Which regulators have publicly commented on Initial Coin Offerings?

Below are some of the stated positions of several different regulators around the world regarding ICOs.  In chronological order:

    • Brazil’s equivalent of the SEC, the Comissão de Valores Mobiliários (CVM), published (July 13th) initial legislation instruction (Instrução CVM No. 588) regulating crowdfunding via ICOs: (Portuguese announcement)
    • The United States SEC published on July 25th on ICOs: (Report on investigation) (Investor bulletin) (Investor alert)
    • Monetary Authority of Singapore published its views on August 1st on ICOs: (Clarification statement) (Consumer advisory)
    • Canadian Securities Administrators (CSA), including the Ontario Securities Commission, published its views on August 24th on ICOs: (Staff Notice) (Announcement)
    • Israel Securities Authority announced on August 30th that it is forming a committee to look at ICOs: (Hebrew announcement) (English)
    • The Financial Supervisory Commission (FSC) in South Korea announced on September 3rd that it held a joint task force meeting to strengthen regulations around digital currency trading, including fundraising with ICOs: (BusinessKorea)
    • Central Bank of Russia issued a public statement on September 4th that included its views on ICOs: (Russian announcement) (English)
    • The People’s Bank of China, along with 6 other Chinese government bodies including the national securities regulator (CSRC), publicly banned ICO fundraising in China on September 4th: (CN announcement) (English) (Bloomberg) (Reuters)
    • SFC in Hong Kong announced its views on ICOs on September 5th: (Announcement)
    • The UK Financial Conduct Authority (FCA) announced that it was keeping a close eye on ICOs on September 6th: (FT)
    • The Securities Commission (SC) of Malaysia issued a press release cautioning investors in ICOs on September 7th: (DNA)
    • The Dubai Financial Services Authority (DFSA) warned investors that ICOs were risky on September 13th: (Statement)
    • The Securities and Exchange Commission in Thailand issued some statements regarding ICOs on September 14th: (Comments)

What do they all say?  A friend who is an attorney said it concisely: when you sell securities, you have to comply with securities laws.

If you plan to do an ICO or some kind of token sale, be sure to speak with more than one lawyer or law firm to get a legal opinion about what it is you are actually selling (or not).

And if you’re interested, below is an interview of Nick Morgan.  He is an attorney who previously was part of the SEC’s enforcement team.  He discusses The DAO, securities regulations, and the current ICO frenzy.


  • ECB’s Draghi rejects Estonia’s virtual currency idea – Reuters
  • Initial Coin Offerings: Know Before You Invest – FINRA
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Panels, quotes, cites for the 2nd quarter of 2017

Below are a variety of events I participated in the last several months.

Events, panels, and presentations:


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A few other perspectives on cryptocurrencies and ICOs

I received a lot of questions regarding my last post.  Over the past month I have read a number of interesting interviews and articles that I think contribute a lot to the discussion.

Some additional perspectives:


On July 25, the SEC published a new Investor Bulletin focused on ICOs and also published a report (pdf) detailing their position on ICOs, using The DAO as an example (which they noted violated several US securities laws).

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A high level overview of ICOs

[Note: I neither own nor have any trading position on any cryptocurrency.  The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

Just as I did with the COIN ETF proposal last year, I have also written a 50-page paper for internal use diving into the world of ICOs.1

I am not sure if or when it will be made public (check back in 3-6 months to see if it has been posted), but here are a few salient points:

    • ICO stands for “initial coin offering.” Depending on what cryptocurrency group is pitching an ICO, it may be in exchange for company equity, but often times there is no explicit contractual link between control of the coin itself with some kind of equity or financial performance of the company… because there is often no formal contract provided to investors.  Not all ICOs are alike and any prospective user or investor should look into the specific operational and funding arrangements.
    • Since January 1, 2017, more than $200 million has been raised by more than a dozen ICO-related projects and companies, a figure that will likely double by the end of the summer and triple by the end of the year as turn-key platforms such as Prism, Swap, 0x, and Iconomi, are flipped on.
    • The primary method of raising and funding an ICO is through bitcoin and ether deposits.  This has driven (mostly) retail investors to create accounts at cryptocurrency exchanges – most of which have poor track records such as Bitfinex – and acquire BTC and ETH.  This demand in turn has been a key driver in the current all-time highs seen by many cryptocurrencies including bitcoin and ether.
    • There is very little regulatory or independent oversight of any of these coin offerings.  Most of the projects attempt to shield themselves from scrutiny from securities, commodities, and money-transmission regulators by setting up a non-profit organization or foundation.  These foundations are typically registered in a couple specific countries, each of which is now home to more than a dozen non-profit organizations specifically managing ICOs.  In addition, ICO promoters will often use euphemisms such as “tokens” instead of coins, or call their fundraiser a “crowdsale” or “donation” or “contribution” that the non-profit organization will later re-distribute after the ICO is over.
    • Some of these non-profit entities sign exclusive development contracts with a for-profit entity that is run by the same people who operate the foundation.  That is to say, the foundation will hire the for-profit company to develop and advise the project that the ICO fundraiser marketed and advertised, yet often with no independent oversight.
    • Ignoring accreditation status: very few, only a handful at most, of these ICOs are done in compliance with any KYC, AML, CFT gathering and sharing requirements. This is problematic.  For instance, over $1 billion in ransomware was liquidated (largely) through cryptocurrencies last year thus it could be relatively easy for bad actors (hackers) to liquidate their bitcoin and ether holdings into ICOs and not be easily caught due to the inability to link real world identities to specific blockchain activity.

Last week Valerie Szczepanik, the head of the SEC’s distributed ledger group, made several public comments.  This included: “Whether or not you are regulated by the SEC, you still have fiduciary duties to your investor.  If you want this industry to flourish, protection of investors should be at the forefront.”

As of right now, there are just a handful of ICOs that have explicitly attempted to protect investors by providing full transparency into their organizations.  Most do not disclose the principals, directors, and insiders involved within these organizations.  Some have private offerings called a pre-sale.  A pre-sale allows participants to acquire coins at a discount (e.g., pre-sale investors might receive 2x the amount of coins that the public coin sale will have at the same price).  In addition, the participants in a pre-sale are not typically named or made public prior to the public offering of the coins; nor are the conditions by which these participants able to sell their holdings typically disclosed.

Historically companies which file paperwork in order to be listed on a public stock exchange have to submit an S-1 or its equivalent to regulators.  The S-1 is important and helpful to the rest of the market because it lays out who the insiders are, who the principals and directors are, how governance is handled, who is responsible, what the business is, what the liabilities are, etc..

In contrast, most ICOs currently have nebulous governance on purpose: because the operators do not want anyone to be held responsible in case the project is unsuccessful or the coin loses its value.  Caveat emptor is the name of the game.

Tulip euphoria

In any given month I am provided inside information about ICOs.  Complete strangers will send me pitch decks that outline their pre-sale and listing opportunities.

Yes, some exchanges are paid to list these coins, often through a percentage negotiated beforehand with the ICO operator.  And there are market makers and underwriters in the form of family offices, high net worth individuals and small hedge funds.  There is an entire ecosystem that is completely opaque and opaque on purpose because many of these participants are trying to deflect responsibility in case a coin crashes or a project is unsuccessful or because they are found in non-compliance with a variety of regulations (e.g., not declaring taxes, self-dealing, insider trading, etc.).

One project involved in building a distributed computer recently offered me about $50,000 over the course of 6 months in addition to the native coin they were pitching to the public.  All they wanted me to do: act as an advisor and promote their coin on social media.

I said no to all of them but others said yes and that project above raised a couple million in USD.

Last week I attended several events including Consensus and a different private conference held later in the week.  I gave a short presentation at one of the events and afterwards I walked to the buffet outside the room to get some food.  While gathering some grilled fish, the audio/visual operator for the event came up to me and told me: “Tim, I just put $100 into bitcoin and also ether.  How much more should I put into them?”

My presentation wasn’t even about cryptocurrency investing or about ICOs, but this illustrates the exuberance of the current time period.  There is a lot of fear of missing out yet few people are actually looking at what these ICO-funded platforms or projects are attempting to do.  How can unsophisticated, technically unsavvy people learn more about them?

Media publications?  But conflict of interest is rife.

I have mentioned this multiple times over the years: unfortunately many “coin” media sites and magazines are not helping the due diligence situation.  Most “coin” reporters, if not all of them, own cryptocurrencies and benefit directly from increased demand of the cryptocurrency, but they often do not disclose it.  In fact, many times they report on coins they own and/or that their parent company owns.  Several small buy-side analysts and their firms also have published uncritical marketing material for cryptocurrencies and some do not disclose their coin holdings or outline the major risks involved in operating these types of networks, in effect white-washing the risks of anarchic chains.

Others in privileged positions including some of the VCs that are active in this space are now also promoting ICOs but few disclose their active long or short positions.  Some of these VCs were entrepreneurs who have pivoted multiple times and this is a last ditch effort to drum up support for their sagging portfolio. 2 3

You just don’t understand the technology!

One common refrain I often hear from ICO promoters is that ICOs are a new form of technology that empowers retail investors like never before and that the traditional world of institutions and laws has no place in the new economy.  And that naysayers and critics just don’t understand the transformative power of ICOs and cryptocurrencies.

That may be true but in my case, definitely is not.

In late 2014 I worked with a company called Melotic.  Melotic is a tech startup that raised about $1.2 million in the summer of 2014 to build a digital asset exchange: a trading platform that new cryptocurrency projects could be listed on, GDAX before GDAX.  For about 9 months I spent the bulk of my time talking to dozens of cryptocurrency projects and operators to find out what unique thing their company did and why they should be listed on Melotic.  Nearly all of them were half-baked scams, and others were just impractical (Urea Coin). 4

In May 2015, Melotic announced it was closing its exchange and moving into cross-border payments where it currently operates under the brand, Kleering.

While Melotic deserves its own dedicated post, the takeaways we learned at the time were that traders (who were most of the user base) only cared about two specific things:

(1) Anonymity.  Some traders publicly complained when we implemented a set of KYC and AML policies.  They said we should snub our noses at the government and banks and provide traders the ability to exchange cryptocurrencies without complying with local or national laws surrounding identity gathering and verification.  This is an opinion that is still very prevalent as shown by similar comments on /r/bitcoinmarkets and /r/ethtrader.

(2) Pump and dump.  Day traders love volatility and cryptocurrencies often provide that volatile environment.  Because new cryptocurrencies such as an ICO are often even more illiquid and thinly traded than say bitcoin (which itself is relatively illiquid), whales and insiders without vesting and lock-up periods can quickly move the market up and down due to the large amounts of coin holdings they have.  This creates the booms and busts that many cryptocurrency traders savor.  Yet at Melotic, we were apprehensive about listing every single cryptocurrency under the sun, and tried to filter those we thought had unique utility and less volatile.  In the end we only listed about 10.  Yet empirically the most successful exchanges – as measured in volume – were those that listed every single coin that was launched.  Quantity over quality continues to persist today as exchanges compete for volume and liquidity of new coins.  This contrasts with regulated exchanges such as NASDAQ (pdf) and NYSE (pdf) which have listing requirements, including transparency into the companies principals.  Most cryptocurrency exchanges do not ask for similar requirements and in fact, some take a cut of the coins – similar to payola – in order to be listed.

Over two years ago I wrote a post that looked at around 20 different ICOs and projects that did some kind of public coin distribution.  My new paper looks at them in more detail.  What were the findings?

While we wait for that paper to be published another key takeaway is that: almost none of the projects lived up to the advertised utility or expectations that their promoters marketed to the community and investors that bought their coins.  Yet most of the cryptocurrencies, even ones that lack a real development community, are seeing all-time highs on the cryptocurrency markets.

In other words: utility is completely divorced from market value of the coins; a phenomenon that seems unlikely to change in the short term.

This is compounded by the fact that ICOs are by their nature, not designed for cash flow or optimized to be profitable.

Why is that?  Because at its core: the non-profit entities that runs them are by definition, not-for-profit.  As a result, these projects largely rely on their token holdings and the price appreciation thereof, in order to be sustainable.  Thus the incentive to focus on marketing and create buzz to further increase the price appreciation of the coin holdings.

And ignoring the informational asymmetries above, there are some other interesting wrinkles.

Earlier this week I participated on a fintech panel and during the group discussion one specific ICO was briefly mentioned, the Basic Attention Token (BAT).  Brave, the company behind the BAT, had just raised $35 million in a crowdsale (unregistered securities?).  Notable to this sale was that over $6,000 in fees to miners were included in the transactions related to the ICO.

How many transactions can you fit into an Ethereum block during high demand times?  It depends on the complexity of the contract. For the BAT, it was about 90.  90ish people were able to participate in the first block of the BAT’s ICO. Those 90 ICO seats went to whoever attached the largest transaction fees.

An unsavvy retail investor would need a lot of mempool luck if there is high demand and larger players investing millions are paying $1,000 USD fees just to increase their chance to get one of those scarce seats in the first block. This could mean that in the long run, all the “good” ICOs will be bought up by sophisticated investors aware of this limitation and only sub-par ICOs will run long enough (more than one block) to let unsophisticated retail investors in.5


ICO organizers often exchange coins for explicit support by outside endorsements and lobbying in their favor (e.g., advisors and influential personas are given a cut of coins). Therefore researchers, regulators, developers and potential investors looking at an ICO should look for paper trails to identify investors, users, organizers, insiders, and potential malicious actors.6  This also includes exchange operators and their principals who may learn weeks beforehand when a cryptocurrency will get listed and thus, may have material, asymmetric information they can act on.

Investors should look very hard at what the risks and recourse there is in the event of a hard fork, what happens if their assets end up on a deprecated chain?  If it is an ERC20 token, what fork will the developers consider the “legitimate” chain?  Ethereum forked multiple times last year and currently, investors of ICOs based on ERC20 have few, if any, protections or recourse in the event an ICO organizer fails to deliver its promises let alone a technical problem occurs.  For instance, what happens if the network becomes too top heavy and open to the Hold-Up Problem?  Who has legal standing or recourse?

ICOs can be done with existing technology – no blockchains are needed (just ask Beenz and Liberty Reserve) – yet because ICOs are being done on anarchic blockchains where reversibility is economically cumbersome and identification is non-existence, it can create new risks and challenges for investors.  Potential investors need to be able to answer: in case a dispute arises, how can recourse take place if key counterparties are not identifiable?

Cryptocurrencies and the coins that piggy back on their network will likely continue to exist so as long as these non-profit entities have enough coins to liquidate to pay for marketing and advertisements. And so as long as there are others willing to buy their coins (e.g., liquidity).

And while it may be too early to distinguish and separate the specific ICOs that are outright scams from poorly run companies, keep in mind that a couple dozen Pyramid schemes failing in 1997 led to massive unrest and a civil war in Albania.  We have already witnessed enormous strain and virtual fighting within the cryptocurrency community (e.g., the never ending Bitcoin block size debate and the Ethereum hard fork because of The DAO attack).  What would happen to the aggregate cryptocurrency market if the investors and insiders in a couple dozen ICO platforms (Pyramid or not) tried to liquidate their holdings onto an illiquid market?

If you’re looking for dramatic excitement (currently) without many investor protections, the ICO world may have what you’re looking for.  But if you’re looking for sustainable operations with repeat revenue and cash flow connected to mainstream utility and accountability – aka a business – then you might want to do a double-take.

See also:


  1. “How the ICO, OCO, and ECO ecosystem works at a high level” by Tim Swanson []
  2. Kik, a messaging application which failed to gain traction, announced it would be issuing a cryptocurrency, but for what purpose?  Likely because it has been unable to raise new venture or institutional capital. []
  3. A number of these portfolio companies likely are on life support, propped up not by revenue but coin holdings which speculators have driven up in market value.  In short: some of these cryptocurrency-based startups are commodity or FX plays, not utility-based investments. []
  4. We also spoke with a lot of cryptocurrency exchanges to learn about their business and compliance practices, shying away from those that raised red flags around KYC and AML compliance.  One cryptocurrency exchange that is still very active today asked us to do the KYC for them as they were ideologically against gathering that information from their own customers. []
  5. Note: this is not an endorsement of BAT.  I have not participated in any ICO or cryptocurrency crowdsale. []
  6. Some ICO organizers have intentionally misled financial institutions about the nature of their business in order to get a bank account. Because ICOs typically do not comply with KYC, AML, and CFT procedures, this could lead to new fines and even banks being de-banked (correspondent banking access cut off). []
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How cryptocurrencies enable ransomware and how regtech can help counter it

Imagine for a moment that Alice, a hacker, was looking at various means for receiving payment for an illicit activity she just undertook.  She has two options to do so, which would she choose?

(1)  Bob built a payment network which was identity-free; it used pseudonyms so no legal identities were required to send transactions between its participants.  And that trying to stop or prevent payments was difficult because the computers running the payment network were widely distributed and run by multiple known and unknown participants across dozens of jurisdictions that were sometimes hard to track down.  Recourse is difficult and sometimes impossible.  Cryptocurrencies such as Bitcoin, Litecoin, and Ethereum are examples of such a network.

(2) Carol built a payment network which requires all users to provide a proof-of-identity, usually by scanning and storing of government-issued IDs or utility bills.  And that stopping, preventing, or even rolling back payments was possible because the computers running the payment network were run by legally identifiable participants who were often located in easy-to-find offices.  Recourse could be cumbersome, but almost always possible.  Wire transfer methods like ACH are examples of such a network.

Alice would probably choose number one and later try use some conversion tool or exchange to move her payment into number two.  How is this done?  See the (dated) flow-of-funds chart below.

While some cryptocurrencies, like Bitcoin, were probably not designed to serve as get-away vehicles – because of key design choices that make legal recourse difficult – they are increasingly used to shuffle ill-gotten gains around.1

For example, data kidnapping – commonly referred to as ransomware – has existed in some form for more than two decades.  But the current plight surrounding ransomware, and the white washing of the role cryptocurrencies have in this plight, have gone hand in hand over the past several years.


The core characteristics of cryptocurrencies – censorship resistance and pseudonymity – are some of the main reasons why ransomware has become increasingly commonplace.  And these cryptocurrencies need liquidity.

Liquidity into-and-out of fiat has fluctuated over time, with some exchanges being debanked and sometimes rebanked, but as an aggregate it has increased overall.  Liquidity is often done through venture-backed gateways and exchanges.

As explored in my previous post, as well as others, many of these gateways and platforms have inadequate and typically non-existent KYC and AML gathering processes.  This post won’t go into the details surrounding some of the investors and promoters of these platforms, but further research could dive deeper into that industry as well as the white washing that goes on to distract investigations.

We see this empirically: attackers do not ask for fiat or credit cards because these would be easily tracked and/or transactions would be halted.  Instead, they ask to be paid in some kind of cryptocurrency because they know the likelihood of getting caught and reprimanded is significantly lower.

This past Friday, WannaCry, a ransomware package, wreaked havoc on more than 200,000 victims across all times of organizations located in over 150 countries.  This included government services including NHS in the UK and the Interior Ministry in Russia.

Source: Twitter

The first-order of victims ranged from small startups that could quickly patch and restart their computers all the way to large hospital systems that were unable to access patient records and had to turn away patients.

This then leads to the second-order of victims: patients and customers of these institutions.  According to the Associated Press, the “cyberattack hit almost 20 percent of UK’s 248 public health trusts.”

While all of the impacted organizations already should have had a formal plan to upgrade and patch these types of vulnerabilities (e.g., create regular back-ups off-site), based on several news stories, many of them did not.

Will they all learn from this lesson?  Probably not.

Either way: none of the victims have a formal means of recourse against the hacker(s) involved in WannaCry because we do not know the identities of the hackers.  Some victims have even paid the ransom of ~$300, denominated in bitcoin, to have their files unlocked.  The hacker is using multiple (4+) bitcoin addresses to receive the ransom and as of this writing, has received more than $50,0002

Last year the FBI estimated that around $1 billion was paid to unlock ransomware and cyber extortion.  Cryptocurrencies, such as Bitcoin, were usually the preferred method of payment.

Two weeks ago, James Comey, former Director of FBI spoke before the Senate Judiciary Committee and noted that:

Some of our criminal investigators face the challenge of identifying online pedophiles who hide their crimes and identities behind layers of anonymizing technologies, or drug traffickers who use virtual currencies to obscure their transactions.

For Bitcoin, there are ways to remain fairly anonymous, like using mixers, however it requires a lot more work to.  But relatively few people are investigating, so the chance of getting caught is likely low.  Newer cryptocurrencies such as Monero and Zcash are designed to be anonymous which makes them harder to track.  Monero has been spotted in the wild alongside the Kirk Ransomware as well as research from Sophos (pdf).3  And Zcash has been used by a botnet to mine more Zcash on devices such as your phone.

And then there is Tor, a software program that enables anonymous communication by passing network traffic through various relays nodes that help conceal the location of the user.  WannaCry used Tor to preserve its “anonymity by proxying their traffic through the Tor network.”

How to bring some light into the darkness?


I reached out to Adam Young who co-created “cryptoviral extortion” (what we call ransomware today).  In his view:4

In terms of the ransomware attack, people/organizations need to do a better job at patching and removing end-of-life systems, clearly. My larger concern is that cryptoviral extortion is the only cryptovirology attack that anyone seems to be paying attention to and there are many, many others.

I also spoke to Danny Yang, CEO of Blockseer who advised everyone to, “update your software, make sure you have latest security patches – that ransomware worked because  people didn’t update their Windows since March when that particular security vulnerability was patched.”5

My recent post looking at Bitfinex and regtech was quite popular.  It was viewed several thousand times and I received a number of calls from reporters looking to investigate some of the points raised.

Some people pointed out that the behavior by Bitfinex and other cryptocurrency exchanges is one of the reasons why a few banks in emerging markets have lost correspondent banking access: that they were de-risked because of what others perceive is a high-risk customer base.

According to research by Accuity, a global financial crime compliance, payments and KYC solutions provider:

Between 2009 and 2016, correspondent banking relationships, where one financial institution provides services on behalf of another in a different location to facilitate cross-border payments, have reduced globally by 25%.

Earlier this year, the People’s Bank of China, SAFE and other government bodies in China, investigated and froze cryptocurrency withdrawals at many, if not all, the cryptocurrency exchanges operating on the mainland.

Why?  Among other reasons: inadequate KYC and AML gathering and sharing processes.

According to Caixin, a notice of administrative punishment may be released in June that details the punishment and fines of these China-based exchange operators.

In addition to freezing and de-banking, what are some other solutions as well?

Companies such as Blockseer and Chainalysis provide tools for law enforcement, regulators, entrepreneurs and compliance teams to trace and track the flow-of-funds on cryptocurrency networks. I have written about them numerous times.

Angel List is tracking 96 startups involved in providing compliance-related software for SMB, hospitals, cloud providers, social media platforms and a handful of other verticals.  It also has job listings for 11 regulatory compliance startups.  There is an additional 2,878 startups listed under the broader category of big data analytics, some of whom who are also working in the regtech space.

While technology can help play a role in identifying participants on these types of networks (blockchains and distributed ledgers), it is also worth exploring the proposed strawman for setting up a Kimberley Process for cryptocurrencies.  Identity systems are critical to all property rights and financial networks.  Creating applications around data lineage, data provenance, KYC management, and standardized digital identities will help provide transparency into all markets.

If you’re interested in learning more about these tools and mechanisms, feel free to reach out or leave a comment below.


  1. In the original white paper, Nakamoto explained ways to route around trusted third parties, such as governments. []
  2. If you’re interested in learning more about how malware researchers identified and stopped it, Malware Tech has a detailed story as well as one from Brian Krebs. []
  3. AlphaBay, the largest darknet market by volume, announced that it was accepting Monero as a form of payment in August 2016. []
  4. Private correspondence, May 14, 2017.  Published with his permission. []
  5. Private conversation reused with permission.  May 13, 2017 []
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How newer regtech could be used to help audit cryptocurrency organizations

[Note: I neither own nor have any trading position on any cryptocurrency.  The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

About two years ago I gave a speech discussing the challenges cryptocurrency-related companies have had in creating reliable internal financial controls.  How over the span of a few short years the cryptocurrency startup landscape (un)intentionally reinvented the same type of intermediaries, custodians, and depository-like structures that the original creator(s) of Bitcoin wanted to route around but… setup without the oversight, assurances, and accountability you would find required in the traditional brick-and-mortar world.

The lack of financial controls and subsequent pitfalls is easily identifiable in the irrational exuberance of the get-rich-quick “initial coin offering” (ICO) world.  I’ll save my ICO post for later, but there is one story that is a bit more concrete and easier to understand and involves a company called Bitfinex.

Bitfinex, as measured in terms liquidity and volume, is considered the top global cryptocurrency exchange.  It is nominally headquartered in Hong Kong, has (had) bank accounts in Taiwan, servers in Europe (Italy?), operations in San Francisco and a staff around 30 altogether.

Source: RobotFinance

Above is a speculative corporate structure created back in September 2016 by an internet user by the name of RobotFinance.  He created it “based on the last annual return of Renrenbee Limited and statements made in the pitch forum.”  Unless you are registered as a user with BnkToTheFuture, you cannot view the pitch deck but an alleged copy of the Bitfinex deck can be found here and a discussion of it here.1  These leaked allegedly legitimate documents also suggest that Bitfinex did an equity swap at a $200 million valuation which was based on their financial growth and targets before they lost roughly $65 million in customer assets due to a hack that will be described below.

This post is not intended to single out Bitfinex as there are any number of other exchanges and wallet providers that could be looked at as well.  Nor is it intended to dive into all of the subsidiaries or even the entire history of the parent company or the cryptocurrency platform.  Rather it serves an illustration as to how new technology and financial controls could help increase visibility and transparency for all stakeholders involved thereby reducing the risks for users and retail investors (among others).

Quick history

Last November I published an internal paper that may be released later this year which explored the proposed Winkleovss COIN ETF.  In it, I highlighted a detailed history of various cryptocurrency exchange platforms and their colorful pasts, some more sordid than others.

