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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.
A couple of years ago in the early months of the 2017, I published a piece called Abundance Via Cryptocurrencies (https://www.reddit.com/C\_S\_T/comments/69d12a/abundance\_via\_cryptocurrencies/) in which I kind of foresaw the crypto boom that had bitcoin go from $1k to $21k and the alt-coin economy swell up to have more than 60% of the bitcoin market capitalisation. At the time, I spoke of coming out from “the Pit” of conspiracy research and that I was a bit suss on bitcoin’s inception story. At the time I really didn’t see the scaling solution being put forward as being satisfactory and the progress on bitcoin seemed stifled by the politics of the social consensus on an open source protocol so I was looking into alt coins that I thought could perhaps improve upon the shortcomings of bitcoin. In the thread I made someone recommended to have a look at 4chan’s business and finance board. I did end up taking a look at it just as the bull market started to really surge. I found myself in a sea of anonymous posters who threw out all kinds of info and memes about the hundreds, thousands, tens of thousands of different shitcoins and why they’re all going to have lambos on the moon. I got right in to it, I loved the idea of filtering through all the shitposts and finding the nuggest of truth amongst it all and was deeply immersed in it all as the price of bitcoin surged 20x and alt coins surged 5-10 times against bitcoin themselves. This meant there were many people who chucked in a few grand and bought a stash of alt coins that they thought were gonna be the next big thing and some people ended up with “portfolios” 100-1000x times their initial investment. To explain what it’s like to be on an anonymous business and finance board populated with incel neets, nazis, capitalist shit posters, autistic geniuses and whoever the hell else was using the board for shilling their coins during a 100x run up is impossible. It’s hilarious, dark, absurd, exciting and ultimately addictive as fuck. You have this app called blockfolio that you check every couple of minutes to see the little green percentages and the neat graphs of your value in dollars or bitcoin over day, week, month or year. Despite my years in the pit researching conspiracy, and my being suss on bitcoin in general I wasn’t anywhere near as distrustful as I should have been of an anonymous business and finance board and although I do genuinely think there are good people out there who are sharing information with one another in good faith and feel very grateful to the anons that have taken their time to write up quality content to educate people they don’t know, I wasn’t really prepared for the level of organisation and sophistication of the efforts groups would go to to deceive in this space. Over the course of my time in there I watched my portfolio grow to ridiculous numbers relative to what I put in but I could never really bring myself to sell at the top of a pump as I always felt I had done my research on a coin and wanted to hold it for a long time so why would I sell? After some time though I would read about something new or I would find out of dodgy relationships of a coin I had and would want to exit my position and then I would rebalance my portfolio in to a coin I thought was either technologically superior or didn’t have the nefarious connections to people I had come across doing conspiracy research. Because I had been right in to the conspiracy and the decentralisation tropes I guess I always carried a bit of an antiauthoritarian/anarchist bias and despite participating in a ridiculously capitalistic market, was kind of against capitalism and looking to a blockchain protocol to support something along the lines of an open source anarchosyndicalist cryptocommune. I told myself I was investing in the tech and believed in the collective endeavour of the open source project and ultimately had faith some mysterious “they” would develop a protocol that would emancipate us from this debt slavery complex. As I became more and more aware of how to spot artificial discussion on the chans, I began to seek out further some of the radical projects like vtorrent and skycoin and I guess became a bit carried away from being amidst such ridiculous overt shilling as on the boards so that if you look in my post history you can even see me promoting some of these coins to communities I thought might be sympathetic to their use case. I didn’t see it at the time because I always thought I was holding the coins with the best tech and wanted to ride them up as an investor who believed in them, but this kind of promotion is ultimately just part of a mentality that’s pervasive to the cryptocurrency “community” that insists because it is a decentralised project you have to in a way volunteer to inform people about the coin since the more decentralised ones without premines or DAO structures