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Bob The Magic Custodian
Summary: Everyone knows that when you give your assets to someone else, they always keep them safe. If this is true for individuals, it is certainly true for businesses. Custodians always tell the truth and manage funds properly. They won't have any interest in taking the assets as an exchange operator would. Auditors tell the truth and can't be misled. That's because organizations that are regulated are incapable of lying and don't make mistakes. First, some background. Here is a summary of how custodians make us more secure: Previously, we might give Alice our crypto assets to hold. There were risks:
Alice might take the assets and disappear.
Alice might spend the assets and pretend that she still has them (fractional model).
Alice might store the assets insecurely and they'll get stolen.
Alice might give the assets to someone else by mistake or by force.
Alice might lose access to the assets.
But "no worries", Alice has a custodian named Bob. Bob is dressed in a nice suit. He knows some politicians. And he drives a Porsche. "So you have nothing to worry about!". And look at all the benefits we get:
Alice can't take the assets and disappear (unless she asks Bob or never gives them to Bob).
Alice can't spend the assets and pretend that she still has them. (Unless she didn't give them to Bob or asks him for them.)
Alice can't store the assets insecurely so they get stolen. (After all - she doesn't have any control over the withdrawal process from any of Bob's systems, right?)
Alice can't give the assets to someone else by mistake or by force. (Bob will stop her, right Bob?)
Alice can't lose access to the funds. (She'll always be present, sane, and remember all secrets, right?)
See - all problems are solved! All we have to worry about now is:
Bob might take the assets and disappear.
Bob might spend the assets and pretend that he still has them (fractional model).
Bob might store the assets insecurely and they'll get stolen.
Bob might give the assets to someone else by mistake or by force.
Bob might lose access to the assets.
It's pretty simple. Before we had to trust Alice. Now we only have to trust Alice, Bob, and all the ways in which they communicate. Just think of how much more secure we are! "On top of that", Bob assures us, "we're using a special wallet structure". Bob shows Alice a diagram. "We've broken the balance up and store it in lots of smaller wallets. That way", he assures her, "a thief can't take it all at once". And he points to a historic case where a large sum was taken "because it was stored in a single wallet... how stupid". "Very early on, we used to have all the crypto in one wallet", he said, "and then one Christmas a hacker came and took it all. We call him the Grinch. Now we individually wrap each crypto and stick it under a binary search tree. The Grinch has never been back since." "As well", Bob continues, "even if someone were to get in, we've got insurance. It covers all thefts and even coercion, collusion, and misplaced keys - only subject to the policy terms and conditions." And with that, he pulls out a phone-book sized contract and slams it on the desk with a thud. "Yep", he continues, "we're paying top dollar for one of the best policies in the country!" "Can I read it?' Alice asks. "Sure," Bob says, "just as soon as our legal team is done with it. They're almost through the first chapter." He pauses, then continues. "And can you believe that sales guy Mike? He has the same year Porsche as me. I mean, what are the odds?" "Do you use multi-sig?", Alice asks. "Absolutely!" Bob replies. "All our engineers are fully trained in multi-sig. Whenever we want to set up a new wallet, we generate 2 separate keys in an air-gapped process and store them in this proprietary system here. Look, it even requires the biometric signature from one of our team members to initiate any withdrawal." He demonstrates by pressing his thumb into the display. "We use a third-party cloud validation API to match the thumbprint and authorize each withdrawal. The keys are also backed up daily to an off-site third-party." "Wow that's really impressive," Alice says, "but what if we need access for a withdrawal outside of office hours?" "Well that's no issue", Bob says, "just send us an email, call, or text message and we always have someone on staff to help out. Just another part of our strong commitment to all our customers!" "What about Proof of Reserve?", Alice asks. "Of course", Bob replies, "though rather than publish any blockchain addresses or signed transaction, for privacy we just do a SHA256 refactoring of the inverse hash modulus for each UTXO nonce and combine the smart contract coefficient consensus in our hyperledger lightning node. But it's really simple to use." He pushes a button and a large green checkmark appears on a screen. "See - the algorithm ran through and reserves are proven." "Wow", Alice says, "you really know your stuff! And that is easy to use! What about fiat balances?" "Yeah, we have an auditor too", Bob replies, "Been using him for a long time so we have quite a strong relationship going! We have special books we give him every year and he's very efficient! Checks the fiat, crypto, and everything all at once!" "We used to have a nice offline multi-sig setup we've been using without issue for the past 5 years, but I think we'll move all our funds over to your facility," Alice says. "Awesome", Bob replies, "Thanks so much! This is perfect timing too - my Porsche got a dent on it this morning. We have the paperwork right over here." "Great!", Alice replies. And with that, Alice gets out her pen and Bob gets the contract. "Don't worry", he says, "you can take your crypto-assets back anytime you like - just subject to our cancellation policy. Our annual management fees are also super low and we don't adjust them often". How many holes have to exist for your funds to get stolen? Just one. Why are we taking a powerful offline multi-sig setup, widely used globally in hundreds of different/lacking regulatory environments with 0 breaches to date, and circumventing it by a demonstrably weak third party layer? And paying a great expense to do so? If you go through the list of breaches in the past 2 years to highly credible organizations, you go through the list of major corporate frauds (only the ones we know about), you go through the list of all the times platforms have lost funds, you go through the list of times and ways that people have lost their crypto from identity theft, hot wallet exploits, extortion, etc... and then you go through this custodian with a fine-tooth comb and truly believe they have value to add far beyond what you could, sticking your funds in a wallet (or set of wallets) they control exclusively is the absolute worst possible way to take advantage of that security. The best way to add security for crypto-assets is to make a stronger multi-sig. With one custodian, what you are doing is giving them your cryptocurrency and hoping they're honest, competent, and flawlessly secure. It's no different than storing it on a really secure exchange. Maybe the insurance will cover you. Didn't work for Bitpay in 2015. Didn't work for Yapizon in 2017. Insurance has never paid a claim in the entire history of cryptocurrency. But maybe you'll get lucky. Maybe your exact scenario will buck the trend and be what they're willing to cover. After the large deductible and hopefully without a long and expensive court battle. And you want to advertise this increase in risk, the lapse of judgement, an accident waiting to happen, as though it's some kind of benefit to customers ("Free institutional-grade storage for your digital assets.")? And then some people are writing to the OSC that custodians should be mandatory for all funds on every exchange platform? That this somehow will make Canadians as a whole more secure or better protected compared with standard air-gapped multi-sig? On what planet? Most of the problems in Canada stemmed from one thing - a lack of transparency. If Canadians had known what a joke Quadriga was - it wouldn't have grown to lose $400m from hard-working Canadians from coast to coast to coast. And Gerald Cotten would be in jail, not wherever he is now (at best, rotting peacefully). EZ-BTC and mister Dave Smilie would have been a tiny little scam to his friends, not a multi-million dollar fraud. Einstein would have got their act together or been shut down BEFORE losing millions and millions more in people's funds generously donated to criminals. MapleChange wouldn't have even been a thing. And maybe we'd know a little more about CoinTradeNewNote - like how much was lost in there. Almost all of the major losses with cryptocurrency exchanges involve deception with unbacked funds. So it's great to see transparency reports from BitBuy and ShakePay where someone independently verified the backing. The only thing we don't have is:
ANY CERTAINTY BALANCES WEREN'T EXCLUDED. Quadriga's largest account was $70m. 80% of funds are in 20% of accounts (Pareto principle). All it takes is excluding a few really large accounts - and nobody's the wiser. A fractional platform can easily pass any audit this way.
ANY VISIBILITY WHATSOEVER INTO THE CUSTODIANS. BitBuy put out their report before moving all the funds to their custodian and ShakePay apparently can't even tell us who the custodian is. That's pretty important considering that basically all of the funds are now stored there.
ANY IDEA ABOUT THE OTHER EXCHANGES. In order for this to be effective, it has to be the norm. It needs to be "unusual" not to know. If obscurity is the norm, then it's super easy for people like Gerald Cotten and Dave Smilie to blend right in.
It's not complicated to validate cryptocurrency assets. They need to exist, they need to be spendable, and they need to cover the total balances. There are plenty of credible people and firms across the country that have the capacity to reasonably perform this validation. Having more frequent checks by different, independent, parties who publish transparent reports is far more valuable than an annual check by a single "more credible/official" party who does the exact same basic checks and may or may not publish anything. Here's an example set of requirements that could be mandated:
First report within 1 month of launching, another within 3 months, and further reports at minimum every 6 months thereafter.
No auditor can be repeated within a 12 month period.
All reports must be public, identifying the auditor and the full methodology used.
All auditors must be independent of the firm being audited with no conflict of interest.
Reports must include the percentage of each asset backed, and how it's backed.
The auditor publishes a hash list, which lists a hash of each customer's information and balances that were included. Hash is one-way encryption so privacy is fully preserved. Every customer can use this to have 100% confidence they were included.
If we want more extensive requirements on audits, these should scale upward based on the total assets at risk on the platform, and whether the platform has loaned their assets out.