Rather than rehash all of those stories, below are a few details specifically related to Bitfinex:

  • In May 2015 Bitfinex was hacked and lost around 1,400 bitcoins (then worth around $350,000).  In August 2016, Bitfinex was hacked again and lost roughly 120,000 bitcoins (at the time worth around $65 million).2  In the first hack, Bitfinex basically ate the losses themselves.3
  • Following the second hack, Bitfinex announced a way to compensate its customers.  Why did it need to compensate the customers?  Because, following the second hack, it socialized the losses, seizing the remaining customer assets and gave nearly all of them a 36% haircut.4 In exchange for giving everyone a haircut, Bitfinex then self-issued two different “tokens” called BFX and then later RRT. These two tokens (or IOUs) effectively enabled Bitfinex to monetize their debt/losses.
  • According to their announcements, over 20 million BFX tokens were issued and exchanged for iFinex shares and then distributed to all affected users.  As a result, Bitfinex basically conducted, from the perspective of a user, a non-voluntary ICO where participation was mandatory, as the BFX token was directly linked to equity of the parent company and users/customers could (later) trade BFX on the Bitfinex exchange.5 In addition, according to a post last summer from their head of communications, “two out of the top ten BFX token-holders are in our management team.”  It is never revealed who these parties are or how they were made whole (or not).  Furthemore, “certain verified, non-U.S. Bitfinex users to convert tokens to equity through a new BFX Trust.”  They set up a dedicated BFX Trust site but did not include the verification requirements for non-accredited BFX holders.  Nor is there public information about who all of the Principals are and the holdings they have.6
  • RRT, the acronym for Recovery Rights Tokens, are opt-in coins issued, “to compensate victims of the security breach and, thereafter, to offer a priority to early BFX token conversions.”  It is unclear how many of these coins were issued or how many were redeemed.
  • To this day, the Bitfinex still has not disclosed exactly how they got hacked and last year even published an open letter to try and negotiate with the hacker; asking to return the funds as part of an ex post facto “bug bounty.”  It is believed that the hacker bypassed the transaction limits set in place by the BitGo multi-sig wallet but that is a story for another post.7
  • Prior to this hack, on June 2, 2016, the Commodity Futures Trading Commission announced that it had fined and settled with Bitfinex for offering regulated products without having properly registered to do so.  This is important because several vocal Bitcoin proponents have distorted the actual historical events.  According to the communications director of Bitfinex last year, “Bitfinex migrated to the BitGo setup before any discussion or anything with the CFTC happened.”8  In other words, this hack was not caused by the CFTC.
  • On April 3, 2017 Bitfinex announced that it was completing the redemption of all BFX tokens and they would all be subsequently destroyed.

How did Bitfinex manage to pay off tens of millions of dollars of self-issued debt in a span of less than 8 months?

Three explanations given by Bitfinex include:

  • Because Bitfinex is a popular trading venue and lists a number of other cryptocurrencies including Ether (both ETH and ETC), it generated enough cash-flow in the form of transaction fees to carve off some of the losses.9
  • Outside investors, through BnkToTheFuture, exchanged fresh capital in exchange for BFX tokens and equity.
  • Bitfinex had a reduction in their contingent liability reserves.10

Another more recent speculative theory explores the connection between BFX redemptions and a cryptocurrency called “Tether.”

Source: Bitfinexed

What is Tether?

Its exact relationship status is complicated. Depending on who you talk to that is affiliated or was affiliated with Bitfinex, Tether Limited is a partially, or fully, or not-at-all owned subsidiary of Bitfinex.  Tether was announced in July 2014 and was originally called “Realcoin.”11

And one of the continual challenges in trying to follow this saga is that Bitfinex representatives, co-founders, and investors often post key comments in disparate social media channels across reddit, Twitter, Youtube, WeChat, TeamSpeak, Telegram, and others.  For instance, there are several different reddit threads discussing the Tether terms of service involving a co-founder and another one with the general counsel, but this material is not centralized in a way for users to easily follow it all.

Source: FinCEN MSB Registrant Search

Tether Limited is also a regulated money service business and has applied to operate in nearly every US state and territory (see above).

What are tethers?

According to the official terms of service:

Based on the information above, tethers are not money or currency and may not necessarily be redeemable for money.

In practice a “tether” is intended to be a type of “stablecoin.”

What is a stablecoin you ask?

Because cryptocurrencies lack any native ability to rebalance or readjust themselves relative to a pricing index, their continual volatility (as measured by purchasing power) causes headaches and risks to users, including those moving money across borders.  That is to say, in the time span it may take to satisfactorily confirm 1 bitcoin being transferred from your wallet to a merchant overseas, the market price may have moved a percent or two or three.12

What if there was some way to lock-in a set price and not be exposed to these constant swings in price?  Some merchant processors like BitPay and cryptocurrency OTC trading desks do quote and lock-in prices over a period of minutes, but these are not usually targeting the cross-border payment and remittance market.13

Another proposed solution, albeit one that involves similar counterparty risk, is a stablecoin which is a pegged value guaranteed or at least marketed as being pegged on par to a specific exchange rate.  The risk in this case is that the exchange operator might not fulfill his or her end of the deal (e.g., abscond with the funds).

There have been several theoretical approaches to creating a native stablecoin and a few efforts to actually implement them in the wild. Last year JP Koning chronicled the fate of one of them called NuBits.  On reflection: at some point they all fail, their peg ends up failing for one reason or another.14

And tether is no exception.

Tether is not so tethered

Originally 1 unit of tether was supposed to be equivalent to $1 USD.  At the time of this writing it has fallen to $0.93.


While Bitfinex has made a few public statements about “pausing” wire transfers, there has been no major public statement explaining the precise nature of the drop in tether price.  So a small army of internet users have pieced together a probable theory and it comes back to how Bitfinex operates.

Earlier this month, a lawsuit revealed that Bitfinex had sued WellsFargo – who had refused to process their wires and returned the USD-denominated funds – a bank that is integral to its correspondent banking relationships.  About a week later Bitfinex withdrew its lawsuit but not before people poured through the documents.

In summary we learned that Tether (which is named in the court documents) is a mechanism for enabling cross-border money flows; although we cannot say what the exact purpose was for these money flows is (e.g., pay for college tuition? buying a home? paying for a large order of buttery popcorn?).

Over a span of a few months, tens of millions of USD had been wired through WellsFargo into and out of four different banks in Taiwan which Bitfinex, Tether Limited, and other affiliated subsidiaries had commercial bank accounts with.  At some point this past March or perhaps earlier, someone on the compliance side of WellsFargo noticed this large flow of USD and for one reason or other (e.g., fell within the guidelines of a “suspicious activity report“?), placed a hold on the funds.

In early April Bitfinex’s parent company, as noted above, filed a lawsuit for WellsFargo to release these funds.  But about a week later retracted its suit.

According to a recent post from Mark Karpeles, the CEO who helmed Mt. Gox prior to its infamous bankruptcy, these actions set in motion a type of Streisand Effect: the lawsuit became newsworthy on mainstream media sites and consequently other banks — and compliance personnel at other banks — learned about the cryptocurrency exchange called Bitfinex and might (have) become wary of doing business with them.

We can only speculate as to all of what happened next, but we do know for certain that the bank accounts Bitfinex and Tether used in Taiwan were either fully terminated and/or unable to withdraw USD from late March until at least the time of this writing.

This is not the first time Bitfinex has been “debanked” before.  Phil Potter, the CFO of Bitfinex, recently gave an interview and explained that whenever they have lost accounts in the past, they would do a number of things to get re-banked.

In his words: “We’ve had banking hiccups in the past, we’ve just always been able to route around it or deal with it, open up new accounts, or what have you… shift to a new corporate entity, lots of cat and mouse tricks that everyone in Bitcoin industry has to avail themselves of.”

But this story isn’t about debanking cryptocurrency companies, a topic which could include the likes of Coinbase (which has been debanked multiple times as well).

Because there is currently no USD exit for Bitfinex users, a price discrepancy has noticeably grown between it and its peers.  The spread between exchanges is typically a good indication of how difficult it is to move into and out of fiat in a country as there are boutique firms that spend all day and night trying to arbitrage that difference.

In the case of Bitfinex, the BTC/USD pair now trades at about $50 to $75 higher than other exchanges such as Bitstamp.  This ties back into the challenges Mt. Gox users had in early 2014, as the ability to withdraw into fiat disappeared, the market price of bitcoins on Mt. Gox traded at a dramatically different level than other cryptocurrency exchanges.

That is not to say that what is happening at Bitfinex is the same thing that happened at Mt. Gox.15  However, there have not been many publicly released audits of most major exchanges in the wake of Mt. Gox’s bankruptcy three years ago.16  Noteably, BTC-e publicly stated it would begin publicly publishing accounting statements certified by external auditors.  It and its peers have not.

More questions than answers

About nine months has passed since the largest (as measured by USD) single successful attack took place on a cryptocurrency platform.17 Yet there are still many lingering questions.

For instance, on August 17, 2016, Bitfinex announced that they had hired Ledger Labs who, “is undertaking an analysis of our systems to determine exactly how the security breach occurred and to make our system’s design better going forward.”

According to one post, Michael Perklin was the Head of Security and Investigative Services at Ledger Labs and part of the team leading this investigation.  However in January 2017 a press release announced that Perklin was joining ShapeShift as the Chief Information Security Officer; his profile no longer exists at Ledger Labs. 18

Thus the question, what happened to the promise of a public audit?

Other questions that remain: as noted above, two of the ten biggest initial debt token (BFX) holders were employees.

Why did Bitfinex redeem the BFX tokens after they knew USD withdrawals were shut down?19  How many insiders such as investors and employees owned that last batch of redemptions?  What was the benefit of redeeming that last batch when they knew they were losing international wire capabilities?

It appears after the hack that Bitfinex shifted assets from the Bitinex side of the books to the customer side. Who owned the bulk of both tokens, and what protection are these virtual assets given by not being on the company books?  Or are they still on the books?

In terms of them redeeming after the withdrawals were ended, the original lawsuit documents lay out that as of March 31st, Bitfinex were actively emailing WellsFargo about the shutdown. The final BFX redemption was done a couple of days later and the lawsuit was filed shortly afterwards. It was roughly week later that Bitfinex informed the public about this international wire issue.  And Tether did not formally announce the issues until a few days ago.

Perhaps it is just miscommunication and only a matter of time before these questions are answered.

Going forward

Nearly two months ago, the SEC rejected a rule change for the COIN ETF to be listed on the BATS exchange.  Last week, the SEC said it would review that ruling.

Among other comments, the original 38 page ruling (pdf) gave a number of reasons why the Gemini-listed Winklevoss COIN ETF was being rejected. In the Commission’s words:

First, the exchange must have surveillance-sharing agreements with significant markets for trading the underlying commodity or derivatives on that commodity. And second, those markets must be regulated.

Later the Commission also writes that:

The Commission, however, does not believe that the record supports a finding that the Gemini Exchange is a “regulated market” comparable to a national securities exchange or to the futures exchanges that are associated with the underlying assets of the commodity – trust ETPs approved to date.

While the Gemini exchange is regulated in New York through a Trust charter, the vast majority of cryptocurrency exchanges and trading venues whose funds flow into and out of Gemini, are not.20

It is unclear what will happen to Tether holders, if they will ever be made whole.  Or what will happen to Bitfinex and future bank accounts.  Or if the COIN ETF and other similar cryptocurrency-denominated ETF’s will be green-lit by securities regulators.  Maybe these are all bumps in the road.

What we are a little more certain about:

(1) The Bitfinex hackers are still at large and no public post-mortem has been done to explain how it happened and what will be done to prevent future attacks.

(2) The unilateral self-issuance of the BFX “cryptoequity” was not done in a fully transparent manner as some customers had bigger haircuts than others nor is it clear if the extinguishing of these BFX coins was done through the use of tethers.

(3) That the tether “stablecoin” is not inherently stable and depends on fiat liquidity via the international correspondent banking network which raises the question of how to stabilize tether in the event that Tether Limited loses its bank accounts again.21

(4) That marketplaces such as Bitfinex — despite a general lack of transparency (where is the “About” page with executive bios?) — are still used as part of the weighting mechanisms in ETFs, including at one stage the Winkdex (which has since been deprecated) as well as the current Tradeblock XBX index used in a couple other proposed ETFs.


As mentioned at the beginning of the post, the current trend over the past four years is that as Bitcoin intermediaries continue to operate as intermediaries and trusted third parties they increase their chances of regulatory scrutiny and oversight.

This empirical fact versus the original theoretical cypherpunk vision is arguably a type of cognitive dissonance.  As Section 1 of the Nakamoto whitepaper explained:

Commerce on the Internet has come to rely almost exclusively on financial institutions serving as trusted third parties to process electronic payments. While the system works well enough for most transactions, it still suffers from the inherent weaknesses of the trust based model. Completely non-reversible transactions are not really possible, since financial institutions cannot avoid mediating disputes. The cost of mediation increases transaction costs, limiting the minimum practical transaction size and cutting off the possibility for small casual transactions, and there is a broader cost in the loss of ability to make non-reversible payments for non-reversible services.

The Bitfinex hack that occurred in August 2016 created measurable amounts of new transactions costs that ended up being mediated through a wide array of social media channels; non-reversibility does not appear to have helped reduce these costs.  For all of the “backed-by-maths” and “epistemological” talk about routing around trusted third parties, Bitfinex and its peers, still play a key role in providing continuous fiat <–> cryptocurrency liquidity to the marketplace.  And as illustrated with the lawsuit above, by in large, these exchange platforms heavily depend on banking access moreso now than at any other time before.

Last summer I proposed a Kimberley Process for Cryptocurrencies: in which market participants met with various regulatory stakeholders to iron out how to stop predators, remove encumbrances, and create best-practices for financial controls in this nascent space.

As more cryptocurrency platforms attempt to comply with a variety of regulations including the surveillance collection and sharing requirements (e.g., KYC and AML), this will likely increase the demand for the tools found in the growing field of “regtech.”

For example, if Alice can cryptographically prove the chain-of-custody from her customer to her customers customer, then she may be able to comply with the banks surveillance requirements and maintain her bank accounts — and international wiring access — as she grows her remittance platform.

There is a set of technology under development and in early pilots that enables  authentication, provenance tracking, and document management and much of it involves digital signatures, standardized/mutualized KYC processes, and permissioned distributed ledgers.  Documentation management, in this case, goes beyond just hashing and timestamping documents to include automatically updating legal agreements and contracts over their entire lifecycle.

Some of it also involves sophisticated data analytic tools created by startups such as Blockseer and Chainalysis.  Universities such as UCL are automating regulatory processes.  And on the enterprise side, there are companies that have built a shared KYC registry and other identity-related tools for highly regulated financial institutions to comply with a battery of reporting requirements.22

Whether these will be adopted by the cryptocurrency community is another matter, but these tools will soon exist in full production mode and could help provide better visibility, auditability, and transparency for investors, users, entrepreneurs, law enforcement, compliance teams, and regulators around the world.

If you’re interested in learning more about these mechanisms, feel free to reach out or leave a comment below.


  1. During an interview on April 3, 2017, Phil Potter mentioned that Bitfinex has 25 shareholders and BnkToTheFuture SPV.  The same interview someone says that there are 450 shareholders of their equity but it is unclear if that is through the BFX token. []
  2. Approximately 1,061 of these coins were moved in March 2017. []
  3. Bitfinex, like all other cryptocurrency exchanges, has experienced significant price crashes in 2014, 2015, and again in 2016 — often as the consequence of a hack. []
  4. There were exceptions. Some users reported smaller haircuts as they were customers of SynapsePay.  Another user claims to have retained a lawyer and he did not have any haircut.  In an interview on April 3, 2017, Phil Potter mentions that they had received some “demand” letters from customers but Bitfinex was able to “quell” those.  See also: You’ve Been ButtFinessed from BitMEX []
  5. BFX was not initially tradeable. []
  6. One staff member is publicly listed, Alistair Milne, but no information is given as to how much BFX, RRT, and company equity he or other staff of BFX Trust may own. []
  7. You’ve Been ButtFinessed from BitMEX []
  8. Group correspondence, August 3, 2016 []
  9. In an interview on April 3, 2017 Phil Potter mentions that the past month they generated $3.5 million (net) from trading volumes and that there are 175 million shares outstanding. []
  10. In an interview on April 3, 2017, Phil Potter mentions that they used the “vast majority” of these reserves. []
  11. The CTO of Realcoin, Craig Sellers, is also the current CTO of Bitfinex.  Sellers is currently a team member of the Omni Foundation.  The general counsel of Tether and Bitfinex are the same individual, Stuart Hoegner.  Brock Pierce is the co-founder of Realcoin. The underlying technology for Realcoin/Tether is Mastercoin, a platform managed by the Mastercoin Foundation (now called the Omni Foundation).  Pierce was one of the founding members of the Mastercoin Foundation before resigning in July 2014. []
  12. Depending on the transaction fee sent to a mining pool, the suggested “safe” confirmation intervals are 3-6 blocks which on average takes 30-60 minutes to build on and propagate across the network. []
  13. There are some remittance companies that utilize Bitcoin as a payment rail; they often try to lock-in a specific value amount during a time-boxed time period but it varies depending on local conditions and business models. []
  14. BitUSD is the sole survivor right now, although it has relatively very little volume. []
  15. The missing Mt. Gox bitcoins from WizSec []
  16. During an April 3, 2017 interview Phil Potter mentions that in order to get an auditor to look at their books, it would be easier to do if they first got rid of the BFX token. []
  17. The DAO was a DAO, not an exchange. []
  18. There are several other interconnected relationships: according to a prior funding announcement, Bitfinex is an investor in ShapeShift.  Similarly, at least one principal in Bitcoin Capital, which has invested in ShapeShift, is also an executive at BnkToTheFuture, which led the recapitalization of Bitfinex following its August 2016 hack. []
  19. During an interview on April 12, 2017, Phil Potter mentioned that when trying to acquire a new banking partnership, the BFX debt tokens were a problem for them, so Bitfinex redeemed them. []
  20. A few others have obtained a BitLicense, but on the whole, most cryptocurrency exchange platforms do not attempt to comply with the strict requirements found in either the BitLicense or Trust charter in New York, let alone at a national level. []
  21. Based on the current terms of of service, according to the Tether Limited general counsel, tethers may not be readable for a variety of reasons. []
  22. This is not to say these new tools are a panacea or silver bullet for detecting all types of money laundering or preventing fraud or stopping identity fraud.  A standardized KYC framework and digital signature-based toolset can help mitigate some of these issues. []
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Intranets and the Internet

It is early into 2017 and at fintech events we can still hear a variety of analogies used to describe what blockchains and distributed ledger technology (DLT) are and are not.

One of the more helpful ones is from Peter Shiau (formerly of Blockstack.io) who used an automobile analogy involving the Model T to describe magic internet chains:1

The Ford Motor Company is well known for its production engineering innovation that gave us the Model T. To this day, the Ford Model T is one of the best selling automobiles of all-time thanks to the sheer number produced and affordability for American middle class families.  And while it was remarkable that Ford was able to sell so many cars, it is well understood Ford’s true innovation was not the Model T but in fact the modern assembly line.

It was this breakthrough that enabled Ford to build a new car every 93 minutes, far more quickly than any of its competitors. Not unlike the Model T, cryptocurrencies like Bitcaoin, are every bit the product of a similar innovative process breakthrough that today we call a “blockchain.”

Carrying the analogy a little further, what is even more powerful about this modern equivalent of the assembly line is that it is not just useful for building cars but also vans and trucks and boats and planes. In just the same way, a blockchain is not just useful for creating a cryptocurrency, but can be applied to a many different processes that multiple parties might rely on to reach agreement on the truth about something.

Less helpful, but all the same plentiful, are the many red herrings and false equivalences that conferences attendees are subjected to.

Arguably, the least accurate analogy is that public blockchains can be understood as being “like the internet” while private blockchains “are like intranets”.

Why is this one so wrong and worthy of comment?

Because it is exactly backwards.

For example, if you want to use a cryptocurrency like Bitcoin, you have to use bitcoin; and if you want to use Ethereum, you have to use ether.  They are not interoperable.  You have to use their proprietary token in order play in their walled garden.

As described in detail below, the internet is actually a bunch of private networks of internet service providers (ISPs) that have legal agreements with the end users, cooperate through “peering” agreements with other ISPs, and communicate via a common, standardized routing protocols such as BGP which publishes autonomous system numbers (ASNs).

In this respect, what is commonly called “the Internet” is closer to interoperable private, distributed ledger networks sharing a common or interoperable communication technology than anarchic, public cryptocurrency blockchain networks, which behave more like independent isolated networks.

Or in short: by design, cryptocurrencies are intranet islands whereas permissioned distributed ledgers — with interoperability hooks (“peering” agreements) — are more like the internet.2


Let’s do a short hands-on activity to see why the original analogy used at fintech conferences is a false equivalence with implications for how we need to frame the conversation and manage expectations in order to integrate DLT in to our reference and business architecture.

If you are using a Windows-based PC, open up a Command window.  If you’re using a Mac or Android device, go to a store and buy a Windows-based PC.

Once you have your Command window open, type in a very simple command:

tracert: www.google.com

Wait a few seconds and count the hops as your signal traces the route through various network switches and servers until you finally land on your destination.  From my abode in the SF area, it took 10 hops to land at Google and 7 hops to land at Microsoft.

If you did this exercise in most developed countries, then the switches and servers your signal zigged and zagged through were largely comprised of privately owned and operated networks called ISPs.  That is to say, what is generally described as “the internet” is just a bunch of privately run networks connected to one another via several types of agreements such as: transit agreements, peering agreements, and interconnect agreements.

By far the most widely used agreement is still done via the proverbial “handshake.”  In fact, according to a 2012 OECD report, 99.5% of internet traffic agreements are done via handshakes.  There is also depeering, but more on that later.

What do all these agreements look like in practice?

According to the 2016 Survey of Internet Carrier Interconnection Agreements (pdf):

The Internet, or network of networks, consists of 7,557 Internet Service Provider (ISP) or carrier networks, which are interconnected in a sparse mesh. Each of the interconnecting links takes one of two forms: transit or peering. Transit agreements are commercial contracts in which, typically, a customer pays a service provider for access to the Internet; these agreements are most prevalent at the edges of the Internet, where the topology consists primarily of singly connected “leaf” networks that are principally concerned with the delivery of their own traffic. Transit agreements have been widely studied and are not the subject of this report. Peering agreements – the value-creation engine of the Internet – are the carrier interconnection agreements that allow carriers to exchange traffic bound for one another’s customers; they are most common in the core of the Internet, where the topology consists of densely interconnected networks that are principally concerned with the carriage of traffic on behalf of the networks which are their customers.

Colloquially it is a lot easier to say “I want to use the Internet” instead of saying “I want to connect with 7,557 ISPs interconnected in a sparse mesh.”

Back to topology, each ISP is able to pass along traffic that originated from other networks, even if these external networks and the traffic therein originate from foreign countries, because the physical systems can speak to one another via standardized transport protocols like TCP and UDP and route via BGP.3 4

Thus there is no such thing as a physical “internet rail,” only an amalgam of privately and publicly owned networks stitched together.

And each year there is inevitably tension between one more ISP and consequently depeering takes place.  A research paper published in 2014 identified 26 such depeering examples and noted that while depeering exists:

Agreements are very quite affair and are not documented for, they are mostly handshake agreements where parties mutually agree  without  any  on  record  documentation.  This  argument is supported by the fact that 141,512 Internet Interconnection Agreements out of 142,210 Internet Agreements examined till March 2011 were Handshake Agreements.

This is the main reason you do not hear of disputes and disagreements between ISPs, this also dovetails into the “net neutrality” topic which is beyond the scope of this post.


Just as the internet is an imperfect analogy for blockchains and DLT in general, so is its offspring the “intranet” is a poor analogy for a permissioned blockchains.  As noted above, the internet is a cluster of several thousand ISPs that typically build business models off of a variety of service plans in both the consumer and corporate environments.

Some of these server plans target corporate environments and also includes building and maintaining “private” intranets.

What is an intranet?

An intranet is a private network accessible only to an organization’s staff. Generally a wide range of information and services from the organization’s internal IT systems are available that would not be available to the public from the Internet. (Source)

And while more and more companies migrate some portion of their operations and work flows onto public and private “clouds,” intranets are expected to be maintained given their continued utility.  From an infrastructure standpoint, notwithstanding that an intranet could be maintained one or more more servers through Software Defined Networks (SDNs), it is still a subset of a mash up of ISPs and mesh networks.

What does this have to do with magic internet chains?

A private blockchain or private distributed ledger, is a nebulous term which typically means that the validation process for transactions is maintained by known, identified participants, not pseudonymous participants.  Depending on the architecture, it can also achieve the level of privacy that is associated with an intranet while staying clear of the hazards associated with preserving true pseudonymity.

Why is the “intranet” analogy so misleading and harmful?

For multiple reasons.

For starters, it is not really valid to make a sweeping generalization of all identity-based blockchains and distributed ledgers, as each is architected around specific use-cases and requirements.  For instance, some vendors insist on installing on-premise nodes behind the firewall of an enterprise.  Some vendors setup and run a centralized blockchain, from one or two nodes, for an enterprise. Some others tap into existing operational practices such as utilizing VPN connections.  And others spin up nodes on public clouds in data centers which are then operated by the enterprise.

There are likely more configurations, but as noted above: from a topological perspective in some cases these private blockchains and distributed ledgers operate within an intranet, or on an ISP, or even as an extranet.

Fundamentally the biggest difference between using an ISP (“the internet”) and using an intranet is about accessibility, who has access rights.  And this is where identity comes into play: most ISPs require the account holder to provide identification materials for what is effectively KYC compliance.

Thus while you may be visit a coffee shop like Starbucks who provides “free” access, Starbucks itself is an identified account holder with an ISP and the ISP could remove Starbucks access for violating its terms of service.  Similarly, most coffee shops, airports, schools, etc. require users to accept a terms of service acknowledging that their access can be revoked for violating it.

Source: FireFox 51.0.1

In short, both the internet and intranet are in effect part of identity and permission-based networks.  There is no such thing as an identity-less internet, only tools to mask the users identity (e.g., Tor, Peerblock, Whisper).  In the same way that, “private” intranets are a fallacy.

Anarchic chains, which were designed to operate cryptocurrencies like Bitcoin, attempt to create an identity-less network on top of an identifiable network, hence the reason people involved in illicit activities can sometimes be caught.


Interestingly, where the internet analogy does hold up is in how public, anarchic blockchains are no less challenged by the effort and complexity of truly masking identity. I mentioned this in a footnote in the previous post, but it deserves being highlighted once more. Anarchic blockchains inspired by cryptocurrencies such as Bitcoin, used blocks because Satoshi wanted identity-free consensus (e.g., pseudonymity).  That implies miners can come and go at will, without any kind of registration, which eliminated the choice of using any existing consensus algorithm.

As a result, Satoshi’s solution was proof-of-work (PoW).  However, PoW is susceptible to collisions (e.g., orphan blocks).  When a collision occurs you have to wait longer to obtain the same level of work done on a transaction. Thus you want to minimize them, which resulted in finding a PoW on average every ten minutes.  This means that in a network with one minute propagation delays, not unlikely in a very large network (BGP sees such propagation times) then you waste ~10% of total work done, which was considered an acceptable loss rate in 2008 when Satoshi was designing and tweaking the parameters of the system.

