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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.
¿Zelle vs Stablecoins? razones para NO usar Zelle en Venezuela
Zelle es una opción de pago inviable para Venezuela y aquí expondré los argumentos:
• Políticas, acuerdos y condiciones Zelle deja bien claro a la hora de firmar el contrato de uso que su plataforma NO es para uso comercial, ¿es por esa razón que los envíos son gratis no? , Zelle es un servicio para realizar pequeñas o medianas remesas ya sea para un familiar o para un amigo cercano, dejando en claro que queda terminantemente prohibido el envió de dinero a desconocidos. Es una plataforma solo para uso exclusivo dentro de EEUU, NO es una opción de envíos para remesas internacionales. • Titular / terceros En Venezuela el servicio de Zelle en algunos casos es inasequible para muchas personas puesto que no todos cuentan con los medios necesarios para hacerse titular de una cuenta bancaria en EEUU lo que provoca que muchas personas dejen de beneficiarse de dicho servicio y que la plataforma no se globalice en todo el país de Venezuela lo que limita el alcance del mercado. Esto a su vez conlleva que muchas personas se vean en la necesidad de manejar presta nombres , alquilar o pedir prestado cuentas Zelle de una tercera persona, lo que resulta incomodo y muy tedioso a la hora de querer hacer uso pleno sobre dichas cuentas. • OFAC (Oficina de control de Activos Extranjeros), Recurriendo al sentido común sabemos que el gobierno de EEUU seguirá ejerciendo presión para que otras instituciones bancarias sigan el ejemplo que tomo Wells Fargo el día 26 de Junio del presente año, hasta lograr el cese total del servicio Zelle para Venezuela. • Limites Zelle presenta limites en cuanto a volumen de transacciones y cantidad de las mismas, es decir, NO se puede enviar altas cantidades de dinero, ni se puede usar la plataforma de manera recurrente ya que según sus políticas se consideraría como "uso indiscriminado" de la cuenta, puesto que el envió de remesas hacia un familiar o amigo en teoría es algo que ocurriría de manera ocasional y no frecuentemente. • Estafas Zelle como plataforma en si, NO es una mala opción, malas son las personas mal intencionadas que usan la plataforma de manera inescrupulosa, quienes aprovechan las leyes de protección al cliente y al consumidor para manipular el sistema a su favor. Y los bancos al evaluar los casos y darse cuenta que uno de los involucrados es venezolano pues motivados por la presión de la OFAC terminan fallando en favor del estafador, lo que queda por entendido que ante cualquier inconveniente o disputa que se presente, siempre el venezolano tendrá todo panorama en contra. Desde aproximadamente hace 2 años muchos clientes venezolanos del Bank Of America se vieron perjudicados de manera arbitraria cuando se dieron cuenta que sus cuentas fueron cerradas y sus fondos congelados puesto que gran parte de las ocasiones cuando se recibe o se envía dinero no se tiene conocimiento sobre con quién estamos transando; un ejemplo típico, es cuando un venezolano encuentra alguna oferta para poder adquirir dolares por Zelle, la transacción se lleva a cabo con éxito, el vendedor obtiene los Bs y el comprador venezolano obtiene los dolares sin ningún contratiempo, pero el problema viene después, cuando este recibe la notificación con el mensaje que sus fondos han sido congelados y que el servicio de Zelle ha sido suspendido o incluso peor que su cuenta bancaria del Bank Of America también había sido cerrada de forma permanente. Esto sucede ya que estafar desde Estados Unidos a un venezolano es relativamente fácil, basta con solo realizar una simple llamada al banco y solicitar un chargeback al denunciar un cargo o una transacción NO reconocida vía Zelle, entonces, el banco al analizar el caso y fijarse que el receptor de la cuenta es un venezolano ya sea por su domicilio, pasaporte o por su conexión a internet , es decir por su IP, pues procede a fallar en favor de la supuesta víctima, quien en realidad es el verdadero estafador. • Tienda app's Desde cualquier móvil celular o tablet, una persona puede darse cuenta que la App de Zelle no se encuentra disponible para Venezuela ni en la APP