The Payments Newsletter including Digital Assets & Blockchain, March 2024

Key developments of interest over the last month include: the UK government publishing draft legislation on payment service contract termination rule changes; the Central Bank of Ireland providing insights into its regulatory priorities for payments and e-money in 2024; the Hong Kong Monetary Authority issuing guidance on digital assets custody; and the U.S. Commodity Futures Trading Commission (CFTC) Global Markets Advisory Committee approving a digital asset taxonomy for recommendation to CFTC Commissioners.

In this Newsletter:

For previous editions of the Payments Newsletters, please visit our Financial Services practice page.

Regulatory Developments: Payments

United Kingdom: Government publishes draft legislation on payment service contract termination rule changes

On 14 March 2024, HM Treasury published draft regulations amending the Payment Services Regulations 2017 (PSRs) to change the requirements on payment service providers (PSPs) when terminating payment service contracts. An accompanying policy note was also published.

The reforms to be introduced under the draft Payment Services and Payment Accounts (Contract Terminations) (Amendment) Regulations 2024 will increase from 2 months to 90 days the notice period PSPs must give customers when terminating a framework contract concluded for an indefinite period. While there are some exceptions, PSPs will also be required to give customers a detailed and specific explanation of the reason for termination so that the customer understands why their contract is being terminated. 

HM Treasury will consider technical comments on the draft regulation. The deadline is 14 April 2024 and any comments should be sent to:

The government intends to lay the regulations before Parliament in Summer 2024, subject to Parliamentary timing, and for them to enter into effect ‘as soon as practicable thereafter’.

Take a look at this Engage article for more on this development.

European Union: Adopted texts of ECON reports on PSD3 and PSR published

In the February edition of the Newsletter, we reported that the European Parliament had announced that its Economic and Monetary Affairs Committee (ECON) had adopted draft reports on the European Commission's legislative proposals for a Directive on payment services and electronic money services (PSD3) and a Regulation on payment services in the EU (PSR). On 5 March 2024, the adopted texts for both the proposed PSD3 and the proposed PSR were published.

The European Parliament is expected to vote on both texts during the first plenary session in April 2024, which is due to be held on 10 and 11 April 2024.

European Union: Council of EU publishes revised text of proposed Regulation on instant credit transfers in euro

On 15 March 2024, the Council of the EU published a revised version of the text of the proposed Regulation on instant credit transfers in euro.

As reported in the February edition of the Newsletter, the Council adopted the proposed Regulation on 26 February 2024 and the European Parliament adopted the proposed Regulation on 7 February 2024.

The Regulation is now awaiting publication in the Official Journal of the EU. It will enter into force 20 days after publication, following which there will be phased implementation deadlines, modified for the different components of the initiative and to allow for euro area and non-euro area member states.

European Union: Payment services versus e-money issuance: Court of Justice of EU clarifies regulatory border

On 22 February 2024, the Court of Justice of the European Union (ECJ) issued its judgment in a case concerning the boundary between regulated payment services and e-money issuance (‘ABC Projektai’ UAB v Lietuvos bankas (Case C-661/22)).

The ECJ held that where a payment institution (PI) receives funds to customers’ payment accounts without a specific payment order and holds them for several days or even months without transferring the funds to the recipients, this should not in itself constitute e-money issuance.

Rather, the minimum requirement for the classification of transferring and holding funds on a payment account as the issuance of e-money is a contractual agreement between the customer and an e-money issuer to issue a separate monetary asset up to the value of those funds (and the other requirements of the definition of e-money must be met).

For more on the background to the decision, the ECJ’s reasoning, next steps and the potential implications of this judgment for member states, please see our recent Engage article.

Ireland: Government to consult on establishment of a National Fintech Hub

On 8 March 2024, it was announced that the Minister for Finance and the Minister of State for Financial Services, Credit Unions, and Insurance had launched the second Ireland for Finance 2024 Action Plan (Action Plan).

The Action Plan details 13 measures, including assessing industry proposals for the establishment of a new National Fintech Hub by Q3 2024. The idea is that this would be a physical space conducive to growth and innovation, where fintech start-ups could collaborate and partner with more established firms, access expertise, and share their innovations.

Facilitated by the Department of Finance in conjunction with the Department of Enterprise, Trade and Employment, in collaboration with key industry and other relevant stakeholders, the parties will explore the costs, merits, and feasibility of establishing the Hub.

