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.
- Over $200m has been stolen impersonating users of cryptocurrency platforms by one group alone. Here's a list of 10 social engineering attacks against corporate companies. Here's an even larger case. While verification methods are improving, so are methods of identity theft and social engineering. We now have sim swapping and deep fake videos to contend with. Hackers have massive database sets of personal information they can utilize. As the sums at stake increase, so to will the level of effort criminals are willing to undertake. Obscurity for an insecure system will only postpone an attack until the "jackpot" is large enough.
- 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.
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https://preview.redd.it/yinduzdexnu31.png?width=565&format=png&auto=webp&s=989c8ae3b2018b6ca2e95124149a0402b46cfd56 Major Korean Banks Back Bitcoin Startup Coinplug’s $6.4 Million Round
Coinplug, one of the earliest Bitcoin exchange, wallet and payment startups in South Korea, has raised 7.5 billion won, or $6.4 million, from venture arms of major local financial institutions. The funding came from KB Investment, a VC unit of the KB Financial Group, one of the largest banking institutions in Korea; Mirae Asset Venture Investment, a listed subsidiary of investment bank and securities broker Mirae Asset Daewoo; as well as private equity and VC firm Smilegate Investment. With the new equity financing, Coinplug said it would be focusing on decentralized identification technologies, an area that has drawn significant interest from the Korean government and major banks in the country. Johannesburg’s Government Website Got Attacked By Hackers Who Ransomed Bitcoins
The City of Joburg on October 24 announced a breach of its network and shut down its website and all e-services as a precautionary measure. The City said it had detected a network breach “which resulted in an unauthorized access to our information systems.” Business Day reported that the attack came hours after the City received a Bitcoin ransom note from a group called the Shadow Kill Hackers. Charlie Lee: Litecoin’s Fate Is Not Dependent On The Fate Of Litecoin Foundation
The Litecoin Foundation now has at most two years of runway left and its co-founders are scraping together a business model to generate more revenue. Charlie Lee, Litecoin founder, said Litecoin’s fate is not dependent on the fate of the Litecoin Foundation. The foundation right now only has one full time, paid employee; everyone else works as a volunteer. NYDFS Requested That Bittrex Postpone The New York Account Closure Deadline Until Further Notice
The New York State Department of Financial Services (NYDFS) has requested that Bittrex postpone the New York account closure deadline until further notice. New York residents will be able to continue to withdraw funds, but may not deposit or trade.
Encrypted project calendar（October 25, 2019）
ADA/Cardano: Cardano (ADA) The Ada community will host a community gathering in the Dominican Republic for the first time on October 25. Crypto.com Coin (CRO): 25 October 2019 Live AMA with CEO “Live AMA with our CEO @Kris_HK on @cryptocom’s Twitter next Friday, 25 October, 11AM HKT.” GST/GSTCOIN: GSTCOIN(GST)LBank will be online GST on October 25, 2019 at 16:00 (UTC+8), open trading pair: GST/USDT, GST/ETH. Vexanium (VEX)：25 October 2019 BP Showcase On Friday, 25 October 2019, Vexanium will blast a BP showcase to all of Vexanium channel and social media. 3DCoin (3DC)：25 October 2019 3DCoin Weekly AMA 3DCoin / ProjectDistricts AMA on Telegram from 9 PM — 11 PM (UTC +4). Zilliqa (ZIL)：25 October 2019 Dev Call “The Moonlet Wallet team will be joining our 5th Dev Call this Friday at 11am EST on Discord. We’ll discuss their vision of becoming Ontology (ONT): 25 October 2019 Twitter AMA “On 25 October, our Senior Architecture Experts will be live on Twitter for the first time to answer all your questions.” FunFair (FUN): 25 October 2019 Bounties Paid “… Your bounty will be paid out in full, straight to your wallet on Friday, 25th October.” Waltonchain (WTC): 25 October 2019 Server Maintenance “#KIRINMINER Mall… server will be down for maintenance from Oct. 25 till estimated Oct. 28 or earlier…” Matrix AI Network (MAN): 25 October 2019 Update “The new update will happen at block 1,420,800, which is estimated to be 4PM on October 25th (GMT+8).”
