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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.
Thanks for the taxes. We don't give a fuck about your business
This is an all-too-familiar sentiment from government to Canada's startup (specifically bitcoin-startup) community. On March 27th, 2020 the Prime Minister proudly announced a $40,000 government backed loan. "For small businesses, there's a $40,000 loan of which $10,000 will not have to be repaid if they meet certain conditions. There are many things we're doing out there with low interest or no interest loans to help businesses get through this, but the wage subsidy and the Canada Emergency Response Benefit for people who lose their jobs are going to be there to make sure that we come through this strongly." ref Prime Minister Justin Trudeau holds a news conference while in self-isolation at Rideau Cottage in Ottawa Friday, March 13, 2020. (Fred Chartrand/The Canadian Press) I, like many small business owners, let out a sigh of relief as we have all seen revenues vanish over the previous weeks following the necessary public health measures put into place. That $40,000 meant one more payroll run. Maybe it made up for the payables or rent that was coming due in 4 days. A $40,000 injection of "worry-about-it-later" money would mean breathing room. The equivalent of a pool noodle while wading in the middle of the ocean. Enough to keep you thinking "you can do this". Banking is hard to come by as a bitcoin/fintech startup. We are not "welcomed into the traditional banking atmosphere with open arms" regardless of our balance sheets or longevity. Even the bank for Alberta's Entrepreneurs (which promotes their "blockchain friendliness") refuses to work with businesses that touch cryptocurrency. Hi Adam - hope all is well. What is wrong with the markets and BTC as a safe haven ? You did mention a few months ago that we will see sub $6k soon and I wasn't sure how … well you were right. You are an Oracle. Regarding banking - When me and [redacted ATB employee] met you, we extended the offer to help out and support your retail banking needs. You decided not to take it. I just heard back from our Compliance team that their Pause extends to all retail accounts as well. Basically, anything that touches crypto / even personal accounts is not supported right now. Unfortunately, I can't help and I am sorry. Hopefully, if the markets turn positive / and pause is lifted / I can try to seek support for your retail and business needs. For now, it is a full stop. I am also moving to a new role at ATB this week and not sure who would manage the crypto portfolio. I will keep you looped in. best, [redacted ATB employee] So forget ATB, I thought SURELY the Business Development Bank of Canada (BDC) would be there to lend a helping hand during this unprecedented economic and health crisis. The fact that our revenue dropped nearly 70% week-over-week with the onset of the pandemic, and the fact that I have paid well into the six figures in provincial and federal taxes last year would mean that, during these hard times, Canada's Small and Medium Sized Business savior wouldn't be as prejudiced. I was wrong. One week after my application went unanswered I was put in touch with a rep through a personal connection of mine. Within minutes a chipper response pinged my inbox: Hi Adam Happy to try and help you. Can you send 2 years of Financial statements to me and: How much do you need? What are your revenue expectations during and after the crisis - do you have a budget and cashflow projections? What would be your ball park cash burn rate per month for the next few months/ Thanks - when I get these I will see if it will be me or another colleague that will be able to help and then we will reach out to arrange a zoom chat. Best, Moments later, before I could prepare the info, he followed up (even threw in an emoji) Hi Again - more info below Best This is the latest from CRA and all the links you'll need to understand and apply😊 https://www.canada.ca/en/revenue-agency/campaigns/covid-19-update/frequently-asked-questions-wage-subsidy-small-businesses.html#h2 https://www.bakertilly.ca/en/btc/publications/taxflash-temporary-wage-subsidy-for-employers https://www.taxtemplates.ca/wage-subsidy/ I thought we had it. I thought my country 🇨🇦 was coming to my rescue to help me and my 11-person locally-employed team pay the bills for a few more weeks. Until I received a third follow up… Hi Adam I just reached out to our Tech Finance Manager and unfortunately we are unable to Bitcoin clients as our board has deemed them ineligible due to potential money laundering. I am very sorry - this is news to me. Being a Crown Corp we have very strict rules. I think you can still access some Federal support though via some of the links I sent earlier. Best Wishes to you and yours, Potential. Money. Laundering. You'll notice he does not ask for my documentation (FINTRAC Registration as a Money Services Business) which should be the first step to verifying that our business goes above and beyond to prevent the money laundering that they claim to be concerned about. Despite sending him our industry-leading policies and FINTRAC Registration the final response was polite but stern: Morning - Thx for the info. Policy such as this are from the Board of Dir's and Minister of Industry. But things change - I now have hemp clients. It will take time though. When we get to the other side, I would love to have a beer with you and [redacted personal connection name] and learn more about your biz and future. I personally believe crypto will be a important solution in rebuilding the world economy. Best, And that was apparently that. However, you don't get to be one of Canada's leading Bitcoin ATM companies without a little bit of grit and resilience. So I tried again through conventional channels. This time the response was just as useless but even more robotic (you'll notice they spelled my last name wrong…) Dear Mr. O`Brian, Thank you for submitting a request for financing. After examination of your application, we regret to inform you that BDC is not able to provide financing for your business. We understand how deeply the COVID-19 situation is affecting. However, we are unable to respond positively to your request that does not meet the eligibility criteria. An evolving situation As the COVID-19 situation continues to evolve, BDC's response is evolving as well and we are working closely with government, financial institutions and our partners. Ensure that you have spoken to your primary financial institution to see if they are able to help with financing: As you may know, additional measures to support entrepreneurs have been announced by the Government of Canada, including anew Canada Emergency Business Account as well as a SME Loan and Guarantee Program. As these programs are not administered by BDC, your primary financial institution is best suited to assess if you may benefit from these relief measures as they get deployed shortly. For the latest updates by the Government of Canada on COVID-19, visit Resources for Canadian businesses: COVID-19. Thank you, This response left me frustrated. How could it not? How could our small, innovative, and incredibly compliant business not be within the "guidelines" set out by Mr Trudeau last week? My response was heated: This is extremely frustrating. The fact that I am denied help, despite paying 100s of thousands in taxes, is discouraging. Why do you take my tax money, but then deny my eligibility based on "crown rules". The eligibility criteria of BDC should be companies that are striving to employ local workers with cutting edge business practices and revolutionizing the world. All of which we do (and have been doing for 7 years) I know you will cite "compliance", and yet refuse to look at my compliance manual. A policy that was written by a previous compliance officer from a schedule 1 "big 5" bank. A policy that has been approved by 2 third party auditors. A policy finalized by my Chief Compliance Officer with 10+ years as a compliance master who has prevented millions of dollars worth of fraud AND played a key role investigating. It is disappointing to see you promoting the narrative that you are "for entrepreneurs" when in fact I have found it to be quite the opposite. We are a licensed money service business and I personally spend my time working with local authorities educating them how to prevent fraud within this space. Yet somehow I've been labeled "ineligible" for assistance when I really need it. What is the point of innovating? Is "the first guy through the wall gets the bloodiest" really the narrative you support? "Don't think outside the box because we don't like that?" The prejudice of the BDC towards alternative financial companies is disappointing to say the least. I would appreciate your response, though if past experience has taught me anything I know better than to expect one. Perhaps the Canadian business environment is not one that is as friendly as you promote. Stay healthy, Adam As you might have guessed this went unanswered (though the robots did manage to regurgitate the exact same original message) and here we are. My initial sentiment from the most recent response to the BDC remain. What is the point of innovating? Why do I spend tens of thousands of dollars every single year to ensure that our compliance is industry-leading? Why do I spend hours and hours working (for free) with local authorities to educate them about Bitcoin and how to prevent fraud? Why do I stretch my hand out so far only to have it slapped when I am looking for the same support everyone else is getting? I've endured years of prejudice from the traditional banking industry. I've built an incredibly successful business that exclusively employs local labour even though it would be all too "easy" to off-shore the work. We've paid our taxes, donated to the community all without the help of the bank's lending products, but being denied support relief during this unprecedented crisi due to "potential money laundering" is as prejudicial as it gets. All of this to ask, Mr. Morneau, will these subsidies affect my taxes? I understand the economic cash injection. As a whole, I am onboard with the injection to help stimulate the economy. But we all know who will end up paying for it. We all know that money doesn't grow on trees (it's printed dummy) and that it will eventually have to be paid back in some capacity… which will eventually be through increased taxes. Taxes that hard-working citizens continue to pay every year. If only you knew how much you were contributing to Bitcoin's adoption… Finally, dear reader, I beg you to think. Listen to my story and ask yourself "is my industry next?" "Can I trust them with my taxes… can I trust them with my money?" I fully believe what I am experiencing is a direct extension of the reason Bitcoin was created. Bitcoin exists to give its owners choice. A choice that doesn't exist with fiat money, printed at will by a centralized body of power. Right now the majority of "industry" is getting help, the government is listening to their people. I am unfortunately in the minority. My business is too edgy. My business is too "risky". My business doesn't deserve help. Will your industry, your business, your pension, your family be next? Adam | www.bitcoinsolutions.ca
Sharering (SHR) I believe this one is going to surprise so many. Already generating revenue and doing buybacks every week. Already over 10 000 registered users. Mainnet + app + masternodes and staking before EOY.
