the powers of the Central Bank also extend over the issuance of securities and exchanges, which were previously supervised by the Federal Financial Markets Service (now defunct), thus making the Central Bank the ultimate authority in the financial industry. The Central Bank is the main licensing authority for banks, insurance companies, broker-dealers, investment advisers, payment systems, etc.
Apart from the Central Bank, some other authorities have adjacent functions in the regulation of fintech:
- the Ministry of Finance is responsible for general financial policy and for overall management in the field of finance in Russia;
- the Federal Tax Service is a part of the Ministry of Finance and supervises compliance with taxation rules, including taxation of cryptocurrency mining and transactions with cryptoassets;
- the Federal Financial Monitoring Service (Rosfinmonitoring) is mainly tasked with anti-money laundering (AML) and counter-terrorism financing functions; and
- the Federal Anti-Monopoly Service enforces regulations applicable to fair competition and advertising, including those related to financial products and services.
Despite the leading role of the Central Bank, with the adoption in 2015 of the Federal Law on Self-Regulated Organisations in Financial Markets,5 certain regulatory functions have been delegated to self-regulated organisations (SROs). As of 9 February 2018, there are 21 SROs in the field of finance approved by the Central Bank. In addition to SROs, there are also industry organisations and unions active in the fintech area, such as the Association for Financial Technologies Development,6 launched by the Central Bank, and the Russian Association for Cryptocurrency and Blockchain.7
In line with global practice, the Central Bank and other regulatory authorities in Russia place special emphasis on consumer protection. This is achieved through the enforcement of rules applicable to marketing and advertising of financial products. The principal source of such rules is the Federal Law on Advertising,8 which sets basic principles, bans misleading and unfair advertising practices and provides for specific rules applicable to financial services and securities.
When it comes to competition, the main Act is the Federal Law on the Protection of Competition,9 which prohibits unfair competitive practices and outlaws abuses of dominant position, with special rules for financial organisations.
Since 2015, after the adoption of the Federal Law on Credit Histories,10 there is now a legal framework for credit information services provided by credit history bureaus. These are private companies providing information services about the creditworthiness of borrowers. Professional lenders are required to submit information about individual borrowers to at least one such credit history bureau. As of February 2018, there are 17 credit history bureaus registered with the Central Bank.
ii Cross-border issues
Unlike in some other jurisdictions, regulated or licensed financial activities may not be passported from other countries into Russia (i.e., companies incorporated abroad and licensed or regulated under their local rules may not automatically become licensed or regulated in Russia). Certain level of passporting may become possible in the future among countries that are members of the Eurasian Economic Union (Armenia, Belarus, Kazakhstan, Kyrgyz Republic, Moldova and Russia).
Traditional financial services that are subject to licensing or registration, such as banking, insurance, brokerage and dealing in securities, require a licence and may be carried out only via a local legal presence. Active targeting of Russian customers may result in liability and most often leads to the blocking of a perpetrator’s website in the territory of Russia. Certain industries are also protected against foreign competitors willing to enter the Russian market. For example, there is a 50 per cent quota on the aggregate amount of foreign capital for banking and insurance industries. Otherwise, there are no restrictions on foreign capital; nor are there requirements to partner or engage with local companies to enter the Russian market.
There is a general rule that foreign organisations engaged in regulated activities under their local laws may carry out such activities in the territory of Russia only subject to prior accreditation with the Central Bank.
Despite the lack of passporting and certain restrictions, many fintech services may be offered to Russian customers from abroad. This is particularly the case for unregulated segments of fintech, such as cryptocurrencies and ICOs. By way of example, until 2015, the trading of foreign currencies, universally known as ‘forex’, was unregulated in Russia and was actively marketed by offshore companies to a Russian audience.