Encrypted project calendar（October 26, 2019）
KAT/Kambria: Kambria (KAT) Kambria will host the 2019 Southern California Artificial Intelligence and Data Science Conference in Los Angeles on October 26th with IDEAS. BTC/Bitcoin: CoinAgenda Global Summit will be held in Las Vegas from October 26th to 28th Horizen (ZEN): 26 October 2019 (or earlier) ZEN 2.0.19 Upgrade Zen 2.0.19 upgrade at block #610000, which is expected around October 26. IOTA (MIOTA): 26 October 2019 Taipei Workshop “Sam Chen, our Software Engineer, will explain how to use IOTA C Client library & will demonstrate 3 IoT projects running on ESP32 at…” Streamr DATAcoin (DATA): 26 October 2019 Data Union Demonstration “This Saturday, Streamr will hold the first demonstration of data unions, with a community built plugin for users to crowdsell…”
Encrypted project calendar（October 27, 2019）
ICON (ICX): 27 October 2019 Money 20/20 USA Event Money 20/20 USA in Las Vegas from October 27–30. Aeternity (AE): and 5 others 27 October 2019 CoinAgenda Conference CoinAgenda conference in Las Vegas from October 26–28.
Encrypted project calendar（October 28, 2019）
LTC/Litecoin: Litecoin (LTC) 2019 Litecoin Summit will be held from October 28th to October 29th in Las Vegas, USA BTC/Bitcoin: Mt.Gox changes the debt compensation plan submission deadline to October 28 ZEC/Zcash: Zcash (ZEC) will activate the Blossom Agreement on October 28th Stellar (XLM): 28 October 2019 Protocol 12 Upgrade Vote Horizon v0.22.0 has been released, which supports Protocol 12. This gives everyone ample time to prepare for the Protocol 12 upgrade vote Celsius (CEL) and 3 others: 28 October 2019 Litecoin Summit “…The Litecoin Summit offers two fun, jam-packed days with something for everyone.” XFOC (XFOC): The IDAX platform will be online XFOC and will open the XFOC/USDT trading pair at 13:00 on October 28. MEDIUM (MDM): The IDAX platform lists MDM and will open MDM/BTC trading pairs on October 28th at 15:00. ZB/ ZB Blockchain: The “2019 Hamburg Intercontinental Dialogue Conference” hosted by ZB.com will be held from October 28th to November 9th at the Four Seasons Hotel Hamburg, Germany. BQT (BQTX)： 28 October 2019 Down for Maintenance BQTX.com will be down for maintenance on the 28th of October from 7 to 12am UTC.
Encrypted project calendar（October 29, 2019）
BTC/Bitcoin: The 2nd World Encryption Conference (WCC) will be held in Las Vegas from October 29th to 31st. ICON (ICX): 29 October 2019 Decentralization “As a result, the decentralization schedule of the ICON Network has been changed from September 24, 2019 to October 29, 2019.” Ark (ARK): and 10 others 29 October 2019 WCC 2019 Second annual Blockchain and Cryptocurrency Technology event, World Crypto Conference (WCC), October 29th — October 31, 2019. Insifa (ISF): 29 October 2019 Prototype Alpha “We from Insifa have decided to be more open. Our Prototype will be developed in scrum. This means new releases every two weeks.” Enjin Coin (ENJ): 29 October 2019 EnjinCraft Stress Test “Join us Oct. 29 at 7:00pm GMT for a stress test. Let’s try to break #EnjinCraft!” IOTA (MIOTA): 29 October 2019 IOTSWC Barcelona IOT Solutions World Congress Digitalizing Industries conference in Barcelona from October 29–31.