I got this stuff from Steve Aitchison, he wrote this review and posted it on Uptrennd. Figured I should put it on here as well since I truly believe this is an incredible moonshot. I'm personally holding SHR myself and am very convinced it will do extremely well. Give a read through it and you will immediatly see why. Enjoy guys. Introduction Imagine for a second the following scenario. You are a 2 car family. One car is used every day going back and forth to work, for shopping, all the little jaunts you and your husband like to go on. Your grown children are at university and come home for the weekends so the other car sits in the driveway all week and doesn’t get used during the week. What a waste of a perfectly good car. You think to yourself we could put that car to good use and actually help to pay for university fees, by renting it out during the week. However, then you think “well it’s only a little Ford Fiesta who’s going to want to rent that.” Well, it turns out a lot of people want to rent it and for a good price: £34 ($40) per day, a possible $800 per month. Peer to peer car sharing has grown massively over the last few years and people are making serious money by letting our vehicles on a daily basis, emulating the Airbnb model. In fact companies like Turo, Getaround and Drivy, which has just been acquired by Getaround for $300 Million, are bringing in serious investors like Toyota, Softbank Vision Fund, Menlo Ventures, and IAC to the tune of over $800 Million. A key difference between rental companies and peer to peer is that they have vastly improved technology with app interfaces that make locating assets and resources, reserving and using them, and making payment convenient and seamless. This, combined with location-specific analytics, allows by-the-minute access to assets and resources (e.g. cars or bicycles) and enables customers to pick up and drop these assets where and when convenient. Car sharing is just one example of an industry that is being disrupted. We have seen, experienced and read about the amazing growth of Airbnb which is now estimated to be valued at $38 Billion. Airbnb has been so successful that companies like booking.com are trying to get in on the act by adopting a similar model when it comes to booking accommodation. There is also the phenomenal rise of bicycle rentals which we see in cities all over the world, not quite the same as peer to peer sharing, but it’s another rental model that is ripe for being disrupted by the new sharing model. With this business model in mind what other areas could it be used in: Transport: Used for the rental of cars, trucks, scooters, trailers, and even heavy vehicles. Delivery Drivers: Facilitate booking and payment for delivery drivers. Agriculture: Garden sharing, seed swap, bee-hive relocation, etc. Finance: Peer to peer lending Food bank, social dining Travel Tours, shared tour groups Real Estate Airbnb, co-housing, co-living, Couchsurfing, shared office space, house swapping. Time: Labour, co-working, freelancing Assets Book swapping, clothes swapping, fractional ownership, freecycling, toy libraries. Transportation Car sharing, ride-sharing, car-pooling, bicycle sharing, delivery company, couriers And so much more! This newly emerging, but highly fragmented sharing industry, is currently worth over $100 billion. It is predicted to grow to at least $335 billion by 2025. As you can see from a few examples above the sharing economy has a lot of room to grow but what it doesn’t have, yet, is a company who can facilitate ALL of the above use cases in one place. That is until now! ShareRing is disrupting the disruptors by bringing everything together in one place and making it easy for you and me to share anything and everything and making it as easy as opening an app on your phone. Business Case The sharing market has exploded over the last several years. This is due, in part, to the digital age we live in, as we now have over 2.82 Billion people with smart phones around the world. It also due to how easy the business model of sharing lends itself to the digital world, and how with the simple installation of an app we can access a plethora of markets to rent almost anything from. Due to this rise of digital platforms and the proliferation of smartphones, revenues coming from sharing economy platforms are only expected to increase. It is estimated to grow to a $335 billion industry in 2025, compared to its $14 billion value in 2014. (PwC UK). The beauty of the sharing economy is that it is a win/win/win situation for the person who wants to rent something for a few days or weeks, the person who is renting out, and the company who facilitates the ease of the transactions between the renter and the person renting out. Typically the renter will save a lot of money whilst renting out someone else’s apartment, car, bicycle, clothes, dog sitting services etc and they can almost be assured of quality due to the social side of the business model with reviews from real people. The person who is renting out can make additional income and will want good reviews and therefore keep the standard of service higher. The company that is facilitating all of this can make a lot of money on transaction fees, as well as from advertising, and partnership deals, and obviously have an exit strategy for possible buyouts. When it comes to looking at the business model, ShareRing fits in to the Commission Based Platform as described in Ritter and Schanz study where they looked at the core difference in difference business models of the sharing economy: Singular Transaction Models, Subscription-Based Models, Commission-Based Platforms and Unlimited Platforms.) Commission Based Platforms are dominated by (at least) triadic relationships amongst providers, intermediaries and consumers with a utility-bound revenue stream. These business models enable their customers to switch between provider and consumer roles by creating and delivering the value proposition. Only a few employees work for the intermediary and the value creation and delivery is externalized. From a consumer perspective, consumers are empowered to collaborate with each other and to design the collaboration terms by negotiating the terms and conditions of the content, creation, distribution and consumption of the value proposition. Depending on the orientation of the value proposition, consumers purchase commodities (Tauschticket, ebay), access commodities in a defined timespan (booking.com, Airbnb) or buy services (uber, turo) from occasional and professional providers found via an intermediary. The intermediary mainly focuses on nurturing a community feeling and reducing exchange insecurity by incorporating rating systems, micro-assurances and standardizations of payment and delivery into the platform. The platform mainly takes commissions for successful matching and executing trade. (Journal of Cleaner Production Volume 213, 10 March 2019, Pages 320-331) The USP of the ShareRing Business Model The USP that ShareRing has is that it brings all of the different forms of sharing together in one app through partnerships and onboarding of users. No other company, to date, is bringing everything together in such a way. However there are other factors that make ShareRing unique, which we will look at. Token Economics SHR is a utility token and will be used to pay for transactions on the network, such as 'new booking', 'add asset', etc. SHR is used by providers to pay for their access to the ShareLedger blockchain, including the addition of assets, renting out of assets, adding attributes, adding smart contracts, and other features. SharePay (SHRP) is used by customers to pay for the rental of assets. Masternodes will also be a main feature of the SHR token. When a transaction fee is incurred, it will be distributed in a way that allows for masternode holders who provide a service to the platform to receive a reward from each transaction. Transaction fees are charged to sharing providers in SHR. The distribution of transaction fees will be as follows: 50% - will be distributed amongst the active masternode holders who host an active node on the blockchain at that point in time (these holders provide a service to the platform). The distribution will be based on a calculation of the Total Amount Staked and the total continuous uptime of the node. 50% - will be provided to ShareRing Ltd (view ShareRing owned masternodes) for various purposes that contribute to working capital and platform growth. Leased Proof of Stake Consensus ShareRing have chosen the Leased Proof-of-Stake protocol as the consensus algorithm for ShareLedger. This choice is based on the practicality and security benefits evident in the Waves platform. It is also much more cost effective than Proof-of-Work (POW), and will not suffer from the current issues Bitcoin and other POW cryptocurrencies are facing such as scalability and electricity consumption. As explained above master nodes will be a main feature but there is the other feature of lightweight nodes. A user with a lightweight node will be able to stake their tokens to a full node of their choosing and participate in reaching consensus. They will also be free to cancel their leasing at any time as there are no contracts or freezing periods. The more tokens that have been staked in a full node, the higher the probability the node will have in producing the next block. Since the reward is given based on the total number of tokens staked in the full node, there will always be a trade-off between the size of the full node and the percentage of the reward. As an average user of the platform, you will not need to have technical knowledge on how to set up a node nor will you have to download the entire blockchain in order to stake your tokens. Only a user who sets up a full node will be required to do this, making it simpler than ever for users to earn a reward for supporting the platform. The return expected for staking is expected to be around 6 - 8% although this has yet to be confirmed. Buybacks ShareRing are currently implementing a series of buybacks which started in the beginning of November: The buyback operation is done at a random time during the week. If there is enough liquidity, SHR tokens will be bought through a single market order at the time of buyback. In case there is not enough liquidity, a limit buy order at last sell order price will be placed on the market, and will remain open until it gets filled. The buyback program was implemented to test the API purchase process for when live transactions occur on ShareLedger The Buyback Program is expected to:
Reduce the supply of ShareTokens available in both public and private markets
Bring New capital and fund inflows into the Shareledger
Substantially magnify value creation for the ShareToken holders