According to the Action Plan, further options to consider include the multi-location model whereby expertise and supports are drawn from existing regional hubs.

Other measures mentioned in the Action Plan include:

  • enhancing supports for ambitious early stage fintech innovators expanding into their first international market;
  • supporting Innovative Fintech and Digital Finance Investments across the IFS Portfolio;
  • continuing funding towards internationalisation and scaling of Irish fintechs;
  • Irish fintech and financial services companies achieving competitive advantage through innovation and digitisation;
  • Team Ireland supporting client participation in 2024 international fintech events; and
  • reviewing the Central Bank of Ireland’s approach to innovation engagement in financial services.
Global: FATF consultation on changes to FATF Recommendation 16: Wire Transfers

On 26 February 2024, the Financial Action Task Force (FATF) launched a consultation on changes to Recommendation 16 on wire transfers, which it is proposing to rename ‘payment transparency’.

The proposed changes to Recommendation 16, its Interpretive Note and the related Glossary of specific terms are aimed at adapting them to changes in payment business models and messaging standards.  

The updates will ensure that the FATF Standards remain technology-neutral and follow the principle of ‘same activity, same risk, same rules’. They also seek to help make cross-border payments faster, cheaper, more transparent and inclusive whilst remaining safe and secure; an objective that is part of the G20 Priority Action Plan.

The proposed changes are included in an Explanatory Memorandum which presents questions for consultation across various topic areas including:

  • additional transparency requirements on exemption for purchase of goods and services using cards;
  • removal of the withdrawal or purchase of cash or cash equivalent from exemption under Recommendation 16, subject to certain conditions; and
  • the definition of payment chain and conditions for net settlement.

The FATF has said that it would like to hear from all stakeholders, particularly in the payment industry. The deadline for responses to this initial consultation is 3 May 2024.

The FATF is envisaging further discussion and engagement to follow on from the initial consultation.

Following finalisation of the changes, the FATF will develop a guidance paper on payment transparency to facilitate consistent implementation of FATF Standards between jurisdictions.

United Kingdom: Government publishes money mules action plan

On 1 March 2024, the Home Office announced the publication of its awaited Money mule and financial exploitation action plan (Action Plan) which builds on commitments made in the government’s Economic Crime Plan 2 and Fraud Strategy to tackle the issue of money muling and related financial exploitation. It will cover England and Wales.

The 22-point Action Plan sets out how government, law enforcement, industry, regulators, and charities will work together to achieve a system-wide response to money muling. It outlines activities in five key areas:

  • Protecting the public​, where measures include the Home Office leading on securing commitments through sector-focused charters from industry to deliver consistent messaging;​
  • Understanding the threat​, where measures include Cifas (the UK fraud prevention service) sharing data insights with the banking industry and law enforcement quarterly.​
  • Safeguarding victims​, where measures include: Cifas investigating a data sharing solution to make it harder for mule recruiters to operate between banks; Home Office working with banks and local authorities to ensure victims are not removed from the banking system; and the government committing to fund a new Financial Exploitation Lead at The Children’s Society to work on educating individuals at the front line of the issue, including bank employees.
  • Pursuing criminal gangs​, where measures include the National Crime Agency (NCA) working with industry – through the National Economic Crime Centre (NECC) - to trial new ways of disrupting money mule networks.​
  • Disrupting transactions, where measures include: the NECC establishing a unit to strengthen the public-private response to crypto illicit finance;​ UK Finance creating best practice guidance for how the financial sector should respond to money mules;​ Pay.UK piloting the Fraud Overlay project, applying new technology to disrupt networks of fraudulent payments;​ the FCA developing work on Firms’ Fraud Controls, including deep dives into money mule controls (this could lead to new guidance being published to help firms improve controls to prevent accounts being abused by mule networks); the FCA publishing its findings on money mules, setting out good practice and areas that need development (see our related Engage article);​ and Pay.UK and UK Finance implementing a data sharing approach to enable both sending and receiving banks to detect high risk payments and prevent fraudulent transactions in real time. ​

The Home Office will monitor progress, with named action owners retaining responsibility for delivering them.​

The government also published accompanying guidance for frontline professionals (including banks) and organisations who work with children and adults at risk.