Store ni en la Play Store, por lo tanto es inaccesible y para poder descargar dicha app toca que recurrir a los “caminos verdes”, es decir, a vías no convencionales, lo que resulta desagradable puesto que es evidente que ellos NO quieren que usemos su servicio.Entonces, ¿A quien le gusta sentirse rechazado? • Monitoreo y privacidad Todo usuario de Zelle esta siendo constantemente monitoreado, la privacidad es poca o nula puesto que es un servicio centralizado. Las actividades contantes que realices con la aplicación de Zelle te pueden colocar en la mira de los reguladores financieros lo que podría ocasionar el cierre de la cuenta ya que dentro de sus políticas esta explicito que las cuentas Zelle personales NO se pueden utilizar para uso comercial. El hecho de recibir o enviar pagos a una cuenta reportada también ameritaría el cese definitivo de tu cuenta Zelle. Para nadie es un secreto que los militares han tomado mayor relevancia en el sector comercial de Venezuela y ahora es común ver que el dueño de una carnicería es militar, que el dueño de una charcutería es militar o que el dueño de un bodegón, farmacia o panadería también es militar, entonces a la hora de ir a hacer compras se corre el riesgo de transferir dinero a una persona sancionada o próxima a ser sancionada por la OFAC , ese riesgo siempre estará latente, lo que acarrearía graves consecuencias para tu cuenta Zelle ya que se supone que en teoría no debes transferir dinero a desconocidos y si estas transfiriendo dinero a ese militar o a ese presta nombre es porque tu formas parte de su circulo intimo y se podría asumir que tienes vínculos con dicha persona, cuando no es así. _ Entonces, como verán la plataforma Zelle es un servicio que no nos conviene a los venezolanos y que nunca debió instaurarse ni popularizarse en el país, mi enfoque está orientado en sí a buscar una solución real que sea asequible y accesible, una alternativa que todos podamos disfrutar de las mismas ventajas y oportunidades con algún medio de pago que pueda ser útil en Venezuela. En fin, yo no solo vengo a criticar, vengo a intentar aportar, es por esa razón que hoy vengo para hacer un llamado a la conciencia, para que juntos nos apoyemos y tomemos la decisión más conveniente que nos permita complementar nuestro sistema monetario en Venezuela, que sean ustedes los portavoces de este mensaje y todo lo que puedan aprender por esta vía, impartan esa misma enseñanza a otros, ya que esta sería una campaña de concientización que nos beneficiaria a todos en el ámbito comercial puesto que esta sería una solución global y lo más importante es que NO es para nada excluyente. Esta solución que yo les traigo es fácil de implementar, esta al alcance de todos y existe ya desde hace un par de años, esta solución son las Stablecoins, específicamente hablo de Tether (USDT) el cual es un dolar digital criptográfico. Al igual que con Zelle también podemos transferir gratis los dolares de Tether por medio de la blockchain TRON usando el protocolo de transporte TRC-20.Para los que no están familiarizados con TRON, luego de instalar una wallet de TRON se darán cuenta que se encontraran con 2 elementos:
Ancho de Banda
Ambos elementos son necesarios para poder realizar transferencias gratuitas, el ancho de banda se usa para transferir criptomonedas nativas de la blockchain de TRON pero Tether a diferencia es una criptomoneda adaptada en TRON que esta basada en contratos inteligentes (Smart Contract) por ende para poder transferir dicha moneda se requiere ejecutar un contrato y los contratos en TRON consumen es energía . La blockchain de TRON posee su propia criptomoneda que también se llama del mismo modo TRON (TRX) , para conseguir puntos de ancho de banda de manera gratuita solo basta con activar la wallet, luego de instalada una wallet cualquiera de TRON debemos activarla y eso se logra transfiriendo la cantidad de 0.1 TRX que para la fecha del post equivale a 0.0018 USD (menos de un centavo de dolar), al activar nuestra wallet, la red de TRON nos va a obsequiar 5000 puntos de Ancho de Banda y esto se repetirá cada 24 horas, mientras realizamos operaciones con la wallet este Ancho de Banda ira disminuyendo pero solo de manera temporal ya que toda wallet