The Token Flow ShareRing will bring in hundreds of merchants to list their rental products, either exclusively or as part of an aggregator system e.g. When you look at the likes of trivago.com they will list the best hotel prices from multiple merchants who are listed on their website. Essentially ShareRing will become part of the aggregator ecosystem and be listed on sites like trivago.com as well as have exclusive agreements with merchants who are listed directly on their app. ShareRing’s USP is that they have everything on one place as well as their OneID module with means buyers can get a hotel, rent a car, rent their ski equipment, book events all through the one app and using the OneID. With that in mind they are going to attract a lot of merchants. This is where it gets exciting so pay attention to this part. When a merchant is part of the ShareRing ecosystem and a buyer rents something from that merchant ShareRing will take a small % commission from that transaction. So say someone books a hotel for $100 for the night, ShareRing might take $0.50 as a commission. What ShareRing will then do is go to one of the exchanges that ShareRing (SHR) is listed on and buy SHR tokens directly using an API system using USDT. Now, the actual commission has not been disclosed yet however if we assume even a 0.25% commission that means for every $100 Million worth of bookings made through the app will net ShareRing $250,000 which means buy backs of $250,000 for the SHR token, which increases the liquidity of SHR on the exchanges. If you think $100 Million of bookings is a lot, booking.com customers book around 1.5 Million rooms per day, if we estimate an average of $50 per room that is $75 million of bookings PER DAY or $2 Billion worth of bookings per month. This revenue coupled with revenue from OneID and eVOA makes ShareRing profitable almost from day one of the app going live. OneID And eVOA Another exciting development from the ShareRing team is the collaboration between ShareRings Self Sovereign Identity protocol and third party providers to bring OneID and eVOA which will utilise OneID With the huge rise in E-commerce and with over 2.82 billion people who now own a smartphone we are entrusting our personal information to more and more centralised entities. These entities are frequently hacked and our information is leaked to outside parties. ShareRing aims to tackle this with their service OneID module. ShareRing’s OneID solution protects users' data by handling Know Your Customer (KYC) information through third parties and ShareRing’s Self Sovereign Identity Protocol. ShareRing does not hold any identifying information anywhere on its servers. It provides the ultimate security for the renter and also the provider, as the Protocol encrypts and stores your data in a secure manner within your device. Essentially, this means that it is near impossible for a hack or data leak to happen, simply because there is no centralized server of data for hackers to exploit. The OneID module is very easy to use. The end-user needs to complete their ID submission only once, with the entire submission process requiring less than two minutes to complete. Once this step has been completed, the customers KYC is destroyed by the 3rd party document verification system and the OneID module allows merchants to verify a customer’s identity via a hashed verification packet, stored on the users device and ShareLedger. This removes the need for merchants to store or see personal information; safeguarding both merchants and users from fraud. To create your ShareRing OneID, simply:
Take a picture of your government ID document
Take a selfie
Confirm and submit your details
This is something I am really excited about for ShareRing and they already have made partnerships for other companies to use this feature which is another income stream for ShareRing. eVOA E-Visa On Arrival allows applicants to apply online and receive a travel authorisation before departure – this eVOA can be shown at dedicated Thailand immigration counters on arrival at major Thailand airports, allowing travellers to pass through in minutes. OneID system is scheduled to become the lynchpin technology in Thailand’s electronic Visa On Arrival (eVOA) system; one of only two companies to partner with Thai authorities to provide this service. The new Visa system eliminates much of the hassle involved in entering the country: This is a strong validation of the OneID system - immigration controls are some of the most scrutinized processes in any branch of government, and if the OneID solution can operate to their standards then it is truly business-ready. As explained by our COO, Rohan Le Page: “We are providing our OneID product for Thailand e-VOA (Visa On Arrival) that allows 5 Million travellers from 20 countries including China and India to complete the visa process on their mobile through our app. This provides a streamlined immigration process that negates the need for an expensive and time-consuming process when you get off the plane. Additionally, fraud is mitigated with several extra layers of security in the back end including our blockchain (ShareLedger) consensus model that makes all data immutable and all but impossible to hack.” Profit Margins on OneID So how does ShareRing make money from OneID and eVOA? With each application for an eVOA using the OneID module ShareRing will make an undisclosed commission. The e-VOA is available to citizens of 21 different countries and is intended for those who will be holidaying in Thailand and not working in the country. This means that each eVOA will last for a period of around 15 days which effectively means that ShareRing will get commission multiple times from each person travelling to one of the 21 countries listed below: Andorra, Bhutan, Bulgaria, China, Ethiopia, Fiji, India, Kazakhstan, Latvia, Lithuania, Maldives, Malta, Mauritius, Papua New Guinea, Republic of Cyprus Romania, San Marino, Saudi Arabia, Taiwan, Ukraine, Uzbekistan The profits on this alone, according to projections, are worth millions of dollars per year to ShareRing, with a healthy growth of about 35% in raw profit over the next 5 years, ultimately netting the company about $1.5 million profit per quarter. The ShareLedger Blockchain Platform ShareRing will utilize the registered intellectual property from the existing KeazACCESS framework (KEAZ: A car sharing company founded by Tim Bos) as well as improving it the blockchain experience in their team. It will consist of fo the primary elements: SharePay (SHRP) – SharePay is the base currency that will allow users of the ShareRing platform to pay for the use of third party assets. ShareToken (SHR) ShareToken (SHR) is the digital utility token that drives sharing transactions to be written to the ShareRing ledger that is managed by the ShareRing platform. Account – This will be a standard account, which such an account being represented by a 24-byte address. The account will contain 4 general fields: SHRP – SharePay token balance SHR – ShareToken balance ASSETS – linked/owned by the account (see below for definition of an Asset) ATTRIBUTES – Any additional attributes that are associated with this account. These attributes may be updated or added by Sharing Economy providers that utilise the ledger such as ID checks by rental companies. These attributes may be ‘global’ (i.e. used by any sharing providers) or ‘local’ (i.e. used by a specific sharing provider). Assets – An asset represents a tangible real-world or digital asset that is being shared, such as a car, a house, industrial machinery, an e-book, and so on. Smart Contracts – Similar to a number of other blockchain platforms, such as Ethereum and NEO, the ShareLedger blockchain will feature highly customisable smart contracts. These Smart Contracts will allow for decentralised autonomous applications that can be attached to an asset and/or account. Every smart contract will be Turing complete, meaning it will have the ability to implement sophisticated logic to manage the sharing of the assets. The smart contracts will be tested and reviewed by ShareRing in a sandbox as well as audited by reputable third-party code auditors prior to implementation. Proof of Stake Consensus ShareRing have chosen the Leased Proof-of-Stake protocol as the consensus algorithm for ShareLedger. This choice is based on the practicality and security benefits evident in the Waves platform. It is also much more cost effective than Proof-of-Work (POW), and will not suffer from the current issues Bitcoin and other POW cryptocurrencies are facing such as scalability and electricity consumption. The ShareRing App At the heart of the ShareRing project lies the ShareRing app: A universal ‘ShareRing’ app is being developed that will allow anyone to easily see and use any sharing services around them. Each partner will have the option of developing a ‘mini’ app within the ShareRing app that will have functionalities specific to that partner. The app will use geolocation-based services to display the ShareRing services that are nearby Social Media Presence Coming from a social media background I feel this is an extremely important area to look into, especially in the crypto world. ShareRing has done an okay job in growing their social media presence however I feel it could be much better. Here is a look at some of the key stats for their online social media presence: Youtube: 191 Subscribers Instagram: 238 Followers Linkedin: 376 Followers Telegram: 6,525 members (very active) Twitter: 2,216 Followers (Fairly regular updates) Facebook: 1,965 Followers Whilst social media may not be a priority just now I feel there has to be a big presence with image-based platforms and video-based platforms. Youtube and Instagram should be made a priority here as it spans all generations: Other News on ShareRing There is a lot of stuff going on at the moment with ShareRing which is what makes it an exciting prospect. Rather than give information on each of them here are some highlights provided by the ShareRing team.: - ShareRing's revolutionary ID management based module OneID. - Worlds first Blockchain based eVOA in place with major Thai company targeting 5 to 10 million travellers from 20 countries. - 2.6 million International Hotels/ Accommodation coming on to the Platform. Lots more to come! - Partnership with HomeAway - 200,000 Activites, Tours and Events added to the ShareRing App - Multi Global Car Sharing Partnerships - 1 Partner Directly Integrating SHR's OneID consisting of 1.2 million Vehicles across 150 Countries - Luxury Car Brand Sharing Platform purely based on SHR - SHR payment system SHRP available in 10% Taxi Terminals in Australia - SHRP available in 10,000 EFTPOS Terminals Australia wide - White Labelling Services incorporating ShareRings revolutionary OneID - 20 Significant Unannounced Partnerships, more to come! - Major Partners include - - BYD (Largest Electric Car Maker in the World) - DJI (Largest Drone Maker in the World) - Keaz (300 locations around the world) - Yogoo EV Car Sharing - MOBI Alliance Member Overview of Positives and Negatives Negatives Social Media and marketing possibly needs to be ramped up in order to bring more awareness to the project. The roadmap and white paper has not been updated recently for 2019/2020 but this I believe is coming soon. Positives With a low market cap project like ShareRing the risk to reward ratio is very good for retail and institutional investors. Technical analysis of current prices, currently at 31 Satoshi, is also very good with resistance levels at 50, 77 and 114 Satoshi which would be nearing its all time high. Referral program will increase the numbers of users that are currently using the site. If ShareRing can capture even a small % of the overall sharing market then success looks assured. There are 20 new announcements coming up and with Tim Bos looking for more partnerships it seems likely that ShareRing will break ATH prices soon. Great long term hold, in my opinion. Realistic Expectations of ROI Short term (4 weeks - 12 weeks) Short term looks great for ShareRing both from a TA point of view and a fundamental point of view. With lots of news still to come out about ShareRing there is not going to be a shortage of fundamentals to drive the price up. From a TA point of view the next line of resistance stands at around the 50 Satoshi level which would complete a massive cup and handle formation from August 24th of this year. After that we are looking at resistances of 77 and 114 to reach near the all time highs which i expect ShareRing to reach going into 2020. Long term (6 Months - 2 Years) If ShareRing can onboard users and keep on making partnerships at the same rate there will be no stopping it. It’s all about onboarding the users and utilising the most powerful marketing tool ever - word of mouth! When a great app is realised with great and useful functionality then it tends to go viral and I am hoping this happens for ShareRing. With a market cap at the moment of just under $6 Million then I don’t think it’s crazy to talk about 1000% increases in the next 2 years and I really believe that is being extremely conservative, given where we think crypto is heading as a whole.
