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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 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.
A couple of years ago in the early months of the 2017, I published a piece called Abundance Via Cryptocurrencies (https://www.reddit.com/C\_S\_T/comments/69d12a/abundance\_via\_cryptocurrencies/) in which I kind of foresaw the crypto boom that had bitcoin go from $1k to $21k and the alt-coin economy swell up to have more than 60% of the bitcoin market capitalisation. At the time, I spoke of coming out from “the Pit” of conspiracy research and that I was a bit suss on bitcoin’s inception story. At the time I really didn’t see the scaling solution being put forward as being satisfactory and the progress on bitcoin seemed stifled by the politics of the social consensus on an open source protocol so I was looking into alt coins that I thought could perhaps improve upon the shortcomings of bitcoin. In the thread I made someone recommended to have a look at 4chan’s business and finance board. I did end up taking a look at it just as the bull market started to really surge. I found myself in a sea of anonymous posters who threw out all kinds of info and memes about the hundreds, thousands, tens of thousands of different shitcoins and why they’re all going to have lambos on the moon. I got right in to it, I loved the idea of filtering through all the shitposts and finding the nuggest of truth amongst it all and was deeply immersed in it all as the price of bitcoin surged 20x and alt coins surged 5-10 times against bitcoin themselves. This meant there were many people who chucked in a few grand and bought a stash of alt coins that they thought were gonna be the next big thing and some people ended up with “portfolios” 100-1000x times their initial investment. To explain what it’s like to be on an anonymous business and finance board populated with incel neets, nazis, capitalist shit posters, autistic geniuses and whoever the hell else was using the board for shilling their coins during a 100x run up is impossible. It’s hilarious, dark, absurd, exciting and ultimately addictive as fuck. You have this app called blockfolio that you check every couple of minutes to see the little green percentages and the neat graphs of your value in dollars or bitcoin over day, week, month or year. Despite my years in the pit researching conspiracy, and my being suss on bitcoin in general I wasn’t anywhere near as distrustful as I should have been of an anonymous business and finance board and although I do genuinely think there are good people out there who are sharing information with one another in good faith and feel very grateful to the anons that have taken their time to write up quality content to educate people they don’t know, I wasn’t really prepared for the level of organisation and sophistication of the efforts groups would go to to deceive in this space. Over the course of my time in there I watched my portfolio grow to ridiculous numbers relative to what I put in but I could never really bring myself to sell at the top of a pump as I always felt I had done my research on a coin and wanted to hold it for a long time so why would I sell? After some time though I would read about something new or I would find out of dodgy relationships of a coin I had and would want to exit my position and then I would rebalance my portfolio in to a coin I thought was either technologically superior or didn’t have the nefarious connections to people I had come across doing conspiracy research. Because I had been right in to the conspiracy and the decentralisation tropes I guess I always carried a bit of an antiauthoritarian/anarchist bias and despite participating in a ridiculously capitalistic market, was kind of against capitalism and looking to a blockchain protocol to support something along the lines of an open source anarchosyndicalist cryptocommune. I told myself I was investing in the tech and believed in the collective endeavour of the open source project and ultimately had faith some mysterious “they” would develop a protocol that would emancipate us from this debt slavery complex. As I became more and more aware of how to spot artificial discussion on the chans, I began to seek out further some of the radical projects like vtorrent and skycoin and I guess became a bit carried away from being amidst such ridiculous overt shilling as on the boards so that if you look in my post history you can even see me promoting some of these coins to communities I thought might be sympathetic to their use case. I didn’t see it at the time because I always thought I was holding the coins with the best tech and wanted to ride them up as an investor who believed in them, but this kind of promotion is ultimately just part of a mentality that’s pervasive to the cryptocurrency “community” that insists because it is a decentralised project you have to in a way volunteer to inform people about the coin since the more decentralised ones without premines or DAO structures don’t have marketing budgets, or don’t have marketing teams. In the guise of cultivating a community, groups form together on social media platforms like slack, discord, telegram, twitter and ‘vote’ for different proposals, donate funds to various boards/foundations that are set up to give a “roadmap” for the coins path to greatness and organise marketing efforts on places like reddit, the chans, twitter. That’s for the more grass roots ones at least, there are many that were started as a fork of another coin, or a ICO, airdrop or all these different ways of disseminating a new cryptocurrency or raising funding for promising to develop one. Imagine the operations that can be run by a team that raised millions, hundreds of millions or even billions of dollars on their ICOs, especially if they are working in conjunction with a new niche of cryptocurrency media that’s all nepotistic and incestuous. About a year and a half ago I published another piece called “Bitcoin is about to be dethroned” (https://www.reddit.com/C\_S\_T/comments/7ewmuu/bitcoin\_is\_about\_to\_be\_dethroned/) where I felt I had come to realise the scaling debate had been corrupted by a company called Blockstream and they had been paying for social media operations in a fashion not to dissimilar to correct the record or such to control the narrative around the scaling debate and then through deceit and manipulation curated an apparent consensus around their narrative and hijacked the bitcoin name and ticker (BTC). I read the post again just before posting this and decided to refer to it to to add some kind of continuity to my story and hopefully save me writing so much out. Looking back on something you wrote is always a bit cringey especially because I can see that although I had made it a premise post, I was acting pretty confident that I was right and my tongue was acidic because of so much combating of shills on /biz/ but despite the fact I was wrong about the timing I stand by much of what I wrote then and want to expand upon it a bit more now. The fork of the bitcoin protocol in to bitcoin core (BTC) and bitcoin cash (BCH) is the biggest value fork of the many that have occurred. There were a few others that forked off from the core chain that haven’t had any kind of attention put on them, positive or negative and I guess just keep chugging away as their own implementation. The bitcoin cash chain was supposed to be the camp that backed on chain scaling in the debate, but it turned out not everyone was entirely on board with that and some players/hashpower felt it was better to do a layer two type solution themselves although with bigger blocks servicing the second layer. Throughout what was now emerging as a debate within the BCH camp, Craig Wright and Calvin Ayre of Coin Geek said they were going to support massive on chain scaling, do a node implementation that would aim to restore bitcoin back to the 0.1.0 release which had all kinds of functionality included in it that had later been stripped by Core developers over the years and plan to bankrupt the people from Core who changed their mind on agreeing with on-chain scaling. This lead to a fork off the BCH chain in to bitcoin satoshis vision (BSV) and bitcoin cash ABC. https://bitstagram.bitdb.network/m/raw/cbb50c322a2a89f3c627e1680a3f40d4ad3cee5a3fb153e5d6d001bdf85de404 The premise for this post is that Craig S Wright was Satoshi Nakamoto. It’s an interesting premise because depending upon your frame of reference the premise may either be a fact or to some too outrageous to even believe as a premise. Yesterday it was announced via CoinGeek that Craig Steven Wright has been granted the copyright claim for both the bitcoin white-paper under the pen name Satoshi Nakamoto and the original 0.1.0 bitcoin software (both of which were marked (c) copyright of satoshi nakamoto. The reactions to the news can kind of be classified in to four different reactions. Those who heard it and rejected it, those who heard it but remained undecided, those who heard it and accepted it, and those who already believed he was. Apparently to many the price was unexpected and such a revelation wasn’t exactly priced in to the market with the price immediately pumping nearly 100% upon the news breaking. However, to some others it was a vindication of something they already believed. This is an interesting phenomena to observe. For many years now I have always occupied a somewhat positively contrarian position to the default narrative put forward to things so it’s not entirely surprising that I find myself in a camp that holds the minority opinion. As you can see in the bitcoin dethroned piece I called Craig fake satoshi, but over the last year and bit I investigated the story around Craig and came to my conclusion that I believed him to be at least a major part of a team of people who worked on the protocol I have to admit that through reading his articles, I have kind of been brought full circle to where my contrarian opinion has me becoming somewhat of an advocate for “the system’. https://coingeek.com/bitcoin-creator-craig-s-wright-satoshi-nakamoto-granted-us-copyright-registrations-for-bitcoin-white-paper-and-code/ When the news dropped, many took to social media to see what everyone was saying about it. On /biz/ a barrage of threads popped up discussing it with many celebrating and many rejecting the significance of such a copyright claim being granted. Immediately in nearly every thread there was a posting of an image of a person from twitter claiming that registering for copyright is an easy process that’s granted automatically unless challenged and so it doesn’t mean anything. This was enough for many to convince them of the insignificance of the revelation because of the comment from a person who claimed to have authority on twitter. Others chimed in to add that in fact there was a review of the copyright registration especially in high profile instances and these reviewers were satisfied with the evidence provided by Craig for the claim. At the moment Craig is being sued by Ira Kleiman for an amount of bitcoin that he believes he is entitled to because of Craig and Ira’s brother Dave working together on bitcoin. He is also engaged in suing a number of people from the cryptocurrency community for libel and defamation after they continued to use their social media/influencer positions to call him a fraud and a liar. He also has a number of patents lodged through his company nChain that are related to blockchain technologies. This has many people up in arms because in their mind Satoshi was part of a cypherpunk movement, wanted anonymity, endorsed what they believed to be an anti state and open source technologies and would use cryptography rather than court to prove his identity and would have no interest in patents. https://bitstagram.bitdb.network/m/raw/1fce34a7004759f8db16b2ae9678e9c6db434ff2e399f59b5a537f72eff2c1a1 https://imgur.com/a/aANAsL3) If you listen to Craig with an open mind, what cannot be denied is the man is bloody smart. Whether he is honest or not is up to you to decide, but personally I try to give everyone the benefit of the doubt and then cut them off if i find them to be dishonest. What I haven’t really been able to do with my investigation of craig is cut him off. There have been many moments where I disagree with what he has had to say but I don’t think people having an opinion about something that I believe to be incorrect is the same as being a dishonest person. It’s very important to distinguish the two and if you are unable to do so there is a very real risk of you projecting expectations or ideals upon someone based off your ideas of who they are. Many times if someone is telling the truth but you don’t understand it, instead of acknowledging you don’t understand it, you label them as being stupid or dishonest. I think that has happened to an extreme extent with Craig. Let’s take for example the moment when someone in the slack channel asked Craig if he had had his IQ tested and what it was. Craig replied with 179. The vast majority of people on the internet have heard someone quote their IQ before in an argument or the IQ of others and to hear someone say such a score that is actually 6 standard deviations away from the mean score (so probably something like 1/100 000) immediately makes them reject it on the grounds of probability. Craig admits that he’s not the best with people and having worked with/taught many high functioning people (sometimes on the spectrum perhaps) on complex anatomical and physiological systems I have seen some that also share the same difficulties in relating to people and reconciling their genius and understandings with more average intelligences. Before rejecting his claim outright because we don’t understand much of what he says, it would be prudent to first