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A NFT (non-fungible token) blockchain project called VIMWorld (www.VIMWorld.com) will allow for all types of gaming including older Board games and newer AAA games to store game IP in a NFT. The NFT's are called VIMS which are linked into the ecosystem VIMWorld, and the token used is called EHrT (Eight Hours Token) currently available on Bitrue (rumor - new exchange listing is imminent, maybe Binance). Game developers and Partners can quickly utilize the NFT VIM and integrate their IP which is then stored on the blockchain and can be used across games including their already selling product called the PlayTable (www.playtable.com). The team just paid out $250 ad-hoc rewards to their S-Tier node holders, not part of the VIMPool rewards which will be released soon paying out 5% every 2 weeks of all $EHrTs spent in the gaming ecosystem. A VIM can be described as Virtually Integrated Metadata which is the core of the 8Hours (www.8hoursfoundation.org) platform meta system that is built on VeChainThor blockchain and stores metdata such as data and transaction history and functions as a memory capsule, a collectible, a digital wallet (storing $EHrTs, the token) and a tool for game play and human connection. VIMS can also be linked to a physical object in the real world. Partners Advisors to the project include:
Glen Schofield - Prolific name in AAA game industry, 3x Call of Duty, grossing $1B+
Sean Barger - Gaming industry veteran who has published over 55 titles, most notably "Tetris"
Kris Alexander - Chief Strategist at Akami, Built business from $0 to $100M+
Jateen Parekh - First employee worked on the Kindle project. Co-founded Jelli and was acquired by the largest media company, iHeartMedia.
Shen Bo - Founding partner of Fenbushi. He is with Bitcoin and DACs. He first worked with Shanghai Huaji Internet Holding as CEO
Kai Huang - Co-creator of the multi-billion dollar Guitar Hero franchise, and co-founder of RedOctane.
Ray Hatoyama - Ex-Pokemon advisor, Ex-Hello Kitty CEO and director of LINE and Mitsubishi
Michael Katz - with 25 years experience in the video game entertainment sector. Industry experience includes Mattel, Coleco, (Donkey Kong and Pacman), Atari’s video game division, President ofSEGAEntertainmentUSA.
Competitors: enjin coin is more of a market place to buy gaming items whereas 8Hours aims to store your gaming life/history on an NFT which is unique and can contain special colored tokens/companions which add to the value of it and utilized across games on any device where a partner has integrated their IP. From an AMA with CEO John Dempsey of 8Hours Foudation, this stood out for me: "we're under NDA for several major companies with big household name brands. These are companies that everyone is familiar with and we can flood their communities with our EHrTs and VIMs. We can't name any right now, but these titles are under development. We've already worked with huge board game brands like Asmodee for Catan and Ticket to Ride. Our partnership deals are being made to create revenue, which we are feeding back into the ecosystem to create more and more value. Larger IPs are being signed which aren't board games, but a greater firt for EHrTs and the VIM economy in general. We do work with smaller indie firms, too, for the creation of unique content (over a dozen developers have submitted / created games for PlayTable) Circulating Supply - 1,854,037,961 Max Supply - 10,000,000,000 Market Cap - $27,549,886
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.
Aryacoin is a new cryptocurrency, which allows for decentralized, peer to peer transactions of electronic cash. It is like Bitcoin and Litecoin, but the trading of the coin occurs on sales platforms that have no restriction to use. Further, it was created with the goal of addressing the double spend issues of Bitcoin and does so using a timestamp server to verify transactions. It works by taking the hash of a block of items to be timestamped and widely publishing the hash. The timestamp proves that the data must have existed at the time in order to get the hash. Each timestamp then includes the previous timestamp in its hash, forming a chain. The Aryacoin team is continuously developing new use cases for the coin, including exchanges where users can exchange the coins without any fees or restrictions, and offline options where the coins can be bought and sold for cash. The coins can also be used on the company’s other platform, mrdigicoin.io. Along with the coin, there is a digital wallet that can be created and controlled by the user entirely, with no control being retained by the Aryacoin team.
The concept of Blockchain first came to fame in October 2008, as part of a proposal for Bitcoin, with the aim to create P2P money without banks. Bitcoin introduced a novel solution to the age-old human problem of trust. The underlying blockchain technology allows us to trust the outputs of the system without trusting any actor within it. People and institutions who do not know or trust each other, reside in different countries, are subject to different jurisdictions, and who have no legally binding agreements with each other, can now interact over the Internet without the need for trusted third parties like banks, Internet platforms, or other types of clearing institutions. When bitcoin was launched it was revolutionary allowing people to transfer money to anytime and anywhere with very low transaction fees . It was decentralized and their is no third party involved in the transaction , only the sender and receiver were involved. This paper provide a solution to the double-spending problem using a peer-to-peer distributed timestamp server to generate computational proof of the chronological order of transactions.The system is secure as long as honest nodes collectively control more CPU power than any cooperating group of attacker nodes. Bitcoin was made so that it would not be controlled or regulated but now exchanges and governments are regulating bitcoin and other cryptocurrencies at every step. Aryacoin was developed to overcome these restrictions on a free currency. Aryacoin is a new age cryptocurrency, which withholds the original principle on which the concept of cryptocurrency was established. Combining the best in blockchain technology since the time of its creation, Aryacoin strives to deliver the highest trading and mining standards for its community.
1.1 OVERVIEW ABOUT ARYACOIN
Aryacoin is a new age cryptocurrency, which withholds the original principle on which the concept of cryptocurrency was established. Combining the best in blockchain technology since the time of its creation, Aryacoin strives to deliver the highest trading and mining standards for its community. Aryacoin is a blockchain based project that allows users to access their wallet on the web and mobile browsers, using their login details. Aryacoin can be mined; it also can be exchanged by other digital currencies in several world-famous exchanges such as Hitbtc, CoinEx, P2pb2b, WhiteBit, Changelly and is also listed in reputable wallets such as Coinomi and Guarda. Aryacoin is a coin, which can be used by anyone looking to use cryptocurrency which allows them to keep their privacy even when buying/selling the coin along with while using the coin during transactions. Proof of work and cryptographic hashes allows transactions to verified. Stable Fee Per AYA is a unique feature of Aryacoin, so by increasing the amount or volume of the transaction, there is no change in the fee within the network, which means that the fee for sending an amount less than 1 AYA is equal to several hundred million AYA. Another unique feature of Aryacoin is the undetectability of transactions in Explorer, such as the DASH and Monero, of course, this operation is unique to Aryacoin. Using Aryacoin digital currency, like other currencies, international transactions can be done very quickly and there are no limitations in this area as the creators claim. Aryacoin aims to allow users to access the Aryacoin wallet via the web and mobile browsers using their login details. Aryacoin is a peer-to-peer electronic cash system that enables users to send and receive payments directly from one party to another, and allow them to transfer funds across borders with no restriction or third party involvement. The blockchain-based system embraces the digital signature, which prevents double spending and low transfer fees, which enables users to transfer huge amounts with very low fees. The proof-of-work consensus mechanism allows each transaction to be verified and confirmed, while anonymity enables users to use the coin anywhere at any time. According to the website of the operation, each wallet is divided into 2 or more AYA wallet addresses for each transaction, and depending on the volume of the transaction block, the origin, and destination of transactions in the network can not be traced and displayed to the public. In fact, each wallet in Aryacoin consists of a total of several wallets. The number of these wallets increases per transaction to increase both security and privacy. Aryacoin also uses the dPoW protocol. In the dPoW protocol, a second layer is added to the network to verify transactions, which makes “51% attack” impossible even with more than half of the network hash, and blocks whose Blockchain uses this second layer of security never run the risk of 51% attacks. AYA has been listed on a number of crypto exchanges, unlike other main cryptocurrencies, it cannot be directly purchased with fiats money. However, You can still easily buy this coin by first buying Bitcoin from any large exchanges and then transfer to the exchange that offers to trade this coin.