don’t have marketing budgets, or don’t have marketing teams. In the guise of cultivating a community, groups form together on social media platforms like slack, discord, telegram, twitter and ‘vote’ for different proposals, donate funds to various boards/foundations that are set up to give a “roadmap” for the coins path to greatness and organise marketing efforts on places like reddit, the chans, twitter. That’s for the more grass roots ones at least, there are many that were started as a fork of another coin, or a ICO, airdrop or all these different ways of disseminating a new cryptocurrency or raising funding for promising to develop one. Imagine the operations that can be run by a team that raised millions, hundreds of millions or even billions of dollars on their ICOs, especially if they are working in conjunction with a new niche of cryptocurrency media that’s all nepotistic and incestuous. About a year and a half ago I published another piece called “Bitcoin is about to be dethroned” (https://www.reddit.com/C\_S\_T/comments/7ewmuu/bitcoin\_is\_about\_to\_be\_dethroned/) where I felt I had come to realise the scaling debate had been corrupted by a company called Blockstream and they had been paying for social media operations in a fashion not to dissimilar to correct the record or such to control the narrative around the scaling debate and then through deceit and manipulation curated an apparent consensus around their narrative and hijacked the bitcoin name and ticker (BTC). I read the post again just before posting this and decided to refer to it to to add some kind of continuity to my story and hopefully save me writing so much out. Looking back on something you wrote is always a bit cringey especially because I can see that although I had made it a premise post, I was acting pretty confident that I was right and my tongue was acidic because of so much combating of shills on /biz/ but despite the fact I was wrong about the timing I stand by much of what I wrote then and want to expand upon it a bit more now. The fork of the bitcoin protocol in to bitcoin core (BTC) and bitcoin cash (BCH) is the biggest value fork of the many that have occurred. There were a few others that forked off from the core chain that haven’t had any kind of attention put on them, positive or negative and I guess just keep chugging away as their own implementation. The bitcoin cash chain was supposed to be the camp that backed on chain scaling in the debate, but it turned out not everyone was entirely on board with that and some players/hashpower felt it was better to do a layer two type solution themselves although with bigger blocks servicing the second layer. Throughout what was now emerging as a debate within the BCH camp, Craig Wright and Calvin Ayre of Coin Geek said they were going to support massive on chain scaling, do a node implementation that would aim to restore bitcoin back to the 0.1.0 release which had all kinds of functionality included in it that had later been stripped by Core developers over the years and plan to bankrupt the people from Core who changed their mind on agreeing with on-chain scaling. This lead to a fork off the BCH chain in to bitcoin satoshis vision (BSV) and bitcoin cash ABC. https://bitstagram.bitdb.network/m/raw/cbb50c322a2a89f3c627e1680a3f40d4ad3cee5a3fb153e5d6d001bdf85de404 The premise for this post is that Craig S Wright was Satoshi Nakamoto. It’s an interesting premise because depending upon your frame of reference the premise may either be a fact or to some too outrageous to even believe as a premise. Yesterday it was announced via CoinGeek that Craig Steven Wright has been granted the copyright claim for both the bitcoin white-paper under the pen name Satoshi Nakamoto and the original 0.1.0 bitcoin software (both of which were marked (c) copyright of satoshi nakamoto. The reactions to the news can kind of be classified in to four different reactions. Those who heard it and rejected it, those who heard it but remained undecided, those who heard it and accepted it, and those who already believed he was. Apparently to many the price was unexpected and such a revelation wasn’t exactly priced in to the market with the price immediately pumping nearly 100% upon the news breaking. However, to some others it was a vindication of something they already believed. This is an interesting phenomena to observe. For many years now I have always occupied a somewhat positively contrarian position to the default narrative put forward to things so it’s not entirely surprising that I find myself in a camp that holds the minority opinion. As you can see in the bitcoin dethroned piece I called Craig fake satoshi, but over the last year and bit I investigated the story around Craig and came to my conclusion that I believed him to be at least a major part of a team of people who worked on the protocol I have to admit that through reading his articles, I have kind of been brought full circle to where my contrarian opinion has me becoming