Besides unregulated business, there are also examples of foreign financial service providers being available to Russian consumers, without being present on the Russian market. This may be the case when a consumer only needs to be able to speak English to access a website where a fintech product is offered, whereas the website itself may not necessarily be actively marketed to the Russian audience. As an example, many foreign crowd investing and automated investment adviser platforms are available to Russian consumers, despite the fact that they are likely offering regulated services. In the era when many financial services are offered through desktop or smartphone application interfaces, one must take active steps to not to be present in a particular market, such as blocking by IP addresses, limiting traffic-generating campaigns to select areas or limiting incoming payments to certain banks.
iii DIGITAL IDENTITY AND ONBOARDING
Over the past couple of years, the Russian government has made significant efforts to introduce a digital identity for individuals and companies. This was initially driven by the desire to improve and ensure access to public services via the internet, which required a stable identity management system in place. Such system, the Unified System of Identification and Authentication (USIA), was created in 2010 with a view to providing access to an online portal of public services, Gosuslugi. As of the beginning of 2018, more than 66 million Russian citizens are registered in the USIA.
Nowadays, the use of the USIA as a method of identification has been extended beyond public services. Certain financial service providers that were previously required by AML or KYC laws11 to identify clients in their presence may now use USIA as a gateway. For example, this applies to consumer (micro) loans, brokerage, securities trust management and certain other financial services, thereby allowing full digital onboarding.
It is expected that digital identification will move to a completely new level with the introduction of the Unified Biometrical System (UBS) on 30 June 2018. UBS was under development since 2016 and is designed to store biometrical personal data of individuals (voice and face image, at this stage). Customers will supply their biometrical data to UBS by appearing in a bank once and following that will be able to access financial services in other credit organisations remotely. This will enable full digital onboarding for banks as well. Other financial service providers, such as insurance companies, will get access to UBS after the system proves itself in banks.
IV DIGITAL MARKETS, FUNDING AND PAYMENT SERVICES
i Collective investment schemes
There are several legal forms that can be used for collective investment purposes in Russia, ranging from purely contractual, such as ‘investment partnership agreements’, to corporate ones, such as joint stock companies or incorporated investment funds. At the same time, available legal forms are not very well suited for modern-day crowd investing purposes. The main hurdles are high incorporation costs, restrictions on the transfer of investment interests or other burdensome requirements.
The standard choice for a large-scale collective investment scheme remains a ‘unit investment fund’. This legal form has been successfully used in the domain of collective real estate investments. The fund must be run by a professional investment management company.
Another option that is suitable for small-scale collective investments is a typical limited liability company (LLC). In this case, investment opportunities are marketed on an online platform, but actual transactions take place offline, since the transfer of interest in an LLC is subject to notary certification. The total number of members in the LLC is capped at 50.
ii Automated digital advisory services or ‘robo-advisers’
Until recently, digital advisers (also known as ‘robo-advisers’) have been beyond regulatory reach. In fact, there were no requirements applicable to investment advisers at all. This has changed in late 2017 with the adoption of amendments into the Federal Law on Securities Market,12 according to which there will be a new type of professional market participant, namely investment advisers.13 The same amendment law states that if investment advice is provided by means of software, including via internet, such software shall be ‘accredited’ by the Central Bank. This provision is interpreted to include robo-advisers within the scope of regulations that will be broadly applicable to investment advisers. The law comes into force on 21 December 2018.
iii Crowdfunding and crowd investing
For the sake of this chapter, we will differentiate between the two concepts. Crowdfunding generally refers to cases where a broad community supports a project in exchange for symbolic tokens (‘perks’) or future products (pre-sale). By its very nature, crowdfunding is less risky and usually subject to less oversight from regulators. In Russia, it is not subject to any specific regulations. There are several platforms on the Russian market that let companies or groups of individuals raise funds in the form of donations or pre-sale orders.