check is there any evidence that may lend support to his claim of a one in a million intelligence quotient. Craig has mentioned on a number of occasions that he holds a number of different degrees and certifications in relation to law, cryptography, statistics, mathematics, economics, theology, computer science, information technology/security. I guess that does sound like something someone with an extremely high intelligence could achieve. Now I haven’t validated all of them but from a simple check on Charles Sturt’s alumni portal using his birthday of 23rd of October 1970 we can see that he does in fact have 3 Masters and a PhD from Charles Sturt. Other pictures I have seen from his office at nChain have degrees in frames on the wall and a developer published a video titled Craig Wright is a Genius with 17 degrees where he went and validated at least 8 of them I believe. He is recently publishing his Doctorate of Theology through an on-chain social media page that you have to pay a little bit for access to sections of his thesis. It’s titled the gnarled roots of creation. He has also mentioned on a number of occasions his vast industry experience as both a security contractor and business owner. An archive from his LinkedIn can be seen below as well. LinkedIn - https://archive.is/Q66Gl https://youtu.be/nXdkczX5mR0 - Craig Wright is a Genius with 17 Degrees https://www.yours.org/content/gnarled-roots-of-a-creation-mythos-45e69558fae0 - Gnarled Roots of Creation. In fact here is an on chain collection of articles and videos relating to Craig called the library of craig - https://www.bitpaste.app/tx/94b361b205196560d1bd09e4e3b3ec7ad6bea478af204cabfe243efd8fc944dd So there is a guy with 17 degrees, a self professed one in a hundred thousand IQ, who’s worked for Australian Federal Police, ASIO, NSA, NASA, ASX. He’s been in Royal Australian Air Force, operated a number of businesses in Australia, published half a dozen academic papers on networks, cryptography, security, taught machine learning and digital forensics at a number of universities and then another few hundred short articles on medium about his work in these various domains, has filed allegedly 700 patents on blockchain related technology that he is going to release on bitcoin sv, copyrighted the name so that he may prevent other competing protocols from using the brand name, that is telling you he is the guy that invented the technology that he has a whole host of other circumstantial evidence to support that, but people won’t believe that because they saw something that a talking head on twitter posted or that a Core Developer said, or a random document that appears online with a C S Wright signature on it that lists access to an address that is actually related to Roger Ver, that’s enough to write him off as a scam. Even then when he publishes a photo of the paper copy which appears to supersede the scanned one, people still don’t readjust their positions on the matter and resort back to “all he has to do is move the coins or sign a tx”. https://imgur.com/urJbe10 Yes Craig was on the Cypherpunk mailing list back in the day, but that doesn’t mean that he was or is an anarchist. Or that he shares the same ideas that Code Is Law that many from the crypto community like to espouse. I myself have definitely been someone to parrot the phrase myself before reading lots of Craig’s articles and trying to understand where he is coming from. What I have come to learn from listening and reading the man, is that although I might be fed up with the systems we have in place, they still exist to perform important functions within society and because of that the tools we develop to serve us have to exist within that preexisting legal and social framework in order for them to have any chance at achieving global success in replacing fiat money with the first mathematically provably scarce commodity. He says he designed bitcoin to be an immutable data ledger where everyone is forced to be honest, and economically disincentivised to perform attacks within the network because of the logs kept in a Write Once Read Many (WORM) ledger with hierarchical cryptographic keys. In doing so you eliminate 99% of cyber crime, create transparent DAO type organisations that can be audited and fully compliant with legislature that’s developed by policy that comes from direct democratic voting software. Everyone who wants anonymous coins wants to have them so they can do dishonest things, illegal things, buy drugs, launder money, avoid taxes. Now this triggers me a fair bit as someone who has bought drugs online, who probably hasn’t paid enough tax, who has done illegal things contemplating what it means to have that kind of an evidence ledger, and contemplate a reality where there are anonymous cryptocurrencies, where massive corporations continue to be able to avoid taxes, or where methamphetamine can be sold by the tonne, or where people can be bought and sold. This is the reality of creating technologies that can enable and empower criminals. I know some criminals and regard them as very good friends, but I know there are some criminals that I do not wish to know at all. I know there are people that do horrific things in the world and I know that something that makes it easier for them is having access to funds or the ability to move money around without being detected. I know arms, drugs and people are some of the biggest markets in the world, I know there is more than $50 trillion dollars siphoned in to off shore tax havens from the value generated as the product of human creativity in the economy and how much human charity is squandered through the NGO apparatus. I could go on and on about the crappy things happening in the world but I can also imagine them getting a lot worse with an anonymous cryptocurrency. Not to say that I don’t think there shouldn’t be an anonymous cryptocurrency. If someone makes one that works, they make one that works. Maybe they get to exist for a little while as a honeypot or if they can operate outside the law successfully longer, but bitcoin itself shouldn’t be one. There should be something a level playing field for honest people to interact with sound money. And if they operate within the law, then they will have more than adequate privacy, just they will leave immutable evidence for every transaction that can be used as evidence to build a case against you committing a crime. His claim is that all the people that are protesting the loudest about him being Satoshi are all the people that are engaged in dishonest business or that have a vested interest in there not being one singular global ledger but rather a whole myriad of alternative currencies that can be pumped and dumped against one another, have all kinds of financial instruments applied to them like futures and then have these exchanges and custodial services not doing any Know Your Customer (KYC) or Anti Money Laundering (AML) processes. Bitcoin SV was delisted by a number of exchanges recently after Craig launched legal action at some twitter crypto influencetalking heads who had continued to call him a fraud and then didn’t back down when the CEO of one of the biggest crypto exchanges told him to drop the case or he would delist his coin. The trolls of twitter all chimed in in support of those who have now been served with papers for defamation and libel and Craig even put out a bitcoin reward for a DOX on one of the people who had been particularly abusive to him on twitter. A big european exchange then conducted a twitter poll to determine whether or not BSV should be delisted as either (yes, it’s toxic or no) and when a few hundred votes were in favour of delisting it (which can be bought for a couple of bucks/100 votes). Shortly after Craig was delisted, news began to break of a US dollar stable coin called USDT potentially not being fully solvent for it’s apparent 1:1 backing of the token to dollars in the bank. Binance suffered an alleged exchange hack with 7000 BTC “stolen” and the site suspending withdrawals and deposits for a week. Binance holds 800m USDT for their US dollar markets and immediately once the deposits and withdrawals were suspended there was a massive pump for BTC in the USDT markets as people sought to exit their potentially not 1:1 backed token for bitcoin. The CEO of this exchange has the business registered out of Malta, no physical premises, the CEO stays hotel room to hotel room around the world, has all kind of trading competitions and the binance launchpad, uses an unregistered security to collect fees ($450m during the bear market) from the trading of the hundreds of coins that it lists on its exchange and has no regard for AML and KYC laws. Craig said he himself was able to create 100 gmail accounts in a day and create binance accounts with each of those gmail accounts and from the same wallet, deposit and withdraw 1 bitcoin into each of those in one day ($8000 x 100) without facing any restrictions or triggering any alerts or such. This post could ramble on for ever and ever exposing the complexities of the rabbit hole but I wanted to offer some perspective on what’s been happening in the space. What is being built on the bitcoin SV blockchain is something that I can only partially comprehend but even from my limited understanding of what it is to become, I can see that the entirety of the crypto community is extremely threatened as it renders all the various alt coins and alt coin exchanges obsolete. It makes criminals play by the rules, it removes any power from the developer groups and turns the blockchain and the miners in to economies of scale where the blockchain acts as a serverless database, the miners provide computational resources/storage/RAM and you interact with a virtual machine through a monitor and keyboard plugged in to an ethernet port. It will be like something that takes us from a type 0 to a type 1 civilisation. There are many that like to keep us in the quagmire of corruption and criminality as it lines their pockets. Much much more can be read about the Cartel in crypto in the archive below. Is it possible this cartel has the resources to mount such a successful psychological operation on the cryptocurrency community that they manage to convince everyone that Craig is the bad guy, when he’s the only one calling for regulation, the application of the law, the storage of immutable records onchain to comply with banking secrecy laws, for Global Sound Money? https://archive.fo/lk1lH#selection-3671.46-3671.55 Please note, where possible, images were uploaded onto the bitcoin sv blockchain through bitstagram paying about 10c a pop. If I wished I could then use an application etch and archive this post to the chain to be immutably stored. If this publishing forum was on chain too it would mean that when I do the archive the images that are in the bitstragram links (but stored in the bitcoin blockchain/database already) could be referenced in the archive by their txid so that they don’t have to be stored again and thus bringing the cost of the archive down to only the html and css.
Daily analysis of cryptocurrencies 20190830(Market index 24 — Extreme Fear state)
https://preview.redd.it/sevbsls5jkj31.jpg?width=540&format=pjpg&auto=webp&s=c6418070423aab93e76875cc81d6e47e448c7f7a https://preview.redd.it/6qz26j67jkj31.png?width=630&format=png&auto=webp&s=366fe0b5006e1a9beae34f9d26345bec8cb75cf2 [UN official: Cryptocurrency makes policing child slavery more difficult] A top United Nations official says cryptocurrencies have made it significantly more difficult to fight child slavery, cyber crime, terror financing and money laundering, according to a report by news website ABC on August 29. Neil Walsh, chief of the Cybercrime and AML section of UN’s Office on Drugs and Crime, noted that the anonymous attribute of cryptocurrencies provide a new layer of secrecy to favor these criminals. [Indian black money special investigation team: the government does not need to supervise the cryptocurrency, the single choice is the only choice] The Indian Black Money Special Investigation Group (SIT) informed the government that criminal gang networks are increasingly relying on cryptocurrencies for money laundering and drug smuggling. It also believes that it is not necessary to supervise cryptocurrencies, because it takes years and inefficiencies to deal with such cases, and a one-size-fits-all approach seems to be the only option. Although the country does not fully ban cryptocurrency transactions, the government has instructed all relevant agencies and law enforcement agencies such as the Reserve Bank of India (RBI), the Law Enforcement Agency (ED) and the income tax department to take action in accordance with existing laws. In the absence of a globally acceptable solution, the government is handling this matter with caution. SIT does not support regulation because it takes a long time to prosecute violations in the country: “We have many laws or regulations that need to be strictly enforced. But experience shows that many law or regulatory enforcement agencies cannot enforce them. Even if they try to enforce them, As a result, many litigations remain pending for many years. In order to avoid this, there is no choice but to declare it an illegal transaction. Those dealing with cryptocurrencies should be punished without any further evidence.” [Terrorist organizations are using social media platforms such as Telegram to raise money through cryptocurrencies] According to a report by the Middle East Media Research Institute (MEMRI), a non-profit research institute, terrorist organizations in areas such as Islam and Hamas are using social media platforms, including Telegram, to raise funds through cryptocurrencies. MEMRI warned that this problem will only be more serious when Telegram launches its own blockchain TON and local cryptocurrency Gram.