Distributed ledgers such as Corda, use a different design and exist precisely as an identified network, where members cannot just come and go at will, and do have to register. With Corda, the team also assumes relatively low propagation times between members of a notary cluster.  One of the key differences between mere PoW (i.e. hashcash) and a blockchain is that in the latter, each block references the prior – thus PoWs aggregate.  It can be tough to do that unless all transactions are visible to everyone and there is a single agreed upon blockchain but if you do not, you will not get enough PoW to yield any meaningful security

When fintech panels talk about the notion of “open” or “closed” networks, this is really a red herring because what is being ignored is how identity and permission work and are maintained on different types of networks.

From the standpoint of miner validation, in practice cryptocurrencies like Bitcoin are effectively permission-based: the only entity that validates a transaction is effectively 1 in 20 semi-static pools each day.  And the miners/hashers within those pools almost never individually generate the appropriate/winning hash towards finding a block.  Each miner generates trillions of invalid hashes each week and are rewarded with shares of a reward as the reward comes in.

And if you want to change something or possibly insert a transaction, you need hashrate to do so.  Not just anyone running a validating node can effect change.

More to the point, nearly all of these pools and many of the largest miners have self-doxxed themselves.  They have linked their real world identities to a pseudonymous network whose goals were to mask identities via a purposefully expensive PoW process.  As a result, their energy and telecommunication access can be revoked by ISPs, energy companies, and governments.  Therefore calling anarchic or public blockchains “open” is more of a marketing gimmick than anything else at this stage.


AOL and CompuServe were early, successful ISPs; not intranets.5  Conflating these terms makes it confusing for users to understand the core technology and identify the best fit use-cases. 6

Alongside the evolution of both the “cloud” and ISP markets, it will be very interesting to watch the evolution of “sovereign” networks and how they seek to address the issue of identity.


Because of national and supranational laws like General Data Protection Regulation (GDPR) that impacts all network users irrespective of origin.

For instance, Marley Gray (Principal Program Manager Blockchain at Microsoft) recently explained in an interview (above) how in order to comply with various data regulations (data custody and sovereignty), Microsoft acquired fiber links that do not interact with the “public” internet.  That is to say, by moving data through physically segregated “dark” networks, Microsoft can comply with requirements of its regulated customers.

And that is what is missing from most fintech panels on this topic: at the end of the day who is the customer and end-user.

If it is cypherpunks and anarchists, then anarchic chains are built around their need for pseudonymous interactions.  If it is regulated enterprises, then identity-based systems are built around the need for SLAs and so forth.  The two worlds will continue to co-exist, but each network has different utility and comparative advantage.

Acknowledgements: I would like to thank Mike Hearn, Stephen Lane-Smith, Antony Lewis, Marcus Lim, Grant McDaniel, Emily Rutland, Kevin Rutter, and Peter Shiau for their constructive feedback. This was originally sent to R3 members on March 31, 2017.


  1. His analogy is reused with permission. []
  2. From a network perspective, some of the integration and interop challenges facing DLT platforms could be similar to the harried IPv4 vs IPv6 coexistence over the past decade.  Who runs the validating nodes, the bridges — the links between the chains and ledgers — still has to be sorted out.  One reviewer noted that: If you equate IPv4 (TCP/UDP/ICMP) to DLTv4 where BGPv4 enables IPv4 networks to interact, we need an equivalent for BPGv4, say DLTGPv4 (DLT Gateway Protocol) for DLTv4 fabrics (ISPv4s) to interact and the same thing for IPv6 and DLTv6 where DLTv6 is a different DLT technology than DLTv4.  So the basic challenge here is solving integration of like DLT networks. []
  3. Venture capitalists such as Marc Andreessen and Fred Wilson have stated at times that they would have supported or invested in something akin to TCPIPcoins or BGPcoins.  That is to say, in retrospect the missing element from the “internet stack” is a cryptocurrency.  This is arguably flawed on many levels and if attempted, would likely have stagnated the growth and adoption of the internet, see page 18-19. []
  4. One reviewer noted that: Because of the IPv4 address restrictions (address space has been allocated – relying on auctions etc for organizations to acquire IPv4 addresses), some sites now only have an IPv6 address.  Most devices today are dual stack (support IPv4 and IPv6), but many ISPs and older devices still only support IPv4 creating issues for individuals to access IPv6 resulting in the development of various approaches for IPv4 to IPv6 (e.g. GW46 – my generic label).  I think, the question with DLTGW46 is whether to go dual stack or facilitate transformation between v4 and v6. []
  5. A reviewer who previously worked at AOL in the mid ’90s noted that: “In its early days, AOL was effectively a walled garden.  For example, it had its own proprietary markup language called RAINMAN for displaying content. And access to the internet was carefully managed at first because AOL wanted its members to stay inside where content was curated and cultural norms relatively safer — and also desirable for obvious business reasons.” []
  6. One reviewer commented: “In my opinion, the “internet” cannot be created by a single party. It is an emergent entity that is the product of multiple ISPs that agree to peer – thus the World Wide Web. DLT-based and blockchain-based services first need to develop into their own robust ecosystems to serve their own members. Eventually, these ecosystems will want to connect because the value of assets and processes in multiple ecosystems will increase when combined.” []
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A brief history of R3 – the Distributed Ledger Group

What’s in a name?

I was at an event last week and someone pulled me aside asked: why do you guys at R3 typically stress the phrase “distributed ledger” instead of “blockchain”?

The short answer is that they are not the same thing.

In simplest terms: a blockchain involves stringing together a chain of containers called blocks, which bundle transactions together like batch processing, whereas a distributed ledger, like Corda, does not and instead validates each transaction (or agreement) individually.1

The longer answer involves telling the backstory of what the R3 consortium is in order to highlight the emphasis behind the term “distributed ledger.”

Inspired by IMF report, page 8


R3 (formerly R3 CEV) started out as a family office in 2014.2 The “3” stood for the number of co-founders: David Rutter (CEO), Todd McDonald (COO), and Jesse Edwards (CFO). The “R” is the first initial of the CEO’s last name.  Very creative!

During the first year of its existence, R3 primarily looked at early stage startups in the fintech space.  The “CEV” was an acronym: “crypto” and “consulting,” “exchanges,” and “ventures.”

Throughout 2014, the family office kept hearing about how cryptocurrency companies were going to obliterate financial institutions and enterprises.  So to better understand the ecosystem and drill into the enthusiasm around cryptocurrencies, R3 organized and held a series of round tables.

The first was held on September 23, 2014 in NYC and included talks from representatives of: DRW, Align Commerce, Perkins Coie, Boost VC, and Fintech Collective.  Also in attendance were representatives from eight different banks.

The second round table was held on December 11, 2014 in Palo Alto and included talks from representatives of: Stanford, Andreessen Horowitz, Xapo, BitGo, Chain, Ripple, Mirror, and myself.  Also in attendance were representatives from 11 different banks.

By the close of 2014, several people (including myself) had joined R3 as advisors and the family office had invested in several fintech startups including Align Commerce.

During the first quarter of 2015, David and his co-founders launched two new initiatives.  The first was LiquidityEdge, a broker-dealer based in NYC that built a new electronic trading platform for US Treasurys.3  It is doing well and is wholly unrelated to R3’s current DLT efforts.

The second initiative was the incorporation of the Distributed Ledger Group (DLG) in Delaware in February 2015.  By February, the family office had also stopped actively investing in companies in order to focus on both LiquidityEdge and DLG.

In April 2015 I published Consensus-as-a-Service (CaaS) which, at the time, was the first paper articulating the differences between what became known as “permissioned” and “permissionless” blockchains and distributed ledgers.  This paper was then circulated to various banks that the small R3 team regularly interacted with.

The following month, on May 13, 2015, a third and final round table was held in NYC and included talks from representatives of Hyperledger (the company), Blockstack, Align Commerce and the Bank of England.  Also in attendance were representatives from 15 banks as well as a market infrastructure operator and a fintech VC firm.  In addition to the CaaS paper, the specific use-case that was discussed involved FX settlement.4

The transition from a working group to a commercial entity was formalized in August and the Distributed Ledger Group officially launched on September 1, 2015 although the first press release was not until September 15.  In fact, you can still find announcements in which the DLG name was used in place of R3.

By the end of November, phase one of the DLG consortium – now known as the R3 consortium – had come to a conclusion with the admission of 42 members.  Because of how the organization was originally structured, no further admissions were made until the following spring (SBI was the first new member in Phase 2).

So what does this all have to do with “distributed ledgers” versus “blockchains”?

Well, for starters, we could have easily (re)named or (re)branded ourselves the “Blockchain Group” or “Blockchain Banking Group” as there are any number of ways to plug that seemingly undefinable noun into articles of incorporation.  In fact, DistributedLedgerGroup.com still exists and points to R3members.com.5 So why was R3 chosen?  Because it is a bit of a mouthful to say DistributedLedgerGroup!

Corda’s genesis

Upon launch, the architecture workstream lead by our team in London (which by headcount is now our largest office), formally recognized that the current hype that was trending around “blockchains” had distinct limitations.  Blockchains as a whole were designed around a specific use-case – originally enabling censorship-resistant cryptocurrencies. This particular use-case is not something that regulated financial institutions, such as our members, had a need for.

While I could spend pages retracing all of the thought processes and discussions surrounding the genesis of what became Corda, Richard Brown’s view (as early as September 2015) was that there were certain elements of blockchains that could be repurposed in other environments, and that simply forking or cloning an existing blockchain – designed around the needs of cryptocurrencies – was a non-starter.  At the end of that same month, I briefly wrote about this view in a post laying out the Global Fabric for Finance (G3F), an acronym that unfortunately never took off. In the post I specifically stated that, “[i]t also bears mentioning that the root layer may or may not even be a chain of hashed blocks.”

In October 2015, both James Carlyle and Mike Hearn formally joined the development team as Chief Engineer and lead platform engineer respectively.  During the fall and winter, in collaboration with our members, the architecture team was consumed in the arduous process of funneling and filtering the functional and non-functional requirements that regulated financial institutions had in relation to back office, post-trade processes.

By the end of Q1 2016, the architecture team gestated a brand new system called Corda.  On April 5, 2016, Richard published the first public explanation of what Corda was, what the design goals were and specifically pointed out that Corda was not a blockchain or a cryptocurrency.  Instead, Corda was a distributed ledger.

Prior to that date, I had personally spent dozens of hours clarifying what the difference between a blockchain and a distributed ledger was to reporters and at events, though that is a different story.  Unfortunately even after all these explanations, and even after Richard’s post, the Corda platform was still inappropriately lumped into the “blockchain” universe.

Following the open sourcing of Corda in November 2016, we formally cut the “CEV” initials entirely from the company name and are now known simply as R3.  Next year we plan to make things even shorter by removing either the R or 3, so watch out domain squatters!


As of February 2017, the R3 consortium is formally split into two groups that share knowledge and resources: one group is focused on building out the Corda platform and the other, the Lab and Research Center, is focused on providing a suite of services to our consortium members.  I work on the services side, and as described in a previous post, my small team spends part of its time filtering vendors and projects for the Lab team which manages several dozen projects at any given time for our consortium members.

The Lab team has completed more than 20 projects in addition to 40 or so ongoing projects.  Altogether these involved (and in some cases still involve) working with a diverse set of platforms including Ethereum, Ripple, Fabric, Axoni, Symbiont and several others including Corda.  Since we are member driven and our members are interested in working and collaborating on a variety of different use-cases, it is likely that the services side will continue to experiment with a range of different technologies in the future.

Thus, while it is accurate to call R3 a technology company focused on building a distributed ledger platform and collaborating with enterprises to solve problems with technology, it is not accurate to pigeonhole it as a “blockchain company.”  Though that probably won’t stop the conflation from continuing to take place.

If you are interested in understanding the nuances between what a blockchain, a database, and a distributed ledger are, I highly recommend reading the multitude of posts penned by my colleagues Antony Lewis and Richard Brown.

  1. Blockchains inspired by cryptocurrencies such as Bitcoin used blocks because Satoshi wanted identity-free consensus (e.g., pseudonymity).  That implies miners can come and go at will, without any kind of registration, which eliminated the choice of using any existing consensus algorithm.

    As a result, Satoshi’s solution was proof-of-work (PoW).  However, PoW is susceptible to collisions (e.g., orphan blocks).  When a collision occurs you have to wait longer to obtain the same level of work done on a transaction. Thus you want to minimize them, which resulted in finding a PoW on average every ten minutes.  This means that in a network with one minute propagation delays, not unlikely in a very large network (BGP sees such propagation times) then you waste ~10% of total work done, which was considered an acceptable loss rate in 2008 when Satoshi was designing and tweaking the parameters of the system.

    Distributed ledgers such as Corda, use a different design because it is an identified network, where members cannot just come and go at will, and do have to register. With Corda, the team also assumes relatively low propagation times between members of a notary cluster.  One of the key differences between mere PoW (i.e. hashcash) and a blockchain is that in the latter, each block references the prior – thus PoWs aggregate.  It can be tough to do that unless all transactions are visible to everyone and there is a single agreed upon blockchain but if you do not, you will not get enough PoW to yield any meaningful security. []

  2. The R3CEV.com domain was created on August 13, 2014. []
  3. It may look like an odd spelling, but Treasurys is the correct spelling. []
  4. At the time, I was an advisor to Hyperledger which was acquired by Digital Asset the following month. []
  5. The DistributedLedgerGroup.com domain was created on December 23, 2014 and R3members.com was created on March 15, 2016. []
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Layer 2 and settlement

Nary a week goes by without having to hear a startup claim their service will have the ability to “settle” a cryptocurrency or virtual asset or something “smart,” on to Layer 2.  In this instance, Layer 2 refers to a separate network that plugs into a cryptocurrency via off-chain channels.1

This often comes up in conjunction with conversations surrounding the Bitcoin block size debate: specifically around (hypothetically) scaling to enable Visa-like transaction throughput vis-a-vis projects like the Thunder and Lightning network proposals which are often characterized as Layer 2 solutions.2

As Wolfgang Pauli might say, this is not even wrong.

Why?  For starters, the comparisons are not the same.

Visa is a credit clearing and authentication network, not a settlement network; in contrast no cryptocurrency has credit lines baked-in.  In addition – as I penned a year ago – in practice “settlement” is a legal concept and typically requires ties into the existing legal infrastructure such as courts and legally approved custodians. 3

Two simplified examples: (1) If Bob wanted to settle cash electronically and he lived in just about any country on the globe, the only venue that this electronic cash ultimately settles in right now is a central bank usually via its real-time gross settlement (RTGS) network.  And (2), if Bob owned the title to a (dematerialized) security and he is trying to transfer ownership of it to someone else, the security ultimately settles in a central securities depository (CSD) such as the DTCC or Euroclear.

What does this have to do with the world of blockchains and DLT?

As of this writing, no central bank-backed digital currency (CBDC) exists.4 As a consequence, there is no real digital cash settlement taking place on any ledger outside of a banks’ own ledger (yet).

One of the key goals for DLT platforms is to eventually get “cash on-ledger” issued by one or more central bank.  For instance, at R3 we are currently working on a couple of CBDC-related projects including with the Bank of Canada and Monetary Authority of Singapore.  And other organizations are engaged in similar efforts.


In short, one of the potential advantages of using a CBDC issued onto a distributed ledger is the enabling of network participants (such as financial institutions) to settle dematerialized (digitized) asset transfers without relying on outside reconciliation processes. Delivery versus Payment (DvP), the simultaneous exchange of an asset and its payment, could actually take place on-chain.5

However, today if participants on a distributed ledger wanted to settle a trade in cash on a distributed ledger, they could not. They would still need to settle via external processes and mechanisms, which according to an estimate from Autonomous research, collectively costs the industry $54 billion a year.  As a result, the industry as a whole is attempting to reduce and – if possible – remove frictions such as these post-trade processes.6  And according to a recent paper from the Bank of England as well as a new paper from the Federal Reserve, CDBCs are one invention that potentially could reduce some of these associated frictions and processes.

So how does that tie back in to a hypothetical Layer 2 or 3, 4, 5, connected to a cryptocurrency network?

Assuming one or more of the Lightning implementations is built, deployed, and goes “into production,” the only object that is being tracked and confirmed is a cryptocurrency.7

Cryptocurrencies, as I have written before, are anarchic: purposefully divorced from legal infrastructure and regulatory compliance.

As a result, it cannot be said that “Layer 2” will act as a settlement layer to anything beyond the cryptocurrency itself, especially since the network it attaches to can at most by design only guarantee probabilistic finality.  In fact, the most accurate description of these add-on networks is that each Lightning implementation requires building completely separate networks run and secured by different third parties: pseudonymous node operators acting as payment processors.  What are the service-level agreements applied to these operators?  What happens if it is no longer profitable or sustainable to operate these nodes?  Who are you going to call when something – like routing – doesn’t work as it is supposed to?

And like most cryptocurrencies, Lightning (the generic Lightning) is developed as a public good, which – as a recent paper explored – may have hurdles from a fiduciary, governance, and accountability perspective.

Assuming the dev teams working on the various implementations solve for decentralized routing and other challenges, at most Lightning will be a clearing network for a cryptocurrency, not electronic cash or securities.  Therefore proponents of existing Layer 2 network proposals might want to drop the “settlement” marketing language because settlement probably isn’t actually occurring.  Trade confirmations are.

But what about colored coins?  Can’t central banks just use the Bitcoin network itself and “peg” bitcoins directly to cash or set-up a Bitcoin-like system that is backed by the central bank itself?

These are tangential to “Layer 2” discussion but sure, they could in theory.  In fact, the latter is an idea explored by JP Koning in a soon-to-be published paper on “Fedcoin.”  In practice this is probably not ideal for a variety of reasons including: privacy, confidentiality, recourse, security, scalability, public goods problems, and the fact that pseudonymous miners operating outside the purview of national regulatory bodies would be in charge of monetary policy (among many other regulatory compliance issues).

Why not just use an existing database to handle these regulated financial instruments then?  This is a topic that has and will fill academic journals in the years to come (e.g., RSCoin).  But for starters I recommend looking at a previous post from Richard Brown and two newer posts from Antony Lewis.


There are real, non-aesthetic reasons why aviation designers and manufacturers stopped building planes with more than two or three wings, namely aerodynamics.  Creative ideas like Lightning may ultimately be built and deployed by cryptocurrency-related companies and organizations, but it is unclear how or why any regulated enterprise would use the existing proposals since these networks are not being architected around requirements surrounding settlement processes.

Perhaps that will change in time, but laws covering custody, settlement, and payment processing will continue to exist and won’t disappear because of anarchic “Layer 2” proposals.  Maybe it is possible to borrow and clone some of the concepts, reusing them for alternative environments, just like some of the “blockchain”-inspired platforms have reused some of the ideas underlying cryptocurrencies to design new financial market infrastructure.  Either way, both worlds will continue to co-exist and potentially learn from one another.

  1. From a word choice, it is arguably a misnomer to call Lightning a “layer” at all because relatively little is being built on top of Bitcoin itself.  These new networks are not powered by mining validators whereas colored coin schemes are. []
  2. While he doesn’t delve too much into any of these specific projects, Vitalik Buterin’s new paper on interoperability does briefly mention a couple of them.  Also note that the Teechan proposal is different than Lightning in that the former scales via trusted hardware, specifically Intel’s SGX tech, and sidesteps some of the hurdles facing current Lightning proposals. []
  3. This topic is a ripe area for legal research as words need to be precisely defined and used.  For instance, if bitcoins do not currently “settle” (in the sense that miners and users do not tie on-chain identities into court recognized identity, contract, and ledger systems thereby enabling traditional ownership transfer), does this impact government auctions of seized cryptocurrencies?  What was the specific settlement process involved in the auction process and are encumbrances also transferred?  It appears in practice, that in these auctions bitcoins do transfer in the sense that new entities take control of the private key(s), is this settlement? []
  4. An argument can be made that there are at least 3 publicly known exceptions to this, though it depends on the definition of an in-production CBDC.  This includes vendors working with: Senegal, Tunisia, and Barbados. []
  5. In blockchain parlance this is called an “atomic transfer.” []
  6. It is not just reconciliation processes, it is the actual DvP itself (plus the subsequent “did you get it yet” reconciliation processes). []
  7. As an aside, what are the requirements for “being in production?”  In the enterprise world, there is a difference between being in a sandbox and being in production.  Which blockchain(s) have been vetted for and secured against real production level situations and fulfilled functional requirements such as scaling and preserving confidentiality? []
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I was recently talking with a friend who spent the past decade in an operations role at a large enterprise in the telecommunication sector.  He has a matter-of-fact personality that likes to cut through the smoke and mirrors to find the fire.

I explained to him my role of having to filter through the dozens of entities that my market research team at R3 speaks with each month. And the formal process that our small team uses to look and find organizations that would be a good fit for R3’s Lab project pipeline.

For instance, because we typically act as the first part of the funnel for our organization, we end up listening to a great deal of startup pitches. And we are continually bombarded by endless “blockchain” and DLT noise.  The first year alone we looked at and spoke to more than 300 entities, a number that has now reached about 400.

This is not to say that there are only 400 companies/vendors/organizations/projects billing themselves as “blockchain” related entities… unfortunately that nebulous term has ballooned to encompass everything from cryptocurrencies to big data to IoT and now probably numbers in the thousands.

If you’re working in capital markets, how to tell the pretenders from the real deal?

Should you seek advice from people who never interface with enterprises or institutions and get all their wisdom from social media?  Or listen to columnists whose only interaction with banks is the ATM or a cryptocurrency meetup?  Or to media outlets that do not disclose their (coin) holdings?  Before answering these, let’s look at a new phrase below.

Thirteen months ago I gave a short presentation talking about the “blockchain” hype cycle.

The month before that – in December 2015 – I mentioned how much of the enthusiasm surrounding “blockchains” seemed a bit similar to the exuberance around “gluten free” food: how most people at fintech conferences talking about “blockchains” really couldn’t explain why blockchains were great in much the same way that many people asking for “gluten-free” food couldn’t tell you why gluten is or is not good for you.

I explained this to my friend and he said that the euphoria surrounding blockchains – and its vertical rise on the Gartner hype cycle – is similar to what he observed and experienced in “the cloud” space earlier this decade.  And more specifically, to the phenomenon called “cloudwashing”:

Cloud washing (also spelled cloudwashing) is the purposeful and sometimes deceptive attempt by a vendor to rebrand an old product or service by associating the buzzword “cloud” with it. (Source)

So with that, I’d like to coin a new phrase: “chainwashing.”

I have personally seen dozens of decks from vendors along the entire spectrum of sizes during the current hype cycle.  And watched the evolution of “blockchain creep” — how over time the word “blockchain” would appear more frequently not just on each slide, but in scope and vertical.

For instance, there are couple dozen different startups that claim to have somehow built an enterprise-grade blockchain system without having to go through the arduous process of gathering the functional and non-functional requirements from the enterprises they intended to integrate with.  Magic!

While startup founders should shoulder the blame for these marketing gimmicks – as should the reporters that often own but do not disclose their (coin) holdings – investors are also to blame for not just talking their book, but also obfuscating their portfolio companies by pressuring them to rebrand retail-focused cryptocurrency products as bonafide “enterprise blockchain” platforms.  They are not the same thing.

So what are some evaluation criteria to help identity the signal from the noise?

If your job is to help filter vendors for financial institutions, governments, investment funds, or other large enterprises, then some of these questions may be helpful in determining whether or not your firm should engage with the vendor:

  • Why is the vendor using a blockchain?
  • What is the vendor’s definition of a blockchain?
  • Who has a problem that needs a blockchain in order to solve it: the vendor or the vendor’s customer?
  • What is it about a blockchain that solves a problem that couldn’t be solved with existing technoloogy?
  • If a blockchain-related infrastructure provides a solution to for the vendor, can it use any other existing technology to solve its needs?
  • Do the founders and management team have experience managing, building, and/or deploying enterprise-grade systems or critical infrastructure?
  • Does the vendor as a whole have the appropriate contacts and connections with institutions and regulators?
  • Does the vendor have enough run way to build through a long sales cycle?

By asking these types of questions our team has helped filter the 400 or so companies/projects into a much more manageable dozen.

We think the number of companies with legs will continue to increase over time but chainwashing will continue to be a noise pollution problem for the next few years in the enterprise world even after production systems have been integrated into institutions.

As a consequence, it is probably safe to assume vendors are trying to pull a fast one on you, especially if it involves needing your company to acquire a cryptocurrency or “permissioning off” an existing cryptocurrency.

Remember: cryptocurrencies in the vein of Bitcoin were intentionally not designed to integrate with and fulfill the requirements of regulated institutions (like settlement finality) any more than a helicopter was designed to handle long distance cargo hauling.  Chainwashing is the opposite of being fit-for-purpose and we see it with marketing gimmicks like “Layer 2,” the topic of the next post.

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Citations, interviews, and events for the final third of 2016

Presenting at Bitcoin / Ethereum Meetup in Hong Kong

I ended up traveling a lot more than I expected last year, including 9 times just to East Asia.  The level of interest in that region will probably increase this year — especially as more projects and companies are funded — though I probably won’t do the Trans-Pacific shuffle nine times again this year.

As of right now there are probably just a small handful of startups in APAC that have the capital, connections, and capability to execute and build the commercial products and applications that are discussed at the plethora of fintech events.  And almost none of them have anything to do with a cryptocurrency itself either… because cryptocurrencies weren’t designed to solve most problems financial service organizations have.

Below are the interviews, events, and presentations I participated in the last few months of 2016.

Note: according to their stats, my “Settlement Risks Involving Public Blockchains” was one of TABB Forum’s top stories of 2016.