1.1.1 ARYACOIN HISTORY
Aryacoin (AYA) is a new cryptocurrency, which has been created by a group of Iranian developers, is an altcoin which allows for decentralised, peer to peer transactions of electronic cash without any fees whatsoever. Along with the coin, there is a digital wallet that can be created and managed by the user entirely, with no control being retained by the Aryacoin team. Aryacoin’s founder, Kiumars Parsa, has been a fan of alternative currencies and particularly Bitcoin. “We see people from all around the world using Blockchain technology and the great benefits that came with it and it then that I decided to solve this puzzle for find a way of bringing the last missing piece to the jigsaw. The idea for Aryacoin was born.” Parsa said. Parsa and his team of Iranian ex-pats not only persevered but expedited the project and just a year later, in the summer of 2019, the first version of Aryacoin was released. In 2020, Aryacoin is the first and only Iranian coin listed on CMC. Parsa goes on to state that it is now the strength of the community that has invested in the coin that will ultimately drive its success, alongside its robust technology and appealing 0% network fees. “We have thousands of voices behind Aryacoin. People for the people make this coin. It is a massive shout out for democracy. This had made us base the whole team strategy on the benefits for both our users and our traders.” “One key example is that the network fee on AYA Blockchain is 0%. Yes, absolutely nothing, which which differentiates us from other networks. What also differentiates us from other coins is that we have AYAPAY which is the first cryptocurrency Gateway in the world which does not save funds on third party storage with all funds being forwarded directly to any wallet address that the Gateway owner requests”. “So for the first time ever, and unlike other gateways, incoming funds will be saved on the users account with submitted withdrawal requests then made on the Gateway host website. In AYAPAY which has also been developed by the Aryacoin team, all funds without extra fees or extra costs will directly forwarded to users wallets. We have named this technology as CloudWithdrawal.” “We are continuously challenging ourselves as it is a crowded marketplace. We are striving to have a safer Blockchain against 51% attacks, faster confirmations speeds of transactions, cheaper network fee, growing the market by cooperation with Top tier Exchangers.”
1.1.2 ARYACOIN’S MAIN GOAL
Aryacoin’s main goal is to educate people and give them the freedom to use cryptocurrency in any way they want. Aryacoin empowers the users to transfer, pay, trade cryptocurrency from any country around the globe. Platforms that have been created by Aryacoin Team, as well as those that will go live in future, operate on the same principle and exclude absolutely no one.
1.1.3 PROBLEM ARYACOIN SEEKS TO SOLVE
Aryacoin aims to provide a long-term solution to the problem of double spending, which is still common in the crypto market. The developers of the system have created a peer-to-peer distributed timestamp server that generates computational proof of the transactions as they occur. Besides, the system remains secure provided honest nodes control more CPU power than any cooperating group of attacker nodes. While Bitcoin was designed not to be regulated or controlled, many exchanges and governments have put regulatory measures on the pioneer cryptocurrency at every step. Aryacoin aims to overcome these restrictions as a free digital currency.
1.1.4 BENEFITS OF USING ARYACOIN
Aryacoin solution offers the following benefits:
Real-time update: whether you’re going on a holiday or a business trip, no problem. You can access your coins all over the world.
Instant operations: Aryacoin makes it quite easy for you to use your digital wallet and perform various operations with it.
Safe and secure: all your data is stored encrypted and can only be decrypted with your private key, seed, or password.
Strong security: The system has no control over your wallet. You are 100% in charge of your wallet and funds.
1.1.5 ARYACOIN FEATURES
1. Anonymity The coin provides decent level of anonymity for all its users. The users can send their transactions to any of the public nodes to be broadcasted , the transaction sent to the nodes should be signed by the private key of the sender address . This allows the users to use the coin anywhere any time , sending transactions directly to the node allows users from any place and country . 2. Real Life Usage aryacoin’s team is continuously developing new and innovative ways to use the coins , they are currently developing exchanges where the users can exchange the coins without any fees and any restrictions . They also are currently developing other innovative technologies, which would allow users to spend our coins everywhere and anywhere. 3. Offline Exchanges They are also working with different offline vendors which would enable them to buy and sell the coins directly to our users on a fixed/variable price this would allow easy buy/sell directly using cash . This would allow the coins to be accessible to users without any restrictions which most of the online exchanges have, also increase the value and number of users along with new ways to spend the coin. This would increase anonymity level of the coin. In addition, introduce new users into the cryptomarket and technology. Creating a revolution, which educates people about crypto and introduce them to the crypto world, which introduces a completely new group of people into crypto and a move towards a Decentralized future! 4. Transactions When it comes to transactions, Aryacoin embraces a chain of digital signatures, where each owner simply transfers the coin to the next person by digitally signing a hash of the previous transaction and the public key of the next owner. The recipient can then verify the signatures to confirm the chain of ownership. Importantly, Aryacoin comes with a trusted central authority that checks every transaction for double spending. 5. Business Partner with Simplex Aryacoin is the first and only Iranian digital currency that managed to obtain a trading license in other countries. In collaboration with the foundation and financial giant Simplex, a major cryptocurrency company that has large companies such as Binance, P2P, Changelly, etc. Aryacoin has been licensed to enter the world’s major exchanges, as well as the possibility of purchasing AYA through Credit Cards, which will begin in the second half of 2020. Also, the possibility of purchasing Aryacoin through Visa and MasterCard credit cards will be activated simultaneously inside the Aryacoin site. plus, in less than a year, AYA will be placed next to big names such as CoinCapMarket, Coinomi, P2P, Coinpayments and many other world-class brands today.
1.1.6 WHY CHOOSE ARYACOIN?
If you want to use a cryptocurrency that allows you to keep your privacy online even when buying and selling the coins, the Aryacoin team claims that AYA is the way to go. Aryacoin is putting in the work: with more ways to buy and sell, and fixing the issues that were present in the original Bitcoin, plus pushing the boundaries with innovative solutions in cryptocurrencies. You can get started using Aryacoin (AYA) payments simply by having a CoinPayments account!
1.1.7 ARYANA CENTRALIZED EXCHANGE
Aryana, the first Iranian exchange is a unique platform with the following features:
The first real international Persian exchange that obtains international licenses and is listed in CoinMarketCap.
The first Iranian exchange that has been cooperating with a legal and European exchange for 3 years.
The possibility of trading in Tomans (available currency in Iran) at the user’s desired price and getting rid of the transaction prices imposed by domestic sites inside Iran.
There is an internal fee payment plan by Iranian domestic banks for depositing and withdrawing Tomans for Aryacoin holders in Aryana Exchange.
The number that you see on the monitor and in your account will be equal to the number that is transferred to your bank account without a difference of one Rial.
The last but not least, noting the fact that there is a trading in Tomans possibility in Aryana exchange.
Aryana Exchange is using the most powerful, fastest, and most expensive server in the world, Google Cloud Platform (GCP), which is currently the highest quality server for an Iranian site, so that professional traders do not lag behind the market even for a second. The feature of Smart Trading Robots is one of the most powerful features for digital currency traders. Digital cryptocurrency traders are well aware of how much they will benefit from smart trading robots. In the Aryana exchange, it is possible to connect exchange user accounts to intelligent trading bots and trade even when they are offline. The injection of $ 1 million a day in liquidity by the WhiteBite exchange to maintain and support the price of Tether and eliminate the Tether fluctuations with Bitcoin instabilities used by profiteers to become a matter of course.