Encrypted project calendar（August 30, 2019）
XDCE/XinFin Network:2019 TraceFinancial webinar will be held on August 30thWAX/WAX Token:WAX TokenSwap (WAX) to August 30, ERC-20 WAX Token token converted to WAX Token CutoffUGAS/Ultrain:Ultrain community news, after the main network mapping starts on August 7, all UGAS holders must complete the registration of the Ultrain main wallet account by August 30th.
Encrypted project calendar（August 31, 2019）
ADX/AdEx:ADEX (ADX) will release the Validator Stack version 2.0 in AugustDADI/DADI:DADI will release the network CLI on August 31, with Stargates to support network services; and release Self Onboarding on the same day to allow the network to be more open.MITH/Mithril:The Mithril (MITH) team decided to implement the first MITH token destruction program on August 31.COS/Contentos:Contentos test network v0.5 “Jupiter” will be launched on August 31, this is the last version of the test before the main online line, alternate release.NOAH/Noah Coin:Noah Coin (NOAH) exchanges the held tokens at BTCNext, ending on August 31st.
Encrypted project calendar（September 01, 2019）
XLM/Stellar:Stellar (XLM) will conduct equity awards in binance on September 1stMHC/MetaHash:MetaHash (MHC) will close all ICO accounts as of September 1 and will permanently close all ICO accounts. All MHCs will need to be transferred to MetaGate Wallet by this date.DGD/DigixDAO:The DigixDAO (DGD) DGXHUB community representative program will be open for application on September 1.
Encrypted project calendar（September 02, 2019）
AE/Aeternity:The third phase of Aeternity token (AE) main network migration will end on September 2nd.PLPillar:The Pillar (PLR) Pillar community will participate in a creative strategy seminar hosted by experiencehaus in London, UK on September 2nd.LA/LAToken:The LAToken (LA) LATOKEN community will host an investor reception in London, England on September 2nd.
Encrypted project calendar（September 03, 2019）
WAN/Wanchain:Wanwei Chain Wanchain (WAN) will be launched on September 3rd based on POS mechanism mining function
Encrypted project calendar（September 04, 2019）
BCH/Bitcoin Cash:The City Conference will be held in North Queensland, Australia from September 4th to 5th, 2019.BETHEBethereum:Bethereum will conduct a user airdrop token plan on September 4th
Encrypted project calendar（September 05, 2019）
CS/Credits:Credits (cs) began to map some of the main network tokens on September 5th.ENG/Enigma:The Enigma(ENG)Enigma community will host a gathering and seminar in Boston on September 5.BTC/Bitcoin:Blockchain Africa conference organizers will host the first cryptocurrency festival in South Africa on September 5.AGI/SingularityNET:SingularityNET (AGI) SingularityNET community Ben Goertzel will attend the Asia Innovation Summit on September 5th and will deliver a speech.
Encrypted project calendar（September 06, 2019）
BTC/Bitcoin: Bakkt official Twitter said that Bakkt Warehouse will begin to provide Bitcoin secure storage services to customers on September 6.VEX/Vexanium:The Vexanium (VEX) DApps competition will end on September 6th with a total of 1.1 million VEX awards, the first of which will receive 350,000 VEX.
Encrypted project calendar（September 20, 2019）
NULS / NULS: The NULS 2.0 Beta hackathon will be held from September 20th to September 21st, 2019.
In case you missed it: Major Crypto and Blockchain News from the week ending 12/14/2018
Developments in Financial Services
A cryptocurrency exchange-traded product (ETP) that trades on Switzerland’s Six Exchange saw record trading volumes on Thursday and Friday last week, suggesting that institutional investors may be buying the dip in cryptocurrencies. Four major cryptocurrencies underlie the HODL ETP, including Bitcoin (BTC), Ripple (XRP), Ethereum (ETH), Litecoin (LTC), and Bitcoin Cash (BCH). While HODL ETP’s one-month average daily trading is 20,000 shares, on Thursday, December 6th, and Friday, December 7th, 53,233 shares and 62.986 shares were traded, respectively.
A report published last week by global anti-money laundering policymaker, the Financial Action Task Force (FATF), indicates that cryptocurrency exchanges in the United Kingdom pose a, “low risk,” for money laundering and terrorist financing activities. The report, however, does highlight that such activities on UK cryptocurrency exchanges are an, “emerging risk,” although there is not yet enough evidence to suggest that these activities are occurring through cryptocurrency exchanges. In its report, the FATF urged UK regulators to, “Continue to develop an understanding of emerging risks (such as virtual currencies) and intelligence gaps, and take appropriate action.”
Andreas Utermann, CEO and CIO of Allianz Global Investors, called on global financial regulators to ban cryptocurrencies while speaking at a panel discussion in London. According to a report by Reuters, Utermann said, “You should outlaw it,” while participating in a panel alongside Andrew Bailey, the head of Britain’s Financial Conduct Authority. Bailey responded by saying that Utermann’s comments were, “quite strong,” before adding that cryptocurrencies have, “no intrinsic value.”
Basis, a major US-based stablecoin project, is shutting down its operations and returning most of its funds to investors, according to a report by crypto news outlet The Block. The report by The Block cited, “multiple people with direct knowledge of the situation,” in claiming that the algorithmic stablecoin project, which generated UDS$133mm of funding through private investments in April, will return funds to investors. According to the Co-Founder and CEO of competing stablecoin project Nevin Freeman, Basis’ shutdown is due to regulatory concerns around one of its token types. Freeman explained, highlighting that algorithmic stablecoins implement a “secondary token”, known as a “bond token”, to help maintain the primary token’s peg. In many cases, regulators like the US Securities and Exchange Commission (SEC) consider these secondary tokens to be securities.
Binance, the world’s largest cryptocurrency exchange by daily trading volume, announced that it has added Circle’s US dollar-pegged stablecoin, USD Coin (USDC), to its combined Stablecoin Market. Circle, a company backed by Goldman Sachs, first released its stablecoin in September of this year. Binance’s combined Stablecoin Market features other notable stablecoins, like Tether (USDT), that trade against cryptocurrencies as interchangeable base pairs.
Coinone, a South Korea-based cryptocurrency exchange, has officially launched Cross, a cross-border payments application that leverages Ripple’s xCurrent product to increase efficiencies. The application, released by Coinone’s payments subsidiary, Coinone Transfer, targets unbanked or underbanked South Koreans by enabling the transfer of funds to Thailand or the Philippines at a low cost.
Gemini, a cryptocurrency exchange heralded by the Winklevoss twins, released an official company blog post this weekend announcing that the firm will support Bitcoin Cash (BCH) custody and trading. The exchange will support only the Bitcoin Cash ABC network at this time, adding that they, “are continuing to evaluate Bitcoin SV over the coming weeks or months, and we may or may not choose to support withdrawals and/or trading of Bitcoin SV in the future.” Additionally, the company detailed that its listing of BCH is pending regulatory approval by the New York State Department of Financial Services.
Gemini, the cryptocurrency trading platform founded by the Winklevoss twins, announced the launch of a mobile crypto trading application in an official blog post today. Accompanying the launch of the crypto trading app is a new investment vehicle, dubbed, “The Cryptoverse,” that is comprised of a basket of cryptocurrencies weighted by market capitalization. While speaking to Bloomberg today, Cameron Winklevoss said that, “A lot of our decisions have perhaps given off a perception that we’re more institutional-based. The reality of the situation is that we have a diverse customer base. And the retail story is just beginning.” The Winklevoss twins went on to detail of a goal to expand reach to Asian markets by 2019’s end.
Good Money, a US neo-banking platform, has closed its Series A investment round that generated USD$30mm led by cryptocurrency-focused merchant bank Galaxy Digital and the founder of EOS (EOS) Block.one. Good Money aims to provide a variety of banking service and certain financial instruments to US account holders while exploring innovative changes to traditional banking practices. “Modern banking is a primary driver of so many issues we as a society face – from economic inequality, institutional racism, environmental destruction to political corruption,” said Good Money founder Gunnar Lovelace. Specifically, Good Money eliminates ATM fees while offering each bank user equity in the company.
Kraken, a notable cryptocurrency exchange, is seeking to raise funding with a USD$4bn valuation for the company and a USD$100,000 investment minimum, according to CoinDesk. In an email to investors, Kraken CEO Jesse Powell wrote, “There is presently a limited time opportunity available to a very small select number of clients to purchase shares.” The email goes on to detail that the exchange will close its offer on December 16th.
OKEx, the second-largest cryptocurrency exchange by daily trading volume, will begin listing Bitcoin Cash ABC under the original Bitcoin Cash ticker (BCH), as per an official announcement Tuesday. Additionally, OKEx will change the Bitcoin Cash SV ticker from BCHSV to BSV. The announcement by OKEx comes after other notable cryptocurrency exchanges have made the same switch, including Coinbase and Gemini.
PayPal, an online payments portal, has launched its own internal private blockchain platform that will allow staff to trade and exchange tokens while generating ideas and participating in programs to foster innovation, as per a report by news outlet Cheddar. The private blockchain network, which was built by 25 PayPal employees in just 6 months, will allow employees to earn more for enrolling in learning and development programs. The PayPal tokens are not tradeable, or worth anything for that matter, outside PayPal’s blockchain.
