21st Century, with the fever caused by cryptocurrencies and the so-called Initial Coin Offering —ICO— an entrepreneur may issue a crypto-asset based on the recent technology called blockchain, to finance his company. The FinTech Law incorporates the “Virtual Asset” concept as the representation of value electronically registered, which is used by the general public as a payment method and which transfer may only be made through electronic means. In an explicit manner, it provides that these electronic transactions are not within the environment pertaining to the legal-tender currency and currencies. That is, the Law acknowledges its existence, but makes clear they are not currencies, but are always cryptocurrencies, duly identified by name. The Law allows, accordingly, that banks and regulated FinTech companies may perform transactions with virtual assets. Thus, Banco de México will determine through secondary legal provisions the virtual assets to be operated. Other financial institutions will be also able to perform transactions with virtual assets, subject to the provisions of Banco de Mexico itself. It should be noted that the Law does not allow other financial companies to operate virtual assets, and this will deprive them from the possible benefits thereof. Another development taking place in markets outside Mexico are ICOs as a mech- anism to raise capital or funds. ICOs, which in practice are tokens based on smart agreements, are not explicitly regulated by the FinTech Law, although (depending on the secondary regulation not published yet) under the concept of smart agreements may be issued through crowdfunding platforms and offered to the public and become a funding source. A TWO-WAY PATH 31