In contrast to crowdfunding, crowd investing implies that there is an investment interest (i.e., participants expect to receive profits from the success of a project, and such profits may vary or be non-existent). In the context of crowd investing, investee companies usually offer some sort of an interest in their capital or cashflow, be it a participation interest in an LLC, shares of stock in a joint-stock company or units in an investment fund. Transactions with all these instruments under Russian law require the physical presence of a purchaser, which is one of the obstacles to the widespread introduction of crowd investing. In fact, the only model that proved viable in these circumstances is ‘online-to-offline’, where investment opportunities are marketed online and actual transactions are entered into offline. At the moment, such platforms themselves are not subject to any licensing requirements, nor are they bound by a duty of care or loyalty to prospective investors. This is likely to change with the introduction of a legal framework for crowd investing, which has been proposed by the Central Bank (covered below).
iv Crowd or peer-to-peer lending
There is no special legal framework for crowd lending (also known as peer-to-peer lending). In 2016, in its analysis of the peer-to-peer lending market, the Central Bank acknowledged that ‘Russia fits the unregulated market model, since no definition of this type of activity exists in the legislation and there is no special regulation.’14 Despite this fact, a lot of peer-to-peer lending platforms on the market (but not all) are registered as microfinancing organisations (covered in more detail below), which allows them to extend loans themselves, instead of just bringing individual borrowers and lenders together on an online platform.
It is contemplated that certain regulations for peer-to-peer lending will be adopted soon. In fact, the Central Bank has already initiated discussions among market participants, created a working group and invited various platforms to submit certain reports on a voluntary basis. Several media outlets have reported that the Central Bank aims to propose the regulatory framework in mid-2018.
Apart from peer-to-peer lending model, there is also a growing market for peer-to-business (P2B) lending, where individuals may extend loans to companies. Notably, such P2B-lending platforms operate despite the restriction set forth in Article 807(4) of the Russian Civil Code that explicitly prevents companies from raising public debt unless by means of a regulated bond offering or in other cases specifically set forth in the law.15
As mentioned above, some platforms combine activities of pure peer-to-peer lending (serving as a marketplace for individual borrowers and lenders) and microcredit (extending loans). In fact, the microfinancing industry (bearing similarities to what are known as ‘payday loans’ in the United States) is a big industry in Russia, with 2,461 microfinancing organisations (MFOs) registered with the Central Bank as of February 2018. The status of an MFO is required for an organisation to be able to extend loans on a regular basis (without being required to obtain a full-scale banking licence).
There are two types of MFOs: (1) microcredit companies (MCCs); and (2) microfinancing companies (MFCs). MCCs are not subject to capital requirements, but also limited in their sources of funding and the size of loans they may extend. MFCs must have at least 70 million roubles in their own capital but may also extend bigger loans and issue bonds.
vi Payment services
Payment services is a regulated activity in Russia. The main piece of legislation is the Federal Law on the National Payment System16 (the NPS Law), which is supplemented by numerous detailed regulations. The NPS Law describes different types of activities within the national payment ecosystem and imposes requirements depending on the type of activity. Credit institutions, including banks, may engage in most types of payment activities, whereas non-banking credit institutions are limited to certain activities (such as payment-clearing services and processing). As of February 2018, there were 32 active payment systems listed in the register maintained by the Central Bank.17
vii Open API
Unlike the European Union, where PSD2 will oblige banks to provide access to their customers’ account information through application programming interfaces (API) to third parties, banks in Russia are not subject to such obligation.
V CRYPTOCURRENCIES AND INITIAL COIN OFFERINGS (ICO)
As early as 2014, various regulators in Russia for the first time acknowledged the existence of Bitcoin by demonstrating their negative views towards it. This even culminated in a bill proposed to introduce criminal liability for transactions with Bitcoin in 2015. The bill was never adopted and since then the overall position has changed. In 2017, the attitude of regulators towards Bitcoin shifted from ‘banned, unrecommended’ to ‘the concept is under investigation, regulation will come soon.’