PricewaterhouseCoopers (PwC), a big four consulting firm, is partnering with Bitfury Group, a large blockchain software and mining firm, to develop a blockchain accelerator specific to Russian businesses. As per an official press release by PwC, the partnership will leverage Exonum, Bitfury’s open source framework to build blockchain applications, for educational courses and seminars. The partnership aims to meet the, “current needs,” of PwC’s enterprise clients in Russia.
Revolut, a digital banking alternative with an in-application cryptocurrency exchange, announced that it has been awarded a European banking license. Seeking to become the, “Amazon of banking,” the license will allow Revolut to offer traditional banking services alongside its current cryptocurrency offerings to European customers. Nikolay Storonsky, Founder and CEO of Revolut, said in regards to the newly acquired license that, “With the banking license now secured, commission-free stock trading progressing well, and five new international markets at final stages of launch, we are living up to our reputation as the ‘Amazon of Banking’. Our vision is simple: one ap with tens of millions of users, where you can manage every aspect of your financial life with the best value and technology.”
Shinhan Bank, the second-largest commercial bank in South Korea, is launching a new project to implement blockchain technology in its internal processes with a goal of eliminating human error. According to a report by news outlet The Korea Times, Shinhan also recently completed a training program for its staff to increase their knowledge of blockchain technology across various applications. After Shinhan implemented blockchain technology for interest rate swap transactions on November 30th, South Korea’s second-largest bank is now aiming to apply the technology in its record-keeping process to enhance overall efficiencies.
SolarisBank, Germany’s second-largest and Europe’s ninth-largest stock exchange, is partnering with Stuttgart Exchange Group, a German fintech company, to jointly develop a cryptocurrency exchange. As per a report by Cointelegraph Germany, the joint cryptocurrency exchange venture, “is scheduled to launch in the first half of 2019.” This news comes after SolarisBank announced plans to launch a zero-fee cryptocurrency trading application this past May.
The Canadian city of Calgary is becoming the first city in Canada to launch a digital version of its local currency, according to a report by the Global News. Dubbed as the Calgary Digital Dollar, the digital currency will be exclusive to Calgary and operate alongside the country’s Canadian Dollar. Calgary-based businesses will now be required by law to accept at least 10% of a payment in digital currency, although they are allowed to accept up to 100%.
The Society for Worldwide Interbank Financial Telecommunication (SWIFT) is launching a pilot of its Global Payment Initiative (GPI) to combat growing blockchain and fintech solutions, according to an official announcement last week. Currently, the SWIFT Network is used by global financial institutions to conduct global financial payments and cross-border transfers of fiat currency. Although the project is still in its early stages, the GPI pilot hopes to, “build the foundation of a new integrated and interactive service that will significantly improve efficiencies in the payments process and which will ultimately be made available to all 10,000 banks across the SWIFT network.”
The United Arab Emirates’(UAE) central bank is partnering with the Saudi Arabian Monetary Authority (SAMA) to develop a cryptocurrency to facilitate cross border transactions between the two countries, according to a report by news outlet GulfNews. In a meeting pertaining to global banking standards and regulation in the Arab region, Mubarak Rashed Al Mansouri, the governor of the UAE’s central bank, said, “This is probably the first time ever that witnesses the cooperation of monetary authorities from different countries on this topic and we hope that this achievement will foster similar collaboration in our region.” The prospective digital currency will be used by both central banks and financial institutions in the countries.
TokenSoft, a security token offering (STO) startup, has acquired a 20% stake in regulated broker-dealer Marpine Securities LLC in order to launch its own regulated broker-dealer. After acquiring the 20% stake, TokenSoft will launch its new regulated broker-dealer entity, called TokenSoft Global Markets, that will be registered through the Financial Industry Regulatory Authority (FINRA). The new regulated broker-dealer entity will allow TokenSoft to advise token issuers through every step of the Initial Coin Offering (ICO) process. Additionally, TokenSoft will now be able to legally operate in services related to insurance and management.
Tom Lee, co-founder of Fundstrat Global Advisors and a notable cryptocurrency pundit, believes that the current fair value of Bitcoin (BTC) is between USD$13,800 and USD$14,800, according to a note published on Thursday. Lee arrived at this valuation by taking into account the number of active wallet addresses, usage per account, and other supply and demand metrics. Additionally, Lee forecasted that the fair value of BTC will reach USD$150,000/coin once BTC wallets account for 7% of Visa’s 4.5bn account holders.
UAE Exchange, an exchange based in the United Arab Emirates (UAE), is partnering with Ripple to launch a blockchain-based cross-border remittances platform by 1Q2019, as per a Reuters report on Thursday. The report details further that Finablr, a payments and foreign exchange company that owns UAE Exchange, observes a high level of remittance inflows from expatriate workers in the Middle East region. “We expect to go live with Rippel by Q1, 2019 with two other Asian banks,” said Finablr CEO Promoth Manghat, adding, “This is for remittances to start with, from across the globe into Asia.”
De Nederlandsche Bank, the Netherlands’ central bank, will soon require domestic cryptocurrency providers to obtain a license from the regulator to operate, as per a report by Dutch news outlet DeTelegraaf. The Netherlands' central bank is taking these measures in the hope that it will, “prevent such cryptocurrencies from being used to launder money obtained through crime or to fund terrorism.” In order to receive a license, cryptocurrency firms must maintain Know-Your-Customer procedures and report any suspicious activity to the Dutch central bank.
Eddie Hughes, a conservative member of the United Kingdom’s Parliament, suggested that Bitcoin (BTC) should be accepted as legal tender for tax and utility payments, according to news outlet Express.co.uk. The article discusses that Hughes, who is a self-described, “crypto enthusiast with amateur knowledge,” recently met with the Royal National Lifeboat Institution, which accepts cryptocurrency donations. This news comes after the US state of Ohio announced that it would begin accepting BTC as legal tender for tax payments.
Following a case in Canadian courts that resulted in a ruling ordering mistakenly sent crypto funds to be returned to their owner, a blog post from the University of Oxford Faculty of Law is noting that there could be repercussions with the case potentially setting a precedent for lost or stolen cryptocurrency claims. The Canadian court case’s ruling will require defendant Brian Wall to return USD$370,482 worth of Ethereum (ETH) tokens to the plaintiff, Copytrack. The blog post from the University of Oxford Faculty of Law reads, ‘This precedent may have major repercussions for the enforcement of claims regarding lost or stolen cryptocurrencies,” adding that the ruling allows the plaintiff to recover tokens, “in whatsoever hands those Ether Tokens may currently be held.”
Japan’s government is considering plans to ease cryptocurrency taxes in an effort to revitalize the domestic cryptocurrency and blockchain industry. This week, Japanese Congressman Takeshi Fujimaki proposed four significant changes to taxation requirements pertaining to digital assets, which include: a reduction on the cryptocurrency gains tax from 55% to 20%; elimination of taxes on crypto-to-crypto payments; elimination of taxes on miniscule cryptocurrency payments; and an adjustment that would allow cryptocurrency investors to carry forward losses across quarters and years, effectively until cryptocurrencies are ‘cashed’ out.
Jay Clayton, Chairman for the United States Securities and Exchange Commission (US SEC), said during a speech that Initial Coin Offerings (ICOs), “can be effective,” for fundraising, but that, “securities laws must be followed.” Clayton went on in his speech to comment on the US SEC’s work regarding distributed ledger technology (DLT), digital assets, and ICOs, saying that it is an, “area where the Commission and staff have spent a significant amount of time,” and, “that this trend will continue in 2019.”
Jay Clayton, the Chairman of the US Securities and Exchange Commission (SEC), expressed his optimism for distributed ledger technology’s potential impact on traditional financial markets in a testimony before the US Senate Committee on Banking, Housing, and Urban Affairs yesterday. According to a transcript published on the SEC’s website, Clayton said, “I am optimistic that developments in distributed ledger technology can help facilitate capital formation, providing promising investment opportunities for both institutional and Main Street Investors.” Additionally, Clayton highlighted that the SEC is, “Focusing a significant amount of attention and resources on digital assets and initial coin offerings (ICOs).”
Maxim Akimov, the Deputy Prime Minister of Russia, announced that no significant changes will be made to the draft of a bill concerning cryptocurrency regulation in the country, as per news outlet Finmarket. The bill was already approved by Russia’s parliament, the State Duma, in May 2018, although the bill has generated substantial discussion since. Since approval of the bill, all cryptocurrency and token-related terminology have been removed and replaced with the term “digital rights”. At the beginning of December, Pavel Krasheninnikov, Chairman of Russia’s State Duma, said that the bill needed to be, “significantly,” changed.
Pan Gongsheng, a deputy governor of the People’s Bank of China, highlighted that Security Token Offerings (STOs) in China are illegal while speaking at a summit in Beijing. As per a report by news outlet the South China Morning Post, Gongsheng told the summit that, “illegal financing activities through STOs and ICOs were still rampant in the mainland despite a nationwide clean-up of the cryptocurrency market last year.” In citing reasoning for the continued ban on STOs, Gongsheng explained that, “Virtual money has become an accomplice to all kinds of illegal and criminal activities.”
Pantera Capital, a blockchain and cryptocurrency-focused investment firm and hedge fund, is warning investors that as much as a quarter of their ICO project could potentially be violating US securities laws, according to a Bloomberg report. In a newsletter to clients, Pantera Capital warned, “While we believe the vast majority of the projects in our portfolio should not be affected, approximately 25% of our fund’s capital is invested in other projects with liquid tokens that sold to US investors without using Regulation D or Regulation S”
Russia has no intention of implementing Venezuela’s state-backed digital currency, the Petro, into commercial operations, according to a report by news outlet RIA Novosti. While speaking to reporters this week, Russian Deputy Finance Minister Sergey Storchak said, “Representatives from our tax service and central bank... got acquainted with the cryptocurrency Venezuela is introducing,” adding, “But no more than that. As for payments, they’re not happening yet.”
South Korea’s representative body, the National Assembly, held its first official meeting with seven of the country’s largest cryptocurrency exchanges on Monday. The purpose of the meeting was to debate cryptocurrency regulation between stakeholders of South Korea’s cryptocurrency industry. Cryptocurrency exchanges Bithumb, CobitCoin, Coinone, Upbit, Gopax, Coinplug, and Hanbitco were among the attendees of the debate, which reportedly focused on Anti-Money Laundering (AML) customer protections and Know Your Customer (KYC) procedures.