A Few Things You Should Know About Getting a BitLicense
The NYDFS rejected Seattle-based cryptocurrency exchange Bittrex’s BitLicense application, and the resulting rejection letter serves as a blueprint for anyone looking to do crypto business in the Empire State. For securities lawyer Jason Seibert, who has served on several landmark crypto cases, the crux of Bittrex’s rejection letter is on Page 4 in Paragraph D. He says it offers the 10,000-foot view of what it takes to operate a crypto exchange. “…Bittrex has failed to demonstrate responsibility, financial and business experience, or the character and fitness to warrant the belief that its business will be conducted honestly, fairly, equitably and carefully,” reads the NYDFS rejection letter of Bittrex, which requested that the exchange provide within two weeks of the rejection written confirmation that it had stopped operating in New York State and doing business with its residents. What’s clear is that anyone looking to operate as an exchange in New York State must abide by the Five Pillars of KYC and AML:
the designation of a Bank Secrecy Act (BSA)/AML officer;
a BSA/AML training program;
independent testing to test programs;
and a risk-based, customer due-diligence procedure
“For instance, you have to be able to know if there’s somebody that’s on a sanctions list or an OFAC list,” explains Mr. Seibert, referencing the Office of Foreign Assets Control. “So, it becomes an issue if an exchange doesn’t even know who their customers are due to the ability for users to create a false name or an alias account.” Seibert points out that no one is going to win points with the regulator when they allow Elvis Presley to trade, as was the case with Bittrex. “An exchange must see some form of ID, some sort of registration, some sort of link between an actual person and an account,” explains Seibert. “You can run an actual ID against a database like OFAC to make sure that it isn’t a sanctioned Russian who’s not supposed to be doing business in the United States or someone laundering money through a cryptocurrency exchange because they’ve created a false account. That’s the issue with these anonymous accounts. When you’re looking to be a government regulated entity, you have to follow all the rules. You can’t allow anonymity anymore.” But, anonymity is the lifeblood of cryptocurrency. And that goal to be able to do things anonymously, to have your money, spend your money, trade your money, and do anything you want without the government knowing, doesn’t fly with regulators. “The goal for a lot of people in this space is to be able to do things anonymously,” says Seibert. “So, when certain people started finding out that you were going to have to have a verified account with your real name like Poloniex did, a lot of people close their accounts. They go someplace where they can be anonymous.” A lot of exchanges, in addition, were not designed to have AML and KYC control. “They didn’t know the policy, didn’t do the training, and quite frankly, I don’t think they really wanted to do that because it was contrary to whatever their internal beliefs were,” said Seibert. “In their minds, they’re not there to be the world’s police, and to prevent illegal transactions, money laundering and sanctioned money from traveling internationally. An exchange cannot list tokens without the required due diligence to know if they were security or not, what was being offered, and who was offering them.” Seibert evokes the Petro cryptocurrency from Venezuela, for instance. “Absolutely sanctioned,” he says. “Nobody in the United States is allowed to buy it or should be allowed to buy it because it’s viewed as getting around sanctions on human rights violations. You’re not supposed to buy Venezuelan oil.” So, for any exchange, listing the Petro token would be a violation. Same goes for an unknown token with unknown issuers and uses. “You could start avoiding sanctions by having this anonymous token created that certain parties may be trading back and forth in order to launder money,” explains Seibert. What’s more, all employees at an exchange must be trained on AML and KYC policies and procedures. In the case of Bittrex, NYDFS said people were not trained and policies and procedures were inadequate. Bittrex said their framework had been approved by outside counsel, but it’s unclear who the outside counsel was and if their compliance framework ran the prescribed way. “You can have a fully approved and creative plan and you put it on your desk, but then not execute it,” says Seibert. “If they did have an approved framework by competent outside counsel, then how is it that DFS found that their compliance was insufficient?” Inspiring confidence in regulators about your ability to serve the public in a regulated manner, moreover, is crucial when it comes to getting a license to operate. “It’s important to demonstrate responsibility, financial and business experience where the character and fitness to warrant the belief that business will be conducted honestly, fairly and equitably,” said Seibert. “Your internal policies need to ensure you’re not going to be laundering money or allowing money from foreign suspected terrorists, countries or organizations that are on the sanctions list. You don’t want to do any business with those people. There’s a duty to basically say who’s behind this? What are they doing? Who’s selling the token?” In opinion letters that Seibert has written for projects looking to be listed on exchanges, he details the complete background on the company, including who the players are, whether they’re on a sanctions list or not, and more. Seibert also highlights the importance of a competent compliance officer and the risks of not having one. “Perhaps, you have a compliance officer, but they didn’t do anything,” he says. “Perhaps there is a lack of training. Every person in the staff who is at minimum operating and working with a transmission of money needs to know what the policies are and what the rules are for filing suspicious activity reports. Every employee, including the CEO, needs to have extensive AML, KYC and BSA training, and everyone needs to be empowered to raise a red flag and file a SAR. Everyone.” It’s just the nature of the business, he notes. “Employees must be trained and empowered to file this stuff,” says Seibert. “There needs to be an AML, KYC folder on your desk. That’s your training folder. And it’s got all the requirements and statutes in it. You need to have absolute compliance with the law to demonstrate that you’re a reliable and trustworthy person who knows how to run a business. In the case of Bittrex, NYDFS is not saying they didn’t have a program, it’s just saying that it was completely deficient.” Not only must an exchange have an AML and KYC policy in place, but that policy must also be audited by an independent party. When Bittrex was rejected by the NYDFS, it was demonstrated in the rejection letter that, while Bittrex claimed to have done this, they failed to inform NYDFS who the independent auditor was. “An exchange’s AML and KYC policy has to be audited and examined by an independent third party,” says Seibert. “In the case of Bittrex, they say they’ve retained an external firm. The department is saying that it would have loved to have seen the engagement letter of who Bittrex’s auditor was.” He uses the SEC denial of the Bitcoin ETF as an example for entrepreneurs to look at and learn from. “If I wanted to operate an exchange in New York, then I would be paying attention to what the SEC is saying about exchanges,” said Seibert. “I’m paying attention to what has happened to other exchanges and I want to be the gold star. The Gemini exchange has shown a way forward when it comes to compliance. Running a regulated exchange is not that hard. It’s not like have to create a framework from whole cloth. There are examples already, you just have to execute that.” He adds: “The SEC declined the Bitcoin ETF because the regulator felt that the bitcoin ecosystem, including its exchanges, were not well-regulated, supervised or had sufficient controls with the ability for regulatory oversight of those exchanges to be able to say that the activity inside of them wasn’t fraudulent.” site: https://cryptographicasset.com/a-few-things-you-should-know-about-getting-a-bitlicense/
Phil Potter - the guy behind Tether (USDT) interview | 11 May 2019
First part of the interview, almost an hour, is about the Bitfinex and 2016 hack. In the second part, he speaks about Tether and the audit problem; in the end he speaks a bit about the New York attorney general case. Here are a few highlights from this very long interview: Bitfinex 2016 hack:
We did have an engagement with CFT ... agreed not to do margin trading … but we still did it through a loophole. 24:30 Our decision was to take 36% haircut on all client positions based on the prices that we set forth … We arrived at this decision through a series of very complex analysis ... We could declare bankruptcy … and all other options would have been too complicated for our clients.This way, we are the ones who are going to administer our bankruptcy ... We created a token for every dollar we took from somebody, we created a market for that token ... And people were selling that dollar for 30 cents. 29:36
We tried and we couldn't get it done (the audit) 1:12:50 You know… auditors, they go independently to confirm your bank accounts. But here they have to go much deeper, to make sure we are not hand in hand with Noble Bank, somehow participating in a giant fraud. That means they have to look at their audit. They were working on one … but you know, the audit may take a long time … like 9-10 months. A very long time. So we would have a situation (we didn't get this far) were the audit may not come in a year, because of the bank. The problem with the Auditor is too much social pressure media. They were getting harassed. This is gold: When auditors get it wrong their reputation suffers … you know ... right ... or if we somehow pull the wool over their eyes and somehow they get exposed 1:19:00 We tried to find an auditor and no one will do it. The auditor fear to fail - reputation risk.