United Kingdom: FCA warns firms over anti-money laundering failings

On 5 March 2024, the FCA published a ‘Dear CEO’ letter regarding the need for action in response to common control failings identified in anti-money laundering (AML) frameworks. This follows on from the FCA’s recent review into firms’ compliance with money laundering regulations.

The letter was addressed to Annex 1 businesses which include those providing payment services, lenders, safe custody providers, money brokers and financial leasing companies, who undertake specified activities which bring them within the scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.

Common issues identified by the FCA include:

  • inconsistencies between firms’ registered and performed activities;
  • financial crime controls which had not been updated to reflect business growth;
  • a failure to assess their own or their customers’ activities properly;
  • inadequate resourcing and management of financial crime issues and requirements.

Annex 1 firms were advised to assess their financial crime controls against the weaknesses identified within the next 6 months. The FCA warned that failure to take suitable steps in response to its letter may result in regulatory or enforcement action.

See the FCA’s press release here.

Ireland: Central Bank of Ireland speech on perspectives and priorities in the payments and e-money sector

At a payments and electronic money institutions event held by the Central Bank of Ireland (CBI) on 29 February 2024, the CBI’s Director of Banking, Payments and Credit Union Supervision, Mary-Elizabeth McMunn, provided insights on the CBI’s regulatory priorities in respect of payments and e-money for the year ahead.

Referring to the CBI’s 2024 Regulatory and Supervisory Outlook Report, it was noted that there have been material levels of growth in the Irish payments and e-money sector. The number of payment and electronic money firms regulated in Ireland has tripled in the last 6 years, with 51 firms operating under CBI licences at the end of December 2023 and approximately €8bn in safeguarded funds.

The following key regulatory priorities for 2024 were highlighted:

  1. Safeguarding;
  2. Operational resilience and outsourcing;
  3. Governance, risk management, and anti-money laundering and countering the financing of terrorism; and
  4. Business model and financial resilience (also highlighted in a Dear CEO letter published on 20 January 2023 - see a related Hogan Lovells Engage article here).

For further information on these regulatory priorities and next steps, see our Engage article.

United Kingdom: Government publishes update on National Payments Vision

On 8 March 2024, HM Treasury published an update confirming that the National Payments Vision will be published as soon as possible later this year.

The National Payments Vision was recommended by the November 2023 Future of Payments Review report. Its aim will be to provide clarity on the government’s ambition for UK payments and provide guidance to the industry. The government seeks to ensure a world-leading payments ecosystem in the UK.

The government has appointed Joe Garner, who chaired the independent Future of Payments Review, to act as Advisor on the National Payments Vision.

For more on the outcome of the 2023 Future of Payments Review, take a look at this Engage article.

United Kingdom: HM Treasury publishes draft legislation on allowing PSPs to delay payments for fraud concerns

On 12 March 2024, HM Treasury published the draft Payment Services (Amendment) Regulations 2024 and an accompanying policy note. The draft Regulations amend the Payment Services Regulations 2017 (PSRs) to allow payment service providers (PSPs) more time to investigate suspicious payments to help tackle authorised push payment (APP) fraud.

The proposed amendments will allow a PSP to delay the execution of an outbound sterling payment within the UK where it has reasonable grounds to suspect the payment order is the result of fraud or dishonesty by someone other than the payer.

The deadline for any technical comments on the draft Regulations is 12 April 2024. The government plans to lay the legislation before Parliament in summer 2024, subject to Parliamentary time allowing. It intends that the changes will take effect on 7 October 2024, at the same time as the Payment Systems Regulator's new rules on mandatory reimbursement for APP fraud go live.

For more information on the proposals and next steps, see our Engage article.

Regulatory Developments: Digital Assets      

Global: BIS recommendations for the regulation, supervision and oversight of global stablecoin arrangements

On 29 February 2024, the Bank for International Settlements (BIS) published its recommendations to address the financial stability risks posed by global stablecoins (GSC).

A stablecoin can be considered a GSC if financial or operational disruptions in its arrangements could have a material impact on the markets and if it can potentially be used in multiple jurisdictions. The potential for GSCs to become systemically important across multiple jurisdictions brings a risk of financial instability.