There are ways to structure audits such that neither crypto assets nor customer information are ever put at risk, and both can still be properly validated and publicly verifiable. There are also ways to structure audits such that they are completely reasonable for small platforms and don't inhibit innovation in any way. By making the process as reasonable as possible, we can completely eliminate any reason/excuse that an honest platform would have for not being audited. That is arguable far more important than any incremental improvement we might get from mandating "the best of the best" accountants. Right now we have nothing mandated and tons of Canadians using offshore exchanges with no oversight whatsoever. Transparency does not prove crypto assets are safe. CoinTradeNewNote, Flexcoin ($600k), and Canadian Bitcoins ($100k) are examples where crypto-assets were breached from platforms in Canada. All of them were online wallets and used no multi-sig as far as any records show. This is consistent with what we see globally - air-gapped multi-sig wallets have an impeccable record, while other schemes tend to suffer breach after breach. We don't actually know how much CoinTrader lost because there was no visibility. Rather than publishing details of what happened, the co-founder of CoinTrader silently moved on to found another platform - the "most trusted way to buy and sell crypto" - a site that has no information whatsoever (that I could find) on the storage practices and a FAQ advising that “[t]rading cryptocurrency is completely safe” and that having your own wallet is “entirely up to you! You can certainly keep cryptocurrency, or fiat, or both, on the app.” Doesn't sound like much was learned here, which is really sad to see. It's not that complicated or unreasonable to set up a proper hardware wallet. Multi-sig can be learned in a single course. Something the equivalent complexity of a driver's license test could prevent all the cold storage exploits we've seen to date - even globally. Platform operators have a key advantage in detecting and preventing fraud - they know their customers far better than any custodian ever would. The best job that custodians can do is to find high integrity individuals and train them to form even better wallet signatories. Rather than mandating that all platforms expose themselves to arbitrary third party risks, regulations should center around ensuring that all signatories are background-checked, properly trained, and using proper procedures. We also need to make sure that signatories are empowered with rights and responsibilities to reject and report fraud. They need to know that they can safely challenge and delay a transaction - even if it turns out they made a mistake. We need to have an environment where mistakes are brought to the surface and dealt with. Not one where firms and people feel the need to hide what happened. In addition to a knowledge-based test, an auditor can privately interview each signatory to make sure they're not in coercive situations, and we should make sure they can freely and anonymously report any issues without threat of retaliation. A proper multi-sig has each signature held by a separate person and is governed by policies and mutual decisions instead of a hierarchy. It includes at least one redundant signature. For best results, 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. History has demonstrated over and over again the risk of hot wallets even to highly credible organizations. Nonetheless, many platforms have hot wallets for convenience. While such losses are generally compensated by platforms without issue (for example Poloniex, Bitstamp, Bitfinex, Gatecoin, Coincheck, Bithumb, Zaif, CoinBene, Binance, Bitrue, Bitpoint, Upbit, VinDAX, and now KuCoin), the public tends to focus more on cases that didn't end well. Regardless of what systems are employed, there is always some level of risk. For that reason, most members of the public would prefer to see third party insurance. Rather than trying to convince third party profit-seekers to provide comprehensive insurance and then relying on an expensive and slow legal system to enforce against whatever legal loopholes they manage to find each and every time something goes wrong, insurance could be run through multiple exchange operators and regulators, with the shared interest of having a reputable industry, keeping costs down, and taking care of Canadians. For example, a 4 of 7 multi-sig insurance fund held between 5 independent exchange operators and 2 regulatory bodies. All Canadian exchanges could pay premiums at a set rate based on their needed coverage, with a higher price paid for hot wallet coverage (anything not an air-gapped multi-sig cold wallet). Such a model would be much cheaper to manage, offer better coverage, and be much more reliable to payout when needed. The kind of coverage you could have under this model is unheard of. You could even create something like the CDIC to protect Canadians who get their trading accounts hacked if they can sufficiently prove the loss is legitimate. In cases of fraud, gross negligence, or insolvency, the fund can be used to pay affected users directly (utilizing the last transparent balance report in the worst case), something which private insurance would never touch. While it's recommended to have official policies for coverage, a model where members vote would fully cover edge cases. (Could be similar to the Supreme Court where justices vote based on case law.) Such a model could fully protect all Canadians across all platforms. You can have a fiat coverage governed by legal agreements, and crypto-asset coverage governed by both multi-sig and legal agreements. It could be practical, affordable, and inclusive. Now, we are at a crossroads. We can happily give up our freedom, our innovation, and our money. We can pay hefty expenses to auditors, lawyers, and regulators year after year (and make no mistake - this cost will grow to many millions or even billions as the industry grows - and it will be borne by all Canadians on every platform because platforms are not going to eat up these costs at a loss). We can make it nearly impossible for any new platform to enter the marketplace, forcing Canadians to use the same stagnant platforms year after year. We can centralize and consolidate the entire industry into 2 or 3 big players and have everyone else fail (possibly to heavy losses of users of those platforms). And when a flawed security model doesn't work and gets breached, we can make it even more complicated with even more people in suits making big money doing the job that blockchain was supposed to do in the first place. We can build a system which is so intertwined and dependent on big government, traditional finance, and central bankers that it's future depends entirely on that of the fiat system, of fractional banking, and of government bail-outs. If we choose this path, as history has shown us over and over again, we can not go back, save for revolution. Our children and grandchildren will still be paying the consequences of what we decided today. Or, we can find solutions that work. We can maintain an open and innovative environment while making the adjustments we need to make to fully protect Canadian investors and cryptocurrency users, giving easy and affordable access to cryptocurrency for all Canadians on the platform of their choice, and creating an environment in which entrepreneurs and problem solvers can bring those solutions forward easily. None of the above precludes innovation in any way, or adds any unreasonable cost - and these three policies would demonstrably eliminate or resolve all 109 historic cases as studied here - that's every single case researched so far going back to 2011. It includes every loss that was studied so far not just in Canada but globally as well. Unfortunately, finding answers is the least challenging part. Far more challenging is to get platform operators and regulators to agree on anything. My last post got no response whatsoever, and while the OSC has told me they're happy for industry feedback, I believe my opinion alone is fairly meaningless. This takes the whole community working together to solve. So please let me know your thoughts. Please take the time to upvote and share this with people. Please - let's get this solved and not leave it up to other people to do. Facts/background/sources (skip if you like):
The inspiration for the paragraph about splitting wallets was an actual quote from a Canadian company providing custodial services in response to the OSC consultation paper: "We believe that it will be in the in best interests of investors to prohibit pooled crypto assets or ‘floats’. Most Platforms pool assets, citing reasons of practicality and expense. The recent hack of the world’s largest Platform – Binance – demonstrates the vulnerability of participants’ assets when such concessions are made. In this instance, the Platform’s entire hot wallet of Bitcoins, worth over $40 million, was stolen, facilitated in part by the pooling of client crypto assets." "the maintenance of participants (and Platform) crypto assets across multiple wallets distributes the related risk and responsibility of security - reducing the amount of insurance coverage required and making insurance coverage more readily obtainable". For the record, their reply also said nothing whatsoever about multi-sig or offline storage.
In addition to the fact that the $40m hack represented only one "hot wallet" of Binance, and they actually had the vast majority of assets in other wallets (including mostly cold wallets), multiple real cases have clearly demonstrated that risk is still present with multiple wallets. Bitfinex, VinDAX, Bithumb, Altsbit, BitPoint, Cryptopia, and just recently KuCoin all had multiple wallets breached all at the same time, and may represent a significantly larger impact on customers than the Binance breach which was fully covered by Binance. To represent that simply having multiple separate wallets under the same security scheme is a comprehensive way to reduce risk is just not true.
Private insurance has historically never covered a single loss in the cryptocurrency space (at least, not one that I was able to find), and there are notable cases where massive losses were not covered by insurance. Bitpay in 2015 and Yapizon in 2017 both had insurance policies that didn't pay out during the breach, even after a lengthly court process. The same insurance that ShakePay is presently using (and announced to much fanfare) was describe by their CEO himself as covering “physical theft of the media where the private keys are held,” which is something that has never historically happened. As was said with regard to the same policy in 2018 - “I don’t find it surprising that Lloyd’s is in this space,” said Johnson, adding that to his mind the challenge for everybody is figuring out how to structure these policies so that they are actually protective. “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.”
The most profitable policy for a private insurance company is one with the most expensive premiums that they never have to pay a claim on. They have no inherent incentive to take care of people who lost funds. It's "cheaper" to take the reputational hit and fight the claim in court. The more money at stake, the more the insurance provider is incentivized to avoid payout. They're not going to insure the assets unless they have reasonable certainty to make a profit by doing so, and they're not going to pay out a massive sum unless it's legally forced. Private insurance is always structured to be maximally profitable to the insurance provider.
The circumvention of multi-sig was a key factor in the massive Bitfinex hack of over $60m of bitcoin, which today still sits being slowly used and is worth over $3b. While Bitfinex used a qualified custodian Bitgo, which was and still is active and one of the industry leaders of custodians, and they set up 2 of 3 multi-sig wallets, the entire system was routed through Bitfinex, such that Bitfinex customers could initiate the withdrawals in a "hot" fashion. This feature was also a hit with the hacker. The multi-sig was fully circumvented.
Bitpay in 2015 was another example of a breach that stole 5,000 bitcoins. This happened not through the exploit of any system in Bitpay, but because the CEO of a company they worked with got their computer hacked and the hackers were able to request multiple bitcoin purchases, which Bitpay honoured because they came from the customer's computer legitimately. Impersonation is a very common tactic used by fraudsters, and methods get more extreme all the time.
A notable case in Canada was the Canadian Bitcoins exploit. Funds were stored on a server in a Rogers Data Center, and the attendee was successfully convinced to reboot the server "in safe mode" with a simple phone call, thus bypassing the extensive security and enabling the theft.
The very nature of custodians circumvents multi-sig. This is because custodians are not just having to secure the assets against some sort of physical breach but against any form of social engineering, modification of orders, fraudulent withdrawal attempts, etc... If the security practices of signatories in a multi-sig arrangement are such that the breach risk of one signatory is 1 in 100, the requirement of 3 independent signatures makes the risk of theft 1 in 1,000,000. Since hackers tend to exploit the weakest link, a comparable custodian has to make the entry and exit points of their platform 10,000 times more secure than one of those signatories to provide equivalent protection. And if the signatories beef up their security by only 10x, the risk is now 1 in 1,000,000,000. The custodian has to be 1,000,000 times more secure. The larger and more complex a system is, the more potential vulnerabilities exist in it, and the fewer people can understand how the system works when performing upgrades. Even if a system is completely secure today, one has to also consider how that system might evolve over time or work with different members.
By contrast, offline multi-signature solutions have an extremely solid record, and in the entire history of cryptocurrency exchange incidents which I've studied (listed here), there has only been one incident (796 exchange in 2015) involving an offline multi-signature wallet. It happened because the customer's bitcoin address was modified by hackers, and the amount that was stolen ($230k) was immediately covered by the exchange operators. Basically, the platform operators were tricked into sending a legitimate withdrawal request to the wrong address because hackers exploited their platform to change that address. Such an issue would not be prevented in any way by the use of a custodian, as that custodian has no oversight whatsoever to the exchange platform. It's practical for all exchange operators to test large withdrawal transactions as a general policy, regardless of what model is used, and general best practice is to diagnose and fix such an exploit as soon as it occurs.
False promises on the backing of funds played a huge role in the downfall of Quadriga, and it's been exposed over and over again (MyCoin, PlusToken, Bitsane, Bitmarket, EZBTC, IDAX). Even today, customers have extremely limited certainty on whether their funds in exchanges are actually being backed or how they're being backed. While this issue is not unique to cryptocurrency exchanges, the complexity of the technology and the lack of any regulation or standards makes problems more widespread, and there is no "central bank" to come to the rescue as in the 2008 financial crisis or during the great depression when "9,000 banks failed".
In addition to fraudulent operations, the industry is full of cases where operators have suffered breaches and not reported them. Most recently, Einstein was the largest case in Canada, where ongoing breaches and fraud were perpetrated against the platform for multiple years and nobody found out until the platform collapsed completely. While fraud and breaches suck to deal with, they suck even more when not dealt with. Lack of visibility played a role in the largest downfalls of Mt. Gox, Cryptsy, and Bitgrail. In some cases, platforms are alleged to have suffered a hack and keep operating without admitting it at all, such as CoinBene.
It surprises some to learn that a cryptographic solution has already existed since 2013, and gained widespread support in 2014 after Mt. Gox. Proof of Reserves is a full cryptographic proof that allows any customer using an exchange to have complete certainty that their crypto-assets are fully backed by the platform in real-time. This is accomplished by proving that assets exist on the blockchain, are spendable, and fully cover customer deposits. It does not prove safety of assets or backing of fiat assets.
If we didn't care about privacy at all, a platform could publish their wallet addresses, sign a partial transaction, and put the full list of customer information and balances out publicly. Customers can each check that they are on the list, that the balances are accurate, that the total adds up, and that it's backed and spendable on the blockchain. Platforms who exclude any customer take a risk because that customer can easily check and see they were excluded. So together with all customers checking, this forms a full proof of backing of all crypto assets.
However, obviously customers care about their private information being published. Therefore, a hash of the information can be provided instead. Hash is one-way encryption. The hash allows the customer to validate inclusion (by hashing their own known information), while anyone looking at the list of hashes cannot determine the private information of any other user. All other parts of the scheme remain fully intact. A model like this is in use on the exchange CoinFloor in the UK.
