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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.
Hello! My name is Mihail Kudryashev, I am a frontend engineer at Platinum. We are a an international STO/IEO/ICO/POST ICO consulting, promotion and fundraising company with huge experience in STO and ICO marketing and best STO blockchain platform in the world! Learn more about it: Platinum.fund Our company gained popularity after launching the world’s number one online university with only practical knowledge on crypto economics. Now you can learn how to create and develop your own ICO and STO, how to market your campaign and make it super successful. Who are cryptocurrency investors? What drives people to invest in cryptocurrency? Read the extract of the UBAI lesson to get all the answers. Introduction to the Investors §2 In 2017, the total cryptocurrency market capitalization was approaching $850B which begs the question: Why are investors turning to cryptocurrencies? A survey by Blockchain Capital indicated that at least 30% of millennials would rather invest in bitcoin than invest in traditional stocks. Cryptocurrency investors, like traditional investors, expect a return at least proportionate to the risk they take. Due to the fundamental lack of regulation, incredible volatility and astronomical relative risk, many cryptocurrency investors expect to earn meteoric returns. Returns in the ranges of multiples from 200% to 1000%. Let us first begin by examining the kinds of people who invest in cryptocurrency, and then let’s see the reasons why each of them is investing in this relatively new market. Types of Investors The “Newbie” Cryptocurrency Investor This investor is just starting out. They probably have not had any significant experience in any form of investing before and bitcoin is their first experience. They have heard about people making incredible returns from cryptocurrency investing, or some aspect of the entire blockchain and crypto revolution attracts them, and they decide they want to invest too. Unfortunately, most of the newbie investors will end up losing their money, primarily because of one specific misconception; they think cryptocurrency investing is an easy way to make huge profits. “ “Types of Investors §2 “Gambler” or “Get Rich Quick” Investor This is the second class of cryptocurrency investor, and is actually not really an investor at all. This type of person is out to make a fortune as fast as possible. They will fall for whatever sweet-sounding scheme they hear. They love ideas that promise to double or triple their investment quickly. Like the Newbie, they do not understand how cryptocurrencies work, and they don’t care. The difference between this kind of investor and the successful individual or professional investor is that the gambler does not care about the management of risk, or about the timing of trades. They place their money on the table, and they hope it will make a good return. They are gambling rather than creating an investment thesis and executing a well-thought out strategy. They might even have an infectious positive attitude, but unfortunately it is not backed by knowledge or the due diligence required to be a successful investor. A good example of this style of thinking, outside of cryptocurrency, is high yield investment plans (HYIPs) that promise to multiply an investors capital by a certain factor. This is not to say that all HYIP programs are scams, but a good number of them are. Most importantly, the investors who flock into such plans have similar characteristics to that of the Get Rich Quick investor in that they will not take the time to learn about the field in which they are investing. They are just looking for fast money and an overnight success. “ “Types of Investors §3 Short Term Traders (Day/Swing Traders) Short term traders must, without a doubt, be the most knowledgeable investors if they are going to succeed at their chosen profession. They have, or they should have, studied the art and science of trading more thoroughly than other people. This is the kind of investor who has taken the time to learn about cryptocurrencies and the markets on which they trade. Short term traders create deliberate and timed strategies in an attempt to profit from fast market movements. Maybe many of the short term traders started off as Newbies, but these are the individuals who took the time and effort to learn about the market. They wanted to know what they were doing. These are the people who survived and thrived to grow into the type of trader that they want to be. Interestingly, the Day Trader does not attach emotion to any given coin. They do not need to believe in the sustainability/whitepapevision/road map, etc. of the project they are buying into at any particular time. They just need to be confident about the direction and timing of the potential price movement of the coin. “ “Types of Investors §4 Long Term Investors/ Hodlers A great majority of successful cryptocurrency investors can be most properly classified as Long Term Investors, or HODLers in true crypto terminology. These are investors who understand