  • Smart Cloud Show 2016 from Chosun Ilbo on September 21, 2016 in Seoul, South Korea.
    • Keynote: “Blockchain and Financial Big Bang”
    • Coverage: Naver
  • Global Blockchain Summit event held by Wanxiang Blockchain Labs on September 23, 2016 in Shanghai, China
    • Presentation: “Opportunities and Challenges for Financial Services in the Cloud: Trade-offs in digitizing and automating finance” (R3 Blurb)
  • Fujitsu Laboratories of America Technology Symposium annual event on October 11, 2016 in Santa Clara, California
    • Panel: “The Blockchain Future – Challenges and Opportunities Ahead”
  • Fórum Blockchain event jointly held by Itaú and Bradesco on October 13, 2016 in São Paulo, Brazil
    • Presentation: “Smart Contracts: cryptographically secured, automated business logic”
  • MIT Fintech Course: Future Commerce on October 18, 2016 (virtual)
    • Discussion: “Distributed Ledger Technology Landscape and Regulations”
  • GAIM OPS West Coast annual event held on October 25, 2016 in Rancho Mirage, California
    • Panel: “Blockchain: What Exactly is it disrupting? Will it Negate Counterparty Risk?” (Photo)
  • CIO Study Trip hosted by the Capgemini Applied Innovation Exchange Lab on behalf of the IT Management Association on October 26, 2016 in San Francisco
    • Presentation: “Distributed Ledger Technology” and “Legal and Regulatory Challenges”
  • Day long discussions on November 9, 2016 at Cornell University in Ithaca, New York
    • Presentation: “Code is not law” (Photos)
  • Guest lecture at the Boston Economic Club on November 16, 2016 in Boston, Massachusetts.
    • Presentation: “DLT as Financial Market Infrastructure” (Photo)
  • Global Trade Review: West Coast Trade & Working Capital Conference on November 17, 2016 in San Jose, California
    • Panel: “Fintech investment and evolution of the trade finance sector” (Photo)
  • The Future of Financial Payment Services Driven by Technology Innovation on November 22, 2016 from Korea Finance Telecommunications & Clearings Institute 30th Anniversary Seminar in Seoul, South Korea
    • Presentation: “DLT as Financial Market Infrastructure” (Photos)
    • Panel: (Photos)
  • Inside Fintech on December 8-9, 2016 in Seoul, South Korea
    • Presentation: “Why Building Financial Infrastructure is Different than Building a Social Media App” (Photos)
    • Panel: “Regulating the Unregulated: How is Regulation and Compliance Impacting the Adoption of New Technology and Innovation” (Photos)
  • Ethereum and Bitcoin joint meetup on December 12, 2016 in Hong Kong
    • Presentation:  “On Consortiums: R3’s Tim Swanson in Conversation”
  • 13th annual China International Finance Forum on December 15, 2016 in Shanghai, China
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Comments on the COIN ETF (SR-BatsBZX-2016-30)

Earlier today, with some help from the R3 research team (thanks for the editing!), I shipped a new paper to the consortium members.  This paper discusses several issues and challenges facing a Bitcoin-based ETF that was originally proposed a couple years ago by the Winklevoss twins (commonly called the COIN ETF).  It specifically looks at questions publicly raised by the SEC.

It bears mentioning that R3 itself is not in any shape or fashion, involved with this ETF or in using the Bitcoin network.  This (tangential) paper solely represents my views and not those of my employer or companies I advise.

We typically make research available 3-6 months after sending it to members, so check back here later next spring or summer to see if it has been posted.

Update: many months later an anonymous egg tweeted (at me) that it has been posted online at Scribd and Docdroid (pdf)

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Emochain and Statistchain

[Note: The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise]

Why open/permissionless and closed/permissioned terminology has become a muddled red herring of totems

It is common to see startups, enthusiasts, and advocacy groups boast how they support “open,” “public,” and “permissionless” innovation.  Their lollipops and rainbows narrative can be found on a multitude of websites, social media accounts, and on panels at conferences.

Similarly several well-to-do consultancies and buttoned-up fintech companies use stoic marketing terms like “permissioned,” “trusted,” and “private” to describe their platforms to what are assumedly monocle-wearing, high-brow clientele.

But very little long-form has been spent explaining what these actually mean beyond superficial warm feelings either side is trying to engender.

Both are at fault for taking a page from the politically charged play book of terms like “pro-choice” and “pro-life” — I mean who wants to be labeled as anti-choice or anti-life?  Or in this case, who would want to be known as anti-open and anti-permissionless?    Or as John Oliver might say, who wants to hang out in intranet sandboxes all day when there is a big fat thing called “The Internet” you can troll on all day instead?

Aside from the fact that “The Internet” is just a bunch of highly regulated, permissioned intranets tied together with KYC and peering agreements, let’s de-escalate and take a quick step back for a moment to focus on two diametrically polar opposites: anarchic and archic networks.1

Why?  Because that’s ultimately what these two camps are fighting a war of words and hashtagged rhetoric about.

Defining definables

There are some general commonalities between anarchic and archic chains but before getting there, what does anarchic mean in this context?

An anarchic network — in this case an anarchic blockchain — simply means a chain that purposefully lacks any ties to legal institutions and nation-state infrastructure.  That is to say, the architects of an anarchic chain set out to create an extralegal virtual-only entity that is divorced from governments and regulators; entities that could censor data transfers and on-chain activities.   Currently, anarchic chains are euphemistically called “public blockchains” to have better marketing varnish at cocktail parties in DC.

There have been multiple attempts to build anarchic-types of networks in the past (such as Tor); perhaps the most popularly known anarchic blockchains in use are Bitcoin and Ethereum.

Anarchic can also mean that a chain, or a network layer, has no formal or de jure governance process for handling disputes.  In this case, both Bitcoin and Ethereum (among others) are double-fisting anarchy.

I am a millennial, is there another way of saying all of this in less than 140 characters?

Not that there is an official marketing slogan but:

  • Bitcoin is supposed to be an unstoppable payment processor (title and abstract of the whitepaper)
  • Ethereum is supposed to be an unstoppable computer that can run and execute untrusted code (motto from Foundation’s website)

In contrast, as can be expected from its name, archic chains and networks explicitly tie into traditional legal infrastructure, into the ‘old world’ laws of physical nation-states.  In addition, many archic chain creators attempt to bake-in and enable on-chain dispute mechanisms and methods for handling disputes off-chain in the event there is a problem.2

Boring laws and wet oppressive code, right?

But wait, there’s more.

I think my favorite tweet last year was along the lines of: sometimes my browser crashes, occasionally I have to restart my phone, but gosh darnit my self-driving car will always work without a hitch!

And that naïve thinking pervades a lot of the development teams in the fintech space.

Sure it’d be cool if you can automate all of the value transfer processes globally with cryptographically assured, tamper-evident mechanisms — but in case something screws up or a governance dispute occurs, you have to design for the fact that somewhere Edward Murphy is in your system with Chaos Monkey.3 And so too it will be with magic internet chains.  Without explicit governance and dispute-resolution mechanisms we will just revert back to our lowest common denominator: arguing on reddit with memes.4

Common ground

By their nature these two worlds are polar opposites in terms of network designs, assumptions, and goals.

With that in mind, below are three commonalities that both types of networks have but each of which is handled differently:

(1) Both have permissioning

(2) Both have cryptographic-linked data structures

(3) Both use ‘other peoples computers’

What does each of these mean?

For anarchic networks like Ethereum and Bitcoin, permissioning — that is to say, deciding who gets to change and update the log of records, or in this case digitally sign blocks, is usually handled via proof-of-work.5

Permissioning in this specific case has nothing to do with what kind of applications can be used on it, who can look at the code, who can modify the code, who can send transactions, etc.  These are all tangential to the key foundational question of who gets to digitally sign and update the log of history in the first place.  After all, the Bitcoin whitepaper wasn’t an exegesis on cloning software libraries and GPL versus MIT licensing maximalism now was it?6)  In fact, to-date several vendors have released open-sourced versions of “private” gated chains — so you can have one without the other.7 Nor did KYCing internet access kill innovation on the internet.

While some promoters like to use terms like “dynamic” to describe the log signing / block validation process on the Bitcoin network, in practice there are roughly 15-20 ‘permissioned’ block makers / log signers on the Ethereum and Bitcoin networks at any given time.8

That is to say, the entire “membership pool” of block signers at any day of the week is fairly static.  Some come and go over time but in general there is a quasi-static membership pool of block signers; and the operators of these membership pools is generally known and no longer identity-less (pseudonymous).  They even sit on stage at public conferences and pose for pictures and… bring photo journalists to their actual data centers.9  There is a joke about the first two rules of Fight Club in there somewhere.

This creates some fundamental problems surrounding the goals of achieving censorship-resistance as well as the goals of routing around regulatory regimes.  Recall that neither Bitcoin nor Ethereum were designed to interface with the traditional legal system which compels validators, payment processors, custodians, and financial intermediaries to comply with a bevy of identity management and consumer protection requirements.

In fact, anarchic chains were designed to do just the opposite and instead maintain a network that enables identity-less participants to move data peer-to-peer without complying with a list of external rules and governance processes. As noted above, anarchic chains set out to be their own sovereign entity, a type of virtual nation-state divorced from traditional legal infrastructure altogether.

And to achieve their objective of enabling identity-less participants to transfer data from one to another without having to be vetted by a party capable of censoring the movement of data, the network designers believed they could make their network of validators and block makers — the cloud of machines processing payments and providing digital signatures — decentralized to the extent that the overall network could maintain reliable uptime in the face of network splits as well as malicious activity from governmental and Byzantine actors.

So in summation, anarchic chains:

(1) typically achieve permissioning and log appendation by requiring (originally) identity-less participants to submit proofs-of-work that consume and irreversibly destroy real economic value (e.g., fossil fuels);

(2) the log of history and payments therein is appended via a digital signature controlled by a nominally identity-less, quasi-static participant who is able to propagate the proof-of-work first across the rest of the network;10

(3) this log of history — in both theory and practice — is propagated to other people computers in other countries in order to attempt to achieve uptime in the face of network partitions and adversaries.

In other words, checkmate statists!

Law maximalism

So what about that cold, heartless world of closed, walled-off gardens managed by intranet builders and training wheel makers?  After all, anarchic chains are supposedly too woolly for regulated institutions like banks and according to random people on social media who talk to other random people on social media about financial infrastructure in 140 characters, banks now have decided to reinvent databases… But With Blockchain™.  Because banks — which collectively have built and operate the largest IT infrastructure globally — don’t understand technology and have just rebranded SQL databases to get some easy softball press releases.  Right?

It’s hard to talk about archic chains in the same snarky depth as anarchic chains because there are so many different ones under development that are taking different tact’s and approaches to solving who knows what.  But challenge accepted.

As Ian Grigg explains, part of the problem entrepreneurs are facing is that “permissionless” can be defined, sort of, but the opposite of permissionless is harder to define.  If we accept it means “with a permission” then we could ask, what permission?  How many?  When, where, who, etc.

Are we talking about permission to enter (walled garden), permission to make any transaction (identified keys not pseudonyms), permission to act (approved by regulator in each instance), permission to put money in, permission to take money out?  All of these permissions have regulatory, architectural, societal, and marketing success implications so it isn’t really plausible to talk about a permissioned system as a thing, it’s more an anti-thing.11

With the private/permissioned world of buzzword bingo, a lot of the platforms are ill-conceived forks of cryptocurrencies that weren’t customized at all for capital markets.

Satoshi wasn’t trying to solve for frictions in the post-trade world of clearing and settlement of regulated institutions.  And Vitalik didn’t wake up 3 years ago and say, “Holy hell the $65-$80 billion in post-trade reconciliation processes could be significantly reduced tomorrow if I build an unstoppable computer program replicated across thousands of nodes!”12

So simply forking Bitcoin and gutting the PoW mining apparatus to move pre-IPO cap tables around or track airline points cannot really be called “fit for purpose” especially since it seems that you can pretty much do the same exact thing with existing off-the-shelf technology.

What can’t be done with an extant databases?

That’s a good question, and one a lot of reporters miss because they aren’t interviewing IT managers at banks — who cares what some social media app designer or Bitcoin API developer thinks about back-offices at banks, talk to actual core banking architects.

The fundamental reason that regulated financial institutions have all collectively done steeplechase into magic internet chains track & field is this: there is no such thing as an off-the-shelf system that allows them to move value from their own internal ledgers to outside of their organization without having to rely on a cornucopia of 3rd parties.  There is no such thing as a global shared ledger standard designed around their operating requirements.   For instance, the aggregate reconciliation process and back-office operations that exist today doesn’t make sense to those used to Gmail swiftness or HFT speeds as seen in the front-office activities of trade.

Banks (and other institutions) are looking for novel, secure solutions to reduce certain legacy costs and have been looking at an army of different technology vendors for years to do so.  But as I have pointed out before, there is no such thing as a fit-for-purpose distributed ledger that can provide the type of back-office utility (yet).13

What does that mean?

Fit-for-purpose means that some team of geeks sat down with other teams of geeks at banks to talk about super unsexy things for months and years on end to solve specific issues based on a set of explicit functional and non-functional requirements at said bank.

If your team didn’t do that massively boring requirements gathering process then you’re gonna have a really bad time going to market.

If you simply just start building a blockchain app for blockchain app sake, you will likely end up like BitPay or ChangeTip.  At least with anarchic chain architects themselves, to their credit, are often attempting to solve for a specific problem-set: how to enable censorship-resistant activities in the face of censorable mandates.

On the other hand: if Bitcoin or Ethereum could do the zillions of things that Bitcoin or Ethereum proponents claim it can do, then of course everyone might use it.  It doesn’t, so unsurprisingly many companies and institutions don’t.  And before getting all high and mighty about “not giving little poor Bitcoin a chance” — financial institutions globally have done over 200 PoCs on forks of cryptocurrencies or even cryptocurrency networks themselves.  They discarded nearly all of them because — spoiler alert — anarchic chains were not built for the requirements that regulated banks have.

Archic chains are not a panacea to everything and they are certainly not the most exciting thing since the invention of the Internet: OxiClean was, and you could only originally get it by calling a 1-800 number.14

The tldr for archic chains is that they:

(1) typically achieve permissioning and log appendation by gating and white-listing the operators of the validation process; this usually involves drawing up a legal contract and service-level agreement specifying the terms of services, quality of service, and how disputes are handled.  Because validators are known and legally accountable, proof-of-work is unneeded and marginal costs actually remain marginal (as opposed to MC=MV relationship in PoW networks)15

(2) the log of history and payments therein, is appended via a digital signature controlled by a known, identifiable potentially-static participant who is can propagate the transaction and block to the rest of the participants whom are permitted to interact with the transaction

(3) this log of history — in both theory and practice — is propagated to ‘other people computers.’  In the archic case, it may be a regulated cloud facility (e.g., sovereign cloud) that complies with all of the regulated data requirements of a specific jurisdiction.  (This may sound like an unimportant area of interest, be sure to look at this presentation.)

Or in short, with archic chains: validation and block signing is handled by known, identifiable parties whom have the appropriate licenses to handle regulated data in the jurisdictions they operate in.

Because of laws like the General Data Protection Regulation (GDPR), replication of regulated data to everyone everywhere ends up in Bad News Bears territory pretty quickly.


I purposefully tried not to use the word “immutability” because the term has been bludgeoned by totem warriors on all sides this past year.  It’s to the point where some cryptocurrency advocates sound like Luddites because they do not acknowledge that immutability is simply achieved by running data through a hashing algorithm, that’s it.  It’s one-way and irreversible and has nothing to do with proof-of-work.  All PoW effectively does is delegate who can append a log in an untrusted network.

As a matter of fact, there is oodles of immutable data that predates cryptocurrency networks like Bitcoin, housed on a sundry of databases worldwide.  And on the other hand, you have consultancies wearing out the word “immutability” as if it about to go out of fashion and they get a year-end bonus for saying it three-times fast.

We are nearing the end of year two of the grand totem wars, of the nonsensical permissioned versus permissionless wannabe debate.  There is no versus.  Fundamentally Sams’ Law is empirically valid:  anything that needs censorship-resistance will gravitate towards censorship-resistant systems and anything that does not will gravitate towards systems that can be censored.16

There are ironclad trade-offs: a network cannot simultaneously be censorship-resistant and tied into legal infrastructure.  A chain cannot be both anarchic and archic.  One set of utilities has to have a priority over the other (e.g., definitive settlement finality versus probabilistic finality) otherwise it all begins to look like the chimera that is the permissioned-on-permissionless ecosystem.17

As a consequence, anarchic chains continue to act as testnets for archic chains.  That is to say, both the Bitcoin and Ethereum ecosystems are effectively providing free R&D to network designers who will learn from the mistakes and incorporate the relevant solutions into their own future systems.  After all, why use an anarchic chain in which governance is handled by anonymous eggs on Twitter and (ironically) censorship-happy moderators on reddit?  Perhaps things will change and the great expectations promised by anarchic chains will come to fruition.  In fact, if Boltzmann brains can exist then that is always in the realm of possibilities.

In the meantime, it’s worth reflecting on what Dave Birch recently pointed out: there is no such thing as a cloud, just other people’s computers.18  And each jurisdiction regulates the activities of what can and cannot be processed and serviced on certain machines.  Perhaps those laws will change, but they might not.  It will be worth checking in on the Emochain and Statistchain caricatures in the coming months: maybe the State will wither and die like Zerohedge has predicted 7,934 times in the past.  Or maybe Panoptichain will be built instead.  Or both simultaneously as the consultants behind Schrödingerchain would have you believe.

Immutability!  Immutability!  Immutability!


  1. Archy and Anarchic Chains []
  2. Smart Contract Templates: foundations, design landscape and research directions by Clack et al. []
  3. Edward Murphy is the namesake of “Murphy’s Law.”  See also: Netflix attacks own network with “Chaos Monkey”—and now you can too from ArsTechnica []
  4. Code is not law []
  5. Why does Ethereum plan to move to Proof of Stake? from StackExchange []
  6. “We were successful exactly because we were *not* maximalists.” – Linus Torvalds (source []
  7. See the Hyperledger github repo []
  8. The term “dynamic-membership multi-party signature” was used in the Blockstream whitepaper []
  9. Self-doxxing, dynamic block making and re-decentralization of mining []
  10. It’s actually not necessarily the first — as blocks can become orphaned — but rather which block ends up being built on by other block makers []
  11. “So maybe the debate is over comparing an apple to a citrus fruit – mandarins, tangerines, grapefruits, lemons etc, and everyone is assuming their particular flavour.” Many thanks to Ian Grigg for this passage. []
  12. Blockchain: Back-Office Block-Buster from Autonomous Research []
  13. Designing a Global Fabric for Finance (G3F); Blockchain, Bitcoin and the rise of banks as shared ledger providers; Explore the Blockchain, Ignore the Bitcoin Maximalists []
  14. OxiClean []
  15. See Some Crypto Quibbles with Threadneedle Street and Bitcoins: Made in China []
  16. See slide 13 []
  17. What is permissioned-on-permissionless?; Settlement Risks Involving Public Blockchains []
  18. Dave Birch, September 20, 2016: Source []
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Citations, presentations, and panels

Below are a number of events, presentations, panels, and interviews I have participated in over the past three months.

Academic citation:






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Non-technical Corda whitepaper released

Earlier today our architecture team released its first public whitepaper on Corda.

The WSJ covered it here and here.

Consequently I am somewhat puzzled by news stories that still refer to a “blockchain” as “Bitcoin technology.”  After all, we don’t refer to combustion engines in cars as “horse-powered technology” or an airplane turbine engine as “bird-powered technology.”

A more accurate phrase would be to say something like, “a blockchain is a type of data structure popularized by cryptocurrencies such as Bitcoin and Ethereum.”  After all, chronologically someone prior to Satoshi could have assembled the pieces of a blockchain into a blockchain and used it for different purposes than censorship-resistant e-cash.  In fact, both Guardtime and Z/Yen Group claim to have done so pre-2008, and neither involves ‘proof-of-work.’

Fun fact: Corda is not a blockchain, but is instead a distributed ledger.

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Code is not law

This past Sunday I gave a new presentation at the Palo Alto Ethereum meetup — it was largely based on my previous two blog posts.

Note: all of the references and citations can be found within the notes section of the slides.  Also, I first used the term “anarchic chain” back in April 2015 based on a series of conversations with Robert Sams.  See p. 27.

Special thanks to Ian Grigg for his constructive feedback.



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Ethereum Core and Ethereum Classic for Dummies

[Note: I neither own nor have any trading position on any cryptocurrency.  The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

If you’re bored of catching Pokemon and happen to have a lot of butter stored up, now is the time to break out the premium organic popcorn kernels and enjoy Fork Wars: Summer 2016 Edition.

As mentioned in the previous post: last week many miners, exchanges, and developers coordinated a hardfork of Ethereum.  At the time there were lots of celebrations for having done something that flew in contrast to the views prominently held by the Bitcoin Core development community: namely that a fast hardfork can’t be done safely on a public blockchain.

Well, it has been done, but there were also some consequences.  Some intended and others unintended.  The biggest consequence — which was touched on in my last post too — was that there were now parallel universes: Ethereum Core (ETH) and Ethereum Classic (ETC).

What does this mean?

If you owned a coin on pre-hardfork Ethereum, you now own not just the ETH facsimile but also the Classic coin (ETC) too.  Two for the price of one!1

This also opens up the very real possibility of replay attacks which was also a possibility when Ethereum moved from Olympic to Frontier.

A replay attack predates cryptocurrencies such as Bitcoin and Ethereum:

[I]s a form of network attack in which a valid data transmission is maliciously or fraudulently repeated or delayed. This is carried out either by the originator or by an adversary who intercepts the data and re-transmits it, possibly as part of a masquerade attack by IP packet substitution.

In this case, it is the retransmission of a transaction (not IP packet).  Or in the Ethereum world, a replay attack would be to take a transaction from one Ethereum fork and maliciously or fraudulently repeating it on another Ethereum fork.

A little confused?  Check out: Sirer, Rapp, and Vessenes.

At first most of the Ethereum community assumed that Classic would effectively become deprecated and fade away into history much like Olympic.  After all, so went the argument, who would want to use or support a network in which at least one participant owned/controlled roughly ~10% in now “hot” ether?

Sidebar: recall that the main motivating force behind the hardfork was spurred on by the successful attack on The DAO, an investment fund created by Slock.it who did not adequately test the smart contract for security vulnerabilities (among other issues).

Well, it seems that Classic will not go silent into the night, at least not yet.

From a technical integration standpoint, while all of the large exchanges initially supported ETH, one altcoin exchange based in Montana — Poloniex — began supporting both forks.2

Traders — seeing a potential arbitrage opportunity — began doing what they do best: speculating and driving up demand for ETC via posts on social media.  As a consequence of their marketing efforts, the price of ETC dramatically rose over 380% in one 24-hour period alone.  In return, some of the miners that had abandoned the original Ethereum chain (ETC) to mine on the ETH hardfork have now begun mining on both which means that the original ETC network actually has once again begun seeing an increase in its hashrate (recall that it had dramatically dropped a week ago).

This is an interesting twist because less than 3 days ago, Chandler Guo an executive at BW.com — a large mining pool — announced he would undertake a 51% attack on the ETC blockchain because of the decision by Poloniex to support it.  Chandler later announced he would not carry it out.

Incidentally, it is likely that the noise that was created from this threat actually drew more attention to the Poloniex arbitrage opportunity, creating a type of Streisand Effect.3


What does this situation look like?

ethereum classic

Source: slacknation

Above is a line graph that is auto-generated and reflects the past 48 hours of two types of ratios: the Ethereum Classic (ETC) to Ethereum Core (ETH) price; and the ETC to ETH hashrate.  Price is derived from the two largest exchanges in terms of ether liquidity (Bitfinex and Poloneix).

This is actually not surprising behavior, we empirically observe the same type of trend with other cryptocurrencies: when price increases more hashrate comes on-board and vice-versa.45


Over the past several days there has been much guessing as to which chain will live or die, but rarely do people suggest that both will live on in the long-run.

And I think that is short-sighted.  While not a fully direct comparison, even though they’re effectively based on the same code, we have seen how Litecoin and Dogecoin have permanently conjoined at the hip via merged mining: they co-exist via the Scrypt Alliance.  In addition, we have seen for years the continued existence of multiple multipools, which automatically direct GPU-miners to the most profitable cryptocurrency usually with a payout in bitcoin.

I cannot predict who which chain outlasts the other.  Perhaps now that ethcore has said it will also support Ethereum Classic, the two (or more!) chains will both continue to exist and grow.  Either way, we do know that the maximalist thesis, that there is a “coming demise of altcoins,” continues to be empirically incorrect and I suspect that it will remain incorrect for as long as there is continued speculative demand for cryptocurrencies in general.  This includes both ETH and ETC.

Other winners and losers

Who else gains from this phenomenon?  In the short run, anyone interested in trading will probably be able to find some kind of arbitrage — assuming demand grows or at least stays at the same level.

Anyone else?

Other cryptocurrency communities that see Ethereum as a competitor could believe they now have an incentive to support multiple forks too, as it draws hashrate and potential mindshare away one chain at the expense of the other.  And the more that the Ethereum community is painted as being “chaotic” the less of a threat it is seen to other public blockchains.  But maybe this is shortsighted too and will simply enlarge the Ethereum community because they now end up as ETC holders and want it to appreciate in value.

Either way, it sounds like the makings of some kind of TV miniseries staring Jean-Luc Bilodeau as Vitalik Buterin (they’re both Canadian).

Want to read more on the topic?


Ignoring the above quasi-illustration of the many-worlds interpretation, surprisingly not much has been discussed regarding the analog world of when fiat currencies are created or even removed at certain exchange rates and the unintended consequences therein.

For instance, in the comedy Good Bye, Lenin! we see the repercussions for those who were unable to convert East German marks for West German marks after the fall of the Berlin Wall.

More recently we have seen multiple Iraqi dinar scams, in which individuals were deceived and conned into acquiring pre-war dinar (a deprecated fiat currency) with the fraudulent pitch that at some point in the future, the previous pre-war exchange rate would somehow be reached.

However, one of the biggest differences with the Ethereum-based chains above is that cryptocurrencies are anarchic — without terms of service or ties to the legal system. Therefore it is difficult (impossible even?) to say which chain is the de jure legitimate chain.  Consequently it is unclear if anyone has a legal claim to prevent or create additional forks in the future and because of this, it is hard to see who has liability for past, present or future forks on these chains.

Whether that is a risk organizations and regulated institutions are willing to take is a topic for another post.  Perhaps if or when this is done, there will be even more chances to consume warm buttery popcorn as we watch and learn from the trials and tribulations of anarchic blockchains.


  1. It is closer to a spinoff than a stock-split.  Similar to the Ebay/Paypal spinoff, where a company that once had single market capitalization (EBAY) now trades under two different symbols (EBAY/PYPL) that trade and move independently. []
  2. Note: by this I mean that the existing exchanges that had already on-boarded ether, not that all large cryptocurrency exchanges had on-boarded ether. []
  3. Guo wanted to remove something (a chain in this case) but by advertising his intention to do so, only drew more interest and activity back into the very chain he intended to remove. []
  4. See Appendix B []
  5. See also Ethereum chain state []
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Archy and Anarchic Chains

[Note: the views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

Yesterday, at block height 1920000, many elements of the Ethereum community coordinated a purposeful hardfork.

After several weeks of debate and just over a couple weeks of preparation, key stakeholders in the community — namely miners and exchanges — attempted to create a smooth transition from Ethereum Prime (sometimes referred to as Ethereum Classic) into Ethereum Core (Ethereum One).1

Users of exchange services such as Kraken were notified of the fork and are now being allowed to withdraw ETH to Ethereum Core, which many miners and exchanges now claim as “mainnet.”

Was the hardfork a success?  To answer that question depends on which parallel universe (or chain) you resided on.  And it also depends on the list of criteria for what “failure” or “success” are measured by.

For instance, if you ended up with ETH on the “unsupported” fork (Classic), who was financially responsible for this and who could attempt to file a lawsuit to rectify any loses?

Maybe no one.  Why?  Because public blockchains intentionally lack terms of service, EULA, and service level agreements, therefore it is difficult to say who is legally liable for mistakes or loses.