A Merkle tree can provide even greater privacy. Instead of a list of balances, the balances are arranged into a binary tree. A customer starts from their node, and works their way to the top of the tree. For example, they know they have 5 BTC, they plus 1 other customer hold 7 BTC, they plus 2-3 other customers hold 17 BTC, etc... until they reach the root where all the BTC are represented. Thus, there is no way to find the balances of other individual customers aside from one unidentified customer in this case.
Proposals such as this had the backing of leaders in the community including Nic Carter, Greg Maxwell, and Zak Wilcox. Substantial and significant effort started back in 2013, with massive popularity in 2014. But what became of that effort? Very little. Exchange operators continue to refuse to give visibility. Despite the fact this information can often be obtained through trivial blockchain analysis, no Canadian platform has ever provided any wallet addresses publicly. As described by the CEO of Newton "For us to implement some kind of realtime Proof of Reserves solution, which I'm not opposed to, it would have to ... Preserve our users' privacy, as well as our own. Some kind of zero-knowledge proof". Kraken describes here in more detail why they haven't implemented such a scheme. According to professor Eli Ben-Sasson, when he spoke with exchanges, none were interested in implementing Proof of Reserves.
And yet, Kraken's places their reasoning on a page called "Proof of Reserves". More recently, both BitBuy and ShakePay have released reports titled "Proof of Reserves and Security Audit". Both reports contain disclaimers against being audits. Both reports trust the customer list provided by the platform, leaving the open possibility that multiple large accounts could have been excluded from the process. Proof of Reserves is a blockchain validation where customers see the wallets on the blockchain. The report from Kraken is 5 years old, but they leave it described as though it was just done a few weeks ago. And look at what they expect customers to do for validation. When firms represent something being "Proof of Reserve" when it's not, this is like a farmer growing fruit with pesticides and selling it in a farmers market as organic produce - except that these are people's hard-earned life savings at risk here. Platforms are misrepresenting the level of visibility in place and deceiving the public by their misuse of this term. They haven't proven anything.
Fraud isn't a problem that is unique to cryptocurrency. Fraud happens all the time. Enron, WorldCom, Nortel, Bear Stearns, Wells Fargo, Moser Baer, Wirecard, Bre-X, and Nicola are just some of the cases where frauds became large enough to become a big deal (and there are so many countless others). These all happened on 100% reversible assets despite regulations being in place. In many of these cases, the problems happened due to the over-complexity of the financial instruments. For example, Enron had "complex financial statements [which] were confusing to shareholders and analysts", creating "off-balance-sheet vehicles, complex financing structures, and deals so bewildering that few people could understand them". In cryptocurrency, we are often combining complex financial products with complex technologies and verification processes. We are naïve if we think problems like this won't happen. It is awkward and uncomfortable for many people to admit that they don't know how something works. If we want "money of the people" to work, the solutions have to be simple enough that "the people" can understand them, not so confusing that financial professionals and technology experts struggle to use or understand them.
For those who question the extent to which an organization can fool their way into a security consultancy role, HB Gary should be a great example to look at. Prior to trying to out anonymous, HB Gary was being actively hired by multiple US government agencies and others in the private sector (with glowing testimonials). The published articles and hosted professional security conferences. One should also look at this list of data breaches from the past 2 years. Many of them are large corporations, government entities, and technology companies. These are the ones we know about. Undoubtedly, there are many more that we do not know about. If HB Gary hadn't been "outted" by anonymous, would we have known they were insecure? If the same breach had happened outside of the public spotlight, would it even have been reported? Or would HB Gary have just deleted the Twitter posts, brought their site back up, done a couple patches, and kept on operating as though nothing had happened?
In the case of Quadriga, the facts are clear. Despite past experience with platforms such as MapleChange in Canada and others around the world, no guidance or even the most basic of a framework was put in place by regulators. By not clarifying any sort of legal framework, regulators enabled a situation where a platform could be run by former criminal Mike Dhanini/Omar Patryn, and where funds could be held fully unchecked by one person. At the same time, the lack of regulation deterred legitimate entities from running competing platforms and Quadriga was granted a money services business license for multiple years of operation, which gave the firm the appearance of legitimacy. Regulators did little to protect Canadians despite Quadriga failing to file taxes from 2016 onward. The entire administrative team had resigned and this was public knowledge. Many people had suspicions of what was going on, including Ryan Mueller, who forwarded complaints to the authorities. These were ignored, giving Gerald Cotten the opportunity to escape without justice.
There are multiple issues with the SOC II model including the prohibitive cost (you have to find a third party accounting firm and the prices are not even listed publicly on any sites), the requirement of operating for a year (impossible for new platforms), and lack of any public visibility (SOC II are private reports that aren't shared outside the people in suits).
Securities frameworks are expensive. Sarbanes-Oxley is estimated to cost $5.1 million USD/yr for the average Fortune 500 company in the United States. Since "Fortune 500" represents the top 500 companies, that means well over $2.55 billion USD (~$3.4 billion CAD) is going to people in suits. Isn't the problem of trust and verification the exact problem that the blockchain is supposed to solve?
To use Quadriga as justification for why custodians or SOC II or other advanced schemes are needed for platforms is rather silly, when any framework or visibility at all, or even the most basic of storage policies, would have prevented the whole thing. It's just an embarrassment.
We are now seeing regulators take strong action. CoinSquare in Canada with multi-million dollar fines. BitMex from the US, criminal charges and arrests. OkEx, with full disregard of withdrawals and no communication. Who's next?
We have a unique window today where we can solve these problems, and not permanently destroy innovation with unreasonable expectations, but we need to act quickly. This is a unique historic time that will never come again.
How DAO users can truly control their voting rights
https://blockchaintopbuzz.medium.com/how-dao-users-can-truly-control-their-voting-rights-f945c9c6b65e Aelf proposed a solution that gives the control of the voting rights back to users by classifying token permissions. As of today, there are still few complete businesses. In addition to mining and building trading platforms, it is difficult to create a complete business model. Moreover, various trading platforms have gradually grown into enterprises with comprehensive products in the blockchain industry, including wallets, nodes, lending, mining pools, etc. At the same time, cloud services can reduce the cost of building small exchanges, but they can also lead to big trading platforms monopolizing data. For example, some Internet companies provide free cloud services in order to collect more valuable data. Currently, Ethereum, which has the richest DeFi ecosystem, is gradually upgrading to V2.0, and its consensus protocol will also be upgraded to PoS. Governance voting can be regarded as the most important feature in the PoS ecosystem. This year, Yearn.Finance rose to sudden prominence. But due to the governance problem, its community members initiated a hard fork, resulting in YFII. Another DeFi project, YAM, had a unfixable rebase function error. The founding team apologized for the error and announced a ‘Migration Plan’, which will turn the project over to the community. For a while, governance voting became all the rage. However, the increasingly bigger trading platforms have been criticized by users in governance voting. Is there a proper solution to handling the relationship between the trading platform and governance voting?
What will we lose when trading platforms monopolize the blockchain industry?
In June 2018, during the BP node election before the EOS mainnet launch, node voting began to have a crisis of confidence between token holders and the trading platform. it is widely believed that the top 20 holders of trading platform wallets held about 40% of all the EOS in circulation. Since then, many trading platforms have enabled the “User Authorization” interface. EOS holders can authorize the token voting rights to the trading platform, who will vote on behalf of the users. The rule caused a backlash from users, forcing these trading platforms to change the rule immediately so that EOS holders could vote on their preferred BP nodes. After the EOS BP node votes, whether the trading platform has the token voting right has been occasionally discussed, but fewhave noticed it. Two years later, Justin Sun, founder of TRON, made a commercial acquisition of Steemit, a decentralized social networking platform. After the acquisition was announced, the Steemit community launched a soft fork to resist the project being controlled by TRON. However, Justin Sun voted with the support of trading platforms such as Binance, Huobi and Poloniex to prevent a soft fork. After being questioned by users, Binance and Huobi said that they would no longer interfere in the voting of the Steemit community. However, hkdev 404 of the Steem community again reveived votes from Huobi accounts. It is said that nearly 40 million votes were cast during the incident, accounting for about 10% of the total circulation of STEEM tokens. There is no doubt that when the trading platform monopolizes the industry, we will lose our voting right. How do we defend our voting rights The fact that the ownership of the tokens belongs to the holders is indisputable, but what about the voting rights of the tokens deposited on the trading platform? How can we defend our voting rights after trading platforms have monopolized the industry?
Trading Platform Model
Traditional centralized trading platforms will assign to each user a separate deposit address. After depositing, the depositedamount will be added into the cold wallet and hot wallet. When users want to withdraw their tokens, the trading platform will transfer the tokens out of the hot wallet. If there is insufficient balance in the hot wallet, then the tokens will be transferred from the cold wallet to the hot wallet, and then be withdrawn. Under the traditional centralized trading platform model, once users transfer their tokens into a trading platform, it means thetoken ownership (including voting rights) is also transferred to that trading platform. The aelf solution: classify token permissions and claim back voting rights For the issue of “voting rights” between token holders and centralized trading platforms, aelf, a decentralized cloud computing blockchain network, has proposed a solution: to establish an aelf Centre Asset Management Contract on the chain. The contract can limit the funds entering the exchange and define different permissions to control the assets. The main feature of the aelf Centre Asset Management Contract is to create the “Main Virtual Address of the Trading Platform”. Each exchange has a main virtual address, which can only be used for transfer operation, but not for voting, trading and other operations. As a result, the exchange cannot misappropriate users’ assets for voting. At the same time, the assets of the primary virtual address are publicly available on the chain, which makes it more difficult for the exchange to misappropriate assets. At the same time, the aelf Centre Asset Management Contract also has the function of “address definition”. The exchange can open different permissions to different addresses, such as opening different permissions according to the amount, transactions exceeding a certain amount can only be given the greenlight by using multiple signatures, and the assets can be frozen through the contract when the assets of the trading platform are stolen, etc. For the users of the trading platform, the access of the trading platform to the aelf Center Asset Management Contract function will not undermine user experience. The virtual system address of the aelf Center Asset Management Contract will assign a virtual address to each user, which offers the same user experience as the traditional mode. For the trading platform, each deposit address constructed by the virtual address system is generated by the algorithm and does not need to be carried out on the blockchain. This means that the trading platform does not need to manage a large number of private keys, and there is no risk that the private keys will be lost. On the most important “voting rights” issue, the aelf Center Asset Management Contract will assign to each user a separate virtual address for voting: Voting address = Hash (Exchange Main Address + Token + “VOTE”) Voting process: the tokens are transferred from the main virtual address of the exchange to the special “voting address” for voting, and are then voted. After voting, the tokens are withdrawn from the voting address back to the main virtual address. We can see that the aelf Centre Asset Management Contract proposed by aelf can improve the efficiency of the trading platform without affecting user experience. In addition, it solves the problem that users would lose their voting rights. According to the data on Crypto Mode, the market value of PoS tokens has exceeded $33 billion without counting Ethereum. In the field of crypto, it is the biggest ecosystem next to Bitcoin. The most important function of PoS is vote staking. faced with bigtrading platforms, if the status quo continues, retail investors will gradually lose their “voting rights” that belong to them. Comparison of Market Value of PoS tokens (Source: Crypto Mode) The emergence of DAO offers an alternative to trading platforms who misappropriate users’ tokens, but it still can not change this situation. Of course, DAO will not die out. Small communities will still use DAO for community governance. The idea behind the design of aelf is to start from the underlying trading platform and solve this issue at the source. Whether the solution can work still takes time. However, as a member of the crypto industry, we should understand the importance of “voting rights”, and cannot allow the exchange to seize our rights at will. Recently, aelf has also announced its DeFi plan, which includes a new blockchain 3.0 project with a large number of new technical features, such as cross chain function, virtual address and cloud services. Aelf also proposed a set of interoperability solutions with ERC-20 tokens. It can directly access the ETH ecosystem, allow ETH-based applications and wallets to directly access it, and maintain the interoperability with ETH. And aelf will provide a high-performance smart contract operation platform and cloud services that can support cross chain interaction. Users on major cloud servers can easily run aelf’s services and adjust the scale of cloud according to their own business needs. The implementation of a slew of tools, cloud services and interoperability solutions developed by aelf means that centralized transactions can be directly connected to the aelf network, realizing one-click adaptation to the DeFi ecosystem. With aelf, CeFi and DeFi are able to learn from and complement each other.