Encrypted project calendar（October 30, 2019）
MIOTA/IOTA: IOTA (MIOTA) IOTA will host a community event on October 30th at the University of Southern California in Los Angeles on the topic “How to store data on IOTA Tangle.” TRON (TRX): 30 October 2019 SFBW19 Afterparty “TRON Official SFBW19 Afterparty from 7–10:30 PM in San Francisco.” Horizen (ZEN): 30 October 2019 Horizen Quarterly Update Join our first Quarterly Update on October the 30th at 5 PM UTC/ 1 PM EST. Deeper look into Engineering, BD, Marketing, and more. Aeternity (AE): 30 October 2019 Hardfork “The third hardfork of the æternity Mainnet is scheduled for October 30, 2019.” Valor Token (VALOR): 30 October 2019 Transaction Fees Resume “It’s September and the SMART VALOR Platform is still waiving transaction fees for all members, until October 30th!” Aragon (ANT): 30 October 2019 Singapore Meetup “Aragon on DAOs and DeFi” from 6:30–8:30 PM. Kambria (KAT): 30 October 2019 Outliers Hashed Awards Outliers Hashed awards from October 30–31. Ethereum Classic (ETC): 30 October 2019 Cohort Demo Day “ETC Labs hosts it’s 2nd Cohort Demo Day. Learn about the companies and project being accelerated through the Ethereum Classic ecosystem.”
Encrypted project calendar（October 31, 2019）
Spendcoin (SPND): 31 October 2019 (or earlier) Cross Ledger Mainnet “Cross Ledger Mainnet Release and SPND Token Swap,” during October 2019. Spendcoin (SPND): 31 October 2019 (or earlier) Blkchn University Beta “Blockchain University Beta goes live,” during October 2019. Stellar (XLM): 31 October 2019 (or earlier) Minor Release “We will have 6 Minor Releases in 2019; one each in February, March, May, June, August, and October.” Bitcoin SV (BSV): 31 October 2019 (or earlier) BSV Conference Seoul No additional information. Seele (SEELE): 31 October 2019 (or earlier) Public Network Mainne launch has been moved to Oct 31 . Howdoo (UDOO): 31 October 2019 (or earlier) Howdoo Live on Huawei Howdoo begins its exciting partnership with Huawei with listing as a featured app starting in October. Chiliz (CHZ): 31 October 2019 (or earlier) App Soft Launch Soft launch of Socios App by end of October. Dent (DENT): 31 October 2019 (or earlier) Loyalty Program “Afterburner loyalty program launch for all 21,6 Million mobile #DENT users will be in October!” IceChain (ICHX): 31 October 2019 (or earlier) Wallet Release IceChain releases wallet during October. Chiliz (CHZ): 31 October 2019 (or earlier) New Partnerships New sports and new teams joining Socios (+more updates and events) will be announced in the upcoming weeks. Horizen (ZEN): 31 October 2019 Weekly Insider Team updates at 3:30 PM UTC/ 11:30 AM EDT: Engineering, Node network, Product/UX, Helpdesk, Legal, BD, Marketing, CEO Closing thoughts, AMA. PCHAIN (PI): 31 October 2019 (or earlier) New Website No additional information. IOST (IOST): 31 October 2019 (or earlier) New Game on IOST “Eternal Fafnir, a new role-playing game developed by INFUN is coming to you in Oct.” Achain (ACT)： 31 October 2019 Mainnet 2.0 Launch “… The main network is officially scheduled to launch on October 31.” Mithril (MITH)：31 October 2019 Burn “MITH burn will take place on 2019/10/31 2pm UTC+8. “ Aergo (AERGO)： 31 October 2019 (or earlier) Aergo Lite V1.0 Release AergoLite, which brings blockchain compatibility to billions of devices using SQLite, released during October 2019. TE-FOOD (TFD)： 31 October 2019 (or earlier) Complementary Product “Development of a new, complementary product with a new partner, which we hope to be launched in September-October.” Edge (DADI)： 31 October 2019 (or earlier) Full Open Source Code base for the network fully open-sourced in September or October. BlockStamp (BST)： 31 October 2019 (or earlier) ASIC Miner Prototype In orderr to ensure BlockStamps continued decentralization, we will release a BST ASIC miner for testing. Perlin (PERL)： 31 October 2019 (or earlier) SSA Partnership “Perlin has partnered with the Singapore Shipping Association to create the International E-Registry of Ships (IERS)” Skrumble Network (SKM)： 31 October 2019 (or earlier) Exchange Release “3rd dApp: Exchange Release,” during October 2019. EDC Blockchain (EDC)： 31 October 2019 (or earlier) Blockchain Marketplace “As you already know, our ECRO blockchain marketplace is ready for release, and will open to the global community in October!” BlockStamp (BST)： 31 October 2019 (or earlier) ASIC Miner Prototype In orderr to ensure BlockStamps continued decentralization, we will release a BST ASIC miner for testing. XinFin Network (XDCE)： 31 October 2019 Homebloc Webinar “XinFin — Homebloc Webinar 2019” from 9–10 PM. Akropolis (AKRO)： 31 October 2019 (or earlier) Alpha Release “Delivers the initial mainnet implementation of protocol. All building blocks will be united to one product.” Hyperion (HYN)： 31 October 2019 (or earlier) Economic Model The final version of the HYN Economic Model launches in October.