Every organization, regardless of market sector or business size, must secure its data to minimize data leakage and other security incidents. The importance of data security in healthcare is compounded by the need to comply with the Health Insurance Portability and Accountability Act (HIPAA). This article describes data protection strategies and tactics healthcare organizations can use to comply with the key provisions of HIPAA, and explores the most common threats to data security in healthcare.
HIPAA data security and privacy rules
Background Technical professionals in healthcare organizations are responsible for protecting healthcare information against security threats and security risks. Both external hackers and malicious insiders are constantly attempting to gain access to electronic protected health information (e-PHI), usually for financial gain from selling the information, identity theft or blackmail. Protected health information comprises all information that relates to a person’s past, present or future health or condition (mental or physical). This includes data about medical services rendered, payments for health care and health insurance benefits. HIPAA was enacted in 1996 to force healthcare organizations to improve their data security. It includes multiple requirements that govern how healthcare organizations must work with healthcare information. For example, they must protect the privacy of personal health information by restricting the use or disclosure of that information without patient authorization. HIPAA includes two key components: the Privacy Rule and the Security Rule.
The HIPAA Privacy Rule regulates who can have access to PHI and how it can be used and disclosed. The key requirements are as follows:
You must implement policies and procedures that restrict access to and use of protected health information based on employees’ roles. Protected health information should not be accessible to any employee who doesn’t need access, such as an office manager or a security
You must implement policies and procedures that limit use and disclosure of PHI to the minimum necessary. For example, if an insurance company needs a person’s name, Social Security number and details of their most recent medical procedure, the privacy rule requires you to not send the person’s entire medical records.
You must obtain a person’s authorization in writing use before disclosing their protected health information. For example, if you plan to send personal health information to a pharmaceutical company, you need to obtain the person’s authorization in writing first.
There are potential civil and criminal penalties for not adhering to the HIPAA Privacy Rule. While some states have their own rules, HIPAA is a federal requirement that overrides conflicting rules at the state level. Covered entities under HIPAA include not only healthcare providers like hospitals and nursing homes, but also health plans (health insurance companies, HMOs, etc.) and healthcare clearing houses (entities that process health information they receive from other entities).
HIPAA Security Rule
The HIPAA Security Rule requires healthcare organizations to protect ePHI using appropriate administrative, physical and technical safeguards. Specifically, the Security Rule requires covered entities to do the following:
Ensure the confidentiality, integrity and availability of all e-PHI they create, receive, maintain or transmit. This rule requires you ensure data confidentiality, integrity and availability (CIA, or the “CIA triad”). Let’s look at the rule’s component individually:
Confidentiality. You can help ensure confidentiality by implementing security controls such as access control lists (ACLs) and encryption. Encryption provides higher security and confidentiality than ACLs. Other security controls or software are often layered on top of ACLs and encryption; these can include configuration management software, monitoring and alerting software, and auditing software.
Integrity. Data integrity means that the data hasn’t been altered. For instance, if a man-in-the-middle attack intercepts and alters data before sending it to its original destination, the data doesn’t have integrity. One way to ensure integrity is to use a digital signature or a hash. For data stored in databases, you need to ensure entity integrity, referential integrity and domain
Availability. Sometimes people forget that availability is a key element of data security. To ensure people can access the data they need, organizations can implement various solutions, such as replication from the primary data center to a secondary data Load balancers, redundant hardware and other strategies can also help ensure high availability.
Identify and protect against reasonably anticipated threats to the security or integrity of protected information. This rule requires some interpretation. Many organizations error on the side of caution and include as many threats as possible, going so far as to include their entire supply chain or restrict the use of mobile devices in certain areas of their facilities. This strict interpretation helps ensure they meet the security rule requirements. In any case, reasonable threats certainly include improper data modification, unauthorized data access and data These and other threats are discussed in more detail later this article.
Protect against reasonably anticipated impermissible uses or disclosures. This rule is also open to interpretation. Is it reasonable to anticipate that an employee might reveal protected health information to a patient’s friend? Might a doctor report some patient records or patient health details to the media if a celebrity is being treated? This rule might require you to consider such cases.
Ensure compliance by their workforce. This rule covers some of the administrative safeguards needed to adhere to the Security Rule. To ensure compliance, you need to educate your workforce. They should understand at a high level what HIPAA is and the role they play in compliance, as well as your organization’s security policies and procedures. Repeated training throughout the year is needed to ensure employees learn about new requirements or methods. Be sure to implement regular testing as well, and follow up with additional training for individuals who need it.
HIPAA Enforcement Rule
Beyond the Privacy Rule and Security Rule, you should also be familiar with the HIPAA Enforcement Rule, which concerns compliance, investigations and penalties.
The Health Information Technology for Economic and Clinical Health (HITECH) Act expands the scope of HIPAA. It promotes the use of electronic health records, increases liability for non-compliance, regulates breach notification, and requires certain business associates of HIPAA-covered organizations to comply with HIPAA.
Strategies for HIPAA Compliance
Clearly, HIPAA compliance is a complex undertaking and the risks for failure are high. There are multiple resources that can help you achieve and maintain a HIPAA-compliant IT environment. The National Institute of Standards and Technology (NIST) establishes national standards and offers free IT security resources, such as frameworks like the NIST Cybersecurity Framework. Their introductory guide can help your organization comply with the HIPAA Security Rule. The Health Information Trust Alliance (HITRUST) is a non-profit organization whose mission is to help organizations safeguard their sensitive data. Their Common Security Framework (CSF) is a framework that makes it easier for organizations to comply with HIPAA and other laws, and it offers good interoperability with other frameworks and standards. While HIPAA is not a certifiable standard, healthcare organizations can become HITRUST-certified.
Biggest threats to the security of healthcare data
The healthcare industry faces many of the same threats to data security as other sectors. The primary difference is that for healthcare organizations, healthcare data is usually the ultimate target, rather than trade secrets or financial records. Here are the top threats and potential security incidents:
Data breach. In general, when someone accesses information without authorization, it is a data breach, whether the person is an insider with malicious intent, a hacker or just an overly curious employee. However, the following cases of PHI disclosure are not considered data breaches under HIPAA:
A person accidentally accesses or uses PHI “in good faith and within the scope of authority” and does not further disclose the PHI in a manner not permitted by the Privacy Rule.
An authorized person accidentally discloses PHI with another authorized person at the same organization and does not further disclose the PHI in a manner that is not compliant with the Privacy Rule.
An authorized person disclosed data to someone improperly but believes in good faith that they will not be able to retain the data.
When organizations discover a data breach, they must provide breach notification as specified by the HIPAA Breach Notification Rule.
Data exfiltration. Data exfiltration is the copying of information to an unauthorized location. Most cases of data exfiltration involve copying data to an unauthorized location outside of the organization. Other common terms for this are data leakage and data exfiltration. The data breach notification rule applies to data exfiltration as well as data breach.
Ransomware attacks. Ransomware is a type of malicious software that denies you access to a computer or data on that computer by encrypting the data. To get your data back, you must either pay a ransom or restore from backup. Ransom payments are often arranged through untraceable digital currencies, such as Bitcoin. According to Coveware research, healthcare ranked third among industries targeted by ransomware attacks in 2019. This situation is unlikely to change for the better, because attackers understand that the urgency of restoring data required for medical treatment means they are more likely to get paid. However, paying the ransom does not guarantee you’ll actually get a decryption key; therefore, the best strategy for ensuring you can recover from ransomware attacks is having offline backups.