Here is how to play the altcoin game - for newbies & champs
I have been here for many previous altcoin seasons (2013,2017 etc) and wanted to share knowedle. It's a LOOONG article. The evaluation of altcoins (i.e not Bitcoin) is one of the most difficult and profitable exercises. Here I will outline my methodology and thinking but we have to take some things as a given. The first is that the whole market is going up or down with forces that we can't predict or control. Bitcoin is correlated with economic environments, money supply increases, safe havens such as Gold, hype and country regulations. This is an impossible mix to analyze and almost everyone fails at it. That's why you see people valuing Bitcoin from $100 to $500k frequently. Although I am bullish on the prospects of Bitcoin and decentralization and smart contract platforms, this is not the game I will be describing. I am talking about a game where you try to maximize your BTC holdings by investing in altcoins. We win this game even if we are at a loss in fiat currency value. To put it another way:
If you are not bullish in general on cryptocurrencies you have no place in investing or trading cryptocurrencies since it's always a losing proposition to trade in bubbles, a scientifically proven fact. If on the other hand you are then your goal is to grow your portfolio more than you would if holding BTC/ETH for example.
Bitcoin is the big boy
How the market works is not easily identifiable if you haven't graduated from the 2017 crypto university. When there is a bull market everything seems amazingly profitable and things keep going up outgrowing Bitcoin by orders of magnitude and you are a genius. The problem with this is that it only works while Bitcoin is going up a little bit or trades sideways. When it decides to move big then altcoins lose value both on the way up and on the way down. The second part is obvious and proven since all altcoins from 2017 are at a fraction of their BTC value (usually in the range of 80% or more down). Also, when BTC is making a big move upwards everyone exits altcoins to ride the wave. It is possible that the altcoin market behaves as an inversed leveraged ETF with leakage where in a certain period while Bitcoin starts at 10k and ends at 10k for example, altcoins have lost a lot of value because of the above things happening.
We are doing it anyway champ!
OK so we understand the risks and just wanna gambol with our money right? I get it. Why do that? Because finding the ideal scenario and period can be extremely profitable. In 2017 several altcoins went up 40x more than BTC. But again, if you don't chose wisely many of them have gone back to zero (the author has first hand experience in this!), they have been delisted and nobody remembers them. The actual mentality to have is very important and resembles poker and other speculative games: A certain altcoin can go up in value indefinitely but can only lose it's starting investment. Think about it. You either lose 1 metric or gain many many more. Now that sounds amazing but firstly as we said we have the goal to outperform our benchmark (BTC) and secondly that going up in value a lot means that the probability is quite low. There is this notion of Expected Value (EV) that poker players apply in these kind of situations and it goes like that. If you think that a certain coin has a probability let's say 10% to go up 10X and 90% probability it goes to zero it's an even bet. If you think that probability is 11% then it's a good bet, a profitable bet and you should take it. You get the point right? It's not that it can only go 10X or 0X, there is a whole range of probability outcomes that are too mathematical to explain here and it doesn't help so much because nobody can do such analysis with altcoins. See below on how we can approximate it.
How to evaluate altcoins
A range of different things to take into account outlined below will form our decision making. Not a single one of them should dictate 100% of our strategy.
It's all about market cap. Repeat after me. The price of a coin doesn't mean anything. Say it 10 times until you believe it. I can't remember how many times I had conversations with people that were comparing coins using their coin price instead of their market cap. To make this easy to get.
If I decide because the sky is blue to make my coin supply 100 Trillion FoolCoins with a price of $0.001 and there is another WiseCoin with a supply of 100 Million and price of $1 then FoolCoins are more expensive. - Alex Fin's Cap Law
This is done usually in the stock world and it means that each company has some fundamental value that includes it's assets, customers, growth prospects, sector prospects and leadership competence but mostly centered in financial measures such as P/E ratios etc. Valuation is a proper economic discipline by itself taught in universities. OK, now throw everything out of the window!. This kind of analysis is impossible in vague concepts and innovations that are currently cryptocurrencies. Ethereum was frequently priced at the fictional price of gas when all financial systems on earth run on the platform after decades (a bit of exaggeration here). No project is currently profitable enough to justify a valuation multiple that is usually equal to P/E in the thousands or more. As such we need to take other things into account. What I do is included in the list below:
Check Github. You need to make sure there is active development for the platform and it's a very bad sign if the project is either keeping the code closed source or even worse there is simply no development. No projects are "complete".
Check Website. If the website is written in bad English the Chinese google translate type it means that they are not serious enough to produce an unbreakable decentralized project. If you can't write English you can't change the world, period. That's a deal breaker.
Check Team's Linkedin. Numerous projects have either fake Linkedin accounts or the team is comprised mainly by unexperienced employees that are even shown to be working in other companies currently.
Check backers. Projects that have Binance, Coinbase or Silicon Valley VC funds backing them are way more legit but way more overpriced too!
One of my favorite ways to value altcoins that is based on the same principle in the stock market is to look at peers and decide what is the maximum cap it can grow to. As an example you take a second layer Ethereum solution that has an ICO and you want to decide if you will enter or not. You can take a look at other coins that are in the same business and compare their market caps. Thinking that your coin will outperform by a lot the top coins currently is overly optimistic so I usually take a lower valuation as a target price. If the initial offering is directly implying a valuation that is more than that then there is no room to grow according to my analysis and I skip it. Many times this has proven me wrong because it's a game theory problem where if many people think irrationally in a market it becomes a self-fulfilling prophecy. But since there is opportunity cost involved, in the long run, getting in initial offerings that have a lot of room to grow will pay off as a strategy.
In 2017 the sexiest sector was platforms and then coins including privacy ones. Platforms are obviously still a highly rated sector because everything is being built on them, but privacy is not as hot as it used to be. In 2018 DEXes were all they hype but still people are massively using centralized exchanges. In 2020 Defi is the hottest sector and it includes platforms, oracles and Defi projects. What I am saying is that a project gets extra points if it's a Defi one in 2020 and minus points if it's a payment system that will conquer the world as it was in 2017 because that's old news. This is closely related to the next section.
Needless to say that the crypto market is a worse FOMO type of inexperienced trigger happy yolo investors , much worse than the Robinhood crowd that drove a bankrupt company's stock 1200% after they declared bankruptcy. The result is that there are numerous projects that are basically either vaporware or just so overhyped that their valuation has no connection to reality. Should we avoid those kind of projects? No and I will explain why. There are many very good technically projects that had zero hype potential due to incompetent marketing departments that made them tank. An example (without shilling because I sold out a while back) is Quantum Resistant Ledger. This project has amazing quantum resistant blockchain, the only one running now, has a platform that people can build tokens and messaging systems and other magnificent stuff. Just check how they fared up to now and you will get the point. A project *needs* to have a hype factor because you cannot judge it as normal stocks that you can do value investing like Warren Buffet does where a company will inevitable post sales and profitability numbers and investors will get dividends. Actually the last sentence is the most important: No dividends. Even projects that give you tokens or coins as dividends are not real dividends because if the coin tanks the value of the dividend tanks. This is NOT the case with company stocks where you get dollars even if the company stock tanks. All that being said, I would advice against betting on projects that have a lot of hype but little substance (but that should be obvious!).
How to construct your portfolio
My strategy and philosophy in investing is that risk should be proportional to investment capital. That means that if you are investing 100K in the crypto market your portfolio should be very different than someone investing 1K because 10% annual gains are nothing in the latter while they are very significant in the former. Starting from this principle each individual needs to construct a portfolio according to how much risk he wants to take. I will emphasize two important concepts that play well with what I said. In the first instance of a big portfolio you should concentrate on this mantra: "Diversification is the only free meal in finance". In the case of a small portfolio then this mantra is more important: "Concentrate to create wealth, diversify to maintain wealth". Usually in a big portfolio you would want to hold some big coins such as BTC and ETH to weather the ups and downs explained in previous paragraphs while generating profits and keep progressively smaller parts of your portfolio for riskier investments. Maybe 50% of this portfolio could be big caps and 10% very risky initial offerings. Adapting risk progressively to smaller portfolios makes sense but I think it would be irrational to keep more than 30% of a portfolio no matter what tied to one coin due to the very high risk of bankruptcy.
The altseason is supposedly coming every 3 months. Truth is that nobody can predict it but altcoins can be profitable no matter what. Forget about maximalists who are stuck in their dogmas. Altcoins deliver different value propositions and it makes sense because we are very far from a situation where some project offers everything like Amazon and we wouldn't even want that in the first place since we are talking about decentralization and not a winner takes all and becomes a monster kind of scenario! Some last minute advice:
Stay out of paid telegram/discord pump groups. They are deadly for your wallet.
Avoid jumping on overhyped coins that have pumped massively during the last days without any very important news.
Don't keep coins in obscure exchanges for too long or you will get burned with certainty.
Stop thinking that your coin will 1000x and overtake Bitcoin!
P.S If you find value in reading this and want more weekly consider subscribing to my newsletterhere
It is no doubt Grayscale’s booming popularity as a mainstream investment has caused a lot of community hullabaloo lately. As such, I felt it was worth making a FAQ regarding the topic. I’m looking to update this as needed and of course am open to suggestions / adding any questions. The goal is simply to have a thread we can link to anyone with questions on Grayscaleand its products. Instead of explaining the same thing 3 times a day, shoot those posters over to this thread.My hope is that these questions are answered in a fairly simple and easy to understand manner. I think as the sub grows it will be a nice reference point for newcomers. Disclaimer: I do NOT work for Grayscale and as such am basing all these answers on information that can be found on their website / reports. (Grayscale’s official FAQ can be found here). I also do NOT have a finance degree, I do NOT have a Series 6 / 7 / 140-whatever, and I do NOT work with investment products for my day job. I have an accounting background and work within the finance world so I have the general ‘business’ knowledge to put it all together, but this is all info determined in my best faith effort as a layman. The point being is this --- it is possible I may explain something wrong or missed the technical terms, and if that occurs I am more than happy to update anything that can be proven incorrect Everything below will be in reference to ETHE but will apply to GBTC as well.If those two segregate in any way, I will note that accordingly.