The BIS provided ten high-level recommendations on the following topics relating to GSC arrangements:

  1. Regulation and supervision;
  2. Comprehensive oversight;
  3. Cross-border cooperation, coordination and information sharing;
  4. Governance structures and decentralised operations;
  5. Risk management;
  6. Data storage and access to data;
  7. Recovery and resolution of the GSC;
  8. Disclosures;
  9. Redemption rights, stabilisation and prudential requirements; and
  10. Conformance with regulatory, supervisory and oversight requirements before commencing operations.

United Kingdom: FCA to permit cryptoasset-backed ETNs

On 11 March 2024, the FCA released a statement to update its position on cryptoasset Exchange Traded Notes (cETNs) for professional investors.

Recognised Investment Exchanges (RIEs) will now be able to create a UK listed market segment for cETNs and make these available to professional investors.

cETNs must comply with all requirements of the UK Listing Regime, such as on prospectuses and ongoing disclosure. The FCA emphasised that exchanges must ensure that sufficient controls are in place in order to protect professional investors and the trading market.

This shift in the FCA’s position follows increased insight and data on cETNs due to a longer period of trading history. The FCA believes that exchanges and professional investors should now be able to better identify whether cETNs meet their risk appetite. The FCA also stated that it maintains its position that cETNs and crypto derivatives are not suited for retail customers due to the harm posed. The ban on the sale of these products to retail consumers remains in place.

Further to the FCA’s statement, the London Stock Exchange also announced on 11 March 2024 that it will start to accept applications from issuers to list notes that are linked to bitcoin and ethereum ETNs.

For more on this development, take a look at this Engage article.

United States: CFTC Global Markets Advisory Committee approves digital asset taxonomy for recommendation to CFTC Commissioners

On 6 March 2024, the U.S. Commodity Futures Trading Commission (CFTC) Global Markets Advisory Committee (GMAC) approved a digital asset taxonomy for recommendation to CFTC Commissioners. This was a collaboration between BNY Mellon, Franklin Templeton, GBBC, BCG (London and New York), and GFMA. The taxonomy may guide future regulatory and policy decisions.

In addition, the GMAC’s Digital Asset Markets Subcommittee will reassess any future developments in the digital asset ecosystem to provide further recommendations to the approach in the taxonomy, based on the guidance of its members. The Subcommittee aims to support effective rules and regulations for digital assets, and recommends continued collaboration between industry, standard-setting bodies, and the regulatory community.

European Union: EBA consults on Guidelines for plans to redeem asset-referenced and e-money tokens under MiCAR

On 8 March 2024, the European Banking Authority (EBA) launched a consultation on the redemption Guidelines that it is required to issue under Regulation (EU) 2023/1114 on Markets in Crypto-assets (also known as MiCAR).

MiCAR mandates the EBA to develop technical standards and guidelines to specify the requirements for asset-referenced tokens and e-money tokens.

The EBA is seeking consultation responses on its proposed Guidelines to redeem asset-referenced or e-money tokens in the event that an issuer fails to fulfil its obligations under MiCAR.

The proposed Guidelines subject to the consultation include the following:

  • A clarification of the principles of redemption, such as equitable treatment of token holders.
  • A description of the steps for the redemption plan, including the communication measures, the content of the redemption claims and the distribution plans.
  • Addressing the scenario of pooled issuance wherein the same token is issued by multiple issuers.
  • Considering the circumstances under which an authority is entitled to activate the plan, and the role that the prudential and resolution authorities will play in this.

The consultation will run until 10 June 2024.

Hong Kong: HKMA guidance on digital assets custody

On 20 February 2024, the Hong Kong Monetary Authority (HKMA) issued a letter addressed to all authorised institutions (AIs) setting out Guidance on the provision of custodial services for digital assets.

The Guidance defines digital assets as assets which depend on cryptography and distributed ledger or similar technologies, and which include virtual assets, tokenised securities and other tokenised assets.

The Guidance sets out expected standards on the following topics:

  • Governance and risk management: AIs must undertake and act on comprehensive risk assessments.
  • Segregation of client digital assets: In the event of an insolvency or resolution of the AI, client digital assets must be segregated from the AI’s own assets.
  • Safeguarding of client digital assets: AIs should have effective measures in place to minimise the risk of theft or misappropriation of client digital assets.
  • Delegation and outsourcing: The use of delegate or outsourced sub-custodians is limited.
  • Disclosures: AIs should disclose custodial arrangements in a full and fair manner.
  • Record keeping and reconciliation of client digital assets: Appropriate records should be maintained.
  • Anti-money laundering and counter-financing of terrorism: AIs should have in place effective anti-money laundering and counter-terrorism financing measures.
  • Ongoing monitoring: AIs must review and audit their policies frequently.