The United Kingdom’s Financial Action Task Force (FATF), an intergovernmental financial security body, is calling on the country’s government to increase monitoring of cryptocurrency markets. According to an official report last week, the UK must overhaul its Anti-Money Laundering (AML) and combat terrorist financing (CFT) efforts in order to prevent illicit activities with cryptocurrencies. “Virtual currency exchange providers are not yet covered by AML/CFT requirements,” the report details, adding, “this is an emerging risk and there is not yet evidence to suggest that broad scale ML/TF is occurring in the UK through this relatively small sector.”
The United States Commodity Futures Trading Commission (CFTC) is interested in learning more about the Ethereum (ETH) network, its technology, and the markets build around it. On Tuesday, the CFTC published a Request for Input (RFI) that requests the public’s feedback on different questions concerning Ethereum. The RFI explains that its goal is to inform the CFTC about Ethereum and similar emerging technology, saying, “The input from this request will advance the CFTC’s mission of ensuring the integrity of the derivatives market as well as monitoring and reducing the systematic risk by enhancing legal certainty in the markets. The RFI seeks to understand the similarities and distinctions between certain virtual currencies, including here ether and bitcoin, as well as ether-specific opportunities, challenges, and risks.”
The United States Securities and Exchange Commission (US SEC) is ordering that cryptocurrency asset manager CoinAlpha Advisors LLC pay a USD$50,000 fine, alleging that the firm conducted an unregistered securities sale. After forming in October 2017, CoinAlpha raised more than USD$600,000 from investors to invest in digital assets. In an official release, the US SEC said that CoinAlpha did not file a Notice of Exempt Offering of Securities, meaning that the firm breached securities laws by soliciting securities investors. Additionally, the firm allegedly did not adhere to proper know-your-customer procedures to verify that investors were accredited.
Venezuela is reportedly beginning to convert its citizens’ monthly pension payments into Petros, Venezuela’s controversial state and oil-backed cryptocurrency, according to a report by local economics blog the Caracas Chronicles. The conversion of Venezuelan pensioners’ payments into Petros came after the country already sent pensioners their monthly payment in the form of a check for Venezuelan Bolivars -- normally, upon receiving their check, pensioners would deposit their funds into a bank account where they could then withdraw fiat from local branches. The Venezuelan government, however, converted pensioners’ fiat payments into the Petro upon their deposit into a bank. In the first few weeks of the Petro’s existence, its value has risen from 9,000 to more than 15,000.
Warren Davidson, an Ohio Congressman and notable advocate of blockchain and digital assets, is floating blockchain technology as a solution to fund US President Donald Trump’s prospective US-Mexico border wall. While interviewing with NPR, Congressman Davidson suggested, “the American people, or whomever should choose to donate,” could pay for the border wall, adding, “you could do it with sort of like a crowdfunding site or you could do a blockchain and you could have WallCoins.”
“The long-term value of Bitcoin (BTC) is more likely to be USD$100 than USD$100,000,” says Kenneth Rogoff, a former Chief Economist for the International Monetary Fund (IMF) and the current Harvard University Professor of Economics and Public Policy. While writing an article for major UK news outlet The Guardian, Rogoff highlighted that, because BTC’s use is limited to transactions, it makes the digital asset more vulnerable to a bubble-like collapse. Rogoff also cited that BTC’s energy-intensive verification processes is, “vastly less efficient,” than systems that leverage, “a trusted central authority like a central bank.”
A new report by PeckShield, a blockchain security company that monitors various cryptocurrency ecosystems, details that decentralized applications (DApps) on the EOS (EOS) blockchain have lost as much as USD$1mm in hacks since July 2018. The report details further that DApps on the EOS network have sustained 27 breaches since July, which are responsible for the up to 400,000 EOS that have been compromised from hacks. Guo Yonggang, a blockchain security expert cited in a report on the matter by crypto media firm Blockchain Truth, believes that the hacks can be attributed to security problems with the DApps themselves, rather than with the EOS network.
A new study published by the Cambridge Centre for Alternative Finance on Wednesday finds that the number of unique ID-verified cryptocurrency users nearly doubled in in the first 3 quarters of 2018. The study details that total ID-verified users increased to 35mm in the first three quarters of 2018 from 18mm at the end of 2017, representing an increase of 94%. As per an analysis of the study by Bloomberg, the growth of crypto’s userbase despite the market decline, “could signal that an eventual recovery could be coming.”
Amid the continued cryptocurrency sell-off, only two cryptocurrency mining machines remain profitable, according to real-time data from ASICMinerValue.com. ASICMInerValue.com, which calculates the profitability of Application-Specific Integrated Circuit (ASIC) miners, indicates that only indicates that only the Ebank Ebit E11++ and ASICminer 8 Nano 44Th mining models are profitable for mining cryptocurrencies based on the SHA-256 hash function -- notable cryptocurrencies like Bitcoin (BTC) and Bitcoin Cash (BCH) use this has function.
Bitmain, a large Chinese cryptocurrency mining firm, announced that it is closing its development center in Israel, citing current cryptocurrency market conditions. In closing Bitmaintech Israel, the crypto mining giant was forced to fire all 23 employees. Among the employees let go is Gadi Glikberg, head of Bitmain’s Israeli branch and Vice President of International Sales, who said on the recent market turmoil, “The crypto market has undergone a shake-up in the past few months, which has forced Bitmain to examine its various activities around the globe and to refocus its business in accordance with the current situation.”
Busan, a major South Korean city, will be the beneficiary of the South Korean government’s plan to spend 4bn Korean won (USD$3.5mm) to establish a blockchain-enabled virtual power plant (VPP). As per a report by South Korean news outlet Yonhap News Agency, the project will be angled as a national competition in 2019, hosted by South Korea’s largest electric utility, Korea Electric Power Corporation (KEPCO). The VPP will integrate the idle capacities of multiple energy resources through a cloud-based distributed ledger in order to optimize power generation and decrease costs.
Church’s Chicken, a large international fast food franchise, is partnering with Dash Venezuela to accept cryptocurrencies in its Venezuelan locations. According to an official press release, 13 Church’s Chicken establishments will begin accepting Dash (DASH) as payment following, “extensive and rigorous days of training,” staff to understand cryptocurrencies. With the addition of Church’s Chicken, more than 2,200 establishments in Venezuela accept DASH as payment.
Crypto.com, a Hong Kong-based cryptocurrency payments platform, announced the appointment of former PayPal executive Tyson Hackwood to serve as the firm’s Vice President and Head of Global Merchant Acquisition in an official press release today. Crypto.com aims to increase cryptocurrency adoption by both merchants and consumers through their point-of-sale (PoS) transaction terminals. Crypto.com CEO Kris Marszalek believes that Hackwood will be integral in furthering this goal, saying, “As we develop the Crypto.com Chain to fulfill the current industry need to pay and be paid in crypto, Tyson will play an important role in expanding the number and quality of merchants that are part of our network.”
Hyperledger, a notable blockchain consortium, is continuing its robust expansion after announcing the addition of 16 new members at the Hyperledger Global Forum in Basel, Switzerland. Among the notables to join the consortium are, Alibaba Cloud, Citigroup’s Citi Ventures arm, and Deutsche Telekom. The latest addition of 16 members brings the total membership of Hyperledger to more than 260 different companies. In a public statement, Hyperledger Executive Director Brian Behlendorf said that, “The growing Hyperledger community reflects the increasing importance of open source efforts to build enterprise blockchain technologies across industries and markets. The latest members showcase the widening interest in and impact of DLT and Hyperledger."
Jeremy Henrickson, the former Chief Product Officer at Coinbase, has departed the US-based cryptocurrency exchange after serving since July 2016. “Jeremy’s contributions to Coinbase over the past two years were invaluable,” said a Coinbase spokesperson, adding that, “he helped to build our scrappy startup team into a high-functioning product and engineering organization -- overseeing a 5x+ growth of the team.” Henrickson’s departure comes after long-term Coinbase executives Adam White and Hunter Merghart left the US-based cryptocurrency exchange in recent months.
LinkedIn’s, “2018 U.S. Emerging Jobs,” report released on Thursday ranks the role of blockchain developer as the fastest growing job in the United States. The report by LinkedIn indicates that blockchain developer jobs have increased 33-fold in the past 12 months alone. San Francisco, New York City, and Atlanta are among the cities with the highest demand for blockchain developer jobs.
Orbs, a unique hybrid blockchain platform, raised more than USD$15mm in cryptocurrencies to fund its development of a public blockchain, according to a company blog post. South Korean application provider Kakao lead the fundraising efforts with a representative telling CoinDesk that the company, “always seeks to invest and support innovative startups, and Orbs is a good example.” In total, Orbs raised 139,000 Ether (ETH) and 892 Bitcoin (BTC), amounting to roughly USD$15.4mm. Orbs aims to build a public blockchain with this funding that is, “universal,” and, “scalable,” for decentralized applications (DApps) with the, “liquidity of a base layer.”
Samsung has reportedly filed patent applications for three different blockchain-related trademark requests that all pertain directly to smartphones, according to news outlet Galaxy Club. Specifically, the patents named “Blockchain KeyStore”, “Blockchain Key Box”, and “Blockchain Core” all pertain to cryptocurrency custody capabilities on smartphones. This news comes amid the release of HTC’s Exodus 1 and Sirin Labs’ FINNEY, both of which are being marketed as blockchain smartphones with cryptocurrency custody capabilities.
Hello! My name is Kristina Semenova, I am the Head of Investors Relation Department at Platinum, the world’s number one business facilitator. Our team knows how to start ICO/STO in 2019! Why are we so sure? Well, our experience speaks for itself: Platinum.fund But what is the difference between ico and sto? What is the cornerstone of ICO marketing strategy? You will know this after finishing the UBAI courses! Here’s just a quick preview of our Short Course lesson. Real World Examples Multinational accounting firm Ernst and Young found that $400 million of the $3.7 billion USD raised from ICOs (as of January 22, 2018) had been stolen. That is, up to 10% of all ICO funding is virtually being stolen from investors. Though ICO scams are the most common method of theft in the crypto world, some projects will actually operate for a period of time before disappearing with the money. Like in a Ponzi scheme, an exit scam may be planned for later, sometime after a manipulated pump; or some other time the team believes is most opportune to take the money and run. Giza: Giza marketed itself as a platform within which different cryptocurrencies could be stored securely. But after raising $2.4 million in one month, the team deleted the website and stopped replying to emails. Investors were duped by a very convincing whitepaper, and actors had been hired to appear in photographs promoting the project. No investor funds have ever been recovered. Centra: The SEC put an end to fundraising for the Centra ICO and charged the founders Robert Farkas and Sohrab Sharma with orchestrating a fraudulent ICO after they raised $32 million USD. They were promoting the ability to develop financial products backed by VISA and Mastercard, though it was later found that neither partnership was real. One of the major red flags in the Centra project was the use of celebrity endorsements for publicity, reportedly paying champion boxer Floyd Mayweather a significant sum to promote their project. Who wants to leave their Blockchain investment decisions up to Floyd Mayweather, regardless of his unbelievable skill as a boxer and regardless of his own financial success? He should still not influence where you invest your money! Ponzi Schemes: Bitconnect: This is the most infamous Ponzi scheme in the history of cryptocurrency, and certainly the most damaging. Bitconnect was a Bitcoin-based project that rose to an all-time high of $463 per token on the back of a fictitious trading bot. The Bitconnect scam operated by paying dividends to users, proportional to the number of tokens they held and the number of referrals they made. The BCC tokens were exchanged for the users’ Bitcoin, and the highly sophisticated and wildly successful trading bot would trade BTC for them and distribute profits as dividends. The value of the dividends offered was approximately 1% of the initial investment per day. In other words, that is approximately 3,780% per year in cumulative gain! The referral system was capitalized upon most heavily by many of the biggest crypto YouTube channels, including CryptoNick and Trevon James, both of whom are now under investigation by the Federal Bureau of Investigation. Shortly after the Bitconnect Token reached its all-time high, they received cease and desist orders from the security regulators of Texas and North Carolina, which caused the owners of the Bitconnect exchange to shut down operations, and the price to plummet. Davorcoin: Davorcoin was a lending platform very similar to Bitconnect. And Davorcoin was farcically promoted by the same Trevon James crypto Youtuber who promoted Bitconnect, and is currently under investigation by the FBI for promoting Ponzi schemes. The Texas State Securities Board, in likening Davor to Bitconnect, stated that “DavorCoin is telling investors they can earn lucrative profits by investing in a lending program based on a new cryptocurrency known as davorcoin. Investors allegedly purchase davorcoin and then lend it to DavorCoin”. Davorcoin promptly plunged from an all-time high of $180 to very close to zero after a cease and desist order was made against them on the 2nd of February 2018. Useless Ethereum Token: Despite brazenly stating in the name of the project that the token has no use, the UET managed to raise $340,000 in its crowdsale, and saw a significant pump of over 300% on the HitBTC exchange in February of 2018. The scam was an obvious case of pump and dump, with the total trading volume for UET crashing back down to as low as $3 per day, after reaching as high as $350,000 per day during the pump. It is currently an unfortunate consequence of the decentralized nature of cryptocurrency, but there is a distinct lack of recourse for scammed investors. It is wise to become as well-acquainted with the various indicators of good and bad ICOs as you possibly can. In weighing the factors that will allow you to avoid expensive mistakes, ask yourself in whose favor are the terms of the ICO slanted, yours or the teams? To what extent are you actually likely to profit from this investment? Cryptocurrency is inherently a grey area, whether you are investing in it or not. Investing is another inherently grey area, no matter what the area or object of investing might be. Laws and regulations are not always able to keep up. Trying to define and prove what was or was not a scam is not likely to be as simple as the scammed investor would want it to be. A project can be set up in certain ways to avoid being technically classified or provable as a scam, but the unprepared investor can still be burnt or scammed just as badly. Now we look at more individual indicators that can help you form a valid impression whether or not an ICO or even a fully-fledged exchange-listed coin is a scam or a bona fide investment opportunity. Common Signposts Contrasting Scam & Legitimate Projects Presale Bonus/Token Release If the ICO allots massive bonuses to team members, you may leave yourself open to getting dumped on by presale investors if you buy when the project tokens are listed on an exchange. Likewise, if the project has a short lock-up period for developers and founders, you run the risk of them selling as soon as the token is listed on a major exchange. The token release schedule for the founders of a worthwhile project should show long-term team commitment to that project. The Jibrel Network team tokens will be locked up for 5 years before release, and they had no early investor bonus in the main sale. Both of these factors instilled confidence in the JNT ICO investors, and the tokens were sold out weeks before the ICO was due to end. No Presale lock up If Presale investor tokens are not locked up at all for any period after listing, that could easily be a set up for an exit scam after the initial listing. No presale lockup for early investor tokens is a crystal clear warning, the project may be fatally rigged toward those in the inner circle, with little commitment to the long term health or success of that project. Unsolicited Offers or Unasked for Additions to Groups Characters running scam projects will often add you to Telegram groups out of the blue or send you unsolicited emails with information about their project. Telegram is the most widely used messaging app in the cryptocurrency community and you should familiarize yourself with it to keep yourself in the loop for specific projects in which you invest as well as all kinds of other relevant crypto info. You can adjust the settings on the Telegram app to disallow anonymous additions to cryptocurrency projects if you find yourself bombarded with offers by scammers. Reputable projects at the ICO stage will spread by word of mouth, or by eloquent and meaningful articles posted on their Medium page. A project with serious potential does not need to actively seek participants for their ICO like that. They will often be able to fill their ICO hard cap in a matter of hours, or even just minutes! Anonymous Team Alarm bells, again, immediately, if the project has minimal online presence. The individual team members could be mere fabrications. The entire project could be a farce by utterly inexperienced characters. What if the project leaders are simply unaware of the importance of a strong social media profile? That in itself would be too strange to ignore. Top-level projects will have team members with experience in crypto and the LinkedIn accounts for those members will be easily accessible right there on the project website. You should be able to easily see and evaluate each individual’s experience in their field and ascertain what they bring to the project team. Bitconnect’s anonymous team should have been the only deterrent prospective investors needed to discourage them from putting money into that doomed project. Ethhorse, a current project with anonymous founders and operators should be steered clear of at all costs for the same reasons. Community Atmosphere The subreddits or Telegram groups of scam projects will often feature moderators that do not allow any kind of criticism in the group chat. If, in the process of your due diligence, you encounter didactic admins that only wish to silence your questioning of certain aspects of the whitepaper or mechanism of the tokenomics , you should be concerned. Similarly if you see a coherent critical reply attacked by many different users who refuse to engage the substance of the point being made, that may be a subreddit infested with bots. Projects that have nothing to hide will allow free debate in the chat. Ideally, they hope to develop a positive community that is itself an asset to the long-term success and overall strength of the project. Good projects do not need to automatically brand all criticism as Fear Uncertainty and Doubt (FUD). Whitepaper One common tactic of scammers is to produce a whitepaper that uses too many buzzwords, and deliberately obfuscates and overcomplicates the explanation of the problem and/or its solution. A good whitepaper clearly and concisely lays out the problem and answer, as well as provides compelling arguments why a Blockchain solution is preferable to the current solution. Another point of concern is a whitepaper that gives unrealistic time frames and goals. Bitconnect’s almost comically optimistic profit projections are a prime example of this, as are the 1,354% yearly gains promised by Plexcoin. Respectable projects will set out development timescales in terms of quarters or years, rather than offering immediate profit projections, which are simply a red flag. Advisors/Connections in the Cryptoworld The most prestigious projects will already have partnerships made before the ICO stage, and the worst ones, i.e. the scams, will not mention any such partnerships. Icon (ICX) for example was spawned from a South Korean project named The Loop, a collaboration between 3 Korean universities and the DAYLIFinancial Group. They boasted an advisory panel consisting of the legendary investor Don Tapscott, Jehan Chu and crowdfunding expert Jason Best. On top of a solid team of advisors, good projects will also be visible at major Blockchain events such as the Consensus, and the World Blockchain Forum, etc. Scam projects will be unable to inspire this same level in confidence. As an investor, you should sense a certain presence and expect a certain feeling of trust that should guide you in your investments. After all, it is actually a people-to-people thing you are doing. Key Stress points upon the Timeline to Identify Scam Projects Post Whitepaper Release The period in the immediate aftermath of the release of the whitepaper can also be decisive in establishing the validity of a project. How a team copes with the roadmap that they have laid out for themselves is key. Valuable insight into the operational efficiency and commitment to the project can be gleaned from the quality of and amount of code committed to GitHub. If you have any experience in computer programming you can see how clean and orderly the code is, which gives insight into the skill of the developers, and in turn the quality of project leaders’ decision-making in hiring team members. Scam projects will have little or no code committed to GitHub, or at best it will be copied and pasted from other projects just to cover their tracks. Start of ICO Sometimes, a scam project, or other project in which you would be better off not investing, will change the terms of the ICO just before the ICO starts. The Key (TKY) ICO doubled the price of tokens on the day before the ICO was due to take place, because the price of NEO had risen so drastically. Currently, the TKY token price is still only half of its ICO price. Initial investors are faced with the prospect of a 50% loss on their investment. Exchange Listing Some particularly greedy scammers will create a scam project with the intent of selling tokens in the ICO for BTC and ETH, and then pumping and dumping their share of the tokens immediately after listing. The team of fraudsters behind Monero Gold used this method after the crowdfunding of their useless ERC-20 token. After listing on CoinExchange.io, the team dumped their tokens until the exchange finally ceased trading. Although it is not uncommon for ICO tokens to sold after listing (just like can happen with shares of stock after an IPO), if the price does not stabilize and massive sell walls are continually placed, a scam is likely taking place and the token is being dumped. Fake Ethereum Twitter giveaway You may have noticed Ethereum creator Vitalik Buterin’s twitter handle has been changed to Vitalik “Not giving away Eth” Buterin in recent months. This is because a group of devious scammers had created fake accounts with almost exact replicas of his profile (deviating by only one character). The fake accounts promised to deposit 1 whole ETH for every 0.1 ETH the potential sucker deposited into the wallet address provided by the scammer. These fake account “Ether giveaway” scam tweets were set up to be sent in just a matter of seconds after the real person tweeted, and usually always appear immediately after the tweet of the real public figure. Fake bot profiles then came into play, thanking the fake Vitalik, or fake Elon Musk, for holding up their end of the bargain and depositing the ETH as promised. One scammer, or group of scammers, managed to fill a wallet up with almost $20 thousand worth of ETH, which they transferred out, never to be seen or heard from again. Effect of Scam Customers, Upon the Affected Parties Of course, this is no fun for the targeted public figure either. They need to take steps to avoid being targeted again. This will mean changing their handle, their username, or making their accounts private. However, the injured party with whom we are most concerned is the unfortunate scammed social media user, who has no chance whatsoever of getting his or her funds back, ever. It is a harsh lesson to learn. But it is a fact of crypto reality. Nearly every one that trades crypto will at least be exposed to frauds or scams in one way or another. In this case, we think it is better to learn about scams by studying them, rather than learn from your own unfortunate and expensive experience. In the case of Mr. Buterin, these incidents were awful public relations for the Ethereum project. It had only been a few years since cryptocurrency as a whole was primarily associated with criminality and seedy transactions on the Darkweb. Any connection with unscrupulous behavior is best avoided at all costs. Negative associations could have been particularly damaging for Ethereum’s brand because the vast majority of ICO fraud is committed using the ERC-20 token as the template for the scam tokens. Any and all the scamming or fraudulent behavior in the cryptocurrency ecosystem is bound to have a negative impact on the speed at which mainstream uptake finally takes place. Cryptocurrencies, as an emerging asset class, will be painted in the worst possible light. Crypto is aiming to, and is in fact in the process of, causing great disruption in traditional centralized finance and business. Mainstream media organizations are also part of that traditional centralized economy. Press coverage will be damning. Something is happening here, but Mr. Jones doesn’t know what it is. Legal Recourse for Scams We clearly understand, there is a possibility of being scammed. We know the scams are happening. The SEC has made some arrests and actually charged people for operating fraudulent ICOs. But it is a struggle to deal with the flood of ICOs coming from anywhere at any time. The SEC filed charges against two founders of a purported financial services startup for orchestrating a fraudulent ICO that raised more than $32million from thousands of investors. As you know from the ICOs we have covered so far, the lack of regulation allows for direct contact and dealing between the entrepreneurs, business owners and potential investors. While we believe this is a blessing according to the founding principles of Bitcoin and other alternate Cryptocurrencies, because it frees us from traditional roadblocks, middle-men, and all kinds of time-consuming procedures; it also leaves investors in a place where there is often little to no hope of ever recovering funds lost in fraudulent schemes. Actions after a Successful ICO Good post-ICO practice is characterized by stringent security, well thought-out legal strategy and clear communication. Many projects have paid the price in damage to their reputation for failing to adequately guard customer information, leaving themselves open to phishing attacks by fraudsters. Investors in the Enigma project had half a million dollars stolen from them; and a whopping $8.4 million was defrauded from investors in Veritaseum via phishing attacks. After a successful token distribution, the team’s main focus is initially on switching the enterprise from one primarily focused on fundraising, to superficially at least, a fully-fledged, functioning business. This involves removing most of the token sale-related content from their main webpage, sending newsletters to all successful ICO participants, and sending refunds to those who may have missed the deadline or the hardcap. Then, with the stressful and complicated fundraising stage finally concluded, a portion of the funds raised can be assigned to fuel the growth of the project community. This can involve hiring community managers, forum admins, and social media managers to outsource the job of keeping investors in the loop. The founders can focus on growth strategy and product development. The cultivation of a thriving and energetic community is extremely important. The community will give you free marketing for your product and your business. Community members who believe in the project, and are engaged by professional moderators, can give you very effective promotion to other prospective investors. Communication with community members is a great way to test ideas and gauge sentiment related to various aspects of your project. The project leads must set aside adequate funds for lawyers. The project will need to address potential future or imminent problems with regulators, at the very least. The transition from fundraising project to full-fledged business can be incredibly challenging, and even more stressful than the ICO itself. The main thing to remember is that your pre-sale and ICO investors are not just silent investors waiting for a return. They are the early adopters of your solution, of your product; they are the community and promoters of your project; and they are the individuals with a vested interest in the financial success of your venture. The ICO environment is not as heavily regulated, so quarterly and/or semi-annual reporting is not required the way it is in the traditional world. That means your own style of effective communication about the progress and key developments on your project matters even more. In the ICO world, you communicate with your press releases, social media, and Medium posts. You also communicate by the very nature of your relations with your exchange, and relationships with your cornerstone investors. Effective communication and good business relationships can play a prominent role in the success or failure of your venture (by token liquidity and valuation). If your investors start to lose interest, and stop trading your token on the exchange, liquidity will dry up and cause increasingly volatile price swings. You need to keep certain things in mind, and follow effective practices to maintain a happy and motivated community. Social Media & Medium In addition to your website, your social media & Medium blog most likely formed a significant part of your ICO preparations. Your purpose pivots after the ICO from one of promotion to one of communication. Consistent, informative and material Medium blogs, also Facebook and Twitter updates, ensure that investors remain engaged and well-informed of what the company is up to. Frequent activity in this space makes investors feel much more comfortable. You can foster a kind of organic community expansion that is consistently advertising your project to potential new members. Cornerstone Investors & Exchanges As we mentioned, your relationship with investors in the ICO world is different from that of the traditional silent IPO minority equity partners. Consistent, Transparent & Honest communication is incredibly important here. Even if an ICO is struggling to overcome a problem or whatever issues are occurring, honest communication from the team is key to business survival. You should think of and treat your exchange like a business partner too, a very important one at that. Exchanges provide liquidity for you and your investors. That liquidity is like the blood for your business. Many top exchanges demand nothing less than absolute honesty and integrity, it is imperative to maintain strong and comfortable relationships with exchanges. Everything we have said so far, also applies to your Telegram channel and forums too. These give you another great opportunity to build a thriving community. Team members and investors can enjoy lively debates in their Telegram channels. This can be constructive discussion, or critical commentary too. But it is always valuable as a direct link between the team and the community. It is always good to know how people are feeling and what they expect from you and your project. You are able to use your Telegram channel and forums to consistently adapt your marketing and communication strategy. Keep your investors as happy and comfortable as possible, and you will be more likely to attract new investors and allocations. Other forums around the internet operate more or less in the same manner as Telegram. After a successful funding round with the hardcap reached and time to spare, legal counsel has been secured, and the community is flourishing, the team will prepare for their first listing by paying the exchange fee and waiting for the announcement by the exchange. Unless they are willing to pay exorbitant fees for an immediate listing on Binance for example, teams will usually settle for an initial listing on a second-tier exchange. The fee charged by an exchange depends on many different factors that we will cover in more detail in the next section. ICO Company actions after a Successful ICO Real World Case Study The Basic Attention Token (BAT) project, when used in conjunction with the Brave Browser, allows users to pay micro-fees in BAT to their most-used sites. The idea was conceived by Brendan Eich, the inventor of Javascipt and former CEO of Mozilla Firefox. Investors absolutely pounced on it at ICO and the project raised an amazing $35million in under 30 seconds. The BAT/Brave project has delivered on time on nearly all of its targets, helped in no small part by having a working product, the Brave Browser, for over a year before the token launch. The project secured a listing on the premier exchange, Binance, in November 2017. A project can suffer through a disappointing funding phase and, for example, fail to reach 75% of its hardcap. The team will be only partially funded. Though they may be able to initiate the project, the value proposition of the token has been compromised, potentially forever. The market has spoken. There is limited faith in the team’s ability to complete or carry out their project. Failure to reach a hardcap is a serious obstacle on the project road map. This will mean massive revisions to the timescales for development and listing. Such a project may have to be content listing on decentralized exchanges for a period of time and they will lose any post-ICO hype that could have helped the project price to “moon” early on. There is less money to be allocated. Each section of the business will be underfunded compared to the original plan. There can be delays in code development, exchange listing, marketing and community development as well. Calling the Tezos ICO a disappointment might seem strange considering they raised over $232million. But this open-source, smart contracts fintech platform became a victim of its own success post-ICO by devolving into multiple class-action lawsuits between the founders and its foundation chairman. They suffered from a distinct lack of clearly defined roles and expectations on key positions. There was infighting at the boardroom level. This all caused an as yet unresolved delay in listing and development. This is also one example why a capped ICO can be more desirable for investors than an uncapped ICO. If the team have a set amount of capital to work with, an amount that isn’t absolutely ridiculous, like in the case of Tezos, perhaps the resultant greed and discord is less likely. Although it may not be so easy for speculative investors to make a profit from an uncapped ICO with such a massive initial market cap, it is a very impressive feat of fundraising nonetheless. Tezos’s post ICO market cap of $232million is already 64th of all projects, and would have to perform brilliantly on listing to maintain this position. Company actions after a Failed ICO Failed ICOs can mean either fundraising initiatives that have failed to reach the softcap and will therefore not be economically viable, or fraudulent projects whose sole intention was to steal from investors and do an exit scam. We’ve already covered scams and fraud projects in detail, but what happens when an ICO just fails to raise the requisite funds? Projects that are legitimate, with honest founders and developers, refund the ETH or BTC deposited by investors as quickly as possible if the softcap is not reached. The same process that is followed by ICOs that are oversubscribed is employed by those that have failed to raise enough capital. The process of returning funds back to the sender ideally should take a period of days, but more likely will take a few weeks. The Sappy Network, advised by Dan Tapscott, failed to come anywhere near to their funding goals. They are currently in the process of sending all investor funds back to the wallets from which they came. The statement from the founders read as a textbook example of how you should react to failure with the founder stating “In the spirit of transparency and honesty, we are sharing with the community that we did not reach the soft cap, and thus we will be honoring our terms and conditions and returning the Ethers to all contributors” Exchange Listing A bottleneck developed in the ICO market after the explosion of crypto prices in 2017. There was a massive increase of ICO teams on all stages along the pathway from start-up to fully listed crypto asset. Certainly, a huge part of the value proposition for both the token and the project depends on securing a listing on an exchange. It is precisely the liquidity of the token as a valuable asset on a free market exchange, that determines or even defines its value. The liquidity is what makes tokens attractive to investors, but that liquidity simply does not exist without a platform for the exchange. Unfortunately for new projects, the balance of power is heavily weighted in favor of large centralized exchanges that can pick and choose which tokens to list, and the timescale within which listing will occur. Each large exchange has its own list of pros and cons as well as its own specific procedure for coin/token listing. They also have their own particular ethos regarding the type of projects they prefer to list. ERC-20 tokens will be available for trade immediately on decentralized exchanges (IDEX Forkdelta) but those platforms are generally quite low volume, and certainly not a long term solution. Projects must often pay huge fees to be listed on the larger centralized exchanges. At first those fees will be prohibitive. The usual route is to initially list on a more reasonably priced smaller exchange like Kucoin or Gate.io. Listing Process Major centralized exchanges have the power to list anything they want, and they also each have a unique structure that projects must adhere to if they wish to be listed. Each potential new listing will undergo a rigorous examination by the exchange operators to test the feasibility for listing the token. An exchange will likely have forms available on its website that you can fill out to give them all the necessary initial information. If a particular project and token qualify for listing, the team will invariably be put under a NDA, Non-Disclosure Agreement, to avoid any insider trading or other regulatory problem s. In the case of larger exchanges like Binance, there is a period within which owners of a newly listed coin or token can transfer them to the exchange in preparation for trading. This is a fantastic opportunity for traders to make use of the likely pump that occurs after a new token is listed on a large exchange. It is common to see up to 100% increases on the first day of trading, and a subsequent dump of up to 50% or more can follow. This allows traders holding the coin already, to sell for a good profit, and maybe buy back in at a much lower price too, if they think that is a good idea. Exchange Fees There are no definitive figures available to the public regarding fees that major exchanges charge new projects to list. Binance, Bitfinex, Kraken and Bittrex have all been quoted as saying that they do not charge any fee at all but this is almost definitely untrue. Knowledgeable industry insiders estimate between $500,000 and $1,000,000 USD for listing on a top-tier exchange. (There have been more rumors of 7 figure exchange listing fees since January 2018 too). This figure will vary greatly from project to project. Various factors can affect how an exchange determines the fee for a particular project. These are some of the most important ones: Market Maker Service Required Whether or not the client project requires liquidity services directly from the exchange, or can connect proprietary ones via API, will lead to a huge reduction in listing cost. Type of Token (ERC-20 NEP-5 or DAG) Not all tokens are created equal in the listing process. ERC-20 tokens and BTC based tokens have code architecture that will almost certainly be preferred by the exchange. NEO based tokens (NEP-5) such as Ontology will be far most costly to integrate because separate new wallets have to be built to facilitate NEO transactions. The costs involved in integrating Direct Acyclic Graph projects such as Nano into the exchange structure are even worse. Expected Daily Volume Exchanges derive their profits largely from transaction fees and withdrawal fees. The trading volume a new token is likely to bring in will have a great influence on the computation of the exchange listing fee. Exchange Listing Procedures Evaluation Different exchanges have different rules for new listings. A new project must of course abide by specific rules for that exchange before they are allowed to list there. There are procedures that must generally be followed for the most noteworthy exchanges. You can get a good idea of the hurdles to be overcome before listing can take place. Ongoing relationship with Exchanges Exchanges, usually Huobi or Kucoin, will sometimes make it essential for newly listed tokens to engage in “trading competitions” after listing. Competitions can last between 2 weeks, or a month or more, aiming to increase the trading volume for that token, thereby increasing trading fees collected by the exchange, and giving the project extra publicity too. The whales may have made a nice profit already and be very happy about it; but the project token can still get stuck in a long period of stagnation and a loss of post-ICO hype. Once a coin or token has been successfully registered for trading on a particular exchange, the project must focus on maintaining regulatory compliance and paying things like annual maintenance fees too. Exchanges can investigate and delist coins or tokens to see if they have fallen below a certain standard set by the exchange. The exchange is concerned about such things as: an extended period with an extremely low volume; a team member connection to an exit scam; or other such immoral/illegal behavior. Post ICO Company Evaluation After a presumably successful ICO, the necessary funds have been obtained, and the real business, the real team challenge is now, to bring the project to life as a bona fide disruptive Blockchain endeavor! The core advantage of the ICO method of funding business startups is the lack of regulatory hurdles to navigate with regards to fundraising and fund allocation. The funds that have been raised have, in effect, been freely given to the project leads to do with what they will in a no-strings-attached transaction. Of course, there are still strings attached in that the team are tasked with making that money grow for the investors. But there is no regulatory oversight of the process. The regulatory freedom is a double edge sword. It gives a good team freedom to work however they want; and it also allows for unscrupulous thieves to use the ICO process to defraud investors of their ETH and BTC. Advantages of being Post ICO From Investor Perspective You should have little to fear in terms of fraud from a project in which you have invested, if you have done your due diligence correctly. You can expect the tokens to be distributed, and the exchange listing to take place as expected. And you know your project is totally legitimate. There are different ways to think about your ICO tokens after the crowd sale has concluded. If you are a speculative investor looking for a quick flip, you can gauge the correct moment and sell anytime you like, assuming the ICO has been well-received by the markets. From Team Perspective The post-ICO period is, from the point of view of the team, a period where stress and responsibility for the safety of investor funds is passed, in the form of ICO tokens, from the team to the investors themselves. This responsibility for tokens is replaced with the stress of building the actual company itself, and succeeding in the business as planned. A small portion of the responsibility for the project’s success is also passed on to the exchange that has listed the tokens. This is especially true if market makers have been employed by the team or the exchange to provide liquidity. After the ICO has concluded, all funds are released to the project team immediately, so they can start building their business brand, and tackling each step on the road map right away. The freedom with which startups can operate is one of the main reasons behind the explosion in Blockchain businesses in 2017. With the ICO funds safe, and money being put to work on various areas essential to the growth of the project, and the tokens already distributed to investors, the risk of fraud is greatly diminished. If KYC and Anti-money Laundering procedures have been followed correctly during the ICO phase, the risk of phishing attacks and theft will also be marginal now. At any rate, with tokens safely delivered to all participants, the responsibility has passed from the team to the investor. From Team Perspective The release of all funds and the freedom to allocate them with no supervision, as cited above, is certainly a tremendous advantage empowering the team to fulfil the entire breadth of their vision unimpeded. But it does have its drawbacks. If there is a mistake made in the allocation of funds, or an unforeseen problem arises, there is nowhere to turn to, and no means of generating further money via crowdfunding. The ICO is over; it is finished. The project simply has to work with what it has. Your community can sometimes turn against you when the market is going down. Times like that just add to the already intense pressure of presiding over a startup Blockchain business. Solution: DAICO The DAICO, or Decentralized Autonomous Organization Initial Coin Offering, is a means to integrate a more specific, rigorous and regimented smart contract schedule into the ICO process. Doing so will eliminate fraudulent ICOs, exit scams, pump and dumps, and many of the other disadvantages listed above. The DAICO method, proposed by Ethereum creator, Vitalik Buterin, will merge the core concepts of both an ICO and a DAO to leverage the most relevant features of both, in order to solve the main problems in the ICO method. For example, to eliminate the risk of an exit scam, the release of funds will be spread out over a period of time, with the next allotment only being released when a certain set of parameters are met. Buterin explains that the DAICO method will provide user protection in a manner not present in the current ICO model, ensuring funds are not misspent or used in any way contrary to the intention of investors. In simpler terms the DAICO will operate as follows: The DAICO will start with a smart contract by its executors that can set whether this is to be a capped or uncapped round of fundraising (amongst many other options) as well as including KYC requirements. After these settings have been configured, the DAICO is set into “contribution mode” and presented to the public. This stage will function identically to a normal ICO with ETH exchanged for project tokens. Once the funding period has elapsed, or the hardcap has been met, investors will have the ability to set the “tap” for the collected funds. This will set the amount per second, or amount per minute, that will be available to the executor to develop that specific portion of the project to which those funds have been assigned. If investors believe at any point that the team is misspending funds or otherwise wasting time, etc., the investors have significant options to take. Of course they could choose to release more funds to the team. But, they could also stop the tap altogether, and stop the entire ICO, by voting, and actually release all unused funds back to their own wallets from which the investment had first been made! Learn more on how to market any ICO and STO, get better understanding of security token definition and learn what a scam project is! Follow the link to read the full article: UBAI.co Contact me via Facebook or LinkedIn to know more about our services: LinkedIn Facebook
As the efforts of law enforcement improve with greater experience, it seems likely that this trend will continue. Related Reading: Is Venezuela’s Bitcoin Stash Really So Bullish for BTC? Featured Image from Shutterstock. The post Binance Helps UK Police Bring $50M Crypto Criminal to Justice appeared first on NewsBTC. Binance, the world’s largest crypto trading platform, has recently aided UK authorities to identify and arrest a Bulgarian criminal. A Bulgarian Phisher . The cryptocurrency industry has attracted plenty of criminals over the past few years. Most of these individuals see Bitcoin and select altcoins as viable tools to launder money. Thankfully, it seems exchanges and other service providers ... As part of our coverage of the Crypto Crime Cartel plaguing Bitcoin, we posited that Binance, its owners and its employees had been doing more than enough to draw the same prosecutions now facing BitMEX personnel. We pointed to the fact that Binance has repeatedly moved offices in order to stay ahead of broadening regulatory […] At this point, Bitcoin isn’t widely spent due to Gresham’s law, which states that bad money drives out good money. What this means is that, when presented with two kinds of currency, individuals will be inclined to spend the inferior one and to hoard the superior one. Users of Bitcoin prefer to spend fiat currencies, as they have little faith in their long-term survival. They hold (or Craig Wright’s Ramblings: Everyone Using Bitcoin And The Lightning Network Are Thieves, Binance Is A Criminal Cartel, Bitcoin Is Breaking The Law And Will Be Sued. Posted by Zachary Mashiach Apr 3, 2020. Craig Wright runs his own blog which is filled with anti crypto space ramblings. Right off the bat, the tagline for the blog is “Bitcoin SV is the original Bitcoin”, which is a solid ... Binance was then contacted by South Korean law enforcement in order to oversee the return of the funds from B.K.’s account. They obliged and ensured the funds were returned to the victim before making B.K. aware of the fact that the situation had led to a criminal investigation. They were then contacted by law enforcement authorities in ...
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