ETHE is essentially a stock that intends to loosely track the price of ETH. It does so by having each ETHE be backed by a specific amount of ETH that is held on chain. Initially, the newly minted ETHE can only be purchased by institutions and accredited investors directly from Grayscale. Once a year has passed (6 months for GBTC) it can then be listed on the OTCQX Best Market exchange for secondary trading. Once listed on OTCQX, anyone investor can purchase at this point. Additional information on ETHE can be found here.
So ETHE is an ETF?
No. For technical reasons beyond my personal understandings it is not labeled an ETF. I know it all flows back to the “Securities Act Rule 144”, but due to my limited knowledge on SEC regulations I don’t want to misspeak past that. If anyone is more knowledgeable on the subject I am happy to input their answer here.
How long has ETHE existed?
ETHE was formed 12/14/2017. GBTC was formed 9/25/2013.
How is ETHE created?
The trust will issue shares to “Authorized Participants” in groups of 100 shares (called baskets). Authorized Participants are the only persons that may place orders to create these baskets and they do it on behalf of the investor. Source: Creation and Redemption of Shares section on page 39 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here Note – The way their reports word this makes it sound like there is an army of authorizers doing the dirty work, but in reality there is only one Authorized Participant. At this moment the “Genesis” company is the sole Authorized Participant. Genesis is owned by the “Digital Currency Group, Inc.” which is the parent company of Grayscale as well. (And to really go down the rabbit hole it looks like DCG is the parent company of CoinDesk and is “backing 150+ companies across 30 countries, including Coinbase, Ripple, and Chainalysis.”) Source: Digital Currency Group, Inc. informational section on page 77 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here Source: Barry E. Silbert informational section on page 75 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here
How does Grayscale acquire the ETH to collateralize the ETHE product?
An Investor may acquire ETHE by paying in cash or exchanging ETH already owned.
Cash: The investor pays the subscription amount in cash and the Authorized Participant will use that cash to purchase ETH.
ETH: The investor transfers the ETH to the Authorized Participant, which will contribute the ETH in-kind to the Trust.
Source: Creation and Redemption of Shares section on page 40 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Where does Grayscale store their ETH? Does it have a specific wallet address we can follow?
ETH is stored with Coinbase Custody Trust Company, LLC. I am unaware of any specific address or set of addresses that can be used to verify the ETH is actually there. As an aside - I would actually love to see if anyone knows more about this as it’s something that’s sort of peaked my interest after being asked about it… I find it doubtful we can find that however. Source: Part C. Business Information, Item 8, subsection A. on page 16 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Can ETHE be redeemed for ETH?
No, currently there is no way to give your shares of ETHE back to Grayscale to receive ETH back. The only method of getting back into ETH would be to sell your ETHE to someone else and then use those proceeds to buy ETH yourself. Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Why are they not redeeming shares?
I think the report summarizes it best:
Redemptions of Shares are currently not permitted and the Trust is unable to redeem Shares. Subject to receipt of regulatory approval from the SEC and approval by the Sponsor in its sole discretion, the Trust may in the future operate a redemption program. Because the Trust does not believe that the SEC would, at this time, entertain an application for the waiver of rules needed in order to operate an ongoing redemption program, the Trust currently has no intention of seeking regulatory approval from the SEC to operate an ongoing redemption program.
Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the fee structure?
ETHE has an annual fee of 2.5%. GBTC has an annual fee of 2.0%. Fees are paid by selling the underlying ETH / BTC collateralizing the asset. Source: ETHE’s informational page on Grayscale’s website - Located Here Source: Description of Trust on page 31 & 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the ratio of ETH to ETHE?
At the time of posting (6/19/2020) each ETHE share is backed by .09391605 ETH. Each share of GBTC is backed by .00096038 BTC. ETHE & GBTC’s specific information page on Grayscale’s website updates the ratio daily – Located Here For a full historical look at this ratio, it can be found on the Grayscale home page on the upper right side if you go to Tax Documents > 2019 Tax Documents > Grayscale Ethereum Trust 2019 Tax Letter.
Why is the ratio not 1:1? Why is it always decreasing?
While I cannot say for certain why the initial distribution was not a 1:1 backing, it is more than likely to keep the price down and allow more investors a chance to purchase ETHE / GBTC. As noted above, fees are paid by selling off the ETH collateralizing ETHE. So this number will always be trending downward as time goes on. Source: Description of Trust on page 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
I keep hearing about how this is locked supply… explain?
As noted above, there is currently no redemption program for converting your ETHE back into ETH. This means that once an ETHE is issued, it will remain in circulation until a redemption program is formed --- something that doesn’t seem to be too urgent for the SEC or Grayscale at the moment. Tiny amounts will naturally be removed due to fees, but the bulk of the asset is in there for good. Knowing that ETHE cannot be taken back and destroyed at this time, the ETH collateralizing it will not be removed from the wallet for the foreseeable future. While it is not fully locked in the sense of say a totally lost key, it is not coming out any time soon. Per their annual statement:
The Trust’s ETH will be transferred out of the ETH Account only in the following circumstances: (i) transferred to pay the Sponsor’s Fee or any Additional Trust Expenses, (ii) distributed in connection with the redemption of Baskets (subject to the Trust’s obtaining regulatory approval from the SEC to operate an ongoing redemption program and the consent of the Sponsor), (iii) sold on an as-needed basis to pay Additional Trust Expenses or (iv) sold on behalf of the Trust in the event the Trust terminates and liquidates its assets or as otherwise required by law or regulation.
Source: Description of Trust on page 31 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Grayscale now owns a huge chunk of both ETH and BTC’s supply… should we be worried about manipulation, a sell off to crash the market crash, a staking cartel?
First, it’s important to remember Grayscale is a lot more akin to an exchange then say an investment firm. Grayscale is working on behalf of its investors to create this product for investor control. Grayscale doesn’t ‘control’ the ETH it holds any more then Coinbase ‘controls’ the ETH in its hot wallet. (Note: There are likely some varying levels of control, but specific to this topic Grayscale cannot simply sell [legally, at least] the ETH by their own decision in the same manner Coinbase wouldn't be able to either.) That said, there shouldn’t be any worry in the short to medium time-frame. As noted above, Grayscale can’t really remove ETH other than for fees or termination of the product. At 2.5% a year, fees are noise in terms of volume. Grayscale seems to be the fastest growing product in the crypto space at the moment and termination of the product seems unlikely. IF redemptions were to happen tomorrow, it’s extremely unlikely we would see a mass exodus out of the product to redeem for ETH. And even if there was incentive to get back to ETH, the premium makes it so that it would be much more cost effective to just sell your ETHE on the secondary market and buy ETH yourself. Remember, any redemption is up to the investors and NOT something Grayscale has direct control over.
Yes, but what about [insert criminal act here]…
Alright, yes. Technically nothing is stopping Grayscale from selling all the ETH / BTC and running off to the Bahamas (Hawaii?). BUT there is no real reason for them to do so. Barry is an extremely public figure and it won’t be easy for him to get away with that. Grayscale’s Bitcoin Trust creates SEC reports weekly / bi-weekly and I’m sure given the sentiment towards crypto is being watched carefully. Plus, Grayscale is making tons of consistent revenue and thus has little to no incentive to give that up for a quick buck.
That’s a lot of ‘happy little feels’ Bob, is there even an independent audit or is this Tether 2.0?
Actually yes, an independent auditor report can be found in their annual reports. It is clearly aimed more towards the financial side and I doubt the auditors are crypto savants, but it is at least one extra set of eyes. Auditors are Friedman LLP – Auditor since 2015. Source: Independent Auditor Report starting on page 116 (of the PDF itself) of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here As mentioned by user TheCrpytosAndBloods (In Comments Below), a fun fact:
The company’s auditors Friedman LLP were also coincidentally TetheBitfinex’s auditors until They controversially parted ways in 2018 when the Tether controversy was at its height. I am not suggesting for one moment that there is anything shady about DCG - I just find it interesting it’s the same auditor.
“Grayscale sounds kind of lame” / “Not your keys not your crypto!” / “Why is anyone buying this, it sounds like a scam?”
Welp, for starters this honestly is not really a product aimed at the people likely to be reading this post. To each their own, but do remember just because something provides no value to you doesn’t mean it can’t provide value to someone else. That said some of the advertised benefits are as follows:
Access to trading within a tax advantaged retirement account
Institutions can easily and safely get exposure to crypto in a more legal-friendly manner
Ease of use for those who are not very technologically savvy
Ease of access for someone who doesn’t want to set up a Coinbase account
Perceived trust in institutional platforms over something like Coinbase or Kraken
Degen traders who just want access to the volatility ETHE provides that have no interest in crypto beyond that
So for example, I can set up an IRA at a brokerage account that has $0 trading fees. Then I can trade GBTC and ETHE all day without having to worry about tracking my taxes. All with the relative safety something like E-Trade provides over Binance. As for how it benefits the everyday ETH holder? I think the supply lock is a positive. I also think this product exposes the Ethereum ecosystem to people who otherwise wouldn’t know about it.
Why is there a premium? Why is ETHE’s premium so insanely high compared to GBTC’s premium?
There are a handful of theories of why a premium exists at all, some even mentioned in the annual report. The short list is as follows:
ETHE is NOT redeeming shares and as such doesn’t have an effective arbitrage mechanism
ETHE has a 1 year wait to be sold on the secondary market, again negating the ability to effectively arbitrage the premium
People may simply be willing to pay a premium for the benefits stated above.
Why is ETHE’s so much higher the GBTC’s? Again, a few thoughts:
ETHE hasn’t been around as long, so there is less secondary market supply to go around
ETHE was listed at an insanely high premium to begin with
ETHE might simply be more popular at the moment
Could just be sheer stupidity (investors think ETHE is a 1:1 ratio not 1:11)
Are there any other differences between ETHE and GBTC?
I touched on a few of the smaller differences, but one of the more interesting changes is GBTC is now a “SEC reporting company” as of January 2020. Which again goes beyond my scope of knowledge so I won’t comment on it too much… but the net result is GBTC is now putting out weekly / bi-weekly 8-K’s and annual 10-K’s. This means you can track GBTC that much easier at the moment as well as there is an extra layer of validity to the product IMO.
I’m looking for some statistics on ETHE… such as who is buying, how much is bought, etc?
There is a great Q1 2020 report I recommend you give a read that has a lot of cool graphs and data on the product. It’s a little GBTC centric, but there is some ETHE data as well. It can be found here hidden within the 8-K filings.Q1 2020 is the 4/16/2020 8-K filing. For those more into a GAAP style report see the 2019 annual 10-K of the same location.
Is Grayscale only just for BTC and ETH?
No, there are other products as well. In terms of a secondary market product, ETCG is the Ethereum Classic version of ETHE. Fun Fact – ETCG was actually put out to the secondary market first. It also has a 3% fee tied to it where 1% of it goes to some type of ETC development fund. In terms of institutional and accredited investors, there are a few ‘fan favorites’ such as Bitcoin Cash, Litcoin, Stellar, XRP, and Zcash. Something called Horizion (Backed by ZEN I guess? Idk to be honest what that is…). And a diversified Mutual Fund type fund that has a little bit of all of those. None of these products are available on the secondary market.
Are there alternatives to Grayscale?