Other cyber threats. A variety of other cyber threats put healthcare organizations at risk. While many attacks aim to steal electronic healthcare data, others strive to take devices, systems or services Healthcare organizations are top targets for all sorts of cyber attacks, since, as noted above, lack of availability of crucial systems or data can lead not just to fines and reputation damage but poor healthcare outcomes and even loss of life. Adoption of new technologies expands the attack surface; in particular, cloud security is an increasingly important concern for the healthcare sector.
Some healthcare organizations rely on internal IT teams to handle most of their technical needs, while others count on service providers or product vendors to implement or support their security management initiatives. No matter which strategy you choose, to properly protect PHI and comply with HIPAA, you need to make sure that both you and all of your business associates are taking the required measures to minimize the risk of health information being improperly disclosed, stolen or encrypted. Original Article - Data Security in Healthcare: Key HIPAA Requirements and Threats to Know About Related:
An extensive guide for cashing out bitcoin and cryptocurrencies into private banks
Hey guys. Merry Xmas ! I am coming back to you with a follow up post, as I have helped many people cash out this year and I have streamlined the process. After my original post, I received many requests to be more specific and provide more details. I thought that after the amazing rally we have been attending over the last few months, and the volatility of the last few days, it would be interesting to revisit more extensively. The attitude of banks around crypto is changing slowly, but it is still a tough stance. For the first partial cash out I operated around a year ago for a client, it took me months to find a bank. They wouldn’t want to even consider the case and we had to knock at each and every door. Despite all my contacts it was very difficult back in the days. This has changed now, and banks have started to open their doors, but there is a process, a set of best practices and codes one has to follow. I often get requests from crypto guys who are very privacy-oriented, and it takes me months to have them understand that I am bound by Swiss law on banking secrecy, and I am their ally in this onboarding process. It’s funny how I have to convince people that banks are legit, while on the other side, banks ask me to show that crypto millionaires are legit. I have a solid background in both banking and in crypto so I manage to make the bridge, but yeah sometimes it is tough to reconcile the two worlds. I am a crypto enthusiast myself and I can say that after years of work in the banking industry I have grown disillusioned towards banks as well, like many of you. Still an account in a Private bank is convenient and powerful. So let’s get started.
A. What is required to open an account in a Private bank when you made your fortune through crypto.
There are two different aspects to your onboarding in a Swiss Private bank, compliance-wise. *The origin of your crypto wealth *Your background (residence, citizenship and probity) These two aspects must be documented in-depth. How to document your crypto wealth. Each new crypto millionaire has a different story. I may detail a few fun stories later in this post, but at the end of the day, most of crypto rich I have met can be categorized within the following profiles: the miner, the early adopter, the trader, the corporate entity, the black market, the libertarian/OTC buyer. The real question is how you prove your wealth is legit. 1. Context around the original amount/investment Generally speaking, your first crypto purchase may not be documented. But the context around this acquisition can be. I have had many cases where the original amount was bought through Mtgox, and no proof of purchase could be provided, nor could be documented any Mtgox claim. That’s perfectly fine. At some point Mtgox amounted 70% of the bitcoin transactions globally, and people who bought there and managed to withdraw and keep hold of their bitcoins do not have any Mtgox claim. This is absolutely fine. However, if you can show me the record of a wire from your bank to Tisbane (Mtgox's parent company) it's a great way to start. Otherwise, what I am trying to document here is the following: I need context. If you made your first purchase by saving from summer jobs, show me a payroll. Even if it was USD 2k. If you acquired your first bitcoins from mining, show me the bills of your mining equipment from 2012 or if it was through a pool mine, give me your slushpool account ref for instance. If you were given bitcoin against a service you charged, show me an invoice. 2. Tracking your wealth until today and making sense of it. What I have been doing over the last few months was basically educating compliance officers. Thanks God, the blockchain is a global digital ledger! I have been telling my auditors and compliance officers they have the best tool at their disposal to lead a proper investigation. Whether you like it or not, your wealth can be tracked, from address to address. You may have thought all along this was a bad feature, but I am telling you, if you want to cash out, in the context of Private Banking onboarding, tracking your wealth through the block explorer is a boon. We can see the inflows, outflows. We can see the age behind an address. An early adopter who bought 1000 BTC in 2010, and let his bitcoin behind one address and held thus far is legit, whether or not he has a proof of purchase to show. That’s just common sense. My job is to explain that to the banks in a language they understand. Let’s have a look at a few examples and how to document the few profiles I mentioned earlier. The trader. I love traders. These are easy cases. I have a ton of respect for them. Being a trader myself in investment banks for a decade earlier in my career has taught me that controlling one’s emotions and having the discipline to impose oneself some proper risk management system is really really hard. Further, being able to avoid the exchange bankruptcy and hacks throughout crypto history is outstanding. It shows real survival instinct, or just plain blissed ignorance. In any cases traders at exchange are easy cases to corroborate since their whole track record is potentially available. Some traders I have met have automated their trading and have shown me more than 500k trades done over the span of 4 years. Obviously in this kind of scenario I don’t show everything to the bank to avoid information overload, and prefer to do some snacking here and there. My strategy is to show the early trades, the most profitable ones, explain the trading strategy and (partially expose) the situation as of now with id pages of the exchanges and current balance. Many traders have become insensitive to the risk of parking their crypto at exchange as they want to be able to trade or to grasp an occasion any minute, so they generally do not secure a substantial portion on the blockchain which tends to make me very nervous. The early adopter. Provided that he has not mixed his coin, the early adopter or “hodler” is not a difficult case either. Who cares how you bought your first 10k btc if you bought them below 3$ ? Even if you do not have a purchase proof, I would generally manage to find ways. We just have to corroborate the original 30’000 USD investment in this case. I mainly focus on three things here: *proof of early adoption I have managed to educate some banks on a few evidences specifically related to crypto markets. For instance with me, an old bitcointalk account can serve as a proof of early adoption. Even an old reddit post from a few years ago where you say how much you despise this Ripple premined scam can prove to be a treasure readily available to show you were early. *story telling Compliance officers like to know when, why and how. They are human being looking for simple answers to simple questions and they don’t want like to be played fool. Telling the truth, even without a proof can do wonders, and even though bluffing might still work because banks don’t fully understand bitcoin yet, it is a risky strategy that is less and less likely to pay off as they are getting more sophisticated by the day. *micro transaction from an old address you control This is the killer feature. Send a $20 worth transaction from an old address to my company wallet and to one of my partner bank’s wallet and you are all set ! This is gold and considered a very solid piece of evidence. You can also do a microtransaction to your own wallet, but banks generally prefer transfer to their own wallet. Patience with them please. they are still learning. *signature message Why do a micro transaction when you can sign a message and avoid potentially tainting your coins ? *ICO millionaire Some clients made their wealth participating in ETH crowdsale or IOTA ICO. They were very easy to deal with obviously and the account opening was very smooth since we could evidence the GENESIS TxHash flow. The miner Not so easy to proof the wealth is legit in that case. Most early miners never took screenshot of the blocks on bitcoin core, nor did they note down the block number of each block they mined. Until the the Slashdot article from August 2010 anyone could mine on his laptop, let his computer run overnight and wake up to a freshly minted block containing 50 bitcoins back in the days. Not many people were structured enough to store and secure these coins, avoid malwares while syncing the blockchain continuously, let alone document the mined blocks in the process. What was 50 BTC worth really for the early miners ? dust of dollars, games and magic cards… Even miners post 2010 are generally difficult to deal with in terms of compliance onboarding. Many pool mining are long dead. Deepbit is down for instance and the founders are MIA. So my strategy to proof mining activity is as follow: *Focusing on IT background whenever possible. An IT background does help a lot to bring some substance to the fact you had the technical ability to operate a mining rig. *Showing mining equipment receipts. If you mined on your own you must have bought the hardware to do so. For instance mining equipment receipts from butterfly lab from 2012-2013 could help document your case. Similarly, high electricity bill from your household on a consistent basis back in the day could help. I have already unlocked a tricky case in the past with such documents when the bank was doubtful. *Wallet.dat files with block mining transactions from 2011 thereafter This obviously is a fantastic piece of evidence for both you and me if you have an old wallet and if you control an address that received original mined blocks, (even if the wallet is now empty). I will make sure compliance officers understand what it means, and as for the early adopter, you can prove your control over these wallet through a microtransaction. With these kind of addresses, I can show on the block explorer the mined block rewards hitting at regular time interval, and I can even spot when difficulty level increased or when halvening process happened. *Poolmining account. Here again I have educated my partner bank to understand that a slush account opened in 2013 or an OnionTip presence was enough to corroborate mining activity. The block explorer then helps me to do the bridge with your current wallet. *Describing your set up and putting it in context In the history of mining we had CPU, GPU, FPG and ASICs mining. I will describe your technical set up and explain why and how your set up was competitive at that time. The corporate entity Remember 2012 when we were all convinced bitcoin would take over the world, and soon everyone would pay his coffee in bitcoin? How naïve we were to think transaction fees would remain low forever. I don’t blame bitcoin