For instance, if financial instruments from a bank were sent to miners during the transition phase and are no longer accessible because the instruments were sent to the “unsupported” chain, who is to blame and bears responsibility?  Which party is supposed to provide compensation and restitution?

De facto versus de jure

This whole hardfork exercise visualizes a number of issues that this blog has articulated in the past.

Perhaps the most controversial is that simply: there is no such thing as a de jure mainnet whilst using a public blockchain.  The best a cryptocurrency community could inherently achieve is a de facto mainnet.2

What does that mean?

Public blockchains such as Bitcoin and Ethereum, intentionally lack any ties into the traditional legal infrastructure.  The original designers made it a point to try and make public blockchains extraterritorial and sovereign to the physical world in which we live in.  In other words, public blockchains are anarchic.

As a consequence, lacking ties into legal infrastructure, there is no recognized external authority that can legitimately claim which fork of Bitcoin or Ethereum is the ‘One True Chain.’  Rather it is through the proof-of-work process (or perhaps proof-of-stake in the future) that attempts to attest to which chain is supposed to be the de facto chain.3

However, even in this world there is a debate as to whether or not it is the longest chain or the chain with the most work done, that is determines which chain is the legitimate chain and which are the apostates.4 5

And this is where, fundamentally, it becomes difficult for regulated institutions to use a public blockchain for transferring regulated data and regulated financial instruments.

For instance, in March 2013 an accidental, unintended fork occurred on what many participants claimed as the Bitcoin mainnet.

To rectify this situation, over roughly four hours, operators of large mining pools, developers, and several exchanges met on IRC to coordinate and choose which chain they would support and which would be discarded.  This was effectively, at the time, the largest fork-by-social-consensus attempted (e.g., proof-of-nym-on-IRC).

There were winners and losers.  The losers included: OKPay, a payment processor, lost several thousand dollars and BTC Guild, a large mining pool who had expended real capital, mined some of the now discarded blocks.

In the Bitcoin world, this type of coordination event is slowly happening again with the never ending block size debate.

One team, Bitcoin Classic, is a small group of developers that supports a hardfork to relatively, quickly increase the block size from 1 MB to 2 MB and higher.  Another group, dubbed Bitcoin Core, prefers a slower role out of code over a period of years that includes changes that would eventually increase the block size (e.g., segwit). 6

Yet as it lacks a formal governance structure, neither side has de jure legitimacy but instead relies on the court of public opinion to make their case.  This is typically done by lobbying well-known figureheads on social media as well as mining pools directly.  Thus, it is a bit ironic that a system purposefully designed for pseudonymous interactions in which participants were assumed to be Byzantine and unknown, instead now relies on known, gated, and trusted individuals and companies to operate.

Note: if the developers and miners did have de jure legitimacy, it could open up a new can of worms around FinCEN administrative requirements. 7  Furthermore, the miners are always the most important stakeholders in a proof-of-work system, if they were not, no one would host events just for them.

arthur twitter pow

Source: Twitter


With this backstory it is increasingly clear that, in the legal sense, public blockchains are not actual distributed ledgers.  Distributed, yes; ledgers, no.

As Robert Sams articulates:8

I think the confusion comes from thinking of cryptocurrency chains as ledgers at all. A cryptocurrency blockchain is (an attempt at) a decentralised solution to the double spending problem for a digital, extra-legal bearer asset. That’s not a ledger, that’s a log.

That was the point I was trying to make all along when I introduced the permissioned/permissionless terminology!9 Notice, I never used the phrase “permissionless ledger” — Permissionless’ness is a property of the consensus mechanism.

With a bearer asset, possession of some instrument (a private key in the cryptocurrency world) means ownership of the asset. With a registered asset, ownership is determined by valid entry in a registry mapping an off-chain identity to the asset. The bitcoin blockchain is a public log of proofs of instrument possession by anonymous parties. Calling this a ledger is the same as calling it “bearer asset ledger”, which is an oxymoron, like calling someone a “married bachelor”, because bearer assets by definition do not record their owners in a registry!

This taxonomy that includes the cryptocurrency stuff in our space (“a public blockchain is a permissionless distributed ledger of cryptocurrency”) causes so much pointless discussion.

I should also mention that the DLT space should really should be using the phrase “registry” instead of “ledger”. The latter is about accounts, and it is one ambition too far at the moment to speak of unifying everyone’s accounts on a distributed ledger.

As I have discussed previously, public blockchains intentionally lack hooks into off-chain legal identification systems.

Why?  Because as Sams noted above: a KYC’ed public blockchain is effectively an oxymoron.  Arguably it is self-defeating to link and tie all of the participants of the validation (mining) process and asset transfer process (users) to legal identities and gate them from using (or not using) the network services.  All you have created is a massively expensive permissioned-on-permissionless platform.

But that irony probably won’t stop projects and organizations from creating a Kimberely Process for cryptocurrencies.

I cannot speak on behalf of the plethora of “private chain” or “private ledger” projects (most of which are just ill-conceived forks of cryptocurrencies), but we know from public comments that some regulators and market structures might only recognize blockchains and distributed ledgers that comply with laws (such as domestic KYC / AML regulations) by tying into the traditional legal infrastructure.10 This means tying together off-chain legal identities with on-chain addresses and activity.


There are multiple reasons, but partly due to the need to reduce settlement risks: to create definitive legal settlement finality and identifying the participants involved in that process.11


As illustrated with the purposeful Ethereum One hardfork and the accidental Bitcoin fork in 2013, public blockchains by design, can only provide probabilistic settlement finality.

Sure, the data inside the blocks itself is immutable, but the ordering and who does the ordering of the blocks is not.

What does this mean?  Recall that for both Ethereum and Bitcoin, information (usually just private keys) are hashed multiple times by a SHA algorithm making the information effectively immutable.12 It is unlikely given the length of time our star is expected to live, that this hash function can be reversed by a non-quantum computer.

However, blocks can and will be reorganized, they are not immutable.  Public blockchains are secured by social and economic consensus, not by math.

As a consequence, there are some fundamental problems with any fork on public blockchains: they may actually increase risks to the traditional settlement process.  And coupled with the lack of hooks for off-chain identity means that public blockchains — anarchic blockchains — are not well-suited or fit-for-purpose for regulated financial institutions.

After all, who is financially, contractually, and legally responsible for the consequences of a softfork or hardfork on a public blockchain?

  • If it is no one, then it might not be used by regulated organizations because they need to work with participants who can be held legally accountable for actions (or inactions).
  • If it is someone specifically (e.g., a doxxed individual) then you have removed the means of pseudonymous consensus to create censorship resistance.

In other words, public blockchains, contrary to the claims of social media, are not “law” because they do not actually tie into the legal infrastructure which they were purposefully designed to skirt.  By attempting to integrate the two worlds — by creating a KYC’ed public blockchain — you end up creating a strange hydra that lacks the utility of pseudonymity (and censorship resistance) yet maintains the expensive and redundant proof-of-work process.

These types of forks also open up the door for future forks: what is the criteria for forking or not in the future?  Who is allowed and responsible to make those decisions?  If another instance like the successful attack and counter-attack on The DAO takes place, will the community decide to fork again?  If 2 MB blocks are seen as inadequate, who bears the legal and financial responsibility of a new fork that supports larger (or smaller) blocks?  If any regulated institution lose assets or funds in this forking process, who bears responsibility?  Members of IRC rooms?

If the answers are caveat emptor, then that level of risk may not be desirable to many market participants.


Who are you going to sue when something doesn’t go according to plan?  In the case of The DAO, the attacker allegedly threatened to sue participants acting against his interests because he claimed: code is law.  Does he have legal standing?  At this time it is unclear what court would have accepted his lawsuit.

But irrespective of courts, it is unclear how smart contract code, built and executed on an anarchic platform, can be considered “legal.”  It appears to be a self-contradiction.

As a consequence, the fundamental need to tie contract code with legal prose is one of the key motivations behind how Richard Brown’s team in London approached Corda’s design.  If you cannot tie your code, chain, or ledger into the legal system, then it might be an unauthoritative ledger from the perspective of courts.13

And regulated institutions can’t simply just ignore regulations as they face real quantifiable consequences for doing so.  To paraphrase George Fogg, that’s akin to putting your head in the sand.

We continue to learn from the public blockchain world, such as the consequences of forks, and the industry as a whole should try to incorporate these lessons into their systems — especially if they want anyone of weight to use them.  Anarchic blockchains will continue to co-exist with their distributed ledger cousins but this dovetails into a conversation about “regtech,” which is a topic of another post.


  1. Rejecting Today’s Hard Fork, the Ethereum Classic Project Continues on the Original Chain: Here’s Why from Bitcoin Magazine []
  2. This doesn’t mean that regulators and/or financial institutions won’t use public blockchains for various activities; perhaps some of them will be comfortable after quantifying the potential risks associated with them. []
  3. Ethereum developers plan to transition Ethereum from proof-of-work to proof-of-stake within the next year. []
  4. See Arthur Breitman’s interview on Epicenter Bitcoin and Mike Hearn’s interview on Money & Tech []
  5. Philosophically when Bob connects to “The Bitcoin Network” — how does Bob know he is actually connected to the “real” Bitcoin network?  One method is to look at the block header: it should take a specific amount of time to recreate the hash with that proof-of-work. This proves which network has the most work done.  However, in the meantime, Bob might connect to other ‘pretenders’ claiming to be “The Bitcoin Network.”  At this time, there does not appear to be any legal recognition of a specific anarchic chain. []
  6. The Bitcoin Core fork, which is euphemistically called a softfork, is basically a hardfork spread over a long period of time. []
  7. See Section 3.4 []
  8. Personal correspondence: March 9, 2016 []
  9. See Blockchain Finance by Robert Sams []
  10. This is not to say that regulators, governments, and various market participants will not use public blockchains for other activity. []
  11. See Section 3.1 []
  12. For proof-of-work mining, Ethereum uses ethash instead of SHA256.  For hashing itself, Ethereum uses SHA-3 which is part of the Keccak family (some people use the terms interchangeably but that isn’t technically correct). []
  13. See Section 9 []
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Looking at public information for quarterly usage

[Note: the views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

It’s the beginning of a new quarter so that means its time to look at the last quarter and find out where public blockchain traction and usage is taking place, or not.  After all, we are continually bombarded by cryptocurrency enthusiasts each day telling us that exponential growth is occurring.  Or as GIF party posters like to say, “It’s Happening!” — so in theory it should be easy to find.

For more background, see previous posts from January and April.



Source: P2SH.info

  • P2SH usage: above are two charts from P2SH.info which illustrates the movement of bitcoins into what most assume are multi-sig wallets of some kind.  There has been a visible increase over the past quarter, with about 200,000 or so more bitcoins moving into P2SH addresses.  Year-on-year, bitcoins held in P2SH addresses has increased from 8% to 13%.
total transactions over time blockstack

Source: Opreturn.org

  • OP_RETURN: above is a line chart from Opreturn.org which illustrates various 3rd party applications that typically use the OP_RETURN field in Bitcoin as a type of datastore (e.g., watermarked tokens).  It is hard to see it on this time scale but the average transactions during Q1 were roughly 1,500-2,500 per day whereas in Q2 it was a bit higher, between 2,500 to 3,500 per day.
percentage of transactions by each protocol opreturn

Source: Opreturn.org

  • Above is another chart looking at the percent of OP_RETURN transactions used by different watermarked token platforms.
  • Compared to Q1, the top 5 have shifted:
    • Blockstack 142,754 transactions (24.9%)
    • Colu 106,489 (18.6%)
    • Open Assets  82,696 (14.4%)
    • Monegraph 54,914 (9.6%)
    • Factom 47,328 (8.3%)
  • While Blockstack (Onename) still rules the roost, Colu has jumped ahead of the other users.  This is slightly interesting because the Colu team has publicly stated it will connect private chains that they are developing, with the Bitcoin network.  The term for this is “anchoring” and there are multiple companies that are doing it, including other Bitcoin/colored coin companies like Colu.  It is probably gimmicky but that’s a topic for a different post.
  • Incidentally the 5 largest OP_RETURN users account in Q2 for 75.8% of all OP_RETURN transactions which is roughly the same as Q1 (76%).
localbitcoins volume

Source: LocalBitcoins.com / Coin Dance

Above is a weekly volume chart denominated in USD beginning from March 2013 for LocalBitcoins.com.  As discussed in previous posts, LocalBitcoins is a site that facilitates the person-to-person transfer of bitcoins to cash and vice versa.

While there is a lot of boasting about how it may be potentially used in developing countries, most of the volume still takes place in developed countries and as shown in other posts, it is commonly used to gain access to illicit channels because there is no KYC, KYCC, or AML involved.  Basically Uber for cash, without any legal identification.

Over the past 6 months, volumes have increased from $10 million and now past $13 million per week. For comparison, most VC-backed exchanges do several multiples more in volume during the same time frame.1


bitcoin volatility 6 months

Source: Btcvol.info

In April, several Bitcoin promoters were crowing about how “stable” Bitcoin was.  Not mentioned: cryptocurrencies can’t simultaneously be stable and also go to the moon.  People that like volatility include: traders, speculators, GIF artisans, pump & dumpers. And people who don’t like volatility: consumers and everyday users.

What articles and reporters should do in the future is actually talk to consumers and everyday users to balance out the hype and euphoria of analysts who do not disclose their holdings (or their firms holdings) of cryptocurrencies.2

As we can see above, volatility measured relative to both USD and EUR hit a five month high this past quarter.  The average user probably would not be very happy about having to hedge that type of volatility, largely because there are few practical ways to do so.  Consumers want boring currencies, not something they have to pay attention to every 10 minutes.

And ether (ETH) was even more volatile during the same time frame: doubling relative to USD during the first half of the quarter then dropping more than 50% from its all-time high by mid-June.

Counterparty all time

Source: Blockscan

Counterparty is a watermarked token platform that, as shown in previous quarters, has hit a plateau and typically just sees a few hundred transactions a day.  Part of this is due to the fact that the core development team has been focused on other commercial opportunities (e.g., building commercial products instead of public goods).3

Another reason is that most of the public interest in “smart contract” prototyping and testing has moved over to Ethereum.

etherscan ethereum transactions

Source: Etherscan

As shown in the chart above, on any given day in Q2 the Ethereum blockchain processed roughly 40,000 transactions.  In Q1 that hovered between 15,000-30,000 transactions.  Note: the large fluctuations in network transactions during the spring may coincide with issues around The DAO (e.g., users were encouraged to actively ‘spam’ the network during one incident).

In addition, according to CoinGecko, Counterparty has lost some popularity — falling to 14th from 10th in its tables from last quarter.  Ethereum remained in 2nd overall.

Another trend observed in the last quarterly review remains constant: Ethereum has significantly more meetups than Counterparty and is 2nd only to Bitcoin in that measure as well.

long chain transactions q2

Source: Organ of Corti — Time period:  January 1, 2014 – June 27, 2016

We’ve discussed “long chain” transactions ad nausem at this point but I have noticed on social media people still talk about the nominal all-time high’s in daily transactions as if it is prima facie evidence that mega super traction is occurring, that everyday users are swarming the Bitcoin network with commercial activity.  Very few (anyone?) digs into what those transactions are.  Perhaps there is genuine growth, but what is the break down?

As we can see from the chart above, while non-long chain transactions have indeed grown over the past quarter, they are still far outpaced by long chain transactions which as discussed in multiple articles, can be comprised of unspendable faucet rewards (dust), gambling bets and a laundry list of other non-commercial activity.

Furthermore, and not to wade into the massive black hole that is the block size debate: even with segwit, there will be an upperbound limit on-chain transactions under the current Core implementation.  As a consequence some have asked if fee pressure would incentivize moving activity off-chain and onto other services and even onto other blockchains.

This may be worth looking into as the block size reaches its max limit in the future.  As far as we can tell right now, it doesn’t appear users are moving over to Litecoin, perhaps they are moving to Ethereum instead?  Or maybe they just pack up and leave the space entirely?


We have looked at wallets here multiple times.  They’re a virtually meaningless metric because of how easy it is to inflate the number.  What researchers want to know is Monthly Active Users (MAU).  To my knowledge no one is willing to publicly discuss their monthly or daily user number.

For instance, two weeks ago Coinbase reached 4 million “users.”  But it is almost certain that they do not actually have 4 million daily or monthly active users.  This number is likely tied to the amount of email-based registrations they have had over the past four years (circa May 12, 2012).

Similarly, Blockchain.info has seen its “users” grow to just over 7.8 million at the time of this writing.  But this is a measure of wallets that have been created on the site, not actual users.

Any other way to gauge usage or traction?

Let’s look in the Google Play Store and Apple App Store.

abra downloads

Source: GoAbra / Google Play

Last October Abra launched its GoAbra app and initially rolled it out in The Philippines.  This past May, when CoinDesk ran a story about the company, I looked in the Google Play Store and it says the app had been downloaded 5,000 times.  Last week, Abra announced it was officially launching its app into the US.  As of this writing, it was still at 5,000 downloads.

“Wait,” you might be thinking to yourself, “Filipinos may prefer the iOS app instead.”

Perhaps that is the case, but according to data as of October 2015, Android has a ~81.4% market share in The Philippines.  Furthermore, the iOS version for some reason doesn’t appear on App Annie.  So it is unlikely that Abra has seen traction that isn’t reflected in these download numbers yet, perhaps it will in the future.

Anything else happening in the stores?

As of this writing, the top 5 Bitcoin wallets in the Google Play Store in order of appearance are:

  • Andreas Schildbach’s Bitcoin Wallet (1 million downloads)
  • Mycelium Bitcoin Wallet (100,000 downloads)
  • Coinbase (500,000 downloads)
  • Blockchain.info (100,000 downloads)
  • Airbitz (10,000 downloads)

The Apple App Store does not publicly state how many times an application has been downloaded.  It does rank apps based on a combination of user ratings and downloads. The top 6 on the iPhone in order of appearance:

  • Coinbase
  • Blockchain.info
  • Sollico (bitWallet)
  • breadwallet
  • Xapo
  • Airbitz

Interestingly however, the order is slightly different in the App Store on an iPad.  The top 6 are:

  • Coinbase
  • Blockchain.info
  • Sollico (bitWallet)
  • breadwallet
  • Airbitz
  • BitPay (Copay)

It may be worth revisiting these again next quarter.  If you want to burn some time, readers may be interested in looking at specific rank and activity via App Annie.


Most new cohorts and batches at startup accelerators and incubators usually only stay 3-4 months.  A typical intake may see 10-15 companies each get a little bit of seed funding in exchange for a percentage of the equity.  During the incubation period the startup is usually provided mentorship, legal advice, office space, access to social networks and so forth.  It is common place to hear people of all stripes in Silicon Valley state that 9 out of 10 of these startups will burn out within a couple years — that the incubator relies on one of them having a big exit in order to fund the other duds.4

500 Startups, Boost.VC, Plug and Play, YCombinator and other incubators have added and removed startups from their websites and marketing material based on the traction startups have had.  And cryptocurrency startups are not too different from this circle of life. 5

For instance, at YCombinator, Bitcoin-specific mentions on applications has declined by 61% over the past year.

Based on pubic information, as of this writing, it appears that out of the roughly 100 Bitcoin-related startups that have collectively come and gone through the incubators listed above, just a handful have gone on to raise additional funding and/or purportedly have active users and customers.  Unfortunately, no one has consistently published user numbers, so it is unclear what the connection between funding and growth is as this time.

In fact, in an odd twist, instead of measuring success by monthly active users, customers, or revenue, many Silicon Valley-based companies are measuring success based on how much money they raised.  That’s probably only a good idea if the business model itself is to always be raising.

For example, 21inc regularly boasts at being the “best funded company in Bitcoin” — but has not stated what traction four separate rounds of funding have created.  How many bitcoins did it mine prior to its pivot into consumer hardware?  How many 21 computers were sold?  How many users have installed 21?  And what are its key differences relative to what Jeremy Rubin created in 2014 (Tidbit)?

Again, this is not to single out 21inc, but rather to point out if companies in the public blockchain space were seeing the traction that they generally claim to on social media and conferences — then as discussed in previous posts, they would probably advertise those wins and successes.


With funding comes hiring.  Since it is very difficult to find public numbers, there is another way to gauge how fast companies are growing: who and how many people they are publicly hiring.

The last Bitcoin Job Fair was last held in April 2015.  Of its 20 sponsors, 6 are now dead and ~7 are either zombies and/or have have done major pivots.  It is unclear how many people that were hired during that event still work for the companies they worked for.

Where else can we look?

Launched in 2014, Coinality is a job matching website that connects employers with prospective employees with the idea that they’d be compensated in cryptocurrencies such as bitcoin and dogecoin.  Fun fact: Coinality is one of the few companies I interviewed for Great Chain of Numbers that is still alive today and hasn’t pivoted (not that pivoting in and of itself is a bad thing).

It currently lists 116 jobs, 105 of which were posted in the past 2 months.

A number of VC-backed companies and large enterprises (or head hunters recruiting on their behalf) have listed openings in the past month.  For example: WellsFargo, Blockchain.info, Circle, Fidelity, IBM, KeepKey, itBit, BNYMellon and SAP logos pop up on the first couple pages of listings.

Among the 67 job listed in June, twenty-six of the positions were freelance positions cross-listed on Upwork (formerly known as Elance / oDesk).

Notable startups that are missing altogether: many cryptocurrency-centered companies whose executives are very vocal and active on social media.  Perhaps they use LinkedIn instead?

Other stats

  • According to CoinATMRadar there are now 690 Bitcoin ATMs installed globally.  That is an increase of 78 ATMs since Q1.  That comes to around 0.86 ATM installations per day in Q2 which is a tick higher than Q1 (0.84).
  • Bitwage launched in July 2014 starting out with zero signups and zero payroll.
    • Fast-forward to January 2016: Bitwage had 3,389 cumulative user signups and cumulative payroll volumes of $2,456,916
    • Through June 2016 it has now reached 5,617 cumulative signups and cumulative payroll volumes of $5,130,971
    • While growing a little faster than ATM installations, this is linear not exponential growth.
  • Open Bazaar is a peer-to-peer marketplace that officially launched on April 4, 2016.  It had been in beta throughout the past year.  The VC-backed team operates a companion website called BazaarBay which has a stats page.
    • It may be worth looking at the “New Nodes” and “New Listings” sections over the coming quarters as they are both currently declining.6


It is unclear what the root cause(s) of the volatility were above.  According to social media it can be one of two dozen things ranging from Brexit to the upcoming “halvening.”  Because we have no optics into exchanges and their customer behavior, speculation surrounding the waxing and waning will remain for the foreseeable future.

Based on process of elimination and the stats in this post, the likely answer does not appear to be consumer usage (e.g., average Joe purchasing alpaca socks with bitcoins).  After all, both BitPay and Coinbase have stopped posting consumer-related stats and they are purportedly the largest merchant processors in the ecosystem.

Most importantly, just because market prices increase (or decreases), it cannot be inferred that “mass adoption” is happening or not.  Extraordinary claims requires extraordinary evidence: there should be ample evidence of mass adoption somewhere if it were genuinely happening.

For instance, the price of ether (ETH) has increased 10x over the past 6 months but there is virtually no economy surrounding its young ecosystem.  Mass consumer adoption is not happening as GIF artisans might says.  Rather it is likely all speculation based — which is probably the same for all other cryptocurrencies, including Bitcoin.

About a year ago we began seeing a big noticeable pivot away from cryptocurrencies to non-cryptocurrency-based distributed ledgers.  That was largely fueled by a lack of commercial traction in the space and it doesn’t appear as if any new incentive has arisen to coax those same businesses to come back.  After all, why continue building products that are not monetizable or profitable for a market that remains diminutive?

Let’s look again next quarter to see if that trend changes.


  1. For more granularity see also BNC’s Liquid index. []
  2. Speaking of interest and hype, CB Insights has some new charts based on keyword searches over time. []
  3. Several members of the development team also co-founded Symbiont. []
  4. Many of these incubators are too young to have a track record that proves or disproves this “conventional” wisdom.  See also Venture Capitalists Get Paid Well to Lose Money from HBR. []
  5. For instance, Mirror closed its Series A round 18 months ago, but was removed from Boost’s website because it no longer is involved in Bitcoin-related activities.  Boost currently lists the following companies out of the 50+ Bitcoin-companies it has previously incubated: BlockCypher, BitPagos, Abra, Stampery, Fluent, SnapCard, Verse.  500 Startups has removed a number of startups as well and currently lists the following on its website: HelloBit, Melotic, Coinalytics, BTCJam, Bonafide, CoinPip. []
  6. Since it has only been “launched” for a quarter, it is probably a little unfair to pass judgement at this time.  But that hasn’t stopped me before.  OpenBazaar has a lot of growing pains that its developers are well aware of including UX/UI issues.  But beyond that, it is unclear that the average consumer is actually interested in using peer-to-peer marketplaces + cryptocurrencies versus existing incumbents like Alibaba, Amazon and eBay — all of whom have customer service, EULAs, insurance policies and accept traditional currencies. I had a chance to speak with one of their investors at Consensus in May and do not think their assumptions about network operating costs were remotely accurate.  Furthermore, where is the market research to support their thesis that consumers will leave incumbents for a platform that lacks insurance policies and live customer service?  Note: OB1 developers and investors insist that their reputation management and arbitration system will increase consumer confidence and customer protection. []
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A Kimberley Process for Cryptocurrencies

[Note: the views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

I have spent the past few weeks in East Asia, primarily in China visiting friends and relatives. Because the connection to the outside world was limited, the upside was that the cacophonous noise of perma cryptocurrency pumpers was relatively muted. I have had a chance to reflect on a number of ideas that are currently being discussed at conferences and on social media.

The first idea is not new or even unique to this blog as other companies, organizations and individuals have proposed a type of digital signature analytics + KYC tracking process for cryptocurrencies. A type of Kimberley Process but for cryptocurrencies.1

For instance, the short lived startup CoinValidation comes to mind as having the first-to-market product but was notably skewered in the media.  Yet its modus operandi continues on in about 10 other companies.2

A Formal Kimberley Process

For those unfamiliar with the actual Kimberley Process, it is a scheme enacted in 2003 to certify where diamonds originated from in order to help prevent conflict diamonds from entering into the broader mainstream diamond market.

The general idea behind proving the provenance of diamonds is that by removing “blood diamonds” from the market, it can cut off a source of funding of insurgencies and warlord activity.3

What does this have to do with cryptocurrencies? Isn’t their core competency allowing non-KYC’ed, pseudonymous participants to send bearer assets to one another without having to provide documentation or proof of where those assets came from? Why would anyone be interested in enabling this?

Some may not like it, but a de facto Kimberley Process is already in place.