In the absence of any specific laws or regulations, experts tend to classify Bitcoin and other cryptocurrencies as property, as opposed to currency, since the only lawful means of payment in the territory of Russia is the rouble. According to the Federal Tax Service, there is no ban on the use of cryptocurrencies in Russian legislation,18 and general taxation principles shall apply to mining and transactions with cryptocurrency transactions.19
When it comes to tokens and ICOs, there is relatively less clarity. In September 2017, the Central Bank warned investors of the risks inherent to ICOs,20 but apart from that no other regulator or court has yet had a chance to investigate the legal nature of tokens. Despite this fact, ICOs in Russia gained significant traction in 2017, which was likely driven by restricted access to venture capital for early-stage projects. It is estimated that projects with Russian founders raised approximately US$310 million in 2017, thus occupying the second position in the total ranking between the United States and Singapore.21 Notably, most of these ICOs have been structured through entities in foreign jurisdictions, not in Russia.
In this context, experts tend to agree that all tokens are different. They may represent various underlying rights or assets, and thus should be treated according to their nature. Arguably, it is more important to introduce an efficient legal framework for crowdfunding, thereby allowing retail investors to support new ventures, instead of regulating technological aspects of tokens. Following this logic, in January 2018, the Central Bank came up with a proposal to introduce crowdfunding in Russia. Under the proposed bill,22 companies will be able to issue ‘tokens’ that will serve as instruments of record for various property rights (see Section IX below).
Internationally, one of the most widely discussed legal aspects of tokens in 2017 was whether tokens constitute securities. Following the report of the US Securities and Exchange commission on the DAO project,23 many regulators all over the world agreed that certain tokens may qualify as securities or other financial instruments. In Russia, the Central Bank has not taken a position on this issue yet. In fact, it is problematic to qualify a token as a ‘security’ under Russian law, since the Civil Code suggests an exhaustive list of securities and, unless specifically listed in Article 142, particular instruments will not be considered securities. This approach contrasts with that in the United States, where courts lean towards a more flexible approach using the Howey test.
It should be noted that Russian securities law limits the circulation of foreign financial instruments, with the Central Bank having a final say on whether a particular instrument may be allowed on to the public market. Unless cleared by the Central Bank, foreign securities may only be offered to accredited investors in Russia and no general solicitation is permitted.
AML and KYC rules apply to transactions with cryptocurrencies to the extent such transactions are carried out via ‘organisations carrying out transactions with monetary funds and other property’ as defined in Article 6 of the Federal Law on Combating Legalisation (Laundering) of Illegally Gained Income and Financing of Terrorism.24
VI OTHER NEW BUSINESS MODELS
New business models in the area of fintech appear every now and then. Most of the time such models are beyond existing regulations and fall in one of the following two groups: (1) unregulated models, which may be implemented within the existing legal framework; and (2) prohibited models, which are explicitly outlawed. Most new models fall within the unregulated domain. We will briefly cover several such business models below.
i Smart or self-executing contracts
While there is no specific regulation applicable to smart contracts, this topic has been widely discussed among both legal and finance professionals in 2017. Moreover, several banks and industry groups announced initiatives to implement smart-contract functionality in their systems. Among such initiatives is Masterchain, which is an Ethereum-based blockchain developed by the consortium of major Russian banks cooperating within the Association for Financial Technologies Development. Masterchain claims to be the first blockchain in Russia to satisfy the requirements of applicable law, thus making smart contracts entered into and executed thereby legally binding. Its White Paper names several use cases, such as a decentralised depository of mortgages, a distributed ledger of digital bank guarantees and electronic letters of credit.25
At the same time, there is still an ongoing discussion about whether smart contracts really represent a new contractual paradigm or rather such contracts are a more efficient way to execute traditional contracts.
ii Automated digital advisory
This sector is currently not regulated. Thus, general provisions of contract and consumer protection laws apply. This will change with the introduction of regulation for investment advisers (see Section IV, above).
iii Financial product comparison
No specific regulation applies to websites comparing financial products or services. Such websites are nonetheless subject to general advertising and fair competition principles.
iv Binary options
The Central Bank has not yet taken any stance on binary options. However, it did announce in its regulatory strategy for 2016–2018 that it would provide guidance on this issue. This announcement was made in the document’s section related to consumer protection and gambling.