cash supporters; I once shared this dream as well. Remember when we thought global adoption was right around the corner and some brick and mortar would soon accept bitcoin transaction as a common mean of payment? Well, some shop actually did accept payment and held. I had a few cases as such of shops holders, who made it to the multi million mark holding and had invoices or receipts to proof the transactions. If you are organized enough to keep a record for these trades and are willing to cooperate for the documentation, you are making your life easy. The digital advertising business is also a big market for the bitcoin industry, and affiliates partner compensated in btc are common. It is good to show an invoice, it is better to show a contract. If you do not have a contract (which is common since all advertising deals are about ticking a check box on the website to accept terms and conditions), there are ways around that. If you are in that case, pm me. The black market Sorry guys, I can’t do much for you officially. Not that I am judging you. I am a libertarian myself. It’s just already very difficult to onboard legit btc adopters, so the black market is a market I cannot afford to consider. My company is regulated so KYC and compliance are key for me if I want to stay in business. Behind each case I push forward I am risking the credibility and reputation I have built over the years. So I am sorry guys I am not risking it to make an extra buck. Your best hope is that crypto will eventually take over the world and you won’t need to cash out anyway. Or go find a Lithuanian bank that is light on compliance and cooperative. The OTC buyer and the libertarian. Generally a very difficult case. If you bought your stack during your journey in Japan 5 years ago to a guy you never met again; or if you accumulated on https://localbitcoins.com/ and kept no record or lost your account, it is going to be difficult. Not impossible but difficult. We will try to build a case with everything else we have, and I may be able to onboard you. However I am risking a lot here so I need to be 100% confident you are legit, before I defend you. Come & see me in Geneva, and we will talk. I will run forensic services like elliptic, chainalysis, or scorechain on an extract of your wallet. If this scan does not raise too many red flags, then maybe we can work together ! If you mixed your coins all along your crypto history, and shredded your seeds because you were paranoid, or if you made your wealth mining professionally monero over the last 3 years but never opened an account at an exchange. ¯_(ツ)_/¯ I am not a magician and don’t get me wrong, I love monero, it’s not the point. Cashing out ICOs Private companies or foundations who have ran an ICO generally have a very hard time opening a bank account. The few banks that accept such projects would generally look at 4 criteria: *Seriousness of the project Extensive study of the whitepaper to limit the reputation risk *AML of the onboarding process ICOs 1.0 have no chance basically if a background check of the investors has not been conducted *Structure of the moral entity List of signatories, certificate of incumbency, work contract, premises... *Fiscal conformity Did the company informed the authorities and seek a fiscal ruling.
B. The tax issue I am not a tax specialist, but I can say that this year I have seen it all. Again I am not judging. You made $100m hodling, and still wouldn’t pay your taxes ? Your decision.I personally advise everyone to pay their taxes, but also to be generous, to give to charities. I mean you eventually made it. Good for you. What about you contribute to make the world a better place now? I will stop patronizing you. It’s just my 2cts, and it’s your money.
For the record, I am not into the tax avoidance business, so people come to me with a set up and I see if I can make it work within the legal framework imposed to me. First, stop thinking Switzerland is a “offshore heaven” Swiss banks have made deals with many governments for the exchange of fiscal information. If you are a French citizen, resident in France and want to open an account in a Private Bank in Switzerland to cash out your bitcoins, you will get slaughtered (>60%). There are ways around that, and I could refer you to good tax specialists for fiscal optimization, but I cannot organize it myself. It would be illegal for me. Swiss private banks makes it easy for you to keep a good your relation with your retail bank and continue paying your bills without headaches. They are integrated to SEPA, provide ebanking and credit cards. For information, these are the kind of set up some of my clients came up with. It’s all legal; obviously I do not onboard clients that are not tax compliant. Further disclaimer: I did not contribute myself to these set up. Do not ask me to organize it for you. I won’t. EU tricks Swiss lump sum taxation Foreign nationals resident in Switzerland can be taxed on a lump-sum basis if they are not gainfully employed in our country. Under the lump-sum tax regime, foreign nationals taking residence in Switzerland may choose to pay an expense-based tax instead of ordinary income and wealth tax. Attractive cantons for the lump sum taxation are Zug, Vaud, Valais, Grisons, Lucerne and Berne. To make it short, you will be paying somewhere between 200 and 400k a year and all expenses will be deductible. Switzerland has adopted a very friendly attitude towards crypto currency in general. There is a whole crypto valley in Zug now. 30% of ICOs are operated in Switzerland. The reason is that Switzerland has thrived for centuries on banking secrecy, and today with FATCA and exchange of fiscal info with EU, banking secrecy is dead. Regulators in Switzerland have understood that digital ledger technologies were a way to roll over this competitive advantage for the generations to come. Switzerland does not tax capital gains on crypto profits. The Finma has a very pragmatic approach. They have issued guidance- updated guidelines here. They let the business get organized and operate their analysis on a case per case basis. Only after getting a deep understanding of the market will they issue a global fintech license in 2019. This approach is much more realistic than legislations which try to regulate everything beforehand. Italy new tax exemption. It’s a brand new fiscal exemption. Go to Aoste, get residency and you could be taxed a 100k/year for 10years. Yes, really. Portugal What’s crazy in Europe is the lack of fiscal harmonization. Even if no one in Brussels dares admit it, every other country is doing fiscal dumping. Portugal is such a country and has proved very friendly fiscally speaking. I personally have a hard time trusting Europe. I have witnessed what happened in Greece over the last few years. Some of our ultra high net worth clients got stuck with capital controls. I mean no way you got out of crypto to have your funds confiscated at the next financial crisis! Anyway. FYI Malta Generally speaking, if you get a residence somewhere you have to live there for a certain period of time. Being stuck in Italy is no big deal with Schengen Agreement, but in Malta it is a different story. In Malta, the ordinary residence scheme is more attractive than the HNWI residence scheme. Being an individual, you can hold a residence permit under this scheme and pay zero income tax in Malta in a completely legal way. Monaco Not suitable for French citizens, but for other Ultra High Net worth individual, Monaco is worth considering. You need an account at a local bank as a proof of fortune, and this account generally has to be seeded with at least EUR500k. You also need a proof of residence. I do mean UHNI because if you don’t cash out minimum 30m it’s not interesting. Everything is expensive in Monaco. Real Estate is EUR 50k per square meter. A breakfast at Monte Carlo Bay hotel is 70 EUR. Monaco is sunny but sometimes it feels like a golden jail. Do you really want that for your kids? Dubaï
Set up a company in Dubaï, get your resident card.
Spend one day every 6 month there
Be tax free
US tricks Some Private banks in Geneva do have the license to manage the assets of US persons and U.S citizens. However, do not think it is a way to avoid paying taxes in the US. Opening an account at an authorized Swiss Private banks is literally the same tax-wise as opening an account at Fidelity or at Bank of America in the US. The only difference is that you will avoid all the horror stories. Horror stories are all real by the way. In Switzerland, if you build a decent case and answer all the questions and corroborate your case in depth, you will manage to convince compliance officers beforehand. When the money eventually hits your account, it is actually available and not frozen. The IRS and FATCA require to file FBAR if an offshore account is open. However FBAR is a reporting requirement and does not have taxes related to holding an account outside the US. The taxes would be the same if the account was in the US. However penalties for non compliance with FBAR are very large. The tax liability management is actually performed through the management of the assets ( for exemple by maximizing long term capital gains and minimizing short term gains). The case for Porto Rico. Full disclaimer here. I am not encouraging this. Have not collaborated on such tax avoidance schemes. if you are interested I strongly encourage you to seek a tax advisor and get a legal opinion. I am not responsible for anything written below. I am not going to say much because I am so afraid of uncle Sam that I prefer to humbly pass the hot potato to pwc From here all it takes is a good advisor and some creativity to be tax free on your crypto wealth if you are a US person apparently. Please, please please don’t ask me more. And read the disclaimer again. Trust tricks Generally speaking I do not accept fringe fiscal situation because it puts me in a difficult situation to the banks I work with, and it is already difficult enough to defend a legit crypto case. Trust might be a way to optimize your fiscal situation. Belize. Bahamas. Seychelles. Panama, You name it. At the end of the day, what matters for Swiss Banks are the beneficial owner and the settlor. Get a legal opinion, get it done, and when you eventually knock at a private bank’s door, don’t say it was for fiscal avoidance you stupid ! You will get the door smashed upon you. Be smarter. It will work. My advice is just to have it done by a great tax specialist lawyer, even if it costs you some money, as the entity itself needs to be structured in a professional way. Remember that with trust you are dispossessing yourself off your wealth. Not something to be taken lightly. “Anonymous” cash out. Right. I think I am not going into this topic, neither expose the ways to get it done. Pm me for details. I already feel a bit uncomfortable with all the info I have provided. I am just going to mention many people fear that crypto exchange might become reporting entities soon, and rightly so. This might happen anyday. You have been warned. FYI, this only works for non-US and large cash out. The difference between traders an investors. Danmark, Holland and Germany all make a huge difference if you are a passive investor or if you are a trader. ICO is considered investing for instance and is not taxed, while trading might be considered as income and charged aggressively. I would try my best to protect you and put a focus on your investor profile whenever possible, so you don't have to pay 52% tax if you do not have to :D
C. The cash out itself So you have accumulated patiently a good amount of wealth. For some of us who have been involved in crypto since 2010, it took years. Remember when BTC was stuck at 200$ for months? I personally feel like it was yesterday. There is no way you screw up your wealth by cashing out in a hurry or with low security standards. Here is how the cash out takes should place.