quite a bit about cryptocurrency and blockchain technology and believe in the sustainability of the coins in which they are investing. Think of the first few investors who bought bitcoin in the early days and years, when it was still deep under the radar for most people. These are the people who believed in the blockchain and cryptocurrency revolution. They didn’t sell their bitcoin for fast profit, although they had many chances to do so. They knew what they were doing, holding for the long term. These early investors and HODLers enjoyed astronomical growth all the way up to 2016 and 2017. But to be a long-term holder despite all the bad news and negative factors surrounding this brand new asset class, they must have really believed that bitcoin and the blockchain were going to change the world. This belief can only be established through study and research about the blockchain industry and the specific currencies and tokens in which you are going to invest. Follow up and learn more on www.ubai.co!” “Types of Investors §5 Sophisticated/Professional Investors These are experts in cryptocurrency investing. They most likely have a background in other forms of trading and investing, such as in stocks, bonds or options etc. They may also be earning fees by investing or managing money for other people. The Iconomi fund managers are a good example. Each Fund Manager manages an array of digital assets. Investors might choose Iconomi because it offers a platform for the investor to allocate funds to specific fund managers, with the ability to swap between managers instantly if the investor desires to do so. Each fund manager selects a number of coins in which they wish to trade or invest, with specified time horizons, short or long term. Investors can buy into the array of mutually held coins. This allows investors to utilize the knowledge and experience of professional fund managers to trade an allocated pool of capital, hopefully generating returns greater than the individual investor would be able to produce on his own. The fund managers are motivated by the fees and commissions they earn, and perhaps a performance-linked bonus. You can certainly be properly classified as a Sophisticated Investor without any need to be a fund manager for other peoples’ money. But a professional fund manager has the ability to trade with a larger pool of capital, manage complicated risk, and diversify trading strategy to generate various streams of income. “ “Between Countries A particular country’s participation in cryptocurrencies largely has to do with the legal regulations about blockchain projects and crypto currency investment in that jurisdiction. When China banned the use of cryptocurrency, most Chinese nationals had to withdraw their investments. Many other countries have also placed bans on the use or trade of cryptocurrencies. Countries like Japan that have allowed the use of cryptocurrencies have witnessed a significant rise in cryptocurrency investments as a result. Japan and South Korea are home to several high-traffic cryptocurrency exchanges, meaning that a notable proportion of their population is investing in cryptocurrencies. Another way to look at cryptocurrency investment demographics is to look at the bitcoin ATMs present in each country. The United States of America is the leading country, followed by Canada and then the United Kingdom. According to a report by Google trends, the five top countries interested in bitcoin are: South Africa, Slovenia, Nigeria, Colombia and Bolivia. Remember, cryptocurrency demographics can be a little tricky due to the anonymity involved. Many people may be afraid to participate in surveys, especially when their governments have placed legal restrictions on cryptocurrency investing. The main point the research seems to validate is that the demographics of the cryptocurrency investor base is diverse. While the average investor may be a white or Asian male between the ages of 26-30 with at least a university degree, the entire investor base is so much larger than that. Many big investors are likely to be significantly older, and have connections and businesses in the traditional economy as well. “ “Notable Investors in Cryptocurrency While many people have made fortunes from cryptocurrency investing, a handful of them stand out as being particularly remarkable. We will take a more detailed look at some of the biggest investment success stories to see how they did it and learn about their investing strategy. The Winklevoss Twins After being awarded their settlement from the lawsuit against Facebook, the Winklevoss twins decided to invest a significant portion of their money in Bitcoin. They invested $11million of the $65million they received. At that time, the price of a single bitcoin was about $120. This high-risk investment paid off handsomely and they became the first publicly known Bitcoin Billionaires, perhaps owning more than 1% of the total bitcoin in circulation. In an interview with Financial Times in 2016, the twins jointly said that they consider “Bitcoin as potentially the greatest social network because it is designed to transfer