1.1.8 HOW DOES ARYACOIN WORK?
Aryacoin (AYA) tries to ensure a high level of security and privacy. The team has made sure to eliminate any trading restrictions for the network users: no verification is required to carry out transactions on AYA, making the project truly anonymous, decentralized, and giving it a real use in day-to-day life. The Delayed-Proof-of-Work (dPoW) algorithm makes the Aryacoin blockchain immune to any attempts of a 51% attack. AYA defines a coin as a chain of digital signatures — each owner transfers the coin to the next owner by digitally signing the hash of the previous transaction and the public key of the next owner, and the receiver verifies the signatures and the chain of ownership.
2. ARYACOIN TECHNOLOGY
They use a proof-of-work system similar to Adam Back’s Hashcash to implement a distributed timestamp server on a peer-to-peer basis, rather than newspaper or Usenet publications. The proof-of-work involves scanning for a value that when hashed, such as with SHA-256, the hash begins with a number of zero bits. The average work required is exponential in the number of zero bits required and can be verified by executing a single hash. For their timestamp network, they implement the proof-of-work by incrementing a nonce in the block until a value is found that gives the block’s hash the required zero bits. Once the CPU effort has been expended to make it satisfy the proof-of-work, the block cannot be changed without redoing the work. As later blocks are chained after it, the work to change the block would include redoing all the blocks after it. The proof-of-work also solves the problem of determining representation in majority decision making. If the majority were based on one-IP-address-one-vote, it could be subverted by anyone able to allocate many IPs. Proof-of-work is essentially one-CPU-one-vote. The majority decision is represented by the longest chain, which has the greatest proof-of-work effort invested in it. If honest nodes control a majority of CPU power, the honest chain will grow the fastest and outpace any competing chains. To modify a past block, an attacker would have to redo the proof-of-work of the block and all blocks after it, then catch up with, and surpass the work of the honest nodes.
The steps to run the network are as follows:
New transactions are broadcast to all nodes.
Each node collects new transactions into a block.
Each node works on finding a difficult proof-of-work for its block.
When a node finds a proof-of-work, it broadcasts the block to all nodes.
Nodes accept the block only if all transactions in it are valid and not already spent.
This is a very simple system that makes the network fast and scalable, while also providing a decent level of anonymity for all users. Users can send their transactions to any of the public nodes to be broadcast, and the private key of the sender’s address should sign any transaction sent to the nodes. This way, all transaction info remains strictly confidential. It also allows users to send transactions directly to the node from any place at any time and allows the transferring of huge amounts with very low fees.
2.3 AYAPAY PAYMENT SERVICES GATEWAY:
According to creators Aryacoin, the development team has succeeded in inventing a new blockchain technology for the first time in the world, which is undoubtedly a big step and great news for all digital currency enthusiasts around the world. This new technology has been implemented on the Aryacoin AYAPAY platform and was unveiled on October 2. AYAPAY payment platform is the only payment gateway in the world that does not save money in users’ accounts and transfers incoming coins directly to any wallet address requested by the gateway owner without any additional transaction or fee. In other similar systems or even systems such as PayPal, money is stored in the user account.
2.4 CONSENSUS ALGORITHM IN ARYACOIN
The devs introduced the Delayed-Proof-of-Work (dPoW) algorithm, which represents a hybrid consensus method that allows one blockchain to take advantage of the security provided by the hashing power of another blockchain. The AYA blockchain works on dPoW and can use such consensus methods as Proof-of-Work (PoW) or Proof-of-Stake (PoS) and join to any desired PoW blockchain. The main purpose of this is to allow the blockchain to continue operating without notary nodes on the basis of its original consensus method. In this situation, additional security will no longer be provided through the attached blockchain, but this is not a particularly significant problem. dPoW can improve the security level and reduce energy consumption for any blockchain.
2.5 DOUBLE-SPEND PROBLEM AND SOLUTION
One of the main problems in the blockchain world is that a receiver is unable to verify whether or not one of the senders did not double-spend. Aryacoin provides the solution, and has established a trusted central authority, or mint, that checks every transaction for double-spending. Only the mint can issue a new coin and all the coins issued directly from the mint are trusted and cannot be double-spent. However, such a system cannot therefore be fully decentralized because it depends on the company running the mint, similar to a bank. Aryacoin implements a scheme where the receiver knows that the previous owners did not sign any earlier transactions. The mint is aware of all transactions including which of them arrived first. The developers used an interesting solution called the Timestamp Server, which works by taking a hash of a block of items to be ‘timestamped’ and publishing the hash. Each timestamp includes the previous timestamp in its hash, forming a chain. To modify a block, an attacker would have to redo the proof-of-work of all previous blocks, then catch up with, and surpass the work of the honest nodes. This is almost impossible, and makes the network processes more secure. The proof-of-work difficulty varies according to circumstances. Such an approach ensures reliability and high throughput.
3. ARYACOIN ROADMAP
April 2019: The launch of Aryacoin; AYA ICO, resulting in over 30BTC collected December 2019: The launch of AYA Pay April 2020: The successful Hamedan Hardfork, supported by all AYA exchanges, aimed at integrating the dPoW algorithm, improving the security of the AYA blockchain. June 2020: Aryana Exchange goes live, opening more trading opportunities globally July 2020: The enabling of our Coin Exchanger November 2020: The implementation of Smart Contracts into the Aryacoin Ecosystem Q1 2021: Alef B goes live (more details coming soon)
Aryacoin (AYA) is a new age cryptocurrency that combines the best of the blockchain technology and strives to deliver high trading and mining standards, enabling users to make peer-to-peer decentralized transactions of electronic cash. Aryacoin is part of an ecosystem that includes payment gateway Ayapay and the Ayabank. AYA has a partnership with the Microsoft Azure cloud platform, which provides the ability to develop applications and store data on servers located in distributed data centers. The network fee for the AYA Blockchain is 0%. In Ayapay service, which has been developed by the Aryacoin team, all funds without extra fees or costs are directly forwarded to users’ wallets with technology called CloudWithdrawal. The devs team is introducing new use cases including exchanges where users will exchange AYA without any restrictions. You can buy AYA on an exchange of your choice, create an Aryacoin wallet, and store it in Guarda.
It is no doubt Grayscale’s booming popularity as a mainstream investment has caused a lot of community hullabaloo lately. As such, I felt it was worth making a FAQ regarding the topic. I’m looking to update this as needed and of course am open to suggestions / adding any questions. The goal is simply to have a thread we can link to anyone with questions on Grayscaleand its products. Instead of explaining the same thing 3 times a day, shoot those posters over to this thread.My hope is that these questions are answered in a fairly simple and easy to understand manner. I think as the sub grows it will be a nice reference point for newcomers. Disclaimer: I do NOT work for Grayscale and as such am basing all these answers on information that can be found on their website / reports. (Grayscale’s official FAQ can be found here). I also do NOT have a finance degree, I do NOT have a Series 6 / 7 / 140-whatever, and I do NOT work with investment products for my day job. I have an accounting background and work within the finance world so I have the general ‘business’ knowledge to put it all together, but this is all info determined in my best faith effort as a layman. The point being is this --- it is possible I may explain something wrong or missed the technical terms, and if that occurs I am more than happy to update anything that can be proven incorrect Everything below will be in reference to ETHE but will apply to GBTC as well.If those two segregate in any way, I will note that accordingly.
ETHE is essentially a stock that intends to loosely track the price of ETH. It does so by having each ETHE be backed by a specific amount of ETH that is held on chain. Initially, the newly minted ETHE can only be purchased by institutions and accredited investors directly from Grayscale. Once a year has passed (6 months for GBTC) it can then be listed on the OTCQX Best Market exchange for secondary trading. Once listed on OTCQX, anyone investor can purchase at this point. Additional information on ETHE can be found here.
So ETHE is an ETF?
No. For technical reasons beyond my personal understandings it is not labeled an ETF. I know it all flows back to the “Securities Act Rule 144”, but due to my limited knowledge on SEC regulations I don’t want to misspeak past that. If anyone is more knowledgeable on the subject I am happy to input their answer here.