somewhat of an advocate for “the system’. https://coingeek.com/bitcoin-creator-craig-s-wright-satoshi-nakamoto-granted-us-copyright-registrations-for-bitcoin-white-paper-and-code/ When the news dropped, many took to social media to see what everyone was saying about it. On /biz/ a barrage of threads popped up discussing it with many celebrating and many rejecting the significance of such a copyright claim being granted. Immediately in nearly every thread there was a posting of an image of a person from twitter claiming that registering for copyright is an easy process that’s granted automatically unless challenged and so it doesn’t mean anything. This was enough for many to convince them of the insignificance of the revelation because of the comment from a person who claimed to have authority on twitter. Others chimed in to add that in fact there was a review of the copyright registration especially in high profile instances and these reviewers were satisfied with the evidence provided by Craig for the claim. At the moment Craig is being sued by Ira Kleiman for an amount of bitcoin that he believes he is entitled to because of Craig and Ira’s brother Dave working together on bitcoin. He is also engaged in suing a number of people from the cryptocurrency community for libel and defamation after they continued to use their social media/influencer positions to call him a fraud and a liar. He also has a number of patents lodged through his company nChain that are related to blockchain technologies. This has many people up in arms because in their mind Satoshi was part of a cypherpunk movement, wanted anonymity, endorsed what they believed to be an anti state and open source technologies and would use cryptography rather than court to prove his identity and would have no interest in patents. https://bitstagram.bitdb.network/m/raw/1fce34a7004759f8db16b2ae9678e9c6db434ff2e399f59b5a537f72eff2c1a1 https://imgur.com/a/aANAsL3) If you listen to Craig with an open mind, what cannot be denied is the man is bloody smart. Whether he is honest or not is up to you to decide, but personally I try to give everyone the benefit of the doubt and then cut them off if i find them to be dishonest. What I haven’t really been able to do with my investigation of craig is cut him off. There have been many moments where I disagree with what he has had to say but I don’t think people having an opinion about something that I believe to be incorrect is the same as being a dishonest person. It’s very important to distinguish the two and if you are unable to do so there is a very real risk of you projecting expectations or ideals upon someone based off your ideas of who they are. Many times if someone is telling the truth but you don’t understand it, instead of acknowledging you don’t understand it, you label them as being stupid or dishonest. I think that has happened to an extreme extent with Craig. Let’s take for example the moment when someone in the slack channel asked Craig if he had had his IQ tested and what it was. Craig replied with 179. The vast majority of people on the internet have heard someone quote their IQ before in an argument or the IQ of others and to hear someone say such a score that is actually 6 standard deviations away from the mean score (so probably something like 1/100 000) immediately makes them reject it on the grounds of probability. Craig admits that he’s not the best with people and having worked with/taught many high functioning people (sometimes on the spectrum perhaps) on complex anatomical and physiological systems I have seen some that also share the same difficulties in relating to people and reconciling their genius and understandings with more average intelligences. Before rejecting his claim outright because we don’t understand much of what he says, it would be prudent to first check is there any evidence that may lend support to his claim of a one in a million intelligence quotient. Craig has mentioned on a number of occasions that he holds a number of different degrees and certifications in relation to law, cryptography, statistics, mathematics, economics, theology, computer science, information technology/security. I guess that does sound like something someone with an extremely high intelligence could achieve. Now I haven’t validated all of them but from a simple check on Charles Sturt’s alumni portal using his birthday of 23rd of October 1970 we can see that he does in fact have 3 Masters and a PhD from Charles Sturt. Other pictures I have seen from his office at nChain have degrees in frames on the wall and a developer published a video titled Craig Wright is a Genius with 17 degrees where he went and validated at least 8 of them I believe. He is recently publishing his Doctorate of Theology through an on-chain social media page that you have to pay a little bit for access to sections of his thesis. It’s titled the gnarled roots of creation. He has also mentioned on a number of occasions his vast industry experience