The March 2018 FMLC paper “Distributed Ledger Technology and Governing Law: Issues of Legal Uncertainty” describes itself as a “canter through potential solutions” to the issues, but admits the correct governing law regarding DLT assets and dealings with them will depend on a variety of issues, such as the type of DLT system (for instance, whether it has an administrator or operator at its centre or is fully decentralised) and the nature of the assets that are circulated on the ledger (e.g., whether they are tokens referencing an asset, or a cryptocurrency). It concludes “it is necessary to create a framework within which the governing law of the proprietary effects of transactions on a DLT system can be determined”, presumably along the lines of the 2008 EU Regulation on the law applicable to contractual obligations, usually known as “Rome 1”. Others may argue that the variety and nascent state of DLT means that at this stage the flexibility of the common law is needed to meet developments.