value over the internet”. They also pointed out that compared to gold, bitcoin has equal or greater foundational traits of scarcity and portability. “ “Notable Investors in Cryptocurrency §2 Michael Novogratz A self-made billionaire ex-Goldman Sachs investment banker, Novogratz has invested more than 30% of his fortune in cryptocurrency. In 2015, he announced a $500million cryptocurrency hedge fund, including $150million of his own money. Novogratz believes that “the blockchain, the computer code that underpins all cryptocurrencies, will reshape finance, just as the internet reshaped communication”. The investment thesis of Mr. Novogratz is similar to that of the Winklevoss twins. He has taken and maintains a long-term position while he trades in and out of short term moves, based on his fundamental belief in the potential and likely application of the underlying blockchain technology. By starting an investment fund in addition to his other cryptocurrency related ventures, he is demonstrating a strong fundamental grasp of the technology, including its applicability and impact across so many industries. Slide Barry Silbert In December 2014 after the US Marshal’s office seized 50,000 bitcoins from the Silk Road, Barry Silbert purchased just 2,000 of those bitcoins at $350 per coin. A few years later of course, those coins were worth millions of dollars. Barry is the founder and CEO of the Digital Currency Group (DCG) a cryptocurrency investment firm. Barry also made significant profits from Ethereum Classic, purchasing the coin in its very first days. He has invested in over 75 bitcoin related companies, including CoinDesk. As founder of the Digital Currency Group, Barry endeavors to support bitcoin and blockchain companies and accelerate the development of the global financial system. “ “Directly through Exchanges Step One: Register on a reputable cryptocurrency exchange To start investing, you first need to register on a reputable cryptocurrency exchange where you can buy bitcoin and other cryptocurrencies. Binance is a good exchange to use in this lesson. While it may or may not be the best, it is currently the largest, and they provide a very supportive layout and customer service department. You should remember, to buy most altcoins (cryptocurrencies other than bitcoin), you specifically need to use an exchange like Coinbase or Kraken that allows you to convert fiat currency into cryptocurrency. From there, if you want to trade altcoins not listed on that exchange, you will have to transfer your BTC or ETH to a larger exchange like Binance, and buy the altcoin you want, using whichever trading pair that is best suited (BTC and ETH pairs are most common). As we have already explained, if you are buying Bitcoin or any cryptocurrencies, you should invest in a wallet to safely store your coins. It is not advisable to store your BTC or other crypto on the exchanges for too long, due to hacking and other risks. “ “Directly through Exchanges Step Two: Determine your Strategy There are different ways to invest. You need to find a strategy that works for you and your specific set of skills. The value of a cryptocurrency is not defined by a formula or something out a textbook. If everyone was able to calculate the actual value of a share of stock, for example, or a bond, or other tradeable asset, then the price on an open market exchange would never move. Buyers and sellers would know exactly how much the asset is worth, so there would be no reason to sell lower or buy higher than the actual value. You need to come up with your own ideas and strategies to take advantage of market moves. Sometimes you will have a position that is contrary to the general market. Other times you might be trading in agreement with a majority of other market participants. Investors are basically separable into one of two groups of thinkers. Contrarian investors go against the crowd, swimming against the current; Momentum investors ride the wave feeling secure in the majority. Being different can be good or it can be bad. You do not always want to necessarily get caught up in the most crowded trade. “ “Things to keep in Mind Bitcoin Futures We need to mention the bitcoin futures market as another potential way to invest. Toward the close of 2017, Bitcoin started trading on two fully recognized and well-established futures markets; the Chicago Board Options Exchange (CBOE), and the Chicago Mercantile Exchange CME. The key quote from the exchanges was “because the futures can be traded on regulated markets, it will attract investors, making the market liquid, stabilizing prices and it will not suffer from low transaction speeds of Bitcoin Exchanges.” For a risk averse investor, this offers a safer entry into cryptocurrency investing. A futures contract commits its owner to buy or sell the underlying asset, BTC, at a set price, and at a set date in the future. The investor in the futures contract does not actually own the underlying asset, but rather is trading on fluctuations in the price of the asset over a certain timeframe, as specified in the futures contract. “ “Things to keep in Mind §2 Common