I know they exist, but I don’t follow them. I’ll leave this as a “to be edited” section and will add as others comment on what they know. Per user Over-analyser (in comments below):
As asked by pegcity - Okay so I was under the impression you can just give them your own ETH and get ETHE, but do you get 11 ETHE per ETH or do you get the market value of ETH in USD worth of ETHE?
I have always understood that the ETHE issued directly through Grayscale is issued without the premium. As in, if I were to trade 1 ETH for ETHE I would get 11, not say only 2 or 3 because the secondary market premium is so high. And if I were paying cash only I would be paying the price to buy 1 ETH to get my 11 ETHE. Per page 39 of their annual statement, it reads as follows:
The Trust will issue Shares to Authorized Participants from time to time, but only in one or more Baskets (with a Basket being a block of 100 Shares). The Trust will not issue fractions of a Basket. The creation (and, should the Trust commence a redemption program, redemption) of Baskets will be made only in exchange for the delivery to the Trust, or the distribution by the Trust, of the number of whole and fractional ETH represented by each Basket being created (or, should the Trust commence a redemption program, redeemed), which is determined by dividing (x) the number of ETH owned by the Trust at 4:00 p.m., New York time, on the trade date of a creation or redemption order, after deducting the number of ETH representing the U.S. dollar value of accrued but unpaid fees and expenses of the Trust (converted using the ETH Index Price at such time, and carried to the eighth decimal place), by (y) the number of Shares outstanding at such time (with the quotient so obtained calculated to one one-hundred-millionth of one ETH (i.e., carried to the eighth decimal place)), and multiplying such quotient by 100 (the “Basket ETH Amount”). All questions as to the calculation of the Basket ETH Amount will be conclusively determined by the Sponsor and will be final and binding on all persons interested in the Trust. The Basket ETH Amount multiplied by the number of Baskets being created or redeemed is the “Total Basket ETH Amount.” The number of ETH represented by a Share will gradually decrease over time as the Trust’s ETH are used to pay the Trust’s expenses. Each Share represented approximately 0.0950 ETH and 0.0974 ETH as of December 31, 2019 and 2018, respectively.
The next XVG? Microcap 100x potential actually supported by fundamentals!
What’s up team? I have a hot one for you. XVG returned 12 million percent in 2017 and this one reminds me a lot of it. Here’s why: Mimblewimble is like Blu-Ray compared to CD-ROM in terms of its ability to compress data on a blockchain. The current BTC chain is 277gb and its capacity is limited because every time you spend a coin, each node needs to validate its history back to when it was mined (this is how double spending is prevented). Mimblewimble is different - all transactions in a block are aggregated and netted out in one giant CoinJoin, and only the current spending needs to be verified. This means that dramatically more transactions can fit into a smaller space, increasing throughput and lowering fees while still retaining the full proof of work game theory of Bitcoin. These blockchains are small enough to run a full node on a cheap smartphone, which enhances the decentralization and censorship resistance of the network. The biggest benefit, though, is that all transactions are private - the blockchain doesn’t reveal amounts or addresses except to the actual wallet owner. Unlike earlier decoy-based approaches that bloat the chain and can still be data mined (XMR), Mimblewimble leaves no trace in the blockchain, instead storing only the present state of coin ownership. The first two Mimblewimble coins, Grin and Beam, launched to great fanfare in 2019, quickly reaching over $100m in market cap (since settled down to $22m and $26m respectively). They are good projects but grin has infinite supply and huge never-decreasing emission, and Beam is a corporate moneygrab whose founding investors are counting on you buying for their ROI. ZEC is valued at $568m today, despite the facts that only 1% of transactions are actually shielded, it has a trusted setup, and generating a confidential transaction takes ~60 seconds on a powerful PC. XMR is a great project but it’s valued at $1.2b (so no 100x) and it uses CryptoNote, which is 2014 tech that relies on a decoy-based approach that could be vulnerable to more powerful computers in the future. Mimblewimble is just a better way to approach privacy because there is simply no data recorded in the blockchain for companies to surveil. Privacy is not just for darknet markets, porn, money launderers and terrorists. In many countries it’s dangerous to be wealthy, and there are all kinds of problems with having your spending data be out there publicly and permanently for all to see. Namely, companies like Amazon are patenting approaches to identify people with their crypto addresses, “for law enforcement” but also so that, just like credit cards, your spending data can be used to target ads. (A) Coinbase is selling user data to the DEA, IRS, FBI, Secret Service, and who knows who else? (B) What about insurance companies raising your premiums or canceling your policy because they see you buying (legal) cannabis? If your business operates using transparent cryptocurrency, competitors can data mine your customer and supply chain data, and employees can see how much everyone else gets paid. I could go on, but the idea of “I have nothing to hide, so what do I care about privacy?” will increasingly ring hollow as people realize that this money printing will have to be paid by massive tax increases AND that those taxes will be directly debited from their “Central Bank Digital Currency” wallets. 100% privacy for all transactions also eliminates one HUGE problem that people aren’t aware of yet, but they will be: fungibility. Fungibility means that each coin is indistinguishable from any other, just like paper cash. Why is this important? Because of the ever-expanding reach of AML/KYC/KYT (Anti-Money Laundering / Know Your Customer / Know Your Transaction) as regulators cramp down on crypto and banks take over, increasingly coins become “tainted” in various ways. For example, if you withdraw coins to a mixing service like Wasabi or Samourai, you may find your account blocked. (C) The next obvious step is that if you receive coins that these chainalysis services don’t like for whatever reason, you will be completely innocent yet forced to prove that you didn’t know that the coins you bought were up to no good in a past life. 3 days ago, $100k of USDC was frozen. (D) Even smaller coins like LTC now have this problem, because “Chinese Drug Kingpins” used them. (E) I believe that censorable money that can be blocked/frozen isn’t really “your money”. Epic Cash is a 100% volunteer community project (like XVG and XMR) that had a fair launch in September last year with no ICO and no premine. There are very few projects like this, and it’s a key ingredient in Verge’s success (still at $110m market cap today despite being down 97% since the bubble peak) and why it’s still around. It has a small but super passionate community of “Freemen” who are united by a belief in the sound money economics of Bitcoin Standard emission (21m supply limit and ever-decreasing inflation) and the importance of privacy. I am super bullish on this coin for the following reasons:
Only $400k market cap
Supply started at zero, so there are no VC’s and team to dump on you into the pumps - all coins are mined into existence, just like Bitcoin.
It just had its first halving, reducing emission from 16 to 8 per block. Between now and 2028 there are FOUR (!) more halvings, from 4 to 2 to 1 and then finally 0.15 (I guess that would be an 85%-ing :p) and at this point the supply is the same as BTC and stays in sync forever until the last coin is mined in 2140. This simple supply curve is already accepted by the market as a winner, so why mess with success? (I)
Meets Andreas Antonopolous’ 5 pillars of open blockchains test: Public, Open, Borderless, Neutral, and Censorship Resistant. (How many coins can say this?)
Unlike Bitcoin, Epic created a multi-algorithm approach that enables people to mine on ordinary computers - 60% for CPU on RandomX, 38% for GPU on ProgPow, and 2% for ASIC’s on Cuckoo31+. The algorithms don’t compete with one another. This is essential for leveling the playing field and preventing massive farms from dominating. These percentages can change over time and new algorithms can be easily dropped in. You can mine today using an old laptop and in 5 years you will still be able to. Incidentally, there is nothing standing in the way of adding mobile phone-based mining, which ETN showed there’s a huge demand for.
Based off the excellent Grin codebase, which means they continue to pull in ongoing core code enhancements and focus on ease of use and market penetration instead. (Smart!)
Litecoin’s Charlie Lee is out there daily talking about their move to Mimblewimble, which provides free publicity. What people don’t realize is that you can’t just bolt on Mimblewimble to a legacy blockchain, that’s like putting a Ferrari engine into a school bus - it’s still a school bus, not a race car! LTC is doing it as an optional soft fork via “extension blocks” which will not be supported by all wallets and exchanges. Also, anyone using “optional” privacy features is declaring themselves to be suspicious, which kind of defeats the point for people who care about privacy.
The community is friendly and welcoming to new people coming in, with lots of helpful (independently created) tutorials and guides. (F)
It’s already a global phenomenon, with the whitepaper in 20+ languages (G) and (not bot-infested) active local-language communities on not only Telegram but also Wechat, LINE, QQ and other messenger platforms.
It’s only on two random little exchanges currently, Citex and Vitex. Vitex is actually a pretty good DEX with no KYC and a great mobile wallet.
They are very creative - since centralized exchanges want huge money to list, they created a non-inflationary ERC20 tracker token that’s exchangeable 1:1 for coins so that Uniswap trading is possible (H)
Because it doesn’t have a huge marketing budget in a sea of VC-funded shitcoins, it is as-yet undiscovered, which is why it’s so cheap. There are only 4 Mimblewimble-based currencies on the market: MWC at $162m, BEAM at $26m, GRIN at $22m, and EPIC at $0.4m. This is not financial advice and as always, do your own research, but I’ve been buying this gem for months and will continue to. This one ticks all the boxes for me, the only real problem is that it’s hard to buy much without causing a huge green candle. Alt season is coming, and coins like this are how your neighbor Chad got his Lambo back in 2017. For 2021, McLaren is a better choice and be sure to pay cash so that it doesn’t get repossessed like Chad!
While no exchange is perfect and they all have their faults, the amount of bullsh!t from Coinbase has become too much to bare.
Blatant spoofing on nearly every coin, daily, which they happily allow
Really bad UI/UX design, like a 10yr old designed it
Crappy trading tools for retail traders
Constant bugs they don't bother fixing such as the 'max fill zero' bug for limit buy and sell orders which can potentially cost traders money when market is hot
Goes down every time bitcoin pumps
Undoubtedly the most dog sh!t crypto app I've ever seen in all of crypto universe
Undoubtedly the most sh!t support of any US exchange
Highest fees of any US exchange
Moved everything to Bittrex, Binance US and Kraken. Volume and liquidity doesn't match Coinbase, but I've adjusted my trading strategy to make it work. Bye bye Coinbase. Also submitted a report to the SEC over the major spoofing problems. If you want change, you have to take action. :) https://www.sec.gov/oiea/Complaint.html #DeleteCoinbase
How To End The Cryptocurrency Exchange "Wild West" Without Crippling Innovation
In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems: • Funds stored online or in a smart contract, • Access controlled by one person or one system, • 51% attacks (rare), • Funds sent to the wrong address (also rare), or • Some combination of the above. For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program. The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms. • 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective. • The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated. The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II. On The Subject of Third Party Custodians Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems. However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies. There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both. On The Subject Of Insurance ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC. However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.” ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance. In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework. A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians. On The Subject of Fractional Reserve There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds. There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past. Proof of Reserves/Transparency/Accountability Canadians need to have visibility into the backing on an ongoing basis. The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users. Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit. The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided. Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense. Hot Wallet Management The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets. However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process. A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage. Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage. (a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet. (b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time). (c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. (d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds. (e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers. (2) Regular and transparent solvency audits. (a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row. (b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored. (c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process. (d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify. (e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible. (3) Protections for hot wallets and transactions. (a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets. (b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy. (c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage. (d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange. (e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized. The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges. The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
The power players of consumer finance in the 21st century will be crypto-native companies who build with blockchain technology at their core.
The crypto landscape is still nascent. We’re still very much in the fragmented, unbundled phase of the industry lifecycle. Beyond what Genesis Block is doing, there are signs of other companies slowly starting to bundle financial services into what could be an all-in-one bank replacement. So the key question that this series hopes to answer:
Which crypto-native company will successfully become the bank of the future?
We obviously think Genesis Block is well-positioned to win. But we certainly aren’t the only game in town. In this series, we’ll be doing an analysis of who is most capable of thwarting our efforts. We’ll look at categories like crypto exchanges, crypto wallets, centralized lending & borrowing services, and crypto debit card companies. Each category will have its own dedicated post. Today we’re analyzing big crypto exchanges. The two companies we’ll focus on today are Coinbase (biggest American exchange) and Binance (biggest global exchange). They are the top two exchanges in terms of Bitcoin trading volume. They are in pole position to winning this market — they have a huge existing userbase and strong financial resources. Will Coinbase or Binance become the bank of the future? Can their early success propel them to winning the broader consumer finance market? Is their growth too far ahead for anyone else to catch up? Let’s dive in. https://preview.redd.it/lau4hevpm7f51.png?width=800&format=png&auto=webp&s=2c5de1ba497199f36aa194e5809bd86e5ab533d8
The most formidable exchange on the global stage is Binance (Crunchbase). All signs suggest they have significantly more users and a stronger balance sheet than Coinbase. No other exchange is executing as aggressively and relentlessly as Binance is. The cadence at which they are shipping and launching new products is nothing short of impressive. As Tushar Jain from Multicoin argues, Binance is Blitzscaling. Here are some of the products that they’ve launched in the last 18 months. Only a few are announced but still pre-launch.
Binance is well-positioned to become the crypto-powered, all-in-one, bundled solution for financial services. They already have so many of the pieces. But the key question is:
Can they create a cohesive & united product experience?
Binance is strong, but they do have a few major weaknesses that could slow them down.
Traders & Speculators Binance is currently very geared for speculators, traders, and financial professionals. Their bread-and-butter is trading (spot, margin, options, futures). Their UI is littered with depth charts, order books, candlesticks, and other financial concepts that are beyond the reach of most normal consumers. Their product today is not at all tailored for the broader consumer market. Given Binance’s popularity and strength among the pro audience, it’s unlikely that they will dumb down or simplify their product any time soon. That would jeopardize their core business. Binance will likely need an entirely new product/brand to go beyond the pro user crowd. That will take time (or an acquisition). So the question remains, is Binance even interested in the broader consumer market? Or will they continue to focus on their core product, the one-stop-shop for pro crypto traders?
Controversies & Hot Water Binance has had a number of controversies. No one seems to know where they are based — so what regulatory agencies can hold them accountable? Last year, some sensitive, private user data got leaked. When they announced their debit card program, they had to remove mentions of Visa quickly after. And though the “police raid” story proved to be untrue, there are still a lot of questions about what happened with their Shanghai office shut down (where there is smoke, there is fire). If any company has had a “move fast and break things” attitude, it is Binance. That attitude has served them well so far but as they try to do business in more regulated countries like America, this will make their road much more difficult — especially in the consumer market where trust takes a long time to earn, but can be destroyed in an instant. This is perhaps why the Binance US product is an empty shell when compared to their main global product.
Disjointed Product Experience Because Binance has so many different teams launching so many different services, their core product is increasingly feeling disjointed and disconnected. Many of the new features are sloppily integrated with each other. There’s no cohesive product experience. This is one of the downsides of executing and shipping at their relentless pace. For example, users don’t have a single wallet that shows their balances. Depending on if the user wants to do spot trading, margin, futures, or savings… the user needs to constantly be transferring their assets from one wallet to another. It’s not a unified, frictionless, simple user experience. This is one major downside of the “move fast and break things” approach.
BNB token Binance raised $15M in a 2017 ICO by selling their $BNB token. The current market cap of $BNB is worth more than $2.6B. Financially this token has served them well. However, given how BNB works (for example, their token burn), there are a lot of open questions as to how BNB will be treated with US security laws. Their Binance US product so far is treading very lightly with its use of BNB. Their token could become a liability for Binance as it enters more regulated markets. Whether the crypto community likes it or not, until regulators get caught up and understand the power of decentralized technology, tokens will still be a regulatory burden — especially for anything that touches consumers.
Binance Chain & Smart Contract Platform Binance is launching its own smart contract platform soon. Based on compatibility choices, they have their sights aimed at the Ethereum developer community. It’s unclear how easy it’ll be to convince developers to move to Binance chain. Most of the current developer energy and momentum around smart contracts is with Ethereum. Because Binance now has their own horse in the race, it’s unlikely they will ever decide to leverage Ethereum’s DeFi protocols. This could likely be a major strategic mistake — and hubris that goes a step too far. Binance will be pushing and promoting protocols on their own platform. The major risk of being all-in on their own platform is that they miss having a seat on the Ethereum rocket ship — specifically the growth of DeFi use-cases and the enormous value that can be unlocked. Integrating with Ethereum’s protocols would be either admitting defeat of their own platform or competing directly against themselves.
The crypto-native company that I believe is more likely to become the bank of the future is Coinbase (crunchbase). Their dominance in America could serve as a springboard to winning the West (Binance has a stronger foothold in Asia). Coinbase has more than 30M users. Their exchange business is a money-printing machine. They have a solid reputation as it relates to compliance and working with regulators. Their CEO is a longtime member of the crypto community. They are rumored to be going public soon.
Let’s look at what makes them strong and a likely contender for winning the broader consumer finance market.
Different Audience, Different Experience Coinbase has been smart to create a unique product experience for each audience — the pro speculator crowd and the common retail user. Their simple consumer version is at Coinbase.com. That’s the default. Their product for the more sophisticated traders and speculators is at Coinbase Pro (formerly GDAX). Unlike Binance, Coinbase can slowly build out the bank of the future for the broad consumer market while still having a home for their hardcore crypto traders. They aren’t afraid to have different experiences for different audiences.
Brand & Design Coinbase has a strong product design team. Their brand is capable of going beyond the male-dominated crypto audience. Their product is clean and simple — much more consumer-friendly than Binance. It’s clear they spend a lot of time thinking about their user experience. Interacting directly with crypto can sometimes be rough and raw (especially for n00bs). When I was at Mainframe we hosted a panel about Crypto UX challenges at the DevCon4 Dapp Awards. Connie Yang (Head of Design at Coinbase) was on the panel. She was impressive. Some of their design philosophies will bode well as they push to reach the broader consumer finance market.
Early Signs of Bundling Though Coinbase has nowhere near as many products & services as Binance, they are slowly starting to add more financial services that may appeal to the broader market. They are now letting depositors earn interest on USDC (also DAI & Tezos). In the UK they are piloting a debit card. Users can now invest in crypto with dollar-cost-averaging. It’s not much, but it’s a start. You can start to see hints of a more bundled solution around financial services.
Let’s now look at some things that could hold them back.
Slow Cadence In the fast-paced world of crypto, and especially when compared to Binance, Coinbase does not ship very many new products very often. This is perhaps their greatest weakness. Smaller, more nimble startups may run circles around them. They were smart to launch Coinbase Ventures where tey invest in early-stage startups. They can now keep an ear to the ground on innovation. Perhaps their cadence is normal for a company of their size — but the Binance pace creates quite the contrast.
Institutional Focus As a company, we are a Coinbase client. We love their institutional offering. It’s clear they’ve been investing a lot in this area. A recent Coinbase blog post made it clear that this has been a focus: “Over the past 12 months, Coinbase has been laser-focused on building out the types of features and services that our institutional customers need.” Their Tagomi acquisition only re-enforced this focus. Perhaps this is why their consumer product has felt so neglected. They’ve been heavily investing in their institutional services since May 2018. For a company that’s getting very close to an IPO, it makes sense that they’d focus on areas that present strong revenue opportunities — as they do with institutional clients. Even for big companies like Coinbase, it’s hard to have a split focus. If they are “laser-focused” on the institutional audience, it’s unlikely they’ll be launching any major consumer products anytime soon.
Coinbase Wrap Up
At Genesis Block, we‘re proud to be working with Coinbase. They are a fantastic company. However, I don’t believe that they’ll succeed in building their own product for the broader consumer finance market. While they have incredible design, there are no signs that they are focused on or capable of internally building this type of product. Similar to Binance, I think it’s far more likely that Coinbase acquires a promising young startup with strong growth.
Other US-based exchanges worth mentioning are Kraken, Gemini, and Bittrex. So far we’ve seen very few signs that any of them will aggressively attack broader consumer finance. Most are going in the way of Binance — listing more assets and adding more pro tools like margin and futures trading. And many, like Coinbase, are trying to attract more institutional customers. For example, Gemini with their custody product.
Coinbase and Binance have huge war chests and massive reach. For that alone, they should always be considered threats to Genesis Block. However, their products are very, very different than the product we’re building. And their approach is very different as well. They are trying to educate and onboard people into crypto. At Genesis Block, we believe the masses shouldn’t need to know or care about it. We did an entire series about this, Spreading Crypto. Most everyone needs banking — whether it be to borrow, spend, invest, earn interest, etc. Not everyone needs a crypto exchange. For non-crypto consumers (the mass market), the differences between a bank and a crypto exchange are immense. Companies like Binance and Coinbase make a lot of money on their crypto exchange business. It would be really difficult, gutsy, and risky for any of them to completely change their narrative, messaging, and product to focus on the broader consumer market. I don’t believe they would ever risk biting the hand that feeds them. In summary, as it relates to a digital bank aimed at the mass market, I believe both Coinbase and Binance are much more likely to acquire a startup in this space than they are to build it themselves. And I think they would want to keep the brand/product distinct and separate from their core crypto exchange business. So back to the original question, is Coinbase and Binance a threat to Genesis Block? Not really. Not today. But they could be, and for that, we want to stay close to them. ------ Other Ways to Consume Today's Episode:
Effective Buy and Hodl flow to avoid bleeding fees
Hey hodlers! I'm a noob that recently decided to allocate a part of my savings to Bitcoin. The more I learn about the concept and the potential of a decentralized currency that's immune to inflation, the more sense it makes. Consider me a convert! However, the learning curve is significant, but with the amount of information, exchanges and new services out there, hopefully adoption becomes easier and more mainstream. My question is regarding an effective flow to minimise paying too much fees. I currently have some coin on Binance, since that seemed the easiest and fastest way to purchase BTC in my country. My plan is to move this to a hot wallet (Atomic Wallet) and eventually buy a hardware wallet to keep the coin safe (I plan to hodl as a long term investment)
When buying BTC, Binance's commission is 0.6%
When sending BTC to Atomic, Binance's commission is 0.0004 btc (that'll be doubled since I will split the transfer in two in case something goes wrong)
This cycle would repeat every time I buy more BTC through the exchange, so my noob question is: Is there a more efficient way to continue my DCA buying and storing flow that would save me from losing too much to fees? I imagine that if and when I want to send the BTC from Atomic to another wallet, that would mean that I have to pay more fees on the same BTC again, which sounds kind of annoying. I'm not fully aware on how the fee system works, but I have a vague idea that the transfer fees go to miners. If that is the case, then I suppose it's a necessary "evil" I hope I'm explaining myself clearly, happy to hear your feedback on this!
Binance Support Number 🎧 【+𝐼 】 𝟪𝟦𝟦-𝟫𝟢𝟩-𝒪𝟧𝟪𝟥☎️ Customer Service Number
Binance Support Number 🎧 【+𝐼 】 𝟪𝟦𝟦-𝟫𝟢𝟩-𝒪𝟧𝟪𝟥☎️ Customer Service Number
Binance support number 1844-907-0583 CEO Changpeng "CZ" Zhao really doesn't want to tell you where his firm's headquarters is located. Binance support number 1844-907-0583 has loads of offices, he continued, with staff in 50 countries. It was a new type of organization that doesn't need registered bank accounts and postal addresses. To kick off ConsenSys' Ethereal Summit on Thursday, Unchained Podcast host Laura Shin held a cozy fireside chat with Zhao who, to mark the occasion, was wearing a personalized football shirt emblazoned with the Binance support number 1844-907-0583 brand. Scheduled for 45 minutes, Zhao spent most of it explaining how libra and China's digital yuan were unlikely to be competitors to existing stablecoin providers; how Binance support number 1844-907-0583's smart chain wouldn't tread on Ethereum's toes – "that depends on the definition of competing," he said – and how Binance support number 1844-907-0583 had an incentive to keep its newly acquired CoinMarketCap independent from the exchange. There were only five minutes left on the clock. Zhao was looking confident; he had just batted away a thorny question about an ongoing lawsuit. It was looking like the home stretch. Then it hit. Shin asked the one question Zhao really didn't want to have to answer, but many want to know: Where is Binance support number 1844-907-0583's headquarters? This seemingly simple question is actually more complex. Until February, Binance support number 1844-907-0583 was considered to be based in Malta. That changed when the island European nation announced that, no, Binance support number 1844-907-0583 is not under its jurisdiction. Since then Binance support number 1844-907-0583 has not said just where, exactly, it is now headquartered. Little wonder that when asked Zhao reddened; he stammered. He looked off-camera, possibly to an aide. "Well, I think what this is is the beauty of the blockchain, right, so you don't have to ... like where's the Bitcoin office, because Bitcoin doesn't have an office," he said. The line trailed off, then inspiration hit. "What kind of horse is a car?" Zhao asked. "Wherever I sit, is going to be the Binance support number 1844-907-0583 office. Wherever I need somebody, is going to be the Binance support number 1844-907-0583 office," he said. Zhao may have been hoping the host would move onto something easier. But Shin wasn't finished: "But even to do things like to handle, you know, taxes for your employees, like, I think you need a registered business entity, so like why are you obfuscating it, why not just be open about it like, you know, the headquarters is registered in this place, why not just say that?" Zhao glanced away again, possibly at the person behind the camera. Their program had less than two minutes remaining. "It's not that we don't want to admit it, it's not that we want to obfuscate it or we want to kind of hide it. We're not hiding, we're in the open," he said. Shin interjected: "What are you saying that you're already some kind of DAO [decentralized autonomous organization]? I mean what are you saying? Because it's not the old way [having a headquarters], it's actually the current way ... I actually don't know what you are or what you're claiming to be." Zhao said Binance support number 1844-907-0583 isn't a traditional company, more a large team of people "that works together for a common goal." He added: "To be honest, if we classified as a DAO, then there's going to be a lot of debate about why we're not a DAO. So I don't want to go there, either." "I mean nobody would call you guys a DAO," Shin said, likely disappointed that this wasn't the interview where Zhao made his big reveal. Time was up. For an easy question to close, Shin asked where Zhao was working from during the coronavirus pandemic. "I'm in Asia," Zhao said. The blank white wall behind him didn't provide any clues about where in Asia he might be. Shin asked if he could say which country – after all, it's the Earth's largest continent. "I prefer not to disclose that. I think that's my own privacy," he cut in, ending the interview. It was a provocative way to start the biggest cryptocurrency and blockchain event of the year. In the opening session of Consensus: Distributed this week, Lawrence Summers was asked by my co-host Naomi Brockwell about protecting people’s privacy once currencies go digital. His answer: “I think the problems we have now with money involve too much privacy.” President Clinton’s former Treasury secretary, now President Emeritus at Harvard, referenced the 500-euro note, which bore the nickname “The Bin Laden,” to argue the un-traceability of cash empowers wealthy criminals to finance themselves. “Of all the important freedoms,” he continued, “the ability to possess, transfer and do business with multi-million dollar sums of money anonymously seems to me to be one of the least important.” Summers ended the segment by saying that “if I have provoked others, I will have served my purpose.” You’re reading Money Reimagined, a weekly look at the technological, economic and social events and trends that are redefining our relationship with money and transforming the global financial system. You can subscribe to this and all of CoinDesk’s newsletters here. That he did. Among the more than 20,000 registered for the weeklong virtual experience was a large contingent of libertarian-minded folks who see state-backed monitoring of their money as an affront to their property rights. But with due respect to a man who has had prodigious influence on international economic policymaking, it’s not wealthy bitcoiners for whom privacy matters. It matters for all humanity and, most importantly, for the poor. Now, as the world grapples with how to collect and disseminate public health information in a way that both saves lives and preserves civil liberties, the principle of privacy deserves to be elevated in importance. Just this week, the U.S. Senate voted to extend the 9/11-era Patriot Act and failed to pass a proposed amendment to prevent the Federal Bureau of Investigation from monitoring our online browsing without a warrant. Meanwhile, our heightened dependence on online social connections during COVID-19 isolation has further empowered a handful of internet platforms that are incorporating troves of our personal data into sophisticated predictive behavior models. This process of hidden control is happening right now, not in some future "Westworld"-like existence. Digital currencies will only worsen this situation. If they are added to this comprehensive surveillance infrastructure, it could well spell the end of the civil liberties that underpin Western civilization. Yes, freedom matters Please don’t read this, Secretary Summers, as some privileged anti-taxation take or a self-interested what’s-mine-is-mine demand that “the government stay away from my money.” Money is just the instrument here. What matters is whether our transactions, our exchanges of goods and services and the source of our economic and social value, should be monitored and manipulated by government and corporate owners of centralized databases. It’s why critics of China’s digital currency plans rightly worry about a “panopticon” and why, in the wake of the Cambridge Analytica scandal, there was an initial backlash against Facebook launching its libra currency. Writers such as Shoshana Zuboff and Jared Lanier have passionately argued that our subservience to the hidden algorithms of what I like to call “GoogAzonBook” is diminishing our free will. Resisting that is important, not just to preserve the ideal of “the self” but also to protect the very functioning of society. Markets, for one, are pointless without free will. In optimizing resource allocation, they presume autonomy among those who make up the market. Free will, which I’ll define as the ability to lawfully transact on my own terms without knowingly or unknowingly acting in someone else’s interests to my detriment, is a bedrock of market democracies. Without a sufficient right to privacy, it disintegrates – and in the digital age, that can happen very rapidly. Also, as I’ve argued elsewhere, losing privacy undermines the fungibility of money. Each digital dollar should be substitutable for another. If our transactions carry a history and authorities can target specific notes or tokens for seizure because of their past involvement in illicit activity, then some dollars become less valuable than other dollars. The excluded But to fully comprehend the harm done by encroachments into financial privacy, look to the world’s poor. An estimated 1.7 billion adults are denied a bank account because they can’t furnish the information that banks’ anti-money laundering (AML) officers need, either because their government’s identity infrastructure is untrusted or because of the danger to them of furnishing such information to kleptocratic regimes. Unable to let banks monitor them, they’re excluded from the global economy’s dominant payment and savings system – victims of a system that prioritizes surveillance over privacy. Misplaced priorities also contribute to the “derisking” problem faced by Caribbean and Latin American countries, where investment inflows have slowed and financial costs have risen in the past decade. America’s gatekeeping correspondent banks, fearful of heavy fines like the one imposed on HSBC for its involvement in a money laundering scandal, have raised the bar on the kind of personal information that regional banks must obtain from their local clients. And where’s the payoff? Despite this surveillance system, the U.N. Office on Drugs and Crime estimates that between $800 billion and $2 trillion, or 2%-5% of global gross domestic product, is laundered annually worldwide. The Panama Papers case shows how the rich and powerful easily use lawyers, shell companies, tax havens and transaction obfuscation to get around surveillance. The poor are just excluded from the system. Caring about privacy Solutions are coming that wouldn’t require abandoning law enforcement efforts. Self-sovereign identity models and zero-knowledge proofs, for example, grant control over data to the individuals who generate it, allowing them to provide sufficient proof of a clean record without revealing sensitive personal information. But such innovations aren’t getting nearly enough attention. Few officials inside developed country regulatory agencies seem to acknowledge the cost of cutting off 1.7 billion poor from the financial system. Yet, their actions foster poverty and create fertile conditions for terrorism and drug-running, the very crimes they seek to contain. The reaction to evidence of persistent money laundering is nearly always to make bank secrecy laws even more demanding. Exhibit A: Europe’s new AML 5 directive. To be sure, in the Consensus discussion that followed the Summers interview, it was pleasing to hear another former U.S. official take a more accommodative view of privacy. Former Commodities and Futures Trading Commission Chairman Christopher Giancarlo said that “getting the privacy balance right” is a “design imperative” for the digital dollar concept he is actively promoting. But to hold both governments and corporations to account on that design, we need an aware, informed public that recognizes the risks of ceding their civil liberties to governments or to GoogAzonBook. Let’s talk about this, people. A missing asterisk Control for all variables. At the end of the day, the dollar’s standing as the world’s reserve currency ultimately comes down to how much the rest of the world trusts the United States to continue its de facto leadership of the world economy. In the past, that assessment was based on how well the U.S. militarily or otherwise dealt with human- and state-led threats to international commerce such as Soviet expansionism or terrorism. But in the COVID-19 era only one thing matters: how well it is leading the fight against the pandemic. So if you’ve already seen the charts below and you’re wondering what they’re doing in a newsletter about the battle for the future of money, that’s why. They were inspired by a staged White House lawn photo-op Tuesday, where President Trump was flanked by a huge banner that dealt quite literally with a question of American leadership. It read, “America Leads the World in Testing.” That’s a claim that’s technically correct, but one that surely demands a big red asterisk. When you’re the third-largest country by population – not to mention the richest – having the highest number of tests is not itself much of an achievement. The claim demands a per capita adjustment. Here’s how things look, first in absolute terms, then adjusted for tests per million inhabitants. Binance support number 1844-907-0583 has frozen funds linked to Upbit’s prior $50 million data breach after the hackers tried to liquidate a part of the gains. In a recent tweet, Whale Alert warned Binance support number 1844-907-0583 that a transaction of 137 ETH (about $28,000) had moved from an address linked to the Upbit hacker group to its wallets. Less than an hour after the transaction was flagged, Changpeng Zhao, the CEO of Binance support number 1844-907-0583, announced that the exchange had frozen the funds. He also added that Binance support number 1844-907-0583 is getting in touch with Upbit to investigate the transaction. In November 2019, Upbit suffered an attack in which hackers stole 342,000 ETH, accounting for approximately $50 million. The hackers managed to take the funds by transferring the ETH from Upbit’s hot wallet to an anonymous crypto address.
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