siempre muestra una barra de carga y los puntos de Ancho de Banda que se hayan consumido se irán recargando automáticamente a lo largo del transcurso del día. Con respecto a la Energía, se utiliza para pagar los contratos que se ejecuten por cada transferencia, indistintamente del monto a transferir ya sean 1 dolar o 1000 dolares de Tether siempre se ejecuta 1 contrato el cual equivale a 14000 puntos de Energía (esto puede variar según lo congestionada que se encuentre la red) y unos 350 puntos de ancho de banda (estas cifras son estimados), la energía NO la podemos obtener gratuitamente, luego que activemos nuestra wallet siempre vamos a tener 0 puntos de Energía, por lo que debemos producirla, esta se produce congelando saldo de TRX, todas las wallet tienen la opción de congelar, por lo tanto lo primero que debemos hacer es comprar 250 TRX (que equivalen a 4 USD) para transferirlos a nuestra wallet y luego que ya contemos con esos fondos, vamos a congelar esos 250 TRX, los cuales se van a transformar en 15000 puntos de Energía y con esa energía disponible ya podremos transferir GRATIS nuestros Tether a otra persona. La energía al igual que el ancho de banda también viene representada en una barra de carga la cual después de consumida también se va autogenerando de manera automática. La energía se puede congelar mínimo por 3 días, luego de transcurrido ese lapso de tiempo se puede descongelar y recuperaremos por completo nuestro saldo TRX, de tal modo que no perderemos nada de dinero en esa operación, es solo un requisito para poder realizar transferencias gratuitas. En caso que nosotros deseemos realizar muchas operaciones al día entonces necesitaremos adquirir mas energía y posiblemente también un poco mas de ancho de banda, por lo que necesitaríamos comprar mas saldo TRX para luego congelarlo y así obtener mas puntos de ambos elementos. En caso de no poseer ninguno de los 2 elementos, de igual modo si se podrá transferir Tether pero para ello debemos poseer saldo TRX ya que hay que pagar una tarifa de red al igual como sucede en cualquier otra blockchain; En ese caso por ejecutar una transacción de Tether la red nos cobraría un monto estimado a 0.25 TRX (que equivaldría a unos 0.0043 USD). Dicho esto, también existen otras maneras de transferir Tether ya que USDT se encuentra alojado también en otras 2 blockchain como Ethereum y Bitcoin, pero usando esos protocolos de transporte ERC-20 y OMNI respectivamente, nos generaría mayores gastos ya que las tarifas de red en esas capas son un poco mas altas, aunque objetivamente hablando, en realidad no es mucho el costo de esas comisiones pero como venezolano en esta crisis que nos encontramos sumergidos siempre buscaremos minimizar los gastos o costos de operación y por ende la red de TRON seria lo ideal. USDT (Tether) no es la única stablecoin, también existen otras criptomonedas centralizadas estables como lo son:
TUSD (True USD)
PAX (Paxos Standar)
BUSD (Binance USD)
USDC (USD Coin)
Finalmente, para culminar, una manera de apoyar esta campaña es la de ir divulgando estos métodos de pago y en caso que usted o un familiar cercano posea un negocio grande o pequeño se pueden tomar acciones como la de publicar un letrero en donde se diga que "Se acepta USDT" o "Se acepta Tether", quizás pasen los meses y ningún cliente pague su servicio o producto por medio de esa vía PERO al menos algunos clientes se irán con la idea de Tether en su mente, lo cual luego les generara curiosidad y poco a poco se mostraran interesados en investigar sobre este mundo criptográfico. Ustedes mismos los internautas y lectores de este post también pueden empezar a cobrar por su trabajo en Tether y fácilmente cambiar estos fondos por Bs o por Bitcoins y estos a su vez por Bs, por medio de plataformas exchange P2P como:
Aquí quiero hacer un paréntesis , HodlHodl es el futuro, con esto no digo que plataformas como Localbitcoins vayan a quedar obsoletas pero si irán poco a poco quedando relegadas, ya que dentro de un par de años plataformas inteligentes como HodlHodl son las que dominaran el mañana. Esto es todo por el momento, quizás ante alguna duda por parte de ustedes, en un futuro podría redactar algún post adicional. Saludos Cordiales para todos...