Encrypted project calendar（November 1, 2019）
INS/Insolar: The Insolar (INS) Insolar wallet and the redesigned Insolar Block Explorer will be operational on November 1, 2019. VeChain (VET)：”01 November 2019 BUIDLer Reunion Party BUIDLer Reunion Party in San Francisco from 8–11 PM. uPlexa (UPX)： 01 November 2019 Steadfast Storm — PoS/PoW split (Utility nodes ie. master nodes) — Upcoming Anonymity Network much like TOR — Privacy-based DApps — Reduced network fees. Enjin Coin (ENJ)： 01 November 2019 MFT Binding “ICYMI: On Enjin Coin’s 2nd anniversary (November 1), Enjin MFTs will be bound to hodlers’ blockchain addresses…” Auxilium (AUX)：01 November 2019 AUX Interest Distribution Monthly interest distribution by Auxilium Interest Distribution Platform for coinholders. Also supports charity. Havy (HAVY)：01 November 2019 Token Buyback “Havy tokens buyback, Only in 1 exchange between Idex, Mercatox & Hotbit. The exchange depends on the most lower sell wall.” Egretia (EGT): 01 November 2019 Global DApp Contest SF 2019 Egretia Global DApp Contest in San Francisco.
Encrypted project calendar（November 2, 2019）
Kambria (KAT)： 02 November 2019 VietAI Summit 2019 Kambria joins forces with VietAI for the annual VietAI Summit, with top experts from Google Brain, NVIDIA, Kambria, VietAI, and more!
Encrypted project calendar（November 4, 2019）
Stellar (XLM)： 04 November 2019 Stellar Meridian Conf. Stellar Meridian conference from Nov 4–5 in Mexico City. Cappasity (CAPP)： 04 November 2019 Lisbon Web Summit Lisbon Web Summit in Lisbon, Portugal from November 4–7.
Encrypted project calendar（November 5, 2019）
Nexus (NXS)： 05 November 2019 Tritium Official Release “Remember, Remember the 5th of November, the day Tritium changed Distributed Ledger. Yes, this is an official release date.” NEM (XEM)： 05 November 2019 Innovation Forum — Kyiv NEM Foundation Council Member Anton Bosenko will be speaking in the upcoming International Innovation Forum in Kyiv on November 5, 2019. TomoChain (TOMO): 05 November 2019 TomoX Testnet “Mark your calendar as TomoX testnet will be live on Tuesday, Nov 5th!” aelf (ELF): 05 November 2019 Bug Bounty Program Ends On Oct 24th, 2019 aelf’s biggest bug bounty will launch with a large reward pool. The event will run for almost 2 weeks.
Encrypted project calendar（November 6, 2019）
STEEM/Steem: The Steem (STEEM) SteemFest 4 conference will be held in Bangkok from November 6th to 10th. KIM/Kimcoin: Kimcoin (KIM) Bitfinex will be online at KIM on November 6, 2019 at 12:00 (UTC).
Encrypted project calendar（November 7, 2019）
XRP (XRP)： 07 November 2019 Swell 2019 Ripple hosts Swell from November 7th — 8th in Singapore. BTC/Bitcoin: Malta The A.I. and Blockchain summit will be held in Malta from November 7th to 8th.
Encrypted project calendar（November 8, 2019）
BTC/Bitcoin: The 2nd Global Digital Mining Summit will be held in Frankfurt, Germany from October 8th to 10th. IOTX/IoTeX: IoTex (IOTX) will participate in the CES Expo on November 08
Encrypted project calendar（November 9, 2019）
CENNZ/Centrality: Centrality (CENNZ) will meet in InsurTechNZ Connect — Insurance and Blockchain on October 9th in Auckland. HTMLCOIN (HTML): 09 November 2019 (or earlier) Mandatory Wallet Update Mandatory Wallet Update: there will be a soft fork on our blockchain. This update adds header signature verification on block 997,655.
Encrypted project calendar（November 11, 2019）
PAX/Paxos Standard: Paxos Standard (PAX) 2019 Singapore Financial Technology Festival will be held from November 11th to 15th, and Paxos Standard will attend the conference. Crypto.com Coin (CRO): and 3 others 11 November 2019 Capital Warm-up Party Capital Warm-up Party in Singapore. GoldCoin (GLC): 11 November 2019 Reverse Bitcoin Hardfork The GoldCoin (GLC) Team will be “Reverse Hard Forking” the Bitcoin (BTC) Blockchain…”
Encrypted project calendar（November 12, 2019）
BTC/Bitcoin: The CoinMarketCap Global Conference will be held at the Victoria Theatre in Singapore from November 12th to 13th Binance Coin (BNB) and 7 others: 12 November 2019 CMC Global Conference “The first-ever CoinMarketCap large-scale event: A one-of-a-kind blockchain / crypto experience like you’ve never experienced before.”
Encrypted project calendar（November 13, 2019）
Fetch.ai (FET): 13 November 2019 Cambridge Meetup “Join us for a @Fetch_ai #Cambridge #meetup on 13 November @pantonarms1.” Binance Coin (BNB) and 5 others: 13 November 2019 Blockchain Expo N.A. “It will bring together key industries from across the globe for two days of top-level content and discussion across 5 co-located events…” OKB (OKB): 13 November 2019 Dnipro, Ukraine- Talks Join us in Dnipro as we journey through Ukraine for our OKEx Cryptour on 11 Nov. Centrality (CENNZ): 13 November 2019 AMA Meetup “Ask our CEO @aaronmcdnz anything in person! Join the AMA meetup on 13 November in Singapore.” OKB (OKB): 13 November 2019 OKEx Cryptotour Dnipro “OKEx Cryptour Ukraine 2019 — Dnipro” in Dnipro from 6–9 PM (EET).
Encrypted project calendar（November 14, 2019）
BTC/Bitcoin: The 2019 BlockShow Asia Summit will be held at Marina Bay Sands, Singapore from November 14th to 15th. https://preview.redd.it/y3aa8i9hxnu31.png?width=504&format=png&auto=webp&s=d3b040a7589dabb253d5ea231df6cc6fbaf7a2a6
Yesterday, there was a sharp decline in bitcoin below the $7,800 support area against the US Dollar. As a result, there was a significant drop in BTC price below the main $7,500 support area.
Moreover, there was a close below $7,800 and the 100 hourly simple moving average. Finally, the price traded close to $7,300 and formed a new monthly low at $7,302. It is currently consolidating losses and is trading above the $7,400 level.
On the upside, there are many key resistances for buyers near the $7,500 and $7,600 levels. Additionally, the 23.6% Fib retracement level of the downward move from the $8,327 high to $7,302 low is also near the $7,540 level.
More importantly, there is a major bearish trend line forming with resistance near $7,500 on the hourly chart of the BTC/USD pair. If there is a break above the trend line, the price could face resistance near the $7,600 level. Review previous articles: https://firstname.lastname@example.org
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