How long has ETHE existed?
ETHE was formed 12/14/2017. GBTC was formed 9/25/2013.
How is ETHE created?
The trust will issue shares to “Authorized Participants” in groups of 100 shares (called baskets). Authorized Participants are the only persons that may place orders to create these baskets and they do it on behalf of the investor. Source: Creation and Redemption of Shares section on page 39 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here Note – The way their reports word this makes it sound like there is an army of authorizers doing the dirty work, but in reality there is only one Authorized Participant. At this moment the “Genesis” company is the sole Authorized Participant. Genesis is owned by the “Digital Currency Group, Inc.” which is the parent company of Grayscale as well. (And to really go down the rabbit hole it looks like DCG is the parent company of CoinDesk and is “backing 150+ companies across 30 countries, including Coinbase, Ripple, and Chainalysis.”) Source: Digital Currency Group, Inc. informational section on page 77 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here Source: Barry E. Silbert informational section on page 75 of the “Grayscale Bitcoin Trust (BTC) Form 10-K (2019)” – Located Here
How does Grayscale acquire the ETH to collateralize the ETHE product?
An Investor may acquire ETHE by paying in cash or exchanging ETH already owned.
Cash: The investor pays the subscription amount in cash and the Authorized Participant will use that cash to purchase ETH.
ETH: The investor transfers the ETH to the Authorized Participant, which will contribute the ETH in-kind to the Trust.
Source: Creation and Redemption of Shares section on page 40 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Where does Grayscale store their ETH? Does it have a specific wallet address we can follow?
ETH is stored with Coinbase Custody Trust Company, LLC. I am unaware of any specific address or set of addresses that can be used to verify the ETH is actually there. As an aside - I would actually love to see if anyone knows more about this as it’s something that’s sort of peaked my interest after being asked about it… I find it doubtful we can find that however. Source: Part C. Business Information, Item 8, subsection A. on page 16 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Can ETHE be redeemed for ETH?
No, currently there is no way to give your shares of ETHE back to Grayscale to receive ETH back. The only method of getting back into ETH would be to sell your ETHE to someone else and then use those proceeds to buy ETH yourself. Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Why are they not redeeming shares?
I think the report summarizes it best:
Redemptions of Shares are currently not permitted and the Trust is unable to redeem Shares. Subject to receipt of regulatory approval from the SEC and approval by the Sponsor in its sole discretion, the Trust may in the future operate a redemption program. Because the Trust does not believe that the SEC would, at this time, entertain an application for the waiver of rules needed in order to operate an ongoing redemption program, the Trust currently has no intention of seeking regulatory approval from the SEC to operate an ongoing redemption program.
Source: Redemption Procedures on page 41 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the fee structure?
ETHE has an annual fee of 2.5%. GBTC has an annual fee of 2.0%. Fees are paid by selling the underlying ETH / BTC collateralizing the asset. Source: ETHE’s informational page on Grayscale’s website - Located Here Source: Description of Trust on page 31 & 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
What is the ratio of ETH to ETHE?
At the time of posting (6/19/2020) each ETHE share is backed by .09391605 ETH. Each share of GBTC is backed by .00096038 BTC. ETHE & GBTC’s specific information page on Grayscale’s website updates the ratio daily – Located Here For a full historical look at this ratio, it can be found on the Grayscale home page on the upper right side if you go to Tax Documents > 2019 Tax Documents > Grayscale Ethereum Trust 2019 Tax Letter.
Why is the ratio not 1:1? Why is it always decreasing?
While I cannot say for certain why the initial distribution was not a 1:1 backing, it is more than likely to keep the price down and allow more investors a chance to purchase ETHE / GBTC. As noted above, fees are paid by selling off the ETH collateralizing ETHE. So this number will always be trending downward as time goes on. Source: Description of Trust on page 32 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
I keep hearing about how this is locked supply… explain?
As noted above, there is currently no redemption program for converting your ETHE back into ETH. This means that once an ETHE is issued, it will remain in circulation until a redemption program is formed --- something that doesn’t seem to be too urgent for the SEC or Grayscale at the moment. Tiny amounts will naturally be removed due to fees, but the bulk of the asset is in there for good. Knowing that ETHE cannot be taken back and destroyed at this time, the ETH collateralizing it will not be removed from the wallet for the foreseeable future. While it is not fully locked in the sense of say a totally lost key, it is not coming out any time soon. Per their annual statement:
The Trust’s ETH will be transferred out of the ETH Account only in the following circumstances: (i) transferred to pay the Sponsor’s Fee or any Additional Trust Expenses, (ii) distributed in connection with the redemption of Baskets (subject to the Trust’s obtaining regulatory approval from the SEC to operate an ongoing redemption program and the consent of the Sponsor), (iii) sold on an as-needed basis to pay Additional Trust Expenses or (iv) sold on behalf of the Trust in the event the Trust terminates and liquidates its assets or as otherwise required by law or regulation.
Source: Description of Trust on page 31 of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here
Grayscale now owns a huge chunk of both ETH and BTC’s supply… should we be worried about manipulation, a sell off to crash the market crash, a staking cartel?
First, it’s important to remember Grayscale is a lot more akin to an exchange then say an investment firm. Grayscale is working on behalf of its investors to create this product for investor control. Grayscale doesn’t ‘control’ the ETH it holds any more then Coinbase ‘controls’ the ETH in its hot wallet. (Note: There are likely some varying levels of control, but specific to this topic Grayscale cannot simply sell [legally, at least] the ETH by their own decision in the same manner Coinbase wouldn't be able to either.) That said, there shouldn’t be any worry in the short to medium time-frame. As noted above, Grayscale can’t really remove ETH other than for fees or termination of the product. At 2.5% a year, fees are noise in terms of volume. Grayscale seems to be the fastest growing product in the crypto space at the moment and termination of the product seems unlikely. IF redemptions were to happen tomorrow, it’s extremely unlikely we would see a mass exodus out of the product to redeem for ETH. And even if there was incentive to get back to ETH, the premium makes it so that it would be much more cost effective to just sell your ETHE on the secondary market and buy ETH yourself. Remember, any redemption is up to the investors and NOT something Grayscale has direct control over.
Yes, but what about [insert criminal act here]…
Alright, yes. Technically nothing is stopping Grayscale from selling all the ETH / BTC and running off to the Bahamas (Hawaii?). BUT there is no real reason for them to do so. Barry is an extremely public figure and it won’t be easy for him to get away with that. Grayscale’s Bitcoin Trust creates SEC reports weekly / bi-weekly and I’m sure given the sentiment towards crypto is being watched carefully. Plus, Grayscale is making tons of consistent revenue and thus has little to no incentive to give that up for a quick buck.
That’s a lot of ‘happy little feels’ Bob, is there even an independent audit or is this Tether 2.0?
Actually yes, an independent auditor report can be found in their annual reports. It is clearly aimed more towards the financial side and I doubt the auditors are crypto savants, but it is at least one extra set of eyes. Auditors are Friedman LLP – Auditor since 2015. Source: Independent Auditor Report starting on page 116 (of the PDF itself) of the “Grayscale Ethereum Trust Annual Report (2019)” – Located Here As mentioned by user TheCrpytosAndBloods (In Comments Below), a fun fact:
The company’s auditors Friedman LLP were also coincidentally TetheBitfinex’s auditors until They controversially parted ways in 2018 when the Tether controversy was at its height. I am not suggesting for one moment that there is anything shady about DCG - I just find it interesting it’s the same auditor.
“Grayscale sounds kind of lame” / “Not your keys not your crypto!” / “Why is anyone buying this, it sounds like a scam?”