VII INTELLECTUAL PROPERTY AND DATA PROTECTION
i Intellectual property
Russian law is familiar with all standard concepts of intellectual property (IP) used to protect business. Most commonly used are (1) patents (protecting inventions, utility models and industrial designs), (2) trade secrets; (3) copyright; and (4) trademarks, including service marks.
Information of any nature relating to the results of intellectual activity may be treated as a trade secret and be protected as IP provided basic confidentiality conditions are met.
Software and databases are usually protected under copyright laws. Copyright is acquired automatically as of the date a copyright object is manifested in objective form. Registration is optional.
Rights over trademarks are granted by virtue of registration with Rospatent,26 a local patent and trademark office. Alternatively, rights may also be acquired by virtue of international agreements to which Russia is a party, such as the Madrid Convention.27 Russia is a ‘first-to-file’ jurisdiction.
Any foreign company may seek protection of its intellectual property in Russia provided national law requirements are met. Russia is also a signatory to most international treaties covering intellectual property protection.
Disputes often arise in the context of employment relationship as to who owns newly created IP. For an employer to acquire rights over such IP, it is important that an employment contract or a job assignment explicitly states that creation of IP falls within the duties of an employee.
ii Data protection
Overall, Russian data protection law is in line with international standards. In fact, the Strasbourg Convention 1981 (ratified by Russia in 2005) laid the foundation for the Russian personal data protection legislation, which was adopted in 2006.
The main pieces of legislation governing the collection, storage and use of personal data in Russia are the Federal Law on Personal Data28 and the Federal Law on Information, Information Technologies, and Data Protection.29
Unlike in some other jurisdictions, there is currently no general obligation to report cybercrimes, although such legislation was proposed in 2017 and may be adopted soon.
VIII YEAR IN REVIEW
It would be fair to say that the most widely discussed fintech topics in 2017 in Russia were cryptocurrencies and ICOs. These areas witnessed great interest from both from investors and regulators and led to several legislative and regulatory initiatives (covered below) and even enforcement actions.
In 2017, the Central Bank took steps to introduce a proportional and risk-oriented approach towards the regulation of financial institutions. According to one of the major changes introduced in the Federal Law on Banks and Banking Activities,30 banking licences are now split into two broad categories – universal and basic. Banks with a universal licence may engage in all types of traditional banking activities and are subject to higher capital requirements. In contrast, banks with basic licence may engage only in selected types of banking activities but are also subject to less strict capital requirements and reporting standards.
Yet another major legislative initiative related to contractual aspects of financial transactions. In the middle of 2017, the President signed into law a package of fundamental amendments into the chapter of the Civil Code relating to financial transactions. These changes were long-awaited but are hardly game-changing when it comes to fintech. They will come in force on 1 June 2018.
Apart from the above changes, the last 18 months were relatively stable and there were no major fintech regulations that became binding law. Despite this, there were several regulatory initiatives at the beginning of 2018. They have not yet been formalised into law but are worth covering here.
In January 2018, the Ministry of Finance and the Central Bank published a jointly developed draft law on digital financial assets.31 The draft law aims to lay the legal foundation for the ‘creation, issuance and circulation of digital financial assets’, as well as to regulate smart contracts. Notably, the bill demonstrates the first attempts to legally define terms such as ‘token’, ‘cryptocurrency’, ‘mining’ and ‘distributed ledger’. Despite the ambitious nature of the proposed bill, experts point to internal inconsistencies and limitations and predict that it is unlikely that the bill in its current version will become law.
Simultaneously, the Central Bank published its draft version of the crowdfunding law, which is supposed to provide legal framework for efficient crowdfunding in Russia. Similarly to other countries, crowdfunding platforms under the proposed law will be subject to capital requirements (5 million roubles) and there will be some limitations on the amount of investment funds, both per one investor and per one project. This draft law appears to be more well thought out and therefore is likely to become binding. Interestingly, the draft law explicitly mentions ‘tokens’, which indicates that it was developed with ICOs in mind.