as both a security contractor and business owner. An archive from his LinkedIn can be seen below as well. LinkedIn - https://archive.is/Q66Gl https://youtu.be/nXdkczX5mR0 - Craig Wright is a Genius with 17 Degrees https://www.yours.org/content/gnarled-roots-of-a-creation-mythos-45e69558fae0 - Gnarled Roots of Creation. In fact here is an on chain collection of articles and videos relating to Craig called the library of craig - https://www.bitpaste.app/tx/94b361b205196560d1bd09e4e3b3ec7ad6bea478af204cabfe243efd8fc944dd So there is a guy with 17 degrees, a self professed one in a hundred thousand IQ, who’s worked for Australian Federal Police, ASIO, NSA, NASA, ASX. He’s been in Royal Australian Air Force, operated a number of businesses in Australia, published half a dozen academic papers on networks, cryptography, security, taught machine learning and digital forensics at a number of universities and then another few hundred short articles on medium about his work in these various domains, has filed allegedly 700 patents on blockchain related technology that he is going to release on bitcoin sv, copyrighted the name so that he may prevent other competing protocols from using the brand name, that is telling you he is the guy that invented the technology that he has a whole host of other circumstantial evidence to support that, but people won’t believe that because they saw something that a talking head on twitter posted or that a Core Developer said, or a random document that appears online with a C S Wright signature on it that lists access to an address that is actually related to Roger Ver, that’s enough to write him off as a scam. Even then when he publishes a photo of the paper copy which appears to supersede the scanned one, people still don’t readjust their positions on the matter and resort back to “all he has to do is move the coins or sign a tx”. https://imgur.com/urJbe10 Yes Craig was on the Cypherpunk mailing list back in the day, but that doesn’t mean that he was or is an anarchist. Or that he shares the same ideas that Code Is Law that many from the crypto community like to espouse. I myself have definitely been someone to parrot the phrase myself before reading lots of Craig’s articles and trying to understand where he is coming from. What I have come to learn from listening and reading the man, is that although I might be fed up with the systems we have in place, they still exist to perform important functions within society and because of that the tools we develop to serve us have to exist within that preexisting legal and social framework in order for them to have any chance at achieving global success in replacing fiat money with the first mathematically provably scarce commodity. He says he designed bitcoin to be an immutable data ledger where everyone is forced to be honest, and economically disincentivised to perform attacks within the network because of the logs kept in a Write Once Read Many (WORM) ledger with hierarchical cryptographic keys. In doing so you eliminate 99% of cyber crime, create transparent DAO type organisations that can be audited and fully compliant with legislature that’s developed by policy that comes from direct democratic voting software. Everyone who wants anonymous coins wants to have them so they can do dishonest things, illegal things, buy drugs, launder money, avoid taxes. Now this triggers me a fair bit as someone who has bought drugs online, who probably hasn’t paid enough tax, who has done illegal things contemplating what it means to have that kind of an evidence ledger, and contemplate a reality where there are anonymous cryptocurrencies, where massive corporations continue to be able to avoid taxes, or where methamphetamine can be sold by the tonne, or where people can be bought and sold. This is the reality of creating technologies that can enable and empower criminals. I know some criminals and regard them as very good friends, but I know there are some criminals that I do not wish to know at all. I know there are people that do horrific things in the world and I know that something that makes it easier for them is having access to funds or the ability to move money around without being detected. I know arms, drugs and people are some of the biggest markets in the world, I know there is more than $50 trillion dollars siphoned in to off shore tax havens from the value generated as the product of human creativity in the economy and how much human charity is squandered through the NGO apparatus. I could go on and on about the crappy things happening in the world but I can also imagine them getting a lot worse with an anonymous cryptocurrency. Not to say that I don’t think there shouldn’t be an anonymous cryptocurrency. If someone makes one that works, they make one that works. Maybe they get to exist for a little while as a honeypot or if they can operate outside the law successfully longer, but bitcoin itself shouldn’t be one. There should be something a level playing field for