Welp, for starters this honestly is not really a product aimed at the people likely to be reading this post. To each their own, but do remember just because something provides no value to you doesn’t mean it can’t provide value to someone else. That said some of the advertised benefits are as follows:
Access to trading within a tax advantaged retirement account
Institutions can easily and safely get exposure to crypto in a more legal-friendly manner
Ease of use for those who are not very technologically savvy
Ease of access for someone who doesn’t want to set up a Coinbase account
Perceived trust in institutional platforms over something like Coinbase or Kraken
Degen traders who just want access to the volatility ETHE provides that have no interest in crypto beyond that
So for example, I can set up an IRA at a brokerage account that has $0 trading fees. Then I can trade GBTC and ETHE all day without having to worry about tracking my taxes. All with the relative safety something like E-Trade provides over Binance. As for how it benefits the everyday ETH holder? I think the supply lock is a positive. I also think this product exposes the Ethereum ecosystem to people who otherwise wouldn’t know about it.
Why is there a premium? Why is ETHE’s premium so insanely high compared to GBTC’s premium?
There are a handful of theories of why a premium exists at all, some even mentioned in the annual report. The short list is as follows:
ETHE is NOT redeeming shares and as such doesn’t have an effective arbitrage mechanism
ETHE has a 1 year wait to be sold on the secondary market, again negating the ability to effectively arbitrage the premium
People may simply be willing to pay a premium for the benefits stated above.
Why is ETHE’s so much higher the GBTC’s? Again, a few thoughts:
ETHE hasn’t been around as long, so there is less secondary market supply to go around
ETHE was listed at an insanely high premium to begin with
ETHE might simply be more popular at the moment
Could just be sheer stupidity (investors think ETHE is a 1:1 ratio not 1:11)
Are there any other differences between ETHE and GBTC?
I touched on a few of the smaller differences, but one of the more interesting changes is GBTC is now a “SEC reporting company” as of January 2020. Which again goes beyond my scope of knowledge so I won’t comment on it too much… but the net result is GBTC is now putting out weekly / bi-weekly 8-K’s and annual 10-K’s. This means you can track GBTC that much easier at the moment as well as there is an extra layer of validity to the product IMO.
I’m looking for some statistics on ETHE… such as who is buying, how much is bought, etc?
There is a great Q1 2020 report I recommend you give a read that has a lot of cool graphs and data on the product. It’s a little GBTC centric, but there is some ETHE data as well. It can be found here hidden within the 8-K filings.Q1 2020 is the 4/16/2020 8-K filing. For those more into a GAAP style report see the 2019 annual 10-K of the same location.
Is Grayscale only just for BTC and ETH?
No, there are other products as well. In terms of a secondary market product, ETCG is the Ethereum Classic version of ETHE. Fun Fact – ETCG was actually put out to the secondary market first. It also has a 3% fee tied to it where 1% of it goes to some type of ETC development fund. In terms of institutional and accredited investors, there are a few ‘fan favorites’ such as Bitcoin Cash, Litcoin, Stellar, XRP, and Zcash. Something called Horizion (Backed by ZEN I guess? Idk to be honest what that is…). And a diversified Mutual Fund type fund that has a little bit of all of those. None of these products are available on the secondary market.
Are there alternatives to Grayscale?
I know they exist, but I don’t follow them. I’ll leave this as a “to be edited” section and will add as others comment on what they know. Per user Over-analyser (in comments below):
As asked by pegcity - Okay so I was under the impression you can just give them your own ETH and get ETHE, but do you get 11 ETHE per ETH or do you get the market value of ETH in USD worth of ETHE?
I have always understood that the ETHE issued directly through Grayscale is issued without the premium. As in, if I were to trade 1 ETH for ETHE I would get 11, not say only 2 or 3 because the secondary market premium is so high. And if I were paying cash only I would be paying the price to buy 1 ETH to get my 11 ETHE. Per page 39 of their annual statement, it reads as follows:
The Trust will issue Shares to Authorized Participants from time to time, but only in one or more Baskets (with a Basket being a block of 100 Shares). The Trust will not issue fractions of a Basket. The creation (and, should the Trust commence a redemption program, redemption) of Baskets will be made only in exchange for the delivery to the Trust, or the distribution by the Trust, of the number of whole and fractional ETH represented by each Basket being created (or, should the Trust commence a redemption program, redeemed), which is determined by dividing (x) the number of ETH owned by the Trust at 4:00 p.m., New York time, on the trade date of a creation or redemption order, after deducting the number of ETH representing the U.S. dollar value of accrued but unpaid fees and expenses of the Trust (converted using the ETH Index Price at such time, and carried to the eighth decimal place), by (y) the number of Shares outstanding at such time (with the quotient so obtained calculated to one one-hundred-millionth of one ETH (i.e., carried to the eighth decimal place)), and multiplying such quotient by 100 (the “Basket ETH Amount”). All questions as to the calculation of the Basket ETH Amount will be conclusively determined by the Sponsor and will be final and binding on all persons interested in the Trust. The Basket ETH Amount multiplied by the number of Baskets being created or redeemed is the “Total Basket ETH Amount.” The number of ETH represented by a Share will gradually decrease over time as the Trust’s ETH are used to pay the Trust’s expenses. Each Share represented approximately 0.0950 ETH and 0.0974 ETH as of December 31, 2019 and 2018, respectively.
Axion - A Global Currency, Built To Serve The People
What is Axion? Per Axion's website:
AXION is the answer to our global financial markets that are on the brink of disaster. The original solution to this impending collapse was Bitcoin, a decentralized peer-to-peer currency. However, since its inception, certain aspects of Bitcoin, such as lack of speed and high fees, have shifted Bitcoin into more of a store-of-value than a currency. Axion is the currency to address that. With a high-interest time-locked savings account, Participants in the Axion Network are rewarded daily.
Rewards people, not the corporate elite
Global & Scalable
How is AXION distributed?
Anyone holding Hex2T (pre-sale) tokens will receive AXION at a rate of 1:1
Hex holders will also receive AXION 1:1, limited at 10M AXION tokens. Hex holders will also be auto-locked for a year, with 2% releasing weekly. More details can be found in the whitepaper. If Hex holders do not claim their AXION tokens, they will become available for purchase in the Daily Auction every week.
The Daily Auction
Putting Tokens and Value into your pocket.
To get Axion, it needs to be claimed by Hex & Hex2T holders, the longer they wait to claim, the more penalties they face. About 2% of their total per week. This 2% is added into a daily auction pool where people can bid using ETH on the Axion tokens within it. If you bid 10% of the ETH on that day, you get 10% of the pool rewards. 80% of the ETH paid in the auction is then used to hyperdrive both the Axion token and the stakers earnings. First, the ETH is used to purchase the tokens, boosting the token price, and then those tokens are distributed to stakers, creating a very strong positive feedback loop.
Axion is on the path to becoming the ideal global currency.
For the first time in history, inflation is increasing the purchasing power of the people within the network. Axion has partnerships lined up to be integrated in online and in-person payment solutions, where you can pay for nearly everything in your every-day life using Axion. The merchants can accept FIAT (converted from Axion), or Axion itself. This is a global movement.