•Cosmos, a blockchain interoperability project has released its platform dubbed “Cosmos Hub”. This comes after 3 years of planning and development and a $16,000,000 USD raise in 2017. The platform aims to solve scalability of distributed technology by proposing a platform of blockchains.
CRYPTOCURRENCY TRADING SERVICES
•Traders on Coinbase can now transfer cryptocurrency directly from its trading platform to the institution’s custodial wallet offering Coinbase Wallet. •Coinbase Pro, Coinbase’s professional platform lists Stellar Lumens for trading. •New Zealand based exchange Cryptopia migrates 35% of the platform’s funds into new wallets. •DX Exchange, an Estonia based exchange utilizing Nasdaq’s trading engine launches security token offering (STO) listings. •Trust Wallet, Binance’s endorsed wallet now supports Ripple (XRP). Traders and developers building on top of Trust Wallet can take advantage of the support of the Ripple ecosystem. •Hong Kong based exchange Gatecoin shuts down as a result of a legal dispute with a payment processor and a devastating 185,000 ETH and 250 BTC hack in 2016.
•In the U.S state of Texas, a bill has been proposed to require identity verification for sending cryptocurrency payments. •Central bank of Russia aims to introduce an annual limit of 600,000 rubles ($9,100 USD) for unqualified investors who want to purchase digital assets. •Thailand Securities and Exchange Commission (SEC) has approved the decision to create a portal for regulated ICO’s. •Singaporean based exchange Quoine has been found liable by the Singapore International Commercial Court (SICC) for reversing 7 trades from market maker B2C2 in April 2017. Trades were valued at 10 Bitcoins per 1 Ethereum. •The Canadian Securities Administrators (CSA) and the Investment Regulatory Organization of Canada (IIROC) is now seeking regulatory input on cryptocurrency exchanges, in an attempt to integrate securities laws where appropriate. •In the U.S state of Colorado, governor Jared Polis has signed the Digital Token Act on March 8th, 2019. This will exempt specific cryptocurrencies with specific characteristics and functionality from being classified as a security.
•Tether has recently updated terms of service which will shift its reserves from 100% traditional currency (USD) to a combination of traditional currency and cash equivalent assets such as loans. •Samsung unveils a native cryptocurrency wallet for its flagship S10 device that can be found on the Samsung Galaxy Store. Wallet will support Ether (ETH) and ERC20 based tokens alongside 4 dApps from the outset. •MyEtherWallet launches an alpha version of its Ethereum blockchain explorer, EthVM. INSTITUTIONALIZATION •Kakao Corp, the creators of KakaoTalk – South Korea’s most used messaging app raises $90 million USD to supplement the launch of a new blockchain platform in June dubbed “Klaytn”. •A blockchain based ETF, consisting of 48 companies involved or building blockchain technology has launched on the London Stock Exchange (LSE). •Chicago Board Options Exchange (CBOE) announces that it will not add a Bitcoin (BTC) futures market in March.
•Mark Karpeles, the CEO of Mt Gox faces a 10-year jail term from the Japanese authorities for embezzlement of client assets. •Danelle Dixon has been appointed the new CEO of the Stellar Foundation, previously COO of Mozilla. •Konstantin Ignatov, CEO of multibillion-dollar pyramid scheme OneCoin has been arrested and charged with conspiracy to commit wire fraud. Ignatov’s sister, Ruja Ignatov is charged with wire fraud, securities fraud and money laundering.
•@cz_binance – “Populaunpopular opinion: Everyone will be in crypto, sooner or later, whether they know it or not, whether you like it or not.” •@barrysilbert – “Wells Fargo, a Buffett investment, has been fined 93 times for fraud and other abuses, for a total of $14.8 billion in fines since just 2000. I'll take bitcoin's "charlatans" over that any day.” •@erikVoorhees – “Crypto is software eating finance”
Specifically, Wells Fargo displays its anti-Bitcoin stance by not allowing its customers to perform transactions involving cryptocurrencies, as the tweet below shows, Thanks for reaching out to us. Unfortunately, Wells Fargo does not allow transactions involving cryptocurrency. -Josh — Ask Wells Fargo (@Ask_WellsFargo) July 12, 2019 Individuals, businesses, developers: learn from our simple Bitcoin guides. How Bitcoin works, what is Bitcoin, what is blockchain, how to buy Bitcoin, what is Bitcoin mining and more. bitcoin to wells fargo - Wells Fargo is the latest bank to jump into the cryptocurrency space with the launch of its stablecoin product, dubbed Wells Fargo Digital Cash. Are banks starting to understand that they can use ... - Wells Fargo has been named a defendant in a lawsuit where it was alleged that the bank sought to block transfer wires to bitcoin exchange Bitfinex. Welcome to Part IV, our final chapter, where we’ll look at new stablecoins issued by Big Business and leading cryptocurrency companies like IBM, JP Morgan, Wells Fargo, Binance and Bitfinex.. In Part I of our Guide to Stablecoins (2014-2019), we discussed the history, features, benefits and current landscape of this new digital asset class.. In Part II: Libra- A Future Under Fire, we dove ... Bitcoin may be digital cash, but it has a lot in common with the paper currency you carry with you. Both Bitcoin and paper money can be bought, sold, and traded. QuadrigaCX, the largest bitcoin exchange in Canada, has lost $190 million worth of crypto after it lost access to its cold storage wallets. An affidavit filed on January 31 with the Supreme Court of Nova Scotia revealed that $190 million in Bitcoin, Bitcoin Cash, Bitcoin Cash SV, Bitcoin Gold, Litecoin, and Ethereum were lost. Wells Fargo Digital Cash uses R3’s Corda Enterprise software and will operate on the banks distributed ledger network. It will be subject to a Proof of Concept, and if successful, it will be launched as a pilot project next year. Wells Fargo is the second bank after JP Morgan to seek its cryptocurrency, for internal fund transfers. Wells Fargo, the third largest bank in the United States, is no longer allowing cryptocurrency purchases. The new policy came to light after a customer of Wells Fargo complained on Twitter. It was already known that Wells Fargo is not a fan of crypto. The American Bank already spoke out against Bitcoin and other cryptocurrencies numerous times ... Die meisten traditionellen Unternehmen beschäftigen sich intensiv mit der Blockchain, um ihre Systeme zu überarbeiten und bessere Services anzubieten. Durch die Einführung der Distributed Ledger Technology (DLT), wie sie im Volksmund genannt wird, können Unternehmen wettbewerbsfähiger werden. Eines der bekanntesten Unternehmen, das die Blockchain-Technologie einsetzt, ist Wells Fargo & Co. “Wells Fargo Digital Cash has the potential to enable Wells Fargo to remove barriers to real-time financial interactions across multiple accounts in multiple marketplaces around the world.” Wells Fargo thus follows the US’ largest bank, JPMorgan Chase, in launching a digital currency as a solution to changes in the global financial realm.
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