On 23 October 2019, the Financial Markets Law Committee (FMLC) published a paper on issues of legal uncertainty in respect of exchange tokens. In the paper, the FMLC provides an overview of the latest regulatory and non-legislative developments with regards to virtual currencies. The paper also explores the possible characterisation of exchange tokens as property, money and e-money. It also analyses the approach to virtual currencies taken by the EU in its anti-money laundering regime, through the Fifth Money Laundering Directive, and investigates the uncertainty arising from this approach and the consequent impact of such uncertainty.