Full cash out or partial cash out? People who have been sitting on crypto for long have grown an emotional and irrational link with their coins. They come to me and say, look, I have 50m in crypto but I would like to cash out 500k only. So first let me tell you that as a wealth manager my advice to you is to take some off the table. Doing a partial cash out is absolutely fine. The market is bullish. We are witnessing a redistribution of wealth at a global scale. Bitcoin is the real #occupywallstreet, and every one will discuss crypto at Xmas eve which will make the market even more supportive beginning 2018, especially with all hedge funds entering the scene. If you want to stay exposed to bitcoin and altcoins, and believe these techs will change the world, it’s just natural you want to keep some coins. In the meantime, if you have lived off pizzas over the last years, and have the means to now buy yourself an nice house and have an account at a private bank, then f***ing do it mate ! Buy physical gold with this account, buy real estate, have some cash at hands. Even though US dollar is worthless to your eyes, it’s good and convenient to have some. Also remember your wife deserves it ! And if you have no wife yet and you are socially awkward like the rest of us, then maybe cashing out partially will help your situation ;) What the Private Banks expect. Joke aside, it is important you understand something. If you come around in Zurich to open a bank account and partially cash out, just don’t expect Private Banks will make an exception for you if you are small. You can’t ask them to facilitate your cash out, buy a 1m apartment with the proceeds of the sale, and not leave anything on your current account. It won’t work. Sadly, under 5m you are considered small in private banking. The bank is ok to let you open an account, provided that your kyc and compliance file are validated, but they will also want you to become a client and leave some money there to invest. This might me despicable, but I am just explaining you their rules. If you want to cash out, you should sell enough to be comfortable and have some left. Also expect the account opening to last at least 3-4 week if everything goes well. You can't just open an account overnight. The cash out logistics. Cashing out 1m USD a day in bitcoin or more is not so hard. Let me just tell you this: Even if you get a Tier 4 account with Kraken and ask Alejandro there to raise your limit over $100k per day, Even if you have a bitfinex account and you are willing to expose your wealth there, Even if you have managed to pass all the crazy due diligence at Bitstamp, The amount should be fractioned to avoid risking your full wealth on exchange and getting slaughtered on the price by trading big quantities. Cashing out involves significant risks at all time. There is a security risk of compromising your keys, a counterparty risk, a fat finger risk. Let it be done by professionals. It is worth every single penny. Most importantly, there is a major difference between trading on an exchange and trading OTC. Even though it’s not publicly disclosed some exchange like Kraken do have OTC desks. Trading on an exchange for a large amount will weight on the prices. Bitcoin is a thin market. In my opinion over 30% of the coins are lost in translation forever. Selling $10m on an exchange in a day can weight on the prices more than you’d think. And if you trade on a exchange, everything is shown on record, and you might wipe out the prices because on exchanges like bitstamp or kraken ultimately your counterparties are retail investors and the market depth is not huge. It is a bit better on Bitfinex. It is way better to trade OTC. Accessing the institutional OTC market is not easy, and that is also the reason why you should ask a regulated financial intermediary if we are talking about huge amounts. Last point, always chose EUR as opposed to USD. EU correspondent banks won’t generally block institutional amounts. However we had the cases of USD funds frozen or delayed by weeks. Most well-known OTC desks are Cumberlandmining (ask for Lucas), Genesis (ask for Martin), Bitcoin Suisse AG (ask for Niklas), circletrade, B2C2, or Altcoinomy (ask for Olivier) Very very large whales can also set up escrow accounts for massive block trades. This world, where blocks over 30k BTC are exchanged between 2 parties would deserve a reddit thread of its own. Crazyness all around. Your options: DIY or going through a regulated financial intermediary. Execution trading is a job in itself. You have to be patient, be careful not to wipe out the order book and place limit orders, monitor the market intraday for spikes or opportunities. At big levels, for a large cash out that may take weeks, these kind of details will save you hundred thousands of dollars. I understand crypto holders are suspicious and may prefer to do it by themselves, but there are regulated entities who now offer the services. Besides, being a crypto millionaire is not a guarantee you will get institutional daily withdrawal limits at exchange. You might, but it will take you another round of KYC with them, and surprisingly this round might be even more aggressive that the ones at Private banks since exchange have gone under intense scrutiny by regulators lately. The fees for cashing out through a regulated financial intermediary to help you with your cash out should be around 1-2% flat on the nominal, not more. And for this price you should get the full package: execution/monitoring of the trades AND onboarding in a private bank. If you are asked more, you are being abused. Of course, you also have the option to do it yourself. It is a way more tedious and risky process. Compliance with the exchange, compliance with the private bank, trading BTC/fiat, monitoring the transfers…You will save some money but it will take you some time and stress. Further, if you approach a private bank directly, it will trigger a series of red flag to the banks. As I said in my previous post, they call a direct approach a “walk-in”. They will be more suspicious than if you were introduced by someone and won’t hesitate to show you high fees and load your portfolio with in-house products that earn more money to the banks than to you. Remember also most banks still do not understand crypto so you will have a lot of explanations to provide and you will have to start form scratch with them! The paradox of crypto millionaires Most of my clients who made their wealth through crypto all took massive amount of risks to end up where they are. However, most of them want their bank account to be managed with a low volatility fixed income capital preservation risk profile. This is a paradox I have a hard time to explain and I think it is mainly due to the fact that most are distrustful towards banks and financial markets in general. Many clients who have sold their crypto also have a cash-out blues in the first few months. This is a classic situation. The emotions involved in hodling for so long, the relief that everything has eventually gone well, the life-changing dynamics, the difficulties to find a new motivation in life…All these elements may trigger a post cash-out depression. It is another paradox of the crypto rich who has every card in his hand to be happy, but often feel a bit sad and lonely. Sometimes, even though it’s not my job, I had to do some psychological support. A lot of clients have also become my friends, because we have the same age and went through the same “ordeal”. First world problem I know… Remember, cashing out is not the end. It’s actually the beginning. Don’t look back, don’t regret. Cash out partially, because it does not make sense to cash out in full, regret it and want back in. relax. The race to cash out crypto billionaire and the concept of late exiter. The Winklevoss brothers are obviously the first of a series. There will be crypto billionaires. Many of them. At a certain level you can have a whole family office working for you to manage your assets and take care of your needs . However, let me tell you it’s is not because you made it so big that you should think you are a genius and know everything better than anyone. You should hire professionals to help you. Managing assets require some education around the investment vehicles and risk management strategies. Sorry guys but with all the respect I have for wallstreebet, AMD and YOLO stock picking, some discipline is necessary. The investors who have made money through crypto are generally early adopters. However I have started to see another profile popping up. They are not early adopters. They are late exiters. It is another way but just as efficient. Last week I met the first crypto millionaire I know who first bough bitcoin over 1000$. 55k invested at the beginning of this year. Late adopter & late exiter is a route that can lead to the million. Last remarks. I know banks, bankers, and FIAT currencies are so last century. I know some of you despise them and would like to have them burn to the ground. With compliance officers taking over the business, I would like to start the fire myself sometimes. I hope this extensive guide has helped some of you. I am around if you need more details. I love my job despite all my frustration towards the banking industry because it makes me meet interesting people on a daily basis. I am a crypto enthusiast myself, and I do think this tech is here to stay and will change the world. Banks will have to adapt big time. Things have started to change already; they understand the threat is real. I can feel the generational gap in Geneva, with all these old bankers who don’t get what’s going on. They glaze at the bitcoin chart on CNBC in disbelief and they start to get it. This bitcoin thing is not a joke. Deep inside, as an early adopter who also intends to be a late exiter, as a libertarian myself, it makes me smile with satisfaction. Cheers. @swisspb on telegram
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