Axion: Built to Scale
500 Billion Initial Total Supply 1:1 Freeclaim ratio for Hex2T and Hex holders 80% of ETH Earned in auctions is used to buy back tokens 8% Annual inflation that goes Directly to stakers 100% of all purchased tokens Are distributed to stakers No Auto-Stake For hex2t holders 100% autostake for hex holders
How to buy:
**Video Tutorials:**Metamask Install – https://www.youtube.com/watch?v=htyEeKNHX5ABuy/Sell Axion (HEX2T) – https://www.youtube.com/watch?v=vYZBOkHIM5k How Do I Buy Axion (HEX2T)? Step One: Purchase Ethereum from your exchange of choice (Coinbase, Binance, etc). You can also purchase Ethereum through Metamask and have it sent directly to your Metamask wallet (More details on this in Step Three). If buying through Coinbase, you’ll have the option to use a linked bank account or a debit card. Funds purchased via linked bank account will have a hold period while the bank transaction clears, funds purchased via debit card will be available for use instantly. Step Two: Install the Metamask desktop browser extension and set up your Ethereum Wallet. You may also install the Metamask app on your Android smartphone and follow the same set up process in the linked video. (Apologies iOS users, the iOS Metamask app has restrictions that disable necessary features, you’ll have to use the desktop browser extension) Step Three: Once you have your Metamask wallet set up and your seed words properly saved, it’s time to deposit Ethereum to your wallet. – If you’ve purchased Ethereum on an exchange such as Coinbase or Binance, you’ll have to copy your wallet address from Metamask and withdraw the Ethereum from the exchange to your Metamask wallet address that you just copied. Be sure to check the wallet address multiple times before sending as transactions can not be reversed. – If you’d like to purchase Ethereum directly through Metamask, you can do so using the Wyre fiat gateway that is integrated into Metamask. Step Four: Now that you have Ethereum in your Metamask wallet, you can head over to our listing on the Uniswap Exchange to purchase Axion (HEX2T). We recommend using Fast GAS to speed up your transactions. You may also have to click on the gear icon in the top right on Uniswap to adjust your slippage limit when buying larger amounts. – If using the Metamask app on Android, you’ll have to access the in-app browser through the menu (three bars top left of app) and paste the provided link. – You will see a “From” input that should have ETH as the selected currency pointing to a “To (estimated)” output that should have HEX2T as the selected currency. The “From” input is the amount of Ethereum you will be spending and the “To (estimated)” output is the amount of HEX2T that you will receive for that amount of Ethereum. – Once you enter the amount of Ethereum you’d like to spend, the button at the bottom of the page should say “Approve”. This “Approve” function allows the exchange to access Ethereum in your wallet, which is necessary to complete this transaction. You’ll click the “Approve” button and the exchange will send a transaction to your wallet, which you will have to confirm. Wait for that Approve transaction to clear and once it does the button should change from “Approve” to “Swap”. – Now that you’ve given the exchange permission to use the Ethereum in your wallet, you can click the “Swap” button. This will send another transaction to your wallet that you’ll have to confirm. Once that transaction clears, you’ll have successfully purchased HEX2T with Ethereum! Side Note: If you can’t see the HEX2T that you’ve purchased in your Metamask wallet’s Asset list, you’ll have to add the token to your Asset list. At the bottom of the Asset list you will see an “Add Token” button, click on that and you’ll see a “Search” and a “Custom Token” tab. Click on the “Custom Token” tab and paste the following address (0xed1199093b1abd07a368dd1c0cdc77d8517ba2a0) into the “Custom Token Address” field, the rest of the info should auto-fill. Then click the “Next” button in the bottom right, and it should display your HEX2T balance, click the “Add Tokens” button and you should now see your HEX2T in your Asset list. **How Do I Sell Axion (HEX2T)?**To sell Axion (HEX2T), you essentially do the inverse of what you did to purchase it.Step One: Head over to Uniswap Exchange and click on ETH in the “From” input, a drop down list will appear and you’ll select HEX2T. In the “To (estimated)” output, click on “Select a Token” and select ETH. To clarify, if you want to sell, HEX2T should be on top, ETH should be on bottom. Step Two: Enter the amount of HEX2T you’d like to sell in the “From” input, the button at the bottom of the page should say “Approve”. This “Approve” function allows the exchange to access HEX2T in your wallet, which is necessary to complete this transaction. You’ll click the “Approve” button and the exchange will send a transaction to your wallet, which you will have to confirm. Wait for that Approve transaction to clear and once it does the button should change from “Approve” to “Swap”. – Now that you’ve given the exchange permission to use the HEX2T in your wallet, you can click the “Swap” button. This will send another transaction to your wallet that you’ll have to confirm. Once that transaction clears, you’ll have successfully sold HEX2T for Ethereum! If at any point you feel that you need help in this process, please do not hesitate to join our fast growingDiscordorTelegram.Once you’re in either of those communities you’ll be able to ask an admin or moderator for assistance.
Their legal proposal is 95% complete, per their Discord announcement - and most likely be finished in the coming days.
Australia to become first crypto-friendly IPO by accepting Tether
An Aussie organization working a hydroponics ranch in Malaysia is directing the principal first sale of stock to acknowledge crypto resources in Australia. https://preview.redd.it/b9esxf8nx7x51.jpg?width=700&format=pjpg&auto=webp&s=f5fa096179a32647bd3f7e685c7d697e3428689a Australia's crypto-accommodating capital-raising stage Stax has declared its customer West Coast Aquaculture Group, or WCA will direct the nation's first sale of stock that acknowledges virtual cash as installment. Speculators taking an interest in WCA's contribution can buy value in the organization utilizing Tether (USDT) or Australian dollars. USDT was picked over Bitcoin (BTC) and Ether (ETH) because of its value dependability. Stax CEO Kenny Lee underlined that stablecoins offer the advantages of cryptographic money without the instability of other computerized resources:
“The acceptance of USDT in an IPO is a transformative move in Australia and a significant step forward for cryptocurrency adoption in general. It paves the way for the future of capital markets down under.”
Lee noted Stax is thinking about help for extra stablecoins in the future. WCA works a huge marine ranch in Langkawi, Malaysia, where it essentially creates new Grouper fish for discount and retail clients in Singapore, Hong Kong, and Malaysia. The capital raised will be utilized for asset extensions including the acquisition of a new incubation centre and nursery offices. WCA is offering between 10 million and 14 million offers at $0.50 each, speaking to somewhere in the range of 8.78% and 11.87% of the complete access. The base objective is $5 million. After the raise, WCA's arrangements for its offers to drift on the Sydney Stock Exchange, with the offers expected to start exchanging close to Nov. 19 SSX CEO Michael Go commended Stax for encouraging a capital raise supporting USDT, expressing:
“This is a first, and historic development in the Australian market which will dictate the future of capital raising, particularly for growth companies.”
Hi, Im in the UK & looking for the best way to make an investment in XRP. I’ve brought bitcoin in the past for online purchases etc, but XRP is new to me. Navigating resources out there is a little confusing, as different sources appear to offer conflicting advice. What I gather is that it may be worth converting GBP to EUR with my revolut account first, as EUR seems to get a better rate on cryptocurrency platforms, I’m not sure how true that is though? I then send EUR to binance or coinbase to convert to BTC/ETH. Here’s where it gets confusing again: many people appear to recommend sending these cryptocurrencies to another platform (Kraken?) to then convert to XRP. From what I can tell binance / coinbase allow conversion to XRP. Why would I add the extra step of using another platform, does it avoid additional fees? I Then send to a cryptowallet. Do you guys have any recommendations for software (preferably android) crypto wallets that can store XRP? im a little lost with that too, as there appear to be so many options. Any advice here is much appreciated, Thanks
How To End The Cryptocurrency Exchange "Wild West" Without Crippling Innovation
In case you haven't noticed the consultation paper, staff notice, and report on Quadriga, regulators are now clamping down on Canadian cryptocurrency exchanges. The OSC and other regulatory bodies are still interested in industry feedback. They have not put forward any official regulation yet. Below are some ideas/insights and a proposed framework.
Typical securities frameworks will cost Canadians millions of dollars (ie Sarbanes-Oxley estimated at $5m USD/yr per firm). Implementation costs of this proposal are significantly cheaper.
Canadians can maintain a diverse set of exchanges, multiple viable business models are still fully supported, and innovation is encouraged while keeping Canadians safe.
Many of you have limited time to read the full proposal, so here are the highlights:
Effective standards to prevent both internal and external theft. Exchange operators are trained and certified, and have a legal responsibility to users.
Regular Transparent Audits
Provides visibility to Canadians that their funds are fully backed on the exchange, while protecting privacy and sensitive platform information.
Establishment of basic insurance standards/strategy, to expand over time. Removing risk to exchange users of any hot wallet theft.
Background and Justifications
Cold Storage Custody/Management After reviewing close to 100 cases, all thefts tend to break down into more or less the same set of problems: • Funds stored online or in a smart contract, • Access controlled by one person or one system, • 51% attacks (rare), • Funds sent to the wrong address (also rare), or • Some combination of the above. For the first two cases, practical solutions exist and are widely implemented on exchanges already. Offline multi-signature solutions are already industry standard. No cases studied found an external theft or exit scam involving an offline multi-signature wallet implementation. Security can be further improved through minimum numbers of signatories, background checks, providing autonomy and legal protections to each signatory, establishing best practices, and a training/certification program. The last two transaction risks occur more rarely, and have never resulted in a loss affecting the actual users of the exchange. In all cases to date where operators made the mistake, they've been fully covered by the exchange platforms. • 51% attacks generally only occur on blockchains with less security. The most prominent cases have been Bitcoin Gold and Ethereum Classic. The simple solution is to enforce deposit limits and block delays such that a 51% attack is not cost-effective. • The risk of transactions to incorrect addresses can be eliminated by a simple test transaction policy on large transactions. By sending a small amount of funds prior to any large withdrawals/transfers as a standard practice, the accuracy of the wallet address can be validated. The proposal covers all loss cases and goes beyond, while avoiding significant additional costs, risks, and limitations which may be associated with other frameworks like SOC II. On The Subject of Third Party Custodians Many Canadian platforms are currently experimenting with third party custody. From the standpoint of the exchange operator, they can liberate themselves from some responsibility of custody, passing that off to someone else. For regulators, it puts crypto in similar categorization to oil, gold, and other commodities, with some common standards. Platform users would likely feel greater confidence if the custodian was a brand they recognized. If the custodian was knowledgeable and had a decent team that employed multi-sig, they could keep assets safe from internal theft. With the right protections in place, this could be a great solution for many exchanges, particularly those that lack the relevant experience or human resources for their own custody systems. However, this system is vulnerable to anyone able to impersonate the exchange operators. You may have a situation where different employees who don't know each other that well are interacting between different companies (both the custodian and all their customers which presumably isn't just one exchange). A case study of what can go wrong in this type of environment might be Bitpay, where the CEO was tricked out of 5000 bitcoins over 3 separate payments by a series of emails sent legitimately from a breached computer of another company CEO. It's also still vulnerable to the platform being compromised, as in the really large $70M Bitfinex hack, where the third party Bitgo held one key in a multi-sig wallet. The hacker simply authorized the withdrawal using the same credentials as Bitfinex (requesting Bitgo to sign multiple withdrawal transactions). This succeeded even with the use of multi-sig and two heavily security-focused companies, due to the lack of human oversight (basically, hot wallet). Of course, you can learn from these cases and improve the security, but so can hackers improve their deception and at the end of the day, both of these would have been stopped by the much simpler solution of a qualified team who knew each other and employed multi-sig with properly protected keys. It's pretty hard to beat a human being who knows the business and the typical customer behaviour (or even knows their customers personally) at spotting fraud, and the proposed multi-sig means any hacker has to get through the scrutiny of 3 (or more) separate people, all of whom would have proper training including historical case studies. There are strong arguments both for and against using use of third party custodians. The proposal sets mandatory minimum custody standards would apply regardless if the cold wallet signatories are exchange operators, independent custodians, or a mix of both. On The Subject Of Insurance ShakePay has taken the first steps into this new realm (congratulations). There is no question that crypto users could be better protected by the right insurance policies, and it certainly feels better to transact with insured platforms. The steps required to obtain insurance generally place attention in valuable security areas, and in this case included a review from CipherTrace. One of the key solutions in traditional finance comes from insurance from entities such as the CDIC. However, historically, there wasn't found any actual insurance payout to any cryptocurrency exchange, and there are notable cases where insurance has not paid. With Bitpay, for example, the insurance agent refused because the issue happened to the third party CEO's computer instead of anything to do with Bitpay itself. With the Youbit exchange in South Korea, their insurance claim was denied, and the exchange ultimately ended up instead going bankrupt with all user's funds lost. To quote Matt Johnson in the original Lloyd's article: “You can create an insurance policy that protects no one – you know there are so many caveats to the policy that it’s not super protective.” ShakePay's insurance was only reported to cover their cold storage, and “physical theft of the media where the private keys are held”. Physical theft has never, in the history of cryptocurrency exchange cases reviewed, been reported as the cause of loss. From the limited information of the article, ShakePay made it clear their funds are in the hands of a single US custodian, and at least part of their security strategy is to "decline to confirm the custodian’s name on the record". While this prevents scrutiny of the custodian, it's pretty silly to speculate that a reasonably competent hacking group couldn't determine who the custodian is. A far more common infiltration strategy historically would be social engineering, which has succeeded repeatedly. A hacker could trick their way into ShakePay's systems and request a fraudulent withdrawal, impersonate ShakePay and request the custodian to move funds, or socially engineer their way into the custodian to initiate the withdrawal of multiple accounts (a payout much larger than ShakePay) exploiting the standard procedures (for example, fraudulently initiating or override the wallet addresses of a real transfer). In each case, nothing was physically stolen and the loss is therefore not covered by insurance. In order for any insurance to be effective, clear policies have to be established about what needs to be covered. Anything short of that gives Canadians false confidence that they are protected when they aren't in any meaningful way. At this time, the third party insurance market does not appear to provide adequate options or coverage, and effort is necessary to standardize custody standards, which is a likely first step in ultimately setting up an insurance framework. A better solution compared to third party insurance providers might be for Canadian exchange operators to create their own collective insurance fund, or a specific federal organization similar to the CDIC. Such an organization would have a greater interest or obligation in paying out actual cases, and that would be it's purpose rather than maximizing it's own profit. This would be similar to the SAFU which Binance has launched, except it would cover multiple exchanges. There is little question whether the SAFU would pay out given a breach of Binance, and a similar argument could be made for a insurance fund managed by a collective of exchange operators or a government organization. While a third party insurance provider has the strong market incentive to provide the absolute minimum coverage and no market incentive to payout, an entity managed by exchange operators would have incentive to protect the reputation of exchange operators/the industry, and the government should have the interest of protecting Canadians. On The Subject of Fractional Reserve There is a long history of fractional reserve failures, from the first banks in ancient times, through the great depression (where hundreds of fractional reserve banks failed), right through to the 2008 banking collapse referenced in the first bitcoin block. The fractional reserve system allows banks to multiply the money supply far beyond the actual cash (or other assets) in existence, backed only by a system of debt obligations of others. Safely supporting a fractional reserve system is a topic of far greater complexity than can be addressed by a simple policy, and when it comes to cryptocurrency, there is presently no entity reasonably able to bail anyone out in the event of failure. Therefore, this framework is addressed around entities that aim to maintain 100% backing of funds. There may be some firms that desire but have failed to maintain 100% backing. In this case, there are multiple solutions, including outside investment, merging with other exchanges, or enforcing a gradual restoration plan. All of these solutions are typically far better than shutting down the exchange, and there are multiple cases where they've been used successfully in the past. Proof of Reserves/Transparency/Accountability Canadians need to have visibility into the backing on an ongoing basis. The best solution for crypto-assets is a Proof of Reserve. Such ideas go back all the way to 2013, before even Mt. Gox. However, no Canadian exchange has yet implemented such a system, and only a few international exchanges (CoinFloor in the UK being an example) have. Many firms like Kraken, BitBuy, and now ShakePay use the Proof of Reserve term to refer to lesser proofs which do not actually cryptographically prove the full backing of all user assets on the blockchain. In order for a Proof of Reserve to be effective, it must actually be a complete proof, and it needs to be understood by the public that is expected to use it. Many firms have expressed reservations about the level of transparency required in a complete Proof of Reserve (for example Kraken here). While a complete Proof of Reserves should be encouraged, and there are some solutions in the works (ie TxQuick), this is unlikely to be suitable universally for all exchange operators and users. Given the limitations, and that firms also manage fiat assets, a more traditional audit process makes more sense. Some Canadian exchanges (CoinSquare, CoinBerry) have already subjected themselves to annual audits. However, these results are not presently shared publicly, and there is no guarantee over the process including all user assets or the integrity and independence of the auditor. The auditor has been typically not known, and in some cases, the identity of the auditor is protected by a NDA. Only in one case (BitBuy) was an actual report generated and publicly shared. There has been no attempt made to validate that user accounts provided during these audits have been complete or accurate. A fraudulent fractional exchange, or one which had suffered a breach they were unwilling to publicly accept (see CoinBene), could easily maintain a second set of books for auditors or simply exclude key accounts to pass an individual audit. The proposed solution would see a reporting standard which includes at a minimum - percentage of backing for each asset relative to account balances and the nature of how those assets are stored, with ownership proven by the auditor. The auditor would also publicly provide a "hash list", which they independently generate from the accounts provided by the exchange. Every exchange user can then check their information against this public "hash list". A hash is a one-way form of encryption, which fully protects the private information, yet allows anyone who knows that information already to validate that it was included. Less experienced users can take advantage of public tools to calculate the hash from their information (provided by the exchange), and thus have certainty that the auditor received their full balance information. Easy instructions can be provided. Auditors should be impartial, their identities and process public, and they should be rotated so that the same auditor is never used twice in a row. Balancing the cost of auditing against the needs for regular updates, a 6 month cycle likely makes the most sense. Hot Wallet Management The best solution for hot wallets is not to use them. CoinBerry reportedly uses multi-sig on all withdrawals, and Bitmex is an international example known for their structure devoid of hot wallets. However, many platforms and customers desire fast withdrawal processes, and human validation has a cost of time and delay in this process. A model of self-insurance or separate funds for hot wallets may be used in these cases. Under this model, a platform still has 100% of their client balance in cold storage and holds additional funds in hot wallets for quick withdrawal. Thus, the risk of those hot wallets is 100% on exchange operators and not affecting the exchange users. Since most platforms typically only have 1%-5% in hot wallets at any given time, it shouldn't be unreasonable to build/maintain these additional reserves over time using exchange fees or additional investment. Larger withdrawals would still be handled at regular intervals from the cold storage. Hot wallet risks have historically posed a large risk and there is no established standard to guarantee secure hot wallets. When the government of South Korea dispatched security inspections to multiple exchanges, the results were still that 3 of them got hacked after the inspections. If standards develop such that an organization in the market is willing to insure the hot wallets, this could provide an acceptable alternative. Another option may be for multiple exchange operators to pool funds aside for a hot wallet insurance fund. Comprehensive coverage standards must be established and maintained for all hot wallet balances to make sure Canadians are adequately protected.
Current Draft Proposal
(1) Proper multi-signature cold wallet storage. (a) Each private key is the personal and legal responsibility of one person - the “signatory”. Signatories have special rights and responsibilities to protect user assets. Signatories are trained and certified through a course covering (1) past hacking and fraud cases, (2) proper and secure key generation, and (3) proper safekeeping of private keys. All private keys must be generated and stored 100% offline by the signatory. If even one private keys is ever breached or suspected to be breached, the wallet must be regenerated and all funds relocated to a new wallet. (b) All signatories must be separate background-checked individuals free of past criminal conviction. Canadians should have a right to know who holds their funds. All signing of transactions must take place with all signatories on Canadian soil or on the soil of a country with a solid legal system which agrees to uphold and support these rules (from an established white-list of countries which expands over time). (c) 3-5 independent signatures are required for any withdrawal. There must be 1-3 spare signatories, and a maximum of 7 total signatories. The following are all valid combinations: 3of4, 3of5, 3of6, 4of5, 4of6, 4of7, 5of6, or 5of7. (d) A security audit should be conducted to validate the cold wallet is set up correctly and provide any additional pertinent information. The primary purpose is to ensure that all signatories are acting independently and using best practices for private key storage. A report summarizing all steps taken and who did the audit will be made public. Canadians must be able to validate the right measures are in place to protect their funds. (e) There is a simple approval process if signatories wish to visit any country outside Canada, with a potential whitelist of exempt countries. At most 2 signatories can be outside of aligned jurisdiction at any given time. All exchanges would be required to keep a compliant cold wallet for Canadian funds and have a Canadian office if they wish to serve Canadian customers. (2) Regular and transparent solvency audits. (a) An audit must be conducted at founding, after 3 months of operation, and at least once every 6 months to compare customer balances against all stored cryptocurrency and fiat balances. The auditor must be known, independent, and never the same twice in a row. (b) An audit report will be published featuring the steps conducted in a readable format. This should be made available to all Canadians on the exchange website and on a government website. The report must include what percentage of each customer asset is backed on the exchange, and how those funds are stored. (c) The auditor will independently produce a hash of each customer's identifying information and balance as they perform the audit. This will be made publicly available on the exchange and government website, along with simplified instructions that each customer can use to verify that their balance was included in the audit process. (d) The audit needs to include a proof of ownership for any cryptocurrency wallets included. A satoshi test (spending a small amount) or partially signed transaction both qualify. (e) Any platform without 100% reserves should be assessed on a regular basis by a government or industry watchdog. This entity should work to prevent any further drop, support any private investor to come in, or facilitate a merger so that 100% backing can be obtained as soon as possible. (3) Protections for hot wallets and transactions. (a) A standardized list of approved coins and procedures will be established to constitute valid cold storage wallets. Where a multi-sig process is not natively available, efforts will be undertaken to establish a suitable and stable smart contract standard. This list will be expanded and improved over time. Coins and procedures not on the list are considered hot wallets. (b) Hot wallets can be backed by additional funds in cold storage or an acceptable third-party insurance provider with a comprehensive coverage policy. (c) Exchanges are required to cover the full balance of all user funds as denominated in the same currency, or double the balance as denominated in bitcoin or CAD using an established trading rate. If the balance is ever insufficient due to market movements, the firm must rectify this within 24 hours by moving assets to cold storage or increasing insurance coverage. (d) Any large transactions (above a set threshold) from cold storage to any new wallet addresses (not previously transacted with) must be tested with a smaller transaction first. Deposits of cryptocurrency must be limited to prevent economic 51% attacks. Any issues are to be covered by the exchange. (e) Exchange platforms must provide suitable authentication for users, including making available approved forms of two-factor authentication. SMS-based authentication is not to be supported. Withdrawals must be blocked for 48 hours in the event of any account password change. Disputes on the negligence of exchanges should be governed by case law.
Continued review of existing OSC feedback is still underway. More feedback and opinions on the framework and ideas as presented here are extremely valuable. The above is a draft and not finalized. The process of further developing and bringing a suitable framework to protect Canadians will require the support of exchange operators, legal experts, and many others in the community. The costs of not doing such are tremendous. A large and convoluted framework, one based on flawed ideas or implementation, or one which fails to properly safeguard Canadians is not just extremely expensive and risky for all Canadians, severely limiting to the credibility and reputation of the industry, but an existential risk to many exchanges. The responsibility falls to all of us to provide our insight and make our opinions heard on this critical matter. Please take the time to give your thoughts.
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