AIs that fall within the scope of the Guidance must confirm that they satisfy the standards within six months of 20 February 2024.

See our Engage article for more on this development.

Hong Kong: HKMA announces new wholesale central bank digital currency project

On 7 March 2024, the Hong Kong Monetary Authority (HKMA) announced Project Ensemble, a new wholesale central bank digital currency (wCBDC) project to support the development of the tokenisation market. The project will explore innovative financial market infrastructure to facilitate efficient interbank settlement of tokenised money through wCBDC.

In connection with Project Ensemble, the HKMA will also launch a wCBDC Sandbox later this year which will research and test tokenisation use cases. Depending on industry interest in the wCBDC Sandbox, the HKMA is prepared to conduct a live issuance of wCBDC.

Hong Kong: HKMA launches Phase 2 of e-HKD Pilot Programme

On 14 March 2024, the Hong Kong Monetary Authority (HKMA) announced the launch of Phase 2 of the e-HKD Pilot Programme and is inviting interested parties to submit applications.

According to the press release, an enhanced e-HKD sandbox, leveraged on the wholesale central bank digital currency (wCBDC) sandbox to be built under Project Ensemble (see above item) will support Phase 2 of the e-HKD Pilot Programme to accelerate the prototyping, development and testing of use cases by pilot participants, as well as facilitate the study of interoperability and interbank settlement between e-HKD and other forms of tokenised money.

Organisations interested in participating in Phase 2 should submit their applications by 17 May 2024. Further details about the application process are available on the HKMA website.

Hong Kong: HKMA guidance on tokenisation of financial products

On 20 February 2024, the Hong Kong Monetary Authority (HKMA) published a circular setting out supervisory standards which authorised institutions (AIs) are expected to follow in the sale and distribution of tokenised products.

Tokenised products are digital representatives of real-world assets using distributed ledger or similar technology. This can include tokenised structured investment products and tokenised spot precious metal products.

The guidance issued in the circular is in addition to the existing supervisory requirements and consumer/investor protection measures which apply to the non-tokenised forms of the products.

The HKMA has provided additional consumer/investor protection measures for tokenised products relating to:

  • Due diligence;
  • Product and risk disclosure; and
  • Risk management.

See our Engage article for more on this development.

Hong Kong: HKMA launches stablecoin issuer sandbox

On 12 March 2024, the Hong Kong Monetary Authority (HKMA) announced the launch of a regulatory sandbox for stablecoin issuers. This ties in with the recent consultation on a legislative proposal for implementing a regulatory regime for stablecoin issuers. The HKMA is looking to use the sandbox to communicate supervisory expectations to parties interested in issuing fiat-referenced stablecoins in Hong Kong, as well as to obtain feedback from participants on the proposed regulatory requirements.

The list of the participants in the sandbox will be available on the HKMA website.

Market Developments

Europe: Fintech Purse acquires ReachFive

On 5 March 2024, ReachFive announced its acquisition by Purse, a payments fintech company founded in Lille in 2021. Purse seeks to personalise, optimise and manage the entire customer payment process from a single interface. ReachFive offers a customer identify and access management system. It provides simplified and secure access to merchant services across multiple touchpoints. It was reported that this acquisition is Purse’s first external growth operation.

Global: Revolut announces Revolut Ramp

On 6 March 2024, Revolut expanded its crypto portfolio by announcing a new product, Revolut Ramp, in partnership with the self-custodial wallet MetaMask.

Revolut Ramp will allow customers to purchase new tokens directly into their MetaMask wallets using their fiat currency balance or Visa or Mastercard bank card. The checkout process will take seconds.

Revolut has said that it will be able to offer competitive prices and increased success rates if customers pay directly from their Revolut account, making the transaction entirely within Revolut’s ecosystem. For non-Revolut customers, Revolut Ramp offers an integrated Know Your Customer process for efficient onboarding.

Global: Amadeus acquires travel payments expert Voxel

On 11 March 2024, travel payments company Amadeus announced its acquisition of Voxel, a provider of electronic invoice and B2B payment solutions for travel sellers, hotels, and other travel payers.