For instance, in many countries, most of the on-ramps and off-ramps of venture-backed cryptocurrency exchanges are actively monitored by law enforcement, compliance teams and data analytic providers who in turn look at the provenance of these assets as they move across the globe.4

On the fiat side, while many jurisdictions in North America and Western Europe currently require domiciled cryptocurrency exchanges and wallets to enforce KYC and AML compliance requirements, several areas of Asia are less strict because the local governments have not defined or decided what buckets cryptocurrencies fall into.5

There are some other noticeable gaps in this system involving crypto-to-crypto exchanges.  Irrespective of regions: implementing harmonized KYC/AML standards on the non-fiat side of exchanges appears to be missing altogether.  That is to say that very few, if any, exchange does any kind of KYC/AML on crypto-to-crypto.6

What are some examples of why a Kimberley Process would be helpful to both consumers and compliance teams?

Below are three examples:

(1) During my multi-country travel I learned that there are several regional companies that sell debit cards with pre-loaded amounts of cryptocurrency on them. Allegedly two of of the popular use-cases for these cards is: bribery and money laundering. The example I was provided was that it is logistically easier to move $1 million via a thin stack of debit cards than it is to carry and disperse bags of cash with.7

Attaching uniform KYC and legal identities to each asset would aid compliance teams in monitoring where the flow of funds originated and terminated with cryptocurrencies.  And it would help consumers shy away from assets that could be encumbered or were proceeds of crime.

(2) Affinity fraud, specifically housewives (家庭主妇), are common targets of predators. This has been the case for long before the existence of computers let alone cryptocurrencies, but it came up several times in conversations with friends. According to my sources, their acquaintances are repeatedly approached and some actually took part in Ponzi schemes that were presented as wealth management products.

The new twist and fuel to these schemes was that there is some kind of altcoin or even Bitcoin itself were used as payout and/or as rails between parties. We have already seen this with MMM Global — which is still an active user of East Asia’s virtual currency exchanges — but two questionable projects that I was specifically shown were OctaCoin and ShellCoin.8

Note: in January 2016 multiple Chinese governmental bodies issued warnings about MMM Global and other Ponzi schemes.

[Video of MMM Global operations in The Philippines. Is that really Manny Pacqiauo?]

Victims who were not tech savvy and lied to, have no recourse because there is no universal KYC / KYCC / AML process to identify the culprits in these regions.  Similarly, when these illicit virtual assets are re-sold to exchanges, customers of those exchanges such as Alice and Bob, may receive potentially encumbered assets that are then resold to others who are unaware of the assets lineage (much like a stolen motorcycle being resold multiple times).  This creates a massive lien problem.

But property theft is not a new or unknown problem, why is it worth highlighting for cryptocurrencies?

Many of the original victims in East Asia are not affluent, so these scams have a material impact on their well being. The average working adult in many provinces is still less than $500 per month. Thus not only do they lack a cushion from scams but any price volatility — such as the kind we continue to see in cryptocurrencies as a whole, can wipe out their savings.

(3) Due to continual usage of botnets and stolen electricity — which is still a problem in places like China — the lack of identification from coin generation onward results in a environment in which ‘virgin coins’ sell at a premium because many exchanges don’t investigate where machines are located, who owns them, who paid for the opex and capex of those operations (e.g., documentation of electric bills).9

Unfortunately, the solutions proposed by many cryptocurrency enthusiasts isn’t to create more transparency and identification standards enabling better optics on coin provenance but rather to make it even harder to track assets via proposals like Confidential Transactions.10

Heists, thefts and encumbered coins

I am frequently asked how is it possible to know who received potentially encumbered cryptocurrencies?  For amateur sleuths, there is a long forum thread which lists out some of the major heists and thefts that occurred early on in Bitcoinland.

Above is a video recording of a specific coin lineage: transactions that came from the Bitcoinica Theft that ended up in the hands of Michael Marquardt (“theymos”) who is a moderator of /r/bitcoin and owner of Bitcoin Talk.11

Recall that in July 2012, approximately 40,000 bitcoins were stolen from the Bitcoinica exchange.12 Where did those end up?  Perhaps we will never know, but several users sued Bitcoinica in August 2012 for compensation from the thefts and hacks.

How are consumer protections handled on public blockchains?

In short, they do not exist by design. Public blockchains intentionally lack any kind of native consumer protections because an overarching goal was to delink off-chain legal identities from the pseudonymous interactions taking place on the network.

Thus, stolen cryptocurrencies often recirculate, even without being mixed and laundered.13

Consequently a fundamental problem for all current cryptocurrencies is that they aren’t exempt from nemo dat and have no real fungibility because they purposefully were not designed to integrate with the legal system (such as UCC 8 and 9).14 Using mixers like SharedCoin and features like Confidential Transactions does not fundamentally solve that legal problem of who actually has legal title to those assets.1516

Why should this matter to the average cryptocurrency enthusiast?

If market prices are being partially driven by predators and Ponzi schemes, wouldn’t it be in the best interest of the community to identity and remove those?17

Perversely the short answer to that is no. If Bob owns a bunch of the a cryptocurrency that is benefiting from this price appreciation, then he may be less than willing to remove the culprits involved of driving the prices upward.

For example, one purported reason Trendon Shavers (“pirateat40”) was not immediately rooted out and was able to last as long as he did — over a year — is that his Ponzi activity (“Bitcoin Savings & Trust”) coincided with an upswing in market prices of bitcoin.18  Recall over time, BS&T raised more than 700,000 bitcoins.  Why remove someone whose activity created new demand for bitcoins? 19

But this incentive is short-sighted.

If the end goal of market participants and enthusiasts is to enable a market where the average, non-savvy user can use and trust, then giving them tools for provenance could be empowering.  Ironically however, by integrating KYC and provenance into a public blockchain, it removes the core — and very costly — characteristic of pseudonymous, censorship-resistant interaction.

Thus there will likely be push back for implementing a Kimberley Process: doxxing every step of provenance back to genesis (coin generation) with real world identities removes pseudonmity and consequently public blockchains would no longer be censorship-resistant.  And if you end up gating all of the on-ramps and off-ramps to a public chain, you end up just creating an overpriced permissioned-on-permissionless platform.

Despite this, Michael Gronager, CEO of Chainalysis, notes that:

Public ledgers are probably here to stay – difficult KYC/AML processes or not.  I probably see this as a Nash equilibrium – like in the ideal world all trees would be low and of equal height but there is no path to that otherwise optimal equilibrium.   We believe that fighting crime on Blockchains will both build trust and increase their use and value.

One way some market participants are trying to help law enforcement fight crime is through self-regulating organizations (SRO).

For instance, because we have seen time and time again that the market is not removing these bad actors from the market, several companies have created SROs to help stem the tide.  However, as of right now, efforts like the US-based “Blockchain Alliance” — a gimmicky name for a group of venture-backed Bitcoin companies — has limited capabilities.20 They have monthly calls to discuss education with one another in the West (e.g., what is coin mixing and how does it work?) but currently lack the teeth to plug the KYC/AML gaps in Asia.  Perhaps that will change over time.

And as one source explained: consider this, has any Bitcoin thief been caught?  Even when there is decent evidence, we are not aware of a Bitcoin thief that was actually found guilt of stealing bitcoin, yet.21  Thus an open to question to people who argue that cryptocurrencies are great because of transparency: a lot of bitcoin has been stolen, and no one has been found guilty for that crime.  Why not?

Process of elimination

Over the past six weeks, there has been very little deep research on why market prices have risen and fallen. Usually it is the same unfounded narratives: emerging market adoption; hedge against inflation; hedge against collapse of country X, Y or Z; hedge against Brexit; etc.  But no one provides any actual data, least of all the investors financing the startups that make the claims.

Perhaps the research that has been done on the matter was from Fran Strajnar’s team at BNC.  For instance, on June 1st they noted that:

brave new coinI reached out to Fran and according to him, in early June, “Somebody dropped many many millions ($) across 4 different Chinese Exchanges in a 2 hour period, without moving price – 4 days before the price rise started last week. Because it was over multiple exchanges and these trades were filled, we are digging into it further.”

If there was a standardized Kimberley Process used by all of these exchanges, it would be much easier to tell who is involved in this process and if those funds were based on proceeds of illicit activity.

Furthermore, barring such a Process, we can only speculate why journalists haven’t looked into this story:

(1) many of them do not have reliable contacts in East Asia
(2) those that do have contacts with exchange operators may not be getting the full story due to exchanges lacking KYC / KYCC / AML standards themselves
(3) some reporters and exchange operators own a bunch of cryptocurrencies and thus do not want to draw any negative attention that could diminish their net worth

Third parties such as Wedbush Securities and Needham have also published reports on price action, but these are relatively superficial in their analysis as they lack robust stats needed to fully quantify and explain the behavior we have seen.

Strangely enough, for all the pronouncements at conferences about how public blockchains can be useful for data analysis, very few organizations, trade media or analysts are publishing bonafide stats.

After all, who are the customers of these virtual currency exchanges?  Because of reporting requirement we know who uses Nasdaq and ICE, why don’t we know who uses virtual currency exchanges still?

Stopping predators

Two months ago I had a chance to speak with Marcus Swanepoel, CEO of BitX, about his experiences in Africa.  BitX coordinates with a variety of compliance teams to help block transactions tied to scams and Ponzi schemes. In the past, BitX has managed to help kill off two ponzi schemes and has tried to block MMM Global which has spread to Africa.

Earlier this spring, some MMM users that were blocked by BitX just moved to another competing local exchange that didn’t block such transactions. As a result, over the course of 8 weeks this exchange did more than 3x volume than BitX during same time frame.22 BitX has subsequently regained part of this market share partly due to MMM fading in popularity.

Why is MMM so successful?  Users are asked to upload videos onto Youtube of why MMM Global is great and why you should join and are then paid by MMM as a reward.  This becomes self-reinforcing in large part because of the unsavvy victims who are targeted.

But MMM isn’t to blame for everything.

For instance, in China there have been a variety of get-rich-quick Ponzi schemes that rose and blew up, such as an ant farm scheme in 2007.  And earlier this year, Ezubao, the largest P2P lending platform in China fell apart as a $7.6 billion Ponzi scam.23 No cryptocurrency was involved in either case.

Yet as Emin Gün Sirer pointed out, some of the activities such as The DAO, basically act as a naturally arising Ponzi.

In fact, one allegation over the past couple weeks is that The DAO attacker placed a short of 3,000 bitcoin on Bitfinex prior to attacking The DAO (which was denominated in ether).24  If there was a Kimberley Process in which all traders on all exchanges had to comply with a universal KYC / KYCC / AML standard, it would be much easier to identify the attackers as well as compensate the victims.

Similarly, because ransomware remains a “killer app” of cryptocurrencies such that companies, police stations, hospitals, elementary schools and even universities are now setting up Coinbase accounts and stockpiling cryptocurrencies to pay off hackers.  What is the aggregate demand of all of this activity?  If it is large, does it impact the market price?  And how would a Kimberley Process help provide restitution to the victims of this ransom activity?

A strawman Kimberley Process

How can you or your organization get involved in creating a Kimberley Process for cryptocurrencies?

Right now there is no global, industry standard for “best practices” in mutualizing, implementing, or carrying out KYC / AML provisions for cryptocurrencies.25

In writing this post, several sources suggested the following process to kick-start an effort:

(1) organize an industry-level event(s) which brings together:

(a) AML analytics companies
(b) representatives from regulatory bodies and law enforcement (e.g., FATF, FinCEN)
(c) KYC/AML practitioners
(d) existing market structures and utilities such as SIFMA, ROC, Swift (e.g., KYC registry, LEI)
(e) compliance teams from cryptocurrency exchanges and wallets

(2) at the event(s) propose a list of baseline standards that exchanges and wallets can try to implement and harmonize:

(a) what documentation is required for KYC / KYCC / AML
(b) other financial controls and accountability standards that can assist exchange operators (e.g., remove the ability for an operator to naked short against its own customer base)

(3) tying these standards together with a uniform digital identity management system could be the next step in this process.

On that last point, Fabio Federici, CEO of Skry (formerly Coinalytics), explained:

In general I believe the biggest unsolved problem is still identity and information sharing. Obviously you don’t want all your PII and transaction meta data on a public blockchain, as this information could not only be leveraged by profit seeking organizations, but also malicious actors. So the question becomes what’s the right framework for sharing the right amount of information with only the people that need access to it (maybe even only temporarily).

PII stands for personal identifying information.  In theory, Zcash (or something like it) has the potential to solve some of Fabio’s concerns: relevant info can be encoded in the transaction, and only the relevant parties can read it.  But this delves into “regulated data” which is a topic for another post.26

Similarly, Ryan Straus, an attorney at Riddell Williams and adjunct professor at Seattle University School of Law explained that:

Identity is central to the legal concept of property. Property systems are information systems: they associate identified entities with identified rights.  With the sole exception of real currency, possession or control is not conclusive indicia of ownership.

Factual fungibility simply makes it harder to prove that you have a better claim to a specific thing than the person who now possesses or controls it.  The hard part about what you have written about is that it is difficult to avoid conflating KYC (which involves identity of people) and the Kimberley Process (which involves identifying things).

In order to enable participants to share information without being unduly hounded by social media, it was also suggested that the presence of: investors, cryptocurrency press and cryptocurrency lobbying groups should kept to a minimum for the initial phase.


In addition to implementing additional financial controls and external audits, cryptocurrency exchanges and wallets adopting a Kimberley Process would help provide transparency for all market participants.

While it is probably impossible to remove all the bad actors from any system, reducing the amount of shadows they have to hide could provide assurances and reduce risks to market participants of all shapes and sizes.

However, the trade-off of implementing such a Process is that it negates the core utility that public blockchains provide, turning them into expensive permissioned gateways.  And if you are permissioning activity from the get-go, you might as well use a permissioned blockchain which are cheaper to manage and operate and also natively bake-in the KYC, KYCC and AML requirements.  But that is a topic for another post as well.

End notes

  1. One reviewer argued that analytics may be superior to KYC.  In the event of a compromised account — so goes the argument — analytics can help provide linkage between the flow of funds whereas KYC of compromised accounts would be “illusory.” []
  2. This includes but is not limited to: Chainalysis, Blockseer, Skry, Elliptic, Netki and ScoreChain. []
  3. Incidentally there is a UK-based startup called Everledger which works with insurance companies and tracks a catalogue of diamonds vis-à-vis a blockchain. []
  4. See: Flow of Funds; KYSF; KYSF part 2; and bitcoin movements. To actively monitoring transactions at these entry and exit points, based on anecdotes, up to 20% of all nodes on the Bitcoin network may be managed and operated by these same set of participants as well. []
  5. Note: it bears mentioning that as of this writing, no country has recognized cryptocurrencies as actual legal tender and consequently cryptocurrencies are not exempt from nemo dat. This is important as it means the provenance of the cryptocurrencies actually does matter because those assets could be encumbered. []
  6. I asked around and my sources do not know of a single exchange that does KYC/AML on cryptocurrencies that are directly exchanged for other cryptocurrencies (e.g., Shapeshift).  Furthermore, as highlighted in the past, there are gaps in compliance when it comes to certain fiat-to-cryptocurrency exchanges such as BTC-e and LocalBitcoins. []
  7. This is in USD equivalence, usually not in USD itself. []
  8. OctaCoin is interesting in that the operators behind it claim that it is financed from revenue streams of 3 online casinos who purportedly payout users on a regular basis. Note: gambling in China is a bit like golf in China: it’s illegal but everywhere. It is only legal in a few internal jurisdictions such as Hainan and Macau and elsewhere on the mainland only a couple of state-run lotteries are given legal status. []
  9. Note: stealing electricity to mine bitcoins has occurred in other areas of the world too, including in The Netherlands. []
  10. The official motivation for developing Confidential Transactions is to enable more user privacy which then leads to more fungibility. As one source pointed out: “At the end of the day it’s a balance between privacy and security. Basically the story goes ‘just because I don’t what anyone to know what I’m buying, doesn’t mean I’m a drug dealer.'” []
  11. Marquardt also allegedly co-owns both Bitcoin.org and Blockexplorer.com, and co-manages the Bitcoin Wiki. []
  12. Here’s another video showing some of those transactions. []
  13. The Craig Wright / Satoshi saga is interesting because in a recent interview Craig admittedly used Liberty Reserve which was an illicit exchange based in Costa Rica shut down by the US government.  According to the interview he also had ties to Ross Ulbricht, the convicted operator of Silk Road. []
  14. See The Law of Bitcoin, Section 1.5 in the United States chapter from Ryan Straus.  There are exceptions, see UCC Article 2 – sale of goods. []
  15. See also: Learning from the past to build an improved future of fintech []
  16. Interestingly, SharedCoin.com (sometimes referred to as Shared Send) used to be a mixer run by Blockchain.info, a venture-backed startup.  It was recently shutdown without any notice and the domain now redirects to the CoinJoin wiki entry.  They also pulled the SharedCoin github repo and any material that links it back to Blockchain.info. []
  17. One reviewer mentioned that: “Ponzi schemes will always exist and should probably be fought not just in the crypto space but where in other industries too; requiring continuous education.  It would be way simpler and more effective to shut down domains owned by MMM than it would to be to do anything else, but here you actually meet the pseudonymity feature of the Internet.  Try to do that internationally – it is not easy!” []
  18. From between September 2011 to September 2012 market prices more than doubled.  See SEC vs. Trendon Shavers []
  19. Note: this is a similar argument that Rick Falkvinge made three years ago. []
  20. There are probably several dozen advocacy groups and non-profit working groups scattered across the world.  Each has different goals.  For instance, ACCESS in Singapore works with some regulators in SEA.  While others are merely trying to create technical standards. []
  21. Most of the criminals that are convicted are found guilty of money laundering and interaction with illicit trade, not theft of bitcoins themselves. []
  22. Two months ago, the Financial Times briefly covered this story and Marcus wrote about some of it in March as well. []
  23. There were some early warning signs for that industry.  For instance, according to a Bloomberg story in February 2015: “The value of China’s peer-to-peer lending transactions surged almost 13-fold since 2012 to $41 billion last year, according to Yingcan Group, which tracks the data,” notes Bloomberg. However, 275 of the more than 1,500 lending went bankrupt or had trouble repaying money in 2014, an increase from 76 just a year earlier, according to Yingcan. []
  24. No one has proven this allegation.  Furthermore, there are multiple exchanges to short cryptocurrencies. []
  25. Much of the technology needed to implement these type of processes, such as PKI anchored by certificate authorities. []
  26. For example, see HIPAA and EU-US Privacy Shield []
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Missing out on the tech-market fit

[Note: the views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

One oft-repeated claims from venture capitalists, such as Fred Wilson at Union Square Ventures who have gone “all in” with cryptocurrency-specific investments, is that “banks need to give bitcoin a chance.”

The problem with this claim is that it shows a lack of market intelligence.  Over the past 24 months, banks and many other types of financial institutions have worked on more than 200 proof-of-concepts (PoCs) and pilots with dozens of companies big and small.  Most of these experiments were conducted using a fork or clone of a public blockchain or even a cryptocurrency such as bitcoin or ether itself.

In other words banks and other financial institutions have given Bitcoin many chances and probably many more in the future.

But nearly all of the PoCs have been rejected and will continue to be rejected not because banks have a reflexive knee-jerk reaction due to Bitcoin’s perceived stigmas, but because Bitcoin was intentionally not designed to solve problems that banks have.

Typewriters and airplanes

Consider the typewriter analogy.  At one point in the mid-20th century, there were dozens of typewriter manufacturers shipping millions of kit each year.  Yet irrespective of the anachronistic enthusiasm that VCs who like typewriters may have, it is unlikely that banks will acquire large quantities of typewriters in 2016.  Not because banks don’t like typewriters or haven’t given typewriters a chance, but rather, typewriters as they currently exist, do not solve many problems that banks actually have.

As a consequence, there is a visible misalignment between the supply of startups funded by many of the VC firms that advocate cryptocurrency-specific solutions, with the services and solutions actually needed by regulated financial institutions.  For instance, Wilson’s current USV current portfolio consists of several Bitcoin companies whose business models largely depend on:

(1) continued price appreciation of bitcoin; and/or

(2) massive adoption of bitcoin demand itself.

While I certainly do not speak for the financial service industry, over the past year I have spoken to hundreds of directors and managing directors at highly regulated financial institutions.  And by and large, their pain points and problems are not solved by a cryptocurrency.  After all, they already have access to dozens and in many cases, hundreds of different financial instruments and assets.  As a consequence, cryptocurrencies alone do not provide the utility that certain VCs think it does for the financial industry.

For instance, at R3, we have spent over a year sitting down with many disparate financial institutions to find out what their internal problems are, gathering copious amounts of functional and non-functional requirements along the way.   We have done our homework on what various platforms can and cannot do, publishing many of the findings to our members and to the public as well.

In contrast, Satoshi probably did not conduct that type of sector specific due diligence in 2007-2008, the time frame he purportedly worked on Bitcoin.  Or if he did, he didn’t publish it; nor have VCs since.  In point in fact, the original white paper was not an architectural design document to rework back office, post-trade systems for banks.  Rather, it was a design document explaining how pseudonymous participants could try to become their own sovereign banks without the need for using existing institutional or legal infrastructure.

Another salient analogy are heavier-than-air aircraft.  Neither Airbus nor Boeing reuse the same design or materials that the Wright Brothers did in 1903 in order to build planes in 2016.

Instead, these modern aerospace companies build customized, fit-for-purpose vehicles that specialize in certain tasks, conditions and environments — and are often made of materials that didn’t exist 100 years ago.  Consequently, enthusiastic VCs that fund startups which build copies of the Wright Flyer are probably not going to find much market demand outside of museums.

What does this have to do with the world of blockchains?

Public blockchains, such as Bitcoin, were designed for an environment in which unknown and untrusted parties could attempt to interact in an anarchic system.  Bitcoin, through its intentionally expensive mining process, allows it to route around regulated gateways and purposefully eschewed any native method for complying with KYC, AML and other government mandated provenance requirements.

In contrast, banks and other financial institutions must, by law, know who all parties of a transaction are as all interactions are tied back into the traditional legal environment. And if you know who the participants to a transaction are — by connecting legal identities to them — then the tools and processes needed for this compliant environment are completely opposite to the design constraints and threats that cryptocurrencies are built around.

Training wheels and open fields

While a recent Bloomberg op-ed used a false equivalence – equating public and private blockchains as being able to provide the same utility – the bigger flaw with the op-ed was that it described private blockchains as “training wheels” for banks.

Public and private blockchains, as described above, were designed for different discrete purposes.

To use another aerospace example: calling private blockchains as a type of “training wheel” would be like saying that an A380 is a “training wheel” for commercial cargo air fleets that should instead, for some reason, be solely comprised of F-18s.  Both types of planes were built for different purposes, for different environments and with different operational constraints.  Because of tradeoffs, neither plane can do it all and there is no shame in that.

Similarly, the usage of the word “open” is being misused by Mr. Wilson and others.  Public blockchains are not “open” like the internet.  In fact, the internet is an amalgamation of intranets (ISPs) with peering agreements and a patchwork set of governance mandates which typically includes fulfilling some kind of gating and KYC mandate.  Yet despite the fact that the on-ramps and off-ramps of the internet are permission-based, creative inclusion continues to flourish because all participants leverage the utility of an open, shared standard: TCP/IP.  Bitcoin is not TCP/IP, rather, it is one instantiation, one application of what a blockchain can be look like.

Similarly, once a common shared ledger standard and fit-for-purpose platform is created for financial institutions, after the permissioning of users and most importantly — validators — is done, the ecosystem that plugs into it could see the flourishing of innovation including increased financial inclusion due to harmonized and mutualized utilities.  In other words, rather than having to spend $450 million a year to operate a network of miners to create unneeded pseudonymous consensus, financial institutions can and will participate in robust platforms that solve their business cases and simultaneously align with traditional legal requirements.


Cryptocurrencies such as Bitcoin do not and cannot do many of the things that many VCs and vocal enthusiasts claim it can.  For instance, public blockchains weren’t designed to provide definitive legal settlement finality anymore than F-18s were designed for crop dusting.  Bitcoin wasn’t designed to provide the types of utility regulated financial institutions require and changing Bitcoin to be customized for this relatively alien environment, not only breaks its pseudonymous utility but also its anarchic security assumptions.

Instead of haranguing prospective customers for not buying a product they don’t want or need – or attempting to shoehorn everything onto one niche blockchain – why not cultivate and partner with those who build solutions that solve business cases for a known customer base?  Other VC and strategic investment firms familiar with the pain points of financial institutions are now cultivating startups based on market demand, the fruits of their labor will begin to blossom in the coming years.

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What’s the deal with DAOs?

[Disclaimer: I do not own any cryptocurrencies nor have I participated in any DAO crowdfunding.]

This post will look at the difference between a decentralized autonomous organization (DAO) and a project called The DAO.

Brief explanation

The wikipedia entry on DAOs is not very helpful.  However, Chapters 2 through 5 may be of some use (although it is dated information).

In terms of the uber hyped blockchain world, at its most basic kernel, a DAO is a bit of code — sometimes called a “smart contract” (a wretched name) — that enables a multitude of parties including other DAOs to send cryptographically verifiable instructions (such as a digitally signed vote) in order to execute the terms and conditions of the cloud-based code in a manner that is difficult to censor.

One way to think of a simple DAO: it is an automated escrow agent that lives on a decentralized cloud where it can only distribute funds (e.g., issue a dividend, disperse payroll) upon on receiving or even not receiving a digital signal that a task has been completed or is incomplete.

For instance, let us assume that a small non-profit aid organization whose staff primarily work in economically and politically unstable regions with strict capital controls, set up a DAO — an escrow agent — on a decentralized cloud to distribute payroll each month.

This cloud-based escrow agent was coded such that it would only distribute the funds once a threshold of digital signatures had signed an on-chain contract — not just by staff members — but also from independent on-the-ground individuals who observed that the staff members were indeed doing their job.  Some might call these independent observers as oracles, but that is a topic for a different post.1

Once enough signatures had been used to sign an on-chain contract, the escrow agent would automatically release the funds to the appropriate individuals (or rather, to a public address that an individual controls via private key).  The terms in which the agent operated could also be amended with a predetermined number of votes, just like corporate board’s and shareholder’s vote to change charters and contracts today.

The purported utility that decentralization brings to this situation is that it makes censoring transactions by third parties more difficult than if the funds flowed through a centralized rail.  There are trade-offs to these logistics but that is beyond the scope of this post.

The reason the DAO acronym includes the “organization” part is that the end-goal by its promoters is for it to provide services beyond these simple escrow characteristics such as handling most if not all administrative tasks such as hiring and firing.

Watch out Zenefits, the cryptocurrency world is going to eat your lunch!  Oh wait.

A short history

It is really easy to get caught up in the euphoria of a shiny new toy.  And the original goal of a DAO sounds like something out of science fiction —  but these undertones probably do it a disservice.

Prior to 2014 there had been several small discussions around the topic of autonomous “agents” as it related to Bitcoin.