Pitfalls We cannot conclude this lesson without one more look at the common pitfalls a new cryptocurrency investor should avoid. The problem areas are: -Falling for scams by failing to carry out due diligence. -Relying solely upon self-acclaimed crypto gurus and experts. If you want to trade, you must understand how to read news and charts for yourself. -Too much Greed. Not taking profit when you should. It is better to take a 20% gain, than wait for a 100% gain, only to lose it all in the end. -Lacking an investment strategy or exit plan. -Not sticking to your investment plan or strategy. -Allowing emotions to rule your decisions. Chasing your losses. -Investing what you cannot afford to lose. And finally, some time-tested wisdom from Wall Street: Bulls make money. Bears make money. Pigs get slaughtered every time. (Don’t be greedy!) We cannot overemphasize the risk involved in cryptocurrency investing. The potential to make huge gains over a short period of time does not come without risk. There is no doubt that significant players in the global financial markets are entering the cryptocurrency markets too. We are likely to witness more and more government authorities trying to regulate cryptocurrencies, hopefully to the overall benefit of a healthy market. It seems safe to say we will see cryptocurrencies become more mainstream due to the intense interest from the traditional financial industry and institutional investing community all over the world. What are better ways to successfully invest in cryptocurrencies? Which pitfalls should you avoid? Learn all on successful ICOs and STOs after reading the full lesson: UBAI.co How to start your STO/ICO campaign in 2019? 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Keeping your wallet as secure as possible can't be stressed enough, because once your bitcoins, bitcoin cash, litecoins, or ether are gone, your chances of getting them back are almost zero. To back this up, Binance doesn't currently offer any form of insurance policy to help cover any losses due to hacks and security breaches. The hack impacted Binance’s so-called “hot wallet,” which is basically storage that connects to the internet and is used for liquidity so bitcoin can be exchanged. According to Binance, just 2 percent of its total bitcoin holdings were in its hot wallet. The rest was presumably in “cold storage,” meaning bitcoin kept offline. Had Binance kept more of its bitcoin in its hot wallet ... Binance Hack. Date: May 2019. Crypto amount stolen: 7,000 Bitcoin. Fiat equivalent at the time: ~ $40 Million USD . No exchange seems immune to being hacked. Binance reported that sophisticated fishing methods were used by hackers who managed to swipe 7,000 Bitcoin from the exchange’s Bitcoin hot-wallet. Although the funds were taken from user accounts, their balances were unaffected as ... The hack impacted Binance’s so-called “hot wallet,” which is basically storage that connects to the internet and is used for liquidity so bitcoin can be exchanged. According to Binance, just ... Hackers just stole $40 million worth of bitcoin from Binance, one of the largest cryptocurrency exchanges in the world. It’s hardly the first time crypto has been targeted by thieves. For a technology that’s supposed to be hyper secure, in practic... Not sure what is the best Bitcoin wallet? What's the safest Bitcoin wallet and how to choose it? Follow our tutorial on best Bitcoin wallet and find out. Bitcoin; News; Der Super-GAU: Binance gehackt, über 40 Millionen Dollar in BTC geklaut – Abhebungen für mindestens eine Woche ausgesetzt . Von. Andre Eberle - 8. Mai 2019. 0. WhatsApp. Twitter. Facebook. Linkedin. Email. Pinterest. Tumblr. Google+. In diesen Stunden kennt die Krypto-Branche nahezu nur ein Thema: Binance, die größte und bekannteste Krypto-Börse, wurde gehackt! Durch ein ... The hack impacted Binance’s so-called “hot wallet,” which is basically storage that connects to the internet and is used for liquidity so bitcoin can be exchanged. According to Binance, just 2 percent of its total bitcoin holdings were in its hot wallet. The rest was presumably in “cold storage,” meaning bitcoin kept offline. Had Binance kept more of its bitcoin in its hot wallet ... Binance, one of the world’s biggest cryptocurrency exchanges, has been hit by a $41m hack — just the latest in a string of thefts in the crypto world.. Malta-based Binance announced in a blog post on Wednesday that “hackers used a variety of techniques, including phishing, viruses and other attacks” to withdraw 7,000 bitcoin.. Binance has suspended withdrawals for the time being but ... To hack your Bitcoin wallet, hackers need to get access to your Private Key. You need to make sure that the best Bitcoin wallet of your choice is secure. In June 2011, hackers got access to the Private Keys of Mt. Gox's (a cryptocurrency exchange) and stole 2609 Bitcoins. The second attack on Mt. Gox happened in 2014. This time, hackers stole around $350 million worth of Bitcoins. Yes, you ...
Bitcoin Wallet Spike, KuCoin Delistings, New Binance Exchange, LTC XRP ETP & SEC No Action
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