One of the effects of the acquisition will be that Amadeus will be better able to further automate the business travel experience, from reservation and payments to expense management.

United States: Jefferson Bank expands partnership with Finastra

On 11 March 2024, fintech Finastra announced that Jefferson Bank, an independent Texas-based bank, has selected Finastra Payments To Go for its new instant payments services.

Jefferson Bank will migrate its wire services from the existing Finastra PayPlus Connect system and fully consolidate all payments services under one Finastra solution.

Germany: Deutsche Börse launches regulated spot platform for cryptoassets

On 5 March 2024, Deutsche Börse Group announced the launch of the Deutsche Börse Digital Exchange (DBDE), a crypto spot platform for institutional clients. DBDX will seek to offer a regulated and reliable ecosystem for trading, settlement and custody of cryptoassets.

Russia: Alfa-bank launches digital asset product

On 3 March 2024, it was reported that Alfa-bank, Russia’s largest private bank, has created a digital financial asset. It is backed by gold, stocks, and cash and named the Evergreen Portfolio.

United Kingdom: Volt Secures UK EMI Licence

On 29 February 2024, Volt, a global real-time payments platform, announced that it had secured an electronic money institution (EMI) licence from the UK Financial Conduct Authority.

Following the granting of the EMI licence, Volt plans to evolve its cash management product, Connect, to allow virtual accounts to be issued to merchants. This product will be targeted at businesses that need to manage funds and reconciliation processes but which may not require payment initiation functionality at the checkout.

Japan: Xsolla launches PayPay for Japanese gamers

On 6 March 2024, Xsolla, a global video game commerce company, announced its partnership with PayPay, a digital wallet provider in Japan.

Xsolla has partnered with PayPay to include its digital wallet in Xsolla Pay Station. This will offer game developers and publishers more ways to generate revenue through in-game purchases.

Australia: Bybit Card launched

On 8 March 2024, Bybit, a crypto exchange, announced the launch of its Bybit Card in Australia. The card is issued by Flywallet and leverages Mastercard’s global payments network. The card will allow customers to debit crypto balances on Bybit and convert them into fiat money.

Europe: Mastercard partners with Nexi to advance open banking payments

On 11 March 2024, Mastercard announced its strategic partnership with Nexi, a European PayTech company, to support open banking account-based payments.

The companies will build an integrated digital payment ecosystem by allowing Mastercard Open Banking to facilitate e-commerce payments across Nexi’s gateways serving merchants in Europe. Open banking allows users to initiate swift digital payments to a merchant’s account. Payments are directly made through existing authentication protocols with a consumer’s bank, such as biometrics. Merchants will benefit from real-time payment authorisation and settlement, allowing them to have quick access to funds and improved management of cashflow and revenue.

Surveys and Reports

Global: Research and Markets report on ‘Payments Market - Global Industry Size, Share, Trends, Opportunity and Forecast 2019 – 2029’

On 6 March 2024, it was reported that Research and Markets’ recent ‘Payments Market - Global Industry Size, Share, Trends, Opportunity, & Forecast 2019-2029’ report stated that the global payments market was valued at USD $2.64 trillion in 2023. The market is expected to grow with a compound annual growth of 10.5% by 2029 to a value of USD $4.78 trillion.

Other insights from the report include the following:

  • In 2023, the market was dominated by North America due to its mature insurance industry, early adoption of technology and financial infrastructure; and
  • High growth rates, government-backed digitisation initiatives and increasing use of e-commerce means that the Asia-Pacific region, led by China and India, has emerged as the fastest growing payments market.
Global: Maximize Market Research report on biometric payment market

On 12 March 2024, a summary of a report published by Maximize Market Research stated that the global biometric payment market is projected to reach USD $19.28 billion by 2029.

The global biometric payment market was valued at USD $7.4 billion in 2023 and has grown due to advancements in technology and increasing demand for secure and convenient payment methods.

Biometric data includes fingerprints, facial recognition or iris scans and is used to authorise transactions. The use areas for biometric data considered by the report include:

  1. Retail
  2. Banking and Finance
  3. Healthcare
  4. Transportation
  5. Government


Authored by Grace Wyatt, Virginia Montgomery and Ada Nourell.


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