For instance, in August 2013, Mike Hearn gave a presentation at Turing Festival (see above), describing what was effectively a series of decentralized agents that operated logistical companies such as an autonomous car service.

Several months later, Vitalik Buterin published the Ethereum white paper which dove into the details of how to build a network — in this case a public blockchain — which natively supported code that could perform complex on-chain tasks: or what he dubbed as a decentralized autonomous organization.


The impetus and timing for this post is based on an ongoing crowdsale / crowdfunding activity for the confusingly named “The DAO” that has drawn a lot of media attention.

Over the past year, a group of developers, some of whom are affiliated with the Ethereum Foundation and others affiliated with a company called Slock.it have created what is marketed as the first living and breathing DAO on the Ethereum network.

The organizers kicked off a month long token sale and at the time of this writing just over 10 million ether (the native currency of the Ethereum blockchain) — or approximately 13% of all mined ether — has been sent to The DAO.  This is roughly equivalent to over $100 million based on the current market price of ether (ETH).

In return for sending ether to The DAO, users receive an asset called a DAO Token which can be used in the future to vote on projects that The DAO wants to fund.2 It is a process that Swarm failed at doing.

An investment fund or a Kickstarter project?

I would argue that, while from a technical standpoint it is possible to successfully set up a DAO in the manner that The DAO team did, that there really isn’t much utility to do so in an environment in which censorship or the theft of funds by third parties will probably not occur.

That is to say, just as I have argued before that permissioned-on-permissionless is a shortsighted idea, The DAO as it is currently set up, is probably a solution to a problem that no one really has.3

Or in short, if you “invested” in The DAO crowdsale thinking you’re going to make money back from the projects via dividends, you might be better off investing in Disney dollars.


Putting aside securities regulations and regulators such as the SEC for a moment, most of the crowdsale “investors” probably don’t realize that:

  1. crowdfunding in general has a checkered track record of return-on-investment4
  2. crowdfunding in the cryptocurrency world almost always relies on the future appreciation of token prices in order to break-even and not through the actual creation of new features or tools (e.g., see Mastercoin/Omni which effectively flopped)
  3. that the funds, when dispersed to Slock.it and other “products,” could take years, if ever to return a dividend

Why would this pool of capital provide any better expected return-on-investment than others?

Or as Nick Zeeb explained to me:

My sense about The DAO is that it’s a fascinating experiment that I do not want to be part of. I also do not think that a committee of over 1,000 strangers will make wise investment decisions. Most good investment decisions are taken by courageous individuals in my opinion. Anything that can get past a big committee will probably not be the next Google. Imagine this pitch: “Hi I’m Larry and this is Sergey and we want to build the world’s 35th search engine.”

While it probably wasn’t the 35th search engine, tor those unfamiliar with the history of Google, Larry Page and Sergey Brin are the co-founders who created a search engine in what was then though a very crowded market.

So why the excitement?

I think part of it is quite simply: if you own a bunch of ether, there really isn’t much you can do with it right now.  This is a problem that plagues the entire cryptocurrency ecosystem.

Despite all the back-patting at conferences, the market is already filled with lots of different tokens. There is a glut of tokens which do not currently provide many useful things that you couldn’t already do with existing cash systems.5

Part of it also is that most probably think they will some become rich quick through dividends, but that probably won’t happen anytime soon, if at all.

With The DAO, only the development teams of projects that are voted and approved by The DAO (e.g., the thousands of users with DAO Tokens), will see any short term gains through a steady paycheck.  And it is only after they build, ship and sell a product that the original investors may begin seeing some kind of return.

Or in other words: over the past several weeks, the pooling of capital has taken place for The DAO.  In the future there will be various votes as to where that capital goes.  Shortly thereafter, some capital is deployed and later KPI’s will be assessed in order to determine whether or not funding should continue.  All the while some type of profit is sought and dividend returned.

Why, I asked another friend, would this pool of capital offer any better risk adjusted return-on-investment than other asset classes?

In his view:

The return might be high but so is the risk. Always adjust for risk. I think The DAO is better compared to a distributed venture capital firm. Whether that’s better or worse I don’t know — I mean you have the crowd deciding on investments. Or more realistically: nerds who know how to obtain ether (ETH) get to decide on investments.

Does that make them better VCs? Probably not. However, The DAO can decide to hire people with actual credentials to manage and select the investments, admitting its own weakness which would then turn into a strength. I think this can go either way but given the regulator is not prepared for any of this it will probably not work out in the short term.

Does the ‘design-by-giant-nerd-committee’ process work?

Over the past year we have already seen the thousands, probably tens-of-thousands of man-hours dropped into the gravity well that is known as the “block size debate.”  In which hundreds of passionate developers have seemingly argued non-stop on Slack, Twitter, reddit, IRC, conferences and so forth without really coming to an amicable decision any one group really likes.

So if block size-design-by-committee hasn’t worked out terribly well, will the thousands of investors in The DAO take to social media to influence and lobby one another in the future?  And if so, how productive is that versus alternative investment vehicles?

Redistributing the monetary base

Assuming Ethereum has an economy (which it probably doesn’t by most conventional measures), will The DAO create a deflationary effect on the Ethereum economy?

For instance, at its current rate, The DAO could absorb about 20% of the ether (ETH) monetary base.

Does that mean it permanently removes some of the monetary base?  Probably not.

For example, we know that there will be some disbursements to projects such as Slock.it, so there will be some liquidity from this on-chain entity.  And that future DAOs will spend their ether on expenses and development like a normal organization.

But we also know that there is a disconnect between what The DAO is, an investment fund, with what many people see it as: a large vault filled with gold laying in Challenger Deep that will somehow appreciate in value and they will be able to somehow extract that value.

Sure, we will all be able to observe that the funds exist at the bottom of the trench, but someone somewhere has to actually create value with the DAO Tokens and/or ether.

For the same reason that most incubators, accelerators and VC funds fail, that entrepreneur-reliant math doesn’t change for The DAO.  Not only does The DAO need to have a large volume of deal flow, but The DAO needs to attract legitimate projects that — as my friend point out above — have a better risk adjusted return-on-investment than other asset classes.

Will the return-on-investment of the DAO as an asset class be positive in the “early days”?  What happens when the operators and recipients of DAO funds eventually confront the problem of securities regulation?

So far, most of the proposals that appear to be geared up for funding are reminiscent to hype cycles we have all seen over the past couple of years.

Let’s build a product…

  • 2014: But with Bitcoin
  • 2015: But with Blockchain
  • 2016: But with DAO

Maybe the funds will not all be vaporized, but if a non-trivial amount of ETH ends up being held in this DAO or others, it could be the case that with sluggish deal flow, a large portion of the funds could remain inert.  And since this ether would not touching any financial flows; it would be equivalent to storing a large fraction of M0 in your basement safe, siloed off from liquid capital markets.

Ten observations

  1. Since the crowdsale / crowdfund began on April 30, the market price of ETH has increased ~30%; is that a coincidence or is there new demand being generated due to The DAO crowdsale?
  2. A small bug has been discovered in terms of the ETH to DAO Token conversion time table
  3. The DAO surpassed the Ethereum Foundation to become the largest single holder of ether (note: the linked article is already outdated)
  4. In terms of concentration of wealth: according to Etherscan, the top 50 DAO Token holders collectively “own” 38.49% of The DAO
  5. The top 500 DAO Token holders collectively “own” 71.39% of The DAO
  6. As of this writing there are over 15,000 entities (not necessarily individuals) that “own” some amount of a DAO Token
  7. Why is “own” in quotation marks? Because it is still unclear if controlling access to these private keys is the same thing as owning them.  See also: Watermarked Tokens as well as The Law of Bitcoin
  8. Gatecoin, which facilitated the crowdsale of both The DAO and DigixDAO was recently hacked and an estimated $2 million in bitcoins and ether were stolen
  9. Yesterday Gavin Wood, a co-founder of Ethereum, announced that he is stepping down as a “curator” for The DAO.  Curators, according to him, are effectively just individuals who identify whether someone is who they say they are — and have no other duties, responsibilities or authority.
  10. Three days ago, the Slock.it dev team — some of whom also worked on creating The DAO — did a live Q/A session that was videotaped and attempted to answer some difficult questions, like how many DAO Tokens they individually own.


About 17 months ago I put together a list of token crowdsales.  It would be interesting to revisit these at some point later this year to see what the return has been for those holders and how many failed.

For instance, there hasn’t really been any qualitative analysis of crowdsales or ICOs in beyond looking at price appreciation.6 What other utility was ultimately created with the issuance of say, factoids (Factom tokens) or REP (Augur tokens)?

Similarly, no one has really probed Bitcoin mining (and all POW mining) through the lens of a crowdsale on network security. Is every 10 minutes an ICO? After all, the scratch-off contest ties up capital seeking rents on seigniorage and in the long run, assuming a competitive market, that seigniorage is bid away to what Robert Sams has pointed out to where the marginal cost equals the marginal value of a token. So you end up with this relatively large capital base — divorced from the real world — that actually doesn’t produce goods or services beyond the need to be circularly protected via capital-intensive infrastructure.

Other questions to explore in the future include:

  • what are the benefits, if any, of using a centralized autonomous organization (CAO) versus decentralized autonomous organization (DAO) for regulated institutions?
  • how can a party or parties sue a decentralized autonomous organization? 7
  • what are the legal implications of conducting a 51% attack on a network with legally recognized DAOs residing on a public blockchain?8
  • will the continued concentration of ether and/or DAO Tokens create a 51% voting problem identified in the “Curator” section?

Still don’t fully understand what The DAO is?  Earlier this week CoinDesk published a pretty good overview of it.

[Special thanks to Raffael Danielli, Robert Sams and Nick Zeeb for their thoughts]


  1. Note: for the purposes of The DAO, “curators” are effectively identity oracles. []
  2. It appears that currently, once a quorum is achieved, a relatively small proportion of token holders can vote “yes” to a proposal to trigger a large payout. []
  3. The current line-up of goods and services are not based around solving for problems in which censorship is a threat, such as those facing an aid worker in a politically unstable region. []
  4. That is not to say that they all fail. In fact according to one statistic from Kickstarter, there was a 9% failure rate on its platform. Thus, it depends on the platform and what the reward is. []
  5. CoinGecko is tracking several hundred tokens. []
  6. ICO stands for “initial coin offering” — it is slight twist to the term IPO as it relates to securities. []
  7. An added wrinkle to identifying liable parties is: what happens when systems like Zcash launch? []
  8. This presupposes that a DAO will gain legal recognition and/or a public blockchain gains legal standing as an actual legal record. []
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Book Review: The Business Blockchain

[Disclaimer: The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

William Mougayar is an angel investor who has been investigating the cryptocurrency and broader distributed ledger ecosystem over the past several years.

He recently published a book that looks at how enterprises and organizations should look at distributed ledgers and specifically, blockchains.

While it is better than “Blockchain Revolution” from the Tapscott’s, it still has multiple errors and unproven conjectures that prevent me from recommending it.  For instance, it does not really distinguish one blockchain from another, or the key differences between a distributed ledger and a blockchain.

Note: all transcription errors below are my own.


On p. xxii he writes:

“These are necessary but not sufficient conditions or properties; blockchains are also greater than the sum of their parts.”

I agree with this and wrote something very similar two years ago in Chapter 2:

While the underlying mathematics and cryptographic concepts took decades to develop and mature, the technical parts and mechanisms of the ledger (or blockchain) are greater than the sum of the ledger’s parts.

On p. xxiv he writes:

“Just like we cannot double spend digital money anymore (thanks to Satoshi Nakamoto’s invention), we will not be able to double copy or forge official certificates once they are certified on a blockchain.”

There are two problems with this:

  1. Double-spending can and does still occur, each month someone posts on social media how they managed to beat a retailer/merchant that accepted zero-confirmation transactions
  2. Double-spending can and is prevented in centralized architectures today, you don’t need a blockchain to prevent double-spending if you are willing to trust a party

Chapter 1

[Note: recommend that future editions should include labeled diagrams/tables/figures]

On p. 11 he writes:

“Solving that problem consists in mitigating any attempts by a small number of unethical Generals who would otherwise become traitors, and lie about coordinating their attack to guarantee victory.”

It could probably be written slightly different: how do you coordinate geographically dispersed actors to solve a problem in which one or more actor could be malicious and attempt to change the plan?  See also Lamport et al. explanation.

On p.13 he writes compares a database with a blockchain which he calls a “ledger.”

I don’t think this is an accurate comparison.

For instance, a ledger, as Robert Sams has noted, assumes ties to legal infrastructure.  Some blockchains, such as Bitcoin, were intentionally designed not to interface with legal infrastructure, thus they may not necessarily be an actual ledger.

To quote Sams:

I think the confusion comes from thinking of cryptocurrency chains as ledgers at all. A cryptocurrency blockchain is (an attempt at) a decentralised solution to the double spending problem for a digital, extra-legal bearer asset. That’s not a ledger, that’s a log.

That was the point I was trying to make all along when I introduced the permissioned/permissionless terminology!  Notice, I never used the phrase “permissionless ledger” — Permissionless’ness is a property of the consensus mechanism.

With a bearer asset, possession of some instrument (a private key in the cryptocurrency world) means ownership of the asset. With a registered asset, ownership is determined by valid entry in a registry mapping an off-chain identity to the asset. The bitcoin blockchain is a public log of proofs of instrument possession by anonymous parties. Calling this a ledger is the same as calling it “bearer asset ledger”, which is an oxymoron, like calling someone a “married bachelor”, because bearer assets by definition do not record their owners in a registry!

This taxonomy that includes the cryptocurrency stuff in our space (“a public blockchain is a permissionless distributed ledger of cryptocurrency”) causes so much pointless discussion.

I should also mention that the DLT space should really should be using the phrase “registry” instead of “ledger”. The latter is about accounts, and it is one ambition too far at the moment to speak of unifying everyone’s accounts on a distributed ledger.

Is this pedantic?  Maybe not, as the authors of The Law of Bitcoin also wrestle with the buckets an anarchic cryptocurrency fall under.

On p. 14 he writes about bank accounts:

“In reality, they provided you the illusion of access and activity visibility on it.  Every time you want to move money, pay someone or deposit money, the bank is giving you explicit access because you gave them implicit trust over your affairs.  But that “access” is also another illusion.  It is really an access to a database record that says you have such amount of money.  Again, they fooled you by giving you the illusion that you “own” that money.”

This is needless inflammatory.  Commercial law and bankruptcy proceedings will determine who owns what and what tranche/seniority your claims fall under.  It is unclear what the illusion is.

On p. 14 he writes:

“A user can send money to another, via a special wallet, and the blockchain network does the authentication, validation and transfer, typically within 10 minutes, with or without a cryptocurrency exchange in the middle.”

Which blockchain is he talking about?  If it is not digital fiat, how does the cash-in/cash-out work?  To my knowledge, no bank has implemented an end-to-end production system with other banks as described above.  Perhaps that will change in the future.

On p. 18 he writes:

“Sometimes it is represented by a token, which is another form of related representation of an underlying cryptocurrency.”

This isn’t very well-defined.  The reason I went to great lengths in November to explain what a “token” is and isn’t is because of the confusion caused by the initial usage of a cryptographic token, a hardware device from companies like RSA.  This is not what a “token” in cryptocurrency usage means. (Note: later on p. 91 he adds a very brief explanation)

On p. 18 he cites Robert Sams who is quoting Nick Szabo, but didn’t provide a source.  It is found in Seigniorage Shares.

On p. 18 he also writes:

“As cryptocurrency gains more acceptance and understanding, its future will be less uncertain, resulting in a more stable and gradual adoption curve.”

This is empirically not true and actually misses the crux of Sams’ argument related to expectations.

On p. 20 he writes:

“As of 2016, the Bitcoin blockchain was far from these numbers, hovering at 5-7 TPS, but with prospects of largely exceeding it due to advances in sidechain technology and expected increases in the Bitcoin block size.”

This isn’t quite correct.  On a given day over the past year, the average TPS is around 2 TPS and Tradeblock estimates by the end of 2016 that with the current block size it will hover around just over 3 TPS.

What is a sidechain?  It is left undefined in that immediate section.  One potential definition is that it is a sofa.

On p. 20 he writes:

“Private blockchains are even faster because they have less security requirements, and we are seeing 1,000-10,000 TPS in 2016, going up to 2,000-15,000 TPS in 2017, and potentially an unlimited ceiling beyond 2019.”

This is untrue.  “Private blockchains” do not have “less” security requirements, they have different security requirements since they involve known, trusted participants.  I am also unaware of any production distributed ledger system that hits 10,000 TPS.  Lastly, it is unclear where the “unlimited ceiling” prediction comes from.

On p. 20 he writes:

“In 2014, I made the strong assertion that the blockchain is the new database, and warned developers to get ready to rewrite everything.”

Where did you warn people?  Link?

On p. 21 he writes:

“For developers, a blockchain is first and foremost a set of software technologies.”

I would argue that it is first and foremost a network.

On p. 22 he writes:

“The fact that blockchain software is open source is a powerful feature. The more open the core of a blockchain is, the stronger the ecosystem around it will become.”

Some, but not all companies building blockchain-related technology, open source the libraries and tools.  Also, this conflates the difference between code and who can validate transactions on the network.  A “private blockchain” can be open sourced and secure, but only permit certain entities to validate transactions.

On p. 24 he writes:

“State machines are a good fit for implementing distributed systems that have to be fault-tolerant.”


On p. 25 he writes:

“Bitcoin initiated the Proof-of-Work (POW) consensus method, and it can be regarded as the granddaddy of these algorithms. POW rests on the popular Practical Byzantine Fault Tolerant algorithm that allows transactions to be safely committed according to a given state.”

There are at least two problems with this statement:

  • The proof-of-work mechanism used in Bitcoin is apocryphally linked to Hashcash from Adam Back; however this does not quite jive with Mougayar’s statement above. Historically, this type of proof-of-work predates Back’s contribution, all the way to 1992.  See Pricing via Processing or Combatting Junk Mail by Dwork and Naor
  • Practical Byzantine Fault Tolerance is the name of a specific algorithm published in 1999 by Castro and Liskov; it is unrelated to Bitcoin.

On p. 26 he writes:

“One of the drawbacks of the Proof-of-Work algorithm is that it is not environmentally friendly, because it requires large amounts of processing power from specialized machines that generate excessive energy.”

This is a design feature: to make it economically costly to change history.  It wasn’t that Satoshi conjured up a consensus method to be environmentally friendly, rather it is the hashrate war and attempt to seek rents on seigniorage that incentivizes the expenditure of capital, in this case energy.  If the market price of a cryptocurrency such as bitcoin declined, so too would the amount of energy used to secure it.

Chapter 2

On p. 29 he writes:

“Reaching consensus is at the heart of a blockchain’s operations.  But the blockchain does it in a decentralized way that breaks the old paradigm of centralized consensus, when one central database used to rule transaction validity.”

Which blockchain is he talking about?  They are not a commodity, there are several different unique types.  Furthermore, distributed consensus is an academic research field that has existed for more than two decades.

On p. 29 he writes:

“A decentralized scheme (which the blockchain is based on) transfers authority and trust to a decentralized network and enables its nodes to continuously and sequentially record their transactions on a public “block,” creating a unique” chain” – the blockchain.”

Mougayar describes the etymology of the word “blockchain” specific to Bitcoin itself.

Note: a block actually is more akin to a “batch” or “bucket” in the sense that transactions are bundled together into a bucket and then propagated.  His definition of what a blockchain is is not inclusive enough in this chapter though because it is unclear what decentralization can mean (1 node, 100 nodes, 10,000 nodes?).  Also, it is important to note that not all distributed ledgers are blockchains.

On p. 31 he writes:

“Credit card companies charge us 23% in interest, even when the prime rate is only at 1%”

Which credit card companies are charging 23%?  Who is being charged this?  Also, even if this were the case, how does a blockchain of some kind change that?

On p. 32 he writes:

“Blockchains offer truth and transparency as a base layer. But most trusted institutions do not offer transparency or truth. It will be an interesting encounter.”

This is just a broad sweeping generalization.  What does truth and transparency mean here?  Which blockchains?  Which institutions?  Cannot existing institutions build or use some kind of distributed ledger to provide the “truth” and “transparency” that he advocates?

On p. 33 he writes:

“The blockchain challenges the roles of some existing trust players and reassigns some of their responsibilities, sometimes weakening their authority.”

Typo: should be “trusted” not “trust.”

On p. 34 he writes:

“There is a lesson from Airbnb, which has mastered the art of allowing strangers to sleep in your house without fear.”

This is not true, there are many examples of Airbnb houses that have been trashed and vandalized.

On p. 34, just as the Tapscott’s did in their book, Mougayar talks about how Airbnb could use a blockchain for identity and reputation.  Sure, but what are the advantages of doing that versus a database or other existing technology?

On p. 37 he writes:

“Enterprises are the ones asking, because the benefits are not necessarily obvious to them.  For large companies, the blockchain presented itself as a headache initially. It was something they had not planned for.”

First off, which blockchain?  And which enterprises had a headache from it?

On p. 39 he writes: “Prior to the Bitcoin invention…”

He should probably flip that to read “the invention of Bitcoin”

On p. 40 he writes:

“… it did not make sense to have money as a digital asset, because the double-spend (or double-send) problem was not solved yet, which meant that fraud could have dominated.”

This is empirically untrue.  Centralized systems prevent double-spending each and every day.  There is a double-spending problem when you are using a pseudonymous, decentralized network and it is partially resolved (but not permanently solved) in Bitcoin by making it expensive, but not impossible, to double-spend.

On p. 41 he writes:

“They will be no less revolutionary than the invention of the HTML markup language that allowed information o be openly published and linked on the Web.”

This is a little redundant and should probably be rewritten as “the invention of the hypertext markup language (HTML).”

On p. 43 he writes:

“Smart contracts are ideal for interacting with real-world assets, smart property, Internet of Things (IoT) and financial services instruments.”

Why are smart contracts ideal for that?

On p. 46 he writes: “Time-stamping” and in other areas he writes it without a dash.

On p. 46 he writes:

“And blockchains are typically censorship resistant, due to the decentralized nature of data storage, encryption, and peer controls at the edge of the network.”

Which blockchains?  Not all blockchains in the market are censorship resistant.  Why and why not?

On p. 48 he mentions “BitIID” – this is a typo for “BitID”

On p. 51 he writes:

“Enter the blockchain and decentralized applications based on it. Their advent brings potential solutions to data security because cryptographically-secured encryption becomes a standard part of blockchain applications, especially pertaining to the data parts. By default, everything is encrypted.”

This is untrue.  Bitcoin does not encrypt anything nor does Ethereum.  A user could encrypt data first, take a hash of it and then send that hash to a mining pool to be added to a block, but the network itself provides no encryption ability.

On p. 52 he writes:

“Consensus in public blockchains is done publicly, and is theoretically subject to the proverbial Sybil attacks (although it has not happened yet).”

Actually, it has on altcoins.  One notable occurrence impacted Feathercoin during June 2013.

On p. 54 he writes:

“The blockchain can help, because too many Web companies centralized and hijacked what could have been a more decentralized set of services.”

This is the same meme in the Tapscott book.  There are many reasons for why specific companies and organizations have large users bases but it is hard to see how they hijacked anyone; but that is a different conversation altogether.

On p. 54 he writes:

“We can also think of blockchains as shared infrastructure that is like a utility. If you think about how the current Internet infrastructure is being paid for, we subsidize it by paying monthly fees to Internet service providers.  As public blockchains proliferate and we start running millions of smart contacts and verification services on them, we might be also subsidizing their operation, by paying via micro transactions, in the form of transaction fees, smart contract tolls, donation buttons, or pay-per-use schemes.”

This is a very liberal use of the word subsidize.  What Mougayar is describing above is actually more of a tax than a charitable donation.

The design behind Bitcoin was intended to make it such that there was a Nash equilibrium model between various actors.  That miners would not need to rely on charity to continue to secure the network because as block rewards decline, the fees themselves would in the long run provide enough compensation to pay for their security services.

It could be argued that this will not happen, that fees will not increase to offset the decline in block rewards but that is for a different article.

As an aside, Mougayar’s statement above then intersects with public policy: which blockchains should receive that subsidy or donation?  All altcoins too?  And who should pay this?


“Blockchains are like a virtual computer somewhere in a distributed cloud that is virtual and does not require server setups. Whoever opens a blockchain node runs the server, but not users or developers.”

This is untrue.  The ~6,400 nodes on the Bitcoin network are all servers that require setup and maintenance to run.  The same for Ethereum and any other blockchain.

On p. 58 he writes:

“It is almost unimaginable to think that when Satoshi Nakamoto released the code for the first Bitcoin blockchain in 2009, it consisted of just two computers and a token.”

A couple issues:

  1. There is a typo – “first” should be removed (unless there was another Bitcoin network before Bitcoin?)
  2. Timo Hanke and Sergio Lerner have hypothesized that Satoshi probably used multiple computers, perhaps more than a dozen.

On p. 58 he writes:

“One of the primary differences between a public and private blockchain is that public blockchains typically have a generic purpose and are generally cheaper to use, whereas private blockchains have a more specific usage, and they are more expensive to set up because the cost is born by fewer owners.”

This is not true.  From a capital and operation expenditure perspective, public blockchains are several orders of magnitude more expensive to own and maintain than a private blockchain.  Why?  Because there is no proof-of-work involved and therefore private blockchain operators do not need to spend $400 million a year, which is roughly the cost of maintaining the Bitcoin network today.

In contrast, depending on how a private blockchain (or distributed ledger) is set up, it could simply be run by a handful of nodes on several different cloud providers – a marginal cost.

Chapter 3

On p. 68 he writes:

“Taken as an extreme case, just about any software application could be rewritten with some blockchain and decentralization flavor into it, but that does not mean it’s a good idea to do so.”

Yes, fully agreed!

On p. 68 he writes:

“By mid-2016, there were approximately 5,000 developers dedicated to writing software for cryptocurrency, Bitcoin or blockchains in general. Perhaps another 20,000 had dabbled with some of that technology, or written front-end applications that connect to a blockchain, one way or the other.”

Mougayar cites his survey of the landscape for this.

I would dispute this though, it’s probably an order of magnitude less.

The only way this number is 5,000 is if you liberally count attendees at meetups or all the various altcoins people have touched over the year, and so forth.  Even the headcount of all the VC funded “bitcoin and blockchain” companies is probably not even 5,000 as of May 2016.

On p. 71 he writes:

“Scaling blockchains will not be different than the way we have continued to scale the Internet, conceptually speaking.  There are plenty of smart engineers, scientists, researchers, and designers who are up to the challenge and will tackle it.”

This is a little too hand-wavy.  One of the top topics that invariably any conversation dovetails into at technical working groups continues to be “how to scale” while keeping privacy requirements and non-functional requirements intact.  Perhaps this will be resolved, but it cannot be assumed that it will be.