IX OUTLOOK AND CONCLUSIONS
We expect 2018 to be driven by the agenda set at the end of 2017. Specifically, on 18 December 2017, the Russian government adopted an extensive action plan aiming to introduce normative regulation of the digital economy that, among other things, includes many areas that will directly impact fintech.32 The action plan promises new and upgraded regulation for such areas, as smart contracts, blockchain, biometrical identification, payments, cryptocurrencies, ICOs and crowdfunding. Apart from simply listing ‘good-to-have’ things, the action plan also names responsible parties (both authorities and industry participants), sets deadlines and commits budgetary funds. This makes this plan a promising and ambitious initiative. Plus, most of the deadlines are set already for 2018.
The upcoming year will also demonstrate whether ambitious draft laws proposed by the Ministry of Finance and the Central Bank will become law or simply serve as material for further discussion.
1 Roman Buzko is a partner at Buzko & Partners.
5 Federal Law No. 223-FZ on Self-Regulated Organisations in Financial Markets dated 13 July 2015.
8 Federal Law No. 38-FZ on Advertising dated 13 March 2006.
9 Federal Law No. 135-FZ on Protection of Competition dated 26 July 2006.
10 Federal Law No. 218-FZ on Credit Histories dated 30 December 2004.
12 Federal Law No. 39-FZ on Securities Market dated 22 April 1996.
13 Federal Law No. 397-FZ ‘On Amendments into the Federal Law ‘On Securities Market’ and into Article 3 of the Federal Law ‘On Self-Regulated Organizations in Financial Markets’” dated 20 December 2017.
14 Financial Markets Regulation Review (‘Обзор регулирования финансовых рынков’), No. 1, 2016, p. 16, available at: www.cbr.ru/finmarkets/files/development/review_280716.pdf.
15 For instance, see Article 9(1)(1) of the Federal Law No. 151-FZ on Microfinancing Activities and Microfinancing Companies dated 2 July 2010, which allows microfinancing companies to raise public debt under certain conditions.
16 Federal Law No. 161-FZ on National Payment System dated 18 July 2011.
18 Letter of the Federal Tax Services No. ОА-18-17/1027 dated 3 October 2016.
19 Letter of the Federal Tax Services No. 03-04-05/66994 dated 13 October 2017.
20 Press release of the Central Bank on the Use of Private ‘Virtual Currencies’ (Cryptocurrencies) dated 4 September 2017.
21 Initial Coin Offering (ICO), Report of EY available at: www.ey.com/ru/ru/newsroom/news-releases/ey-news-ico-survey-2017.
22 Available at: www.cbr.ru/analytics/standart_acts/others/20180125_02.pdf.
24 Federal Law No. 115-FZ on Combating Legalization (Laundering) of Illegally Gained Income and Financing of Terrorism dated 7 August 2001.
25 Masterchain’s whitepaper is available in English at: http://fintechru.org/en/Masterchain_whitepaper_v1.1_en.pdf.
26 Federal Service for Intellectual Property, Patents and Trademarks.
27 Madrid Agreement Concerning the International Registration of Marks of 1983.
28 Federal Law No. 152-FZ on Personal Data dated 27 July 2006.
29 Federal Law No. 149-FZ on Information, Information Technologies, and Data Protection dated 27 July 2006.
30 Federal Law No. 395-1 on Banks and Banking Activities dated 2 December 1990.
32 Action Plan ‘Normative Regulation’ within the programme ‘Digital Economy of the Russian Federation’, as adopted by the Government Commission on the Use of Information Technologies for Life Quality and Business Environment Improvement on 18 December 2017. Available at: http://static.government.ru/media/files/P7L0vHUjwVJPlNcHrMZQqEEeVqXACwXR.pdf.