honest people to interact with sound money. And if they operate within the law, then they will have more than adequate privacy, just they will leave immutable evidence for every transaction that can be used as evidence to build a case against you committing a crime. His claim is that all the people that are protesting the loudest about him being Satoshi are all the people that are engaged in dishonest business or that have a vested interest in there not being one singular global ledger but rather a whole myriad of alternative currencies that can be pumped and dumped against one another, have all kinds of financial instruments applied to them like futures and then have these exchanges and custodial services not doing any Know Your Customer (KYC) or Anti Money Laundering (AML) processes. Bitcoin SV was delisted by a number of exchanges recently after Craig launched legal action at some twitter crypto influencetalking heads who had continued to call him a fraud and then didn’t back down when the CEO of one of the biggest crypto exchanges told him to drop the case or he would delist his coin. The trolls of twitter all chimed in in support of those who have now been served with papers for defamation and libel and Craig even put out a bitcoin reward for a DOX on one of the people who had been particularly abusive to him on twitter. A big european exchange then conducted a twitter poll to determine whether or not BSV should be delisted as either (yes, it’s toxic or no) and when a few hundred votes were in favour of delisting it (which can be bought for a couple of bucks/100 votes). Shortly after Craig was delisted, news began to break of a US dollar stable coin called USDT potentially not being fully solvent for it’s apparent 1:1 backing of the token to dollars in the bank. Binance suffered an alleged exchange hack with 7000 BTC “stolen” and the site suspending withdrawals and deposits for a week. Binance holds 800m USDT for their US dollar markets and immediately once the deposits and withdrawals were suspended there was a massive pump for BTC in the USDT markets as people sought to exit their potentially not 1:1 backed token for bitcoin. The CEO of this exchange has the business registered out of Malta, no physical premises, the CEO stays hotel room to hotel room around the world, has all kind of trading competitions and the binance launchpad, uses an unregistered security to collect fees ($450m during the bear market) from the trading of the hundreds of coins that it lists on its exchange and has no regard for AML and KYC laws. Craig said he himself was able to create 100 gmail accounts in a day and create binance accounts with each of those gmail accounts and from the same wallet, deposit and withdraw 1 bitcoin into each of those in one day ($8000 x 100) without facing any restrictions or triggering any alerts or such. This post could ramble on for ever and ever exposing the complexities of the rabbit hole but I wanted to offer some perspective on what’s been happening in the space. What is being built on the bitcoin SV blockchain is something that I can only partially comprehend but even from my limited understanding of what it is to become, I can see that the entirety of the crypto community is extremely threatened as it renders all the various alt coins and alt coin exchanges obsolete. It makes criminals play by the rules, it removes any power from the developer groups and turns the blockchain and the miners in to economies of scale where the blockchain acts as a serverless database, the miners provide computational resources/storage/RAM and you interact with a virtual machine through a monitor and keyboard plugged in to an ethernet port. It will be like something that takes us from a type 0 to a type 1 civilisation. There are many that like to keep us in the quagmire of corruption and criminality as it lines their pockets. Much much more can be read about the Cartel in crypto in the archive below. Is it possible this cartel has the resources to mount such a successful psychological operation on the cryptocurrency community that they manage to convince everyone that Craig is the bad guy, when he’s the only one calling for regulation, the application of the law, the storage of immutable records onchain to comply with banking secrecy laws, for Global Sound Money? https://archive.fo/lk1lH#selection-3671.46-3671.55 Please note, where possible, images were uploaded onto the bitcoin sv blockchain through bitstagram paying about 10c a pop. If I wished I could then use an application etch and archive this post to the chain to be immutably stored. If this publishing forum was on chain too it would mean that when I do the archive the images that are in the bitstragram links (but stored in the bitcoin blockchain/database already) could be referenced in the archive by their txid so that they don’t have to be stored again and thus bringing the cost of the archive down to only the html and css.
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