On p. 72 he writes:

“Large organizations, especially banks, have not been particularly interested in adopting public blockchains for their internal needs, citing potential security issues. The technical argument against the full security of public blockchains can easily be made the minute you introduce a shadow of a doubt on a potential scenario that might wreak havoc with the finality of a transaction.  That alone is enough fear to form a deterring factor for staying away from public blockchain, although the argument could be made in favor of their security.”

This is a confusing passage.  The bottom line is that public blockchains were not designed with the specific requirements that regulated financial institutions have.  If they did, perhaps they would be used.  But in order to modify a public blockchain to provide those features and characteristics, it would be akin to turning an aircraft carrier into a submarine.  Sure it might be possible, but it would just be easier and safer to build a submarine instead.

Also, why would an organization use a public blockchain for their internal needs?  What does that mean?

On p. 78 he writes:

“Targeting Bitcoin primarily, several governments did not feel comfortable with a currency that was not backed by a sovereign country’s institutions.”

Actually, what made law enforcement and regulators uncomfortable was a lack of compliance for existing AML/KYC regulations.  The headlines and hearings in 2011-2013 revolved around illicit activities that could be accomplished as there were no tools or ability to link on-chain activity with real world identities.

Chapter 4

On p. 87 he writes:

“The reality is that customers are not going to the branch as often (or at all), and they are not licking as many stamps to pay their bills.  Meanwhile, FinTech growth is happening: it was a total response to banks’ lack of radical innovation.”

There are a couple issues going on here.

Banks have had to cut back on all spending due to cost cutting efforts as a whole and because their spending has had to go towards building reporting and compliance systems, neither of which has been categorized as “radical innovation.”

Also, to be balanced, manyh of the promises around “fintech” innovation still has yet to germinate due to the fact that many of the startups involved eventually need to incorporate and create the same cost structures that banks previously had to have.  See for instance, financial controls in marketplace lending – specifically Lending Club.

On p. 88 he writes:

“If you talk to any banker in the world, they will admit that ApplePay and PayPal are vexing examples of competition that simply eats into their margins, and they could not prevent their onslaught.”

Any banker will say that?  While a couple of business lines may change, which banks are being displaced by either of those two services right now?

On p. 89 he writes:

“Blockchains will not signal the end of banks, but innovation must permeate faster than the Internet did in 1995-2000.”

Why?  Why must it permeate faster?  What does that even mean?

On p. 89 he writes:

“This is a tricky question, because Bitcoin’s philosophy is about decentralization, whereas a bank is everything about centrally managed relationships.”

What does this mean?  If anything, the Bitcoin economy is even more concentrated than the global banking world, with only about a dozen exchanges globally that handle virtually all of the trading volume of all cryptocurrencies.

On p. 89 he writes:

“A local cryptocurrency wallet skirts some of the legalities that existing banks and bank look-alikes (cryptocurrency exchanges) need to adhere to, but without breaking any laws. You take “your bank” with you wherever you travel, and as long as that wallet has local onramps and bridges into the non-cryptocurrency terrestrial world, then you have a version of a global bank in your pocket.”

This is untrue.  There are many local and international laws that have been and continue to be broken involving money transmission, AML/KYC compliance and taxes.  Ignoring those though, fundamentally there are probably more claims on bitcoins – due to encumbrances – than bitcoins themselves.  This is a big problem that still hasn’t been dealt with as of May 2016.

On p. 95 he writes:

“The decentralization of banking is here. It just has not been evenly distributed yet.”

This is probably inspired by William Gibson who said: ‘The future is already here — it’s just not very evenly distributed.’

On p. 95 he writes:

“The default state and starting position for innovation is to be permissionless. Consequently, permissioned and private blockchain implementations will have a muted innovation potential.  At least in the true sense of the word, not for technical reasons, but for regulatory ones, because these two aspect are tie together.”

This is not a priori true, how can he claim this?  Empirically we know that permissioned blockchains are designed for different environments than something like Bitcoin.  How can he measure the amount of potential “innovation” either one has?

On p. 95 he writes:

“We are seeing the first such case unfold within the financial services sector, that seems to be embracing the blockchain fully; but they are embracing it according to their own interpretation of it, which is to make it live within the regulatory constraints they have to live with. What they are really talking about is “applying innovation,” and not creating it. So, the end-result will be a dialed down version of innovation.”

This is effectively an ad hominem attack on those working with regulated institutions who do not have the luxury of being able to ignore laws and regulations in multiple jurisdictions.  There are large fines and even jail time for ignoring or failing to comply with certain regulations.

On p. 95 he writes:

“That is a fact, and I am calling this situation the “Being Regulated Dilemma,” a pun on the innovator’s dilemma. Like the innovator’s dilemma, regulated companies have a tough time extricating themselves from the current regulations they have to operate within.  So, when they see technology, all they can do is to implement it within the satisfaction zones of regulators. Despite the blockchain’s revolutionary prognosis, the banks cannot outdo themselves, so they risk only guiding the blockchain to live within their constrained, regulated world.”

“It is a lot easier to start innovating outside the regulatory boxes, both figuratively and explicitly. Few banks will do this because it is more difficult.”

“Simon Taylor, head of the blockchain innovation group at Barclays, sums it up: “I do not disagree the best use cases will be outside regulated financial services. Much like the best users of cloud and big data are not the incumbent blue chip organizations.  Still their curioisity is valuable for funding and driving forward the entire space.” I strongly agree; there is hope some banks will contribute to the innovation potential of the blockchain in significant ways as they mature their understanding and experiences with this next technology.

An ending note to banks is that radical innovation can be a competitive advantage, but only if it is seen that way. Otherwise innovation will be dialed down to fit their own reality, which is typically painted in restrictive colors.

It would be useful to see banks succeed with the blockchain, but they need to push themselves further in terms of understanding what the blockchain can do. They need to figure out how they will serve their customers better, and not just how they will serve themselves better. Banks should innovate more by dreaming up use cases that we have not though about yet, preferably in the non-obvious category.

The fundamental problem with his statement is this: banks are heavily regulated, they cannot simply ignore the regulations because someone says they should.  If they fail to maintain compliance, they can be fined.

But that doesn’t mean they cannot still be innovative, or that the technology they are investigating now isn’t useful or helpful to their business lines.

In effect, this statement is divorced from the reality that regulated financial institutions operate in.  [Note: some of his content such as the diagram originated from his blog post]

On p. 102 he writes:

“Banks will be required to apply rigorous thinking to flush out their plans and positions vis-à-vis each one of these major blockchain parameters. They cannot ignore what happens when their core is being threatened.”

While this could be true, it is an over generalization: what type of business lines at banks are being threatened?  What part of “their” core is under attack?

On p. 103 he writes:

“More than 200 regulatory bodies exist in 150 countries, and many of them have been eyeing the blockchain and pondering regulatory updates pertaining to it.”

Surely that is a typo, there are probably 200 regulatory bodies alone in the US itself.

On p. 105 he writes:

“Banks will need to decide if they see the blockchain as a series of Band-Aids, or if they are willing to find the new patches of opportunity.  That is why I have been advocating that they should embrace (or buy) the new cryptocurrency exchanges, not because these enable Bitcoin trades, but because they are a new generation of financial networks that has figured out how to transfer assets, financial instruments, or digital assets swiftly and reliably, in essence circumventing the network towers and expense bridges that the current financial services industry relies upon.”

This is a confusing passage.

Nearly all of the popular cryptocurrency exchanges in developed countries require KYC/AML compliance in order for users to cash-in and out of their fiat holdings.  How do cryptocurrency exchanges provide any utility to banks who are already used to transferring and trading foreign exchange?

In terms of percentages, cryptocurrency exchanges are still very easy to compromise versus banks; what utility do banks obtain by acquiring exchanges with poor financial controls?

And, in order to fund their internal operations, cryptocurrency exchanges invariably end up with the same type of cost structures regulated financial institutions have; the advantage that they once had effectively involved non-compliance – that is where some of the cost savings was.  And banks cannot simply ignore regulations because people on social media want them to; these cryptocurrency sites require money to operate, hence the reason why many of them charge transaction fees on all withdrawals and some trades.

Chapter 5

On p. 115 he mentions La’Zooz and Maidsafe, neither of which – after several years of development, actually work.  Perhaps that changes in the future.

On p.118 he writes:

“There is another potential application of DIY Government 2.0. Suppose a country’s real government is failing, concerned citizens could create a shadow blockchain governance that is more fair, decentralized and accountable. There are at least 50 failed, fragile, or corrupt states that could benefit from an improve blockchain governance.”

Perhaps this is true, that there could be utility gain from some kind of blockchain.  But this misses a larger challenge: many of these same countries lack private property rights, the rule of law and speedy courts.

On p. 119 he writes about healthcare use cases:

“Carrying a secure wallet with our full electronic medical record in it, or our stored DNA, and allowing its access, in case of emergency.”

What advantage do customers gain from carrying this around in a secure wallet?  Perhaps they do, but it isn’t clear in this chapter.

On p. 126-127 he makes the case for organizations to have a “blockchain czar” but an alternative way to pitch this without all the pomp is simply to have someone be tasked with becoming a subject-matter expert on the topic.

On p. 131 he writes:

“Transactions are actually recorded in sequential data blocks (hence the word blockchain), so there is a historical, append-only log of these transaction that is continuously maintained and updated.  A fallacy is that the blockchain is a distributed ledger.”

It is not a fallacy.

Chapter 7

On p. 149 he writes: “What happened to the Web being a public good?”

Costs.  Websites have real costs.  Content on those websites have real costs.  And so forth.  Public goods are hard to sustain because no one wants to pay for them but everyone wants to use them.  Eventually commercial entities found a way to build and maintain websites that did not involve external subsidization.

On p. 150 he writes:

“Indeed, not only was the Web hijacked with too many central choke points, regulators supposedly continue to centralize controls in order to lower risk, whereas the opposite should be done.”

This conflicts with the “Internet is decentralized” meme that was discussed throughout the book.  So if aspects of the Internet are regulated, and Mougayar disagrees with those regulations, doesn’t this come down to disagreements over public policy?

On p. 153 he writes:

“Money is a form of value.  But not all value is money. We could argue that value has higher hierarchy than money. In the digital realm, a cryptocurrency is the perfect digital money.  The blockchain is a perfect exchange platform for digital value, and it rides on the Internet, the largest connected network on the planet.”

Why are cryptocurrencies perfect?  Perhaps they are, but it is not discussed here.

On p. 153 he also talks about the “programmability” of cryptocurrencies but doesn’t mention that if fiat currencies were digitally issued by central banks, they too could have the same programmable abilities.

On p. 160 he predicts:

“There will be dozens of commonly used, global virtual currencies that will be considered mainstream, and their total market value will exceed $5 trillion, and represent 5% of the world’s $100 trillion economy in 2025.”

Perhaps that occurs, but why?  And are virtual currencies now different than digital currencies?  Or are they the same?  None of these questions are really addressed.


This book is quick read but unfortunately is weighed down by many opinions that are not supported by evidence and consequently, very few practical applications for enterprises are explained in detail.

For regulated businesses such as financial institutions, there are several questions that need to be answered such as: what are the specific cost savings for using or integrating with some kind of blockchain?  What are the specific new business lines that could be created?  And unfortunately the first edition of this book did not answer these types of questions.  Let us look again at a future version.

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Book review: Blockchain Revolution

[Disclaimer: The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]

A couple weeks ago I joked that while containment is impossible, it would be nice to know who patient-zero was for using the term “blockchain” without an article preceding it.  The mystery of who exactly removed the “a” before “blockchain” is probably residing on the same island that Yeti, Sasquatch, and the New England Patriot’s equipment team are now located.

The Tapscott’s, a Canada-based father-son duo, co-authored a new book that not only suffers from this grammatical faux pas but has several dozen errors and unproven assertions which are detailed in this review.

Below is a chapter-by-chapter look into a book that should have baked in the oven for a bit more time.  Note: all transcription errors are my own.

Chapter 1

On p. 5 the authors write:

“A decade later in 2009, the global financial industry crashed. Perhaps propitiously, a pseudonymous person or persons named Satoshi Nakamoto outlined a new protocol for a peer-to-peer electronic cash system using a cryptocurrency called bitcoin.”

Ignoring the current drama surrounding Craig Wright — the Australian who claims to be Satoshi — during the initial threads on Metzdowd, Satoshi mentioned he had been working on this project for 18 months prior; roughly mid-2007.  So it was more coincidental timing than intentional.

And much like other books on the same topic, the authors do not clarify that there are more than one type of blockchain in existence and that some are a type of distributed ledger.

For instance, on p. 6 they write:

“At its most basic, it is an open source code: anyone can download it for free, run it, and use it to develop new tools for managing transactions online.”

With the ‘it’ being a ‘blockchain.’  The problem with this grammatical issue is that we know empirically that there many different types of distributed ledgers and blockchains currently under development and not all of them are open sourced.  Nor does being open source axiomatically qualify something as a blockchain.

On p. 6 they write:

“However, the most important and far-reaching blockchains are based on Satoshi’s bitcoin model.”

That’s an opinion that the authors really don’t back up with facts later on.

In addition, on the same page they make the “encryption” error that also plagues books in this space: the Bitcoin blockchain does not use encryption.

For example, on page 6 they write:

“And the blockchain is encrypted: it uses heavy-duty encryption involving public and private keys (rather like the two-key system to access a safety deposit box) to maintain virtual security.”

Incorrect.  Bitcoin employs a couple different cryptographic processes, but it doesn’t use encryption.  Furthermore, the example of a ‘two-key system’ actually illustrates multisig, not public-private key pairs.

On p. 8 they write:

“Bankers love the idea of secure, frictionless, and instant transactions, but some flinch at the idea of openness, decentralization and new forms of currency.  The financial services industry has already rebranded and privatized blockchain technology, referring to it as distributed ledger technology, in an attempt to reconcile the best of bitcoin — security, speed, and cost — with an entirely closed system that requires a bank or financial institution’s permission to use.”

There is a lot of assumptions in here:

(1) it is unclear which “bankers” they are speaking about, is it every person who works at a bank?

(2) the term ‘openness’ is not very well defined, does that mean that people at banks do not want to have cryptographically proven provenance?

In addition, in order for something to be privatized it must have been public at first.  Claiming that the “blockchain” toolkit of ideas and libraries was privatized away from Bitcoin is misleading.  The moving pieces of Bitcoin itself are comprised of no less than 6 elements that previously existed in the cryptography and distributed systems communities.

The Bitcoin network itself is not being privatized by financial institutions.  In fact, if anything, empirically Bitcoin itself is being carved away by entities and efforts largely financed by venture capital — but that is a topic for another article.  Furthermore, research into distributed computing and distributed consensus techniques long predates Bitcoin itself, by more than a decade.

Lastly, and this is why it helps to clearly define words at the beginning of a book, it is important to note that some blockchains are a type of distributed ledger but not all distributed ledgers are blockchains.

On page 9 they write that:

“In 2014 and 2015 alone more than $1 billion of venture capital flooded into the emerging blockchain ecosystem, and the rate of investment is almost doubling annually.”

This is only true if you conflate cryptocurrency systems with non-cryptocurrency systems.  The two are separate and have completely different business models.  See my December presentation for more details about the divergence.

On p. 9 they write:

“A 2013 study showed that 937 people owned half of all bitcoin, although that is changing today.”

First off, this is a typo because the original article the authors cite, actually says the number is 927 not 937.  And the ‘study’ showed that about half of all bitcoins resided on addresses controlled by 937 on-chain entities.  Addresses does not mean individuals.  It is likely that some of these addresses (or rather, UTXOs) are controlled and operated by early adopters (like Roger Ver) as well as exchanges (like Bitstamp and Coinbase).

Furthermore, it is unclear from the rest of the book how that concentration of wealth is changing — where is that data?

On p. 18 they write about Airbnb, but with a blockchain.  It is unclear from their explanation what the technical advantage is of using a blockchain versus a database or other existing technology.

On p. 20 they write:

“Abra and other companies are building payment networks using the blockchain. Abra’s goal is to turn every one of its users into a teller. The whole process — from the funds leaving one country to their arriving in another — takes an hour rather than a week and costs 2 percent versus 7 percent or higher.  Abra wants its payment network to outnumber all physical ATMs in the world.  It took Western Union 150 years to get to 500,000 agents worldwide.  Abra will have that many tellers in its first years.”

There are at least 3 problems with this statement:

  1.  the authors conflate a blockchain with all blockchains; empirically there is no “the” blockchain
  2.  Abra’s sales pitch relies on the ability to convince regulators that the company itself just make software and doesn’t participate in money transmission or movement of financial products (which it does by hedging)
  3.  Abra was first publicly announced in March 2015 and then formally launched in the Philippines in October 2015.

Fast forward to May 2016 and according to the Google Play Store and Abra has only been downloaded about 5,000 times.

Perhaps it will eventually reach 500,000 and even displace Western Union, but the authors’ predictions that this will occur in one year is probably not going to happen at the current rate.

Furthermore, on p. 186 they write that “Abra takes a 25-basis-point fee on conversion.”

Will this require a payment processing license in each jurisdiction the conversion takes place?

On page 24 they write:

“Other critics point to the massive amount of energy consumed to reach consensus in just the bitcoin network: What happens when thousands or perhaps millions of interconnected blockchains are each processing billions of transactions a day?  Are the incentives great enough for people to participate and behave safely over time, and not try to overpower the network? Is blockchain technology the worst job killer ever?”

There are multiple problems with this statement:

  1.  on a proof-of-work blockchain, the amount of energy consumed is not connected with the amount of transactions being processed.  Miners consume energy to generate proofs-of-work irrespective of the number of transactions waiting in the memory pool.  Transaction processing itself is handled by a different entity entirely called a block maker or mining pool.
  2.  as of May 2016, it is unclear why there would be millions of interconnected proof-of-work blockchains.  There are perhaps a couple hundred altcoins, at least 100 of which are dead, but privately run blockchains do not need to use proof-of-work — thus the question surrounding incentives is a non sequitur.
  3.  while blockchains however defined may displace workers of some kind at some point, the authors never really zero in on what “job killing” blockchains actually do?

On p. 25 they write:

“The blockchain and cryptocurrencies, particularly bitcoin, already have massive momentum, but we’re not predicting whether or not all this will succeed, and if it does, how fast it will occur.”

Nowhere do the authors actually cite empirical data showing traction.  If there was indeed massive momentum, we should be able to see that from data somewhere, but so far that is not happening.  Perhaps that changes in the future.

The closing paragraph of Chapter 1 states that:

“Everyone should stop fighting it and take the right steps to get on board. Let’s harness this force not for the immediate benefit of the few but for the lasting benefit of the many.”

Who is fighting what?  They are presumably talking about a blockchain, but which one?  And why should people stop what they are doing to get on board with something that is ill-defined?

Chapter 2

On p. 30 they write that:

“Satoshi leveraged an existing distributed peer-to-peer network and a bit of clever cryptography to create a consensus mechanism that could solve the double-spend problem as well as, if not better than, a trusted third party.”

The word “trust” or variation thereof appears 11 times in the main body of the original Satoshi whitepaper.  Routing around trusted third parties was the aim of the project as this would then allow for pseudonymous interaction.  That was in October 2008.

What we empirically see in 2016 though is an increasingly doxxed environment in which it could be argued that ‘trusted’ parties could do the same job — movement of payments — in a less expensive manner.  But that is a topic for another article.

On p. 33 they write:

“So important are the processes of mining — assembling a block of transactions, spending some resource, solving the problem, reaching consensus, maintaining a copy of the full ledger — that some have called the bitcoin blockchain a public utility like the Internet, a utility that requires public support. Paul Brody of Ernst & Young thinks that all our appliances should donate their processing power to upkeep of a blockchain: “Your lawnmower or dishwasher is going to come with a CPU that is probably a thousand times more powerful than it actually needs, and so why not have it mine? Not for the purpose of making you money, but to maintain your share of the blockchain,” he said.  Regardless of the consensus mechanism, the blockchain ensures integrity through clever code rather than through human beings who choose to do the right thing.”

Let’s dissect this:

  1.  the process of mining, as we have looked at before, involves a division of labor between the entities that generate proofs-of-work – colloquially referred to as miners, and those that package transactions into blocks, called blockmakers.  Miners themselves do not actually maintain a copy of a blockchain, pools do.
  2.  while public blockchains like Bitcoin are a ‘public good,’ it doesn’t follow how or why anyone should be compelled to subsidize them, at least the reasons why are not revealed to readers.
  3.  the only reason proof-of-work was used for Bitcoin is because it was a way to prevent Sybil attacks on the network because participants were unknown and untrusted.  Why should a washing machine vendor integrate an expensive chip to do calculations that do not help in the washing process?  See Appendix B for why they shouldn’t.
  4.  because proof-of-work is used in a public blockchain and public blockchains are a public good, how does anyone actually have a “share” of a blockchain? What does that legally mean?

On p. 34 they write:

“The blockchain resides everywhere. Volunteers maintain it by keeping their copy of the blockchain up to date and lending their spare computer processing units for mining. No backdoor dealing.”

There are multiple problems with this:

  1.  to some degree entities that run a fully validating node could be seen as volunteering for a charity, but most do not lend spare computer cycles because they do not have the proper equipment to do so (ASIC hardware)
  2.  to my knowledge, none of the professional mining farms that exist have stated they are donating or lending their mining power; instead they calculate the costs to generate proofs-of-work versus what the market value of a bitcoin is worth and entering and exiting the market based on the result.
  3.  this is a contentious issue, but because of the concentration and centralization of both mining and development work, there have been multiple non-public events in which mining pools, mining farms and developers get together to discuss roadmaps and policy. Is that backdoor dealing?

On p. 35 they write:

“Nothing passes through a central third party; nothing is stored on a central server.”

This may have been true a few years ago, but only superficially true today.  Most mining pools connect to the Bitcoin Relay Network, a centralized network that allows miners to propagate blocks faster than they would if they used the decentralized network itself to do so (it lowers the amount of orphan blocks).

On p. 37 they write:

“The paradox of these consensus schemes is that by acting in one’s self-interest, one is serving the peer-to-peer (P2P) network, and that in turn affects one’s reputation as a member of the economic set.”

Regarding cryptocurrencies, there is currently no built-in mechanism for tracking or maintaining reputation on their internal P2P network.  There are projects like OpenBazaar which are trying to do this, but an on-chain Bitcoin user does not have a reputation because there is no linkage real world identity (on purpose).

On p. 38 they write:

“Trolls need not apply”

Counterfactually, there are many trolls in the overall blockchain-related world, especially on social media in part because there is no identity system that links pseudonymous entities to real world, legal identities.

On p. 39 the authors list a number of high profile data breaches and identity thefts that took place over the past year, but do not mention the amount of breaches and thefts that take place in the cryptocurrency world each year.

On p. 41 they write:

“Past schemes failed because they lacked incentive, and people never appreciated privacy as incentive enough to secure those systems,” Andreas Antonopoulos said. The bitcoin blockchain solves nearly all these problem by providing the incentive for wide adoption of PKI for all transaction of value, not only through the use of bitcoin but also in the shared bitcoin protocols.  We needn’t worry about weak firewalls, thieving employees, or insurance hackers. If we’re both using bitcoin, if we can store and exchange bitcoin securely, then we can store and exchange highly confidential information and digital assets securely on the blockchain.”

There are multiple problems with this statement:

  1.  it is overly broad and sweeping to say that every past PKI system has not only failed, but that they all failed because of incentives; neither is empirically true
  2.  Bitcoin does not solve for connecting real world legal identities that still will exist with our without the existence of Bitcoin
  3.  there are many other ways to securely transmit information and digital assets that does not involve the use of Bitcoin; and the Bitcoin ecosystem itself is still plagued by thieving employees and hackers

On p. 41 they write:

“Hill, who works with cryptographer Adam Back at Blockstream, expressed concern over cryptocurrencies that don’t use proof of work. “I don’t think proof of stake ultimately works. To me, it’s a system where the rich get richer, where people who have tokens get to decide what the consensus is, whereas proof of works ultimately is a system rooted in physics. I really like that because it’s very similar to the system for gold.”

There are multiple problems with this as well:

  1.  people that own bitcoins typically try to decide what the social consensus of Bitcoin is — by holding conferences and meetings in order to decide what the roadmap should or should not be and who should and should not be administrators
  2.  the debate over whether or not a gold-based economy is good or not is a topic that is probably settled, but either way, it is probably irrelevant to creating Sybil resistance.

On p. 42 they write:

“Satoshi installed no identity requirement for the network layer itself, meaning that no one had to provide a name, e-mail address, or any other personal data in order to download and use the bitcoin software. The blockchain doesn’t need to know who anybody is.”

The authors again conflate the Bitcoin blockchain with all blockchains in general:

  1.  there are projects underway that integrate a legal identity and KYC-layer into customized distributed ledgers including one literally called KYC-Chain (not an endorsement)
  2.  empirically public blockchains like Bitcoin have trended towards being able to trace and track asset movement back to legal entities; there are a decreasing amount of non-KYC’ed methods to enter and exit the network

On p. 43 they write:

“The blockchain offers a platform for doing some very flexible forms of selective and anonymous attestation. Austin Hill likened it to the Internet. “A TCP/IP address is not identified to a public ID. The network layer itself doesn’t know. Anyone can join the Internet, get an IP address, and start sending and receiving packets freely around the world. As a society, we’ve seen an incredible benefit allowing that level of pseudonymity… Bitcoin operates almost exactly like this. The network itself does not enforce identity. That’s a good thing for society and for proper network design.”

This is problematic in a few areas:

  1.  it is empirically untrue that anyone can just “join the Internet” because the Internet is just an amalgamation of intranets (ISPs) that connect to one another via peering agreements.  These ISPs can and do obtain KYC information and routinely kick people off for violating terms of service.  ISPs also work with law enforcement to link IP addresses with legal identities; in fact on the next page the authors note that as well.
  2.  in order to use the Bitcoin network a user must obtain bitcoins somehow, almost always — as of 2016 — through some KYC’ed manner.  Furthermore, there are multiple projects to integrate identity into distributed ledger networks today.  Perhaps they won’t be adopted, but regulated institutions are looking for ways to streamline the KYC/AML process and baking in identity is something many of them are looking at.

On p. 44 they write:

“So governments can subpoena ISPs and exchanges for this type of user data.  But they can’t subpoena the blockchain.”

That is not quite true.  There are about 10 companies that provide data analytics to law enforcement in order to track down illicit activity involving cryptocurrencies all the way to coin generation itself.

Furthermore, companies like Coinbase and Circle are routinely subpoenaed by law enforcement.  So while the network itself cannot be physically subpoenaed, there are many other entities in the ecosystem that can be.

On p. 46 they write:

“Combined with PKI, the blockchain not only prevents a double spend but also confirms ownership of every coin in circulation, and each transaction is immutable and irrevocable.”

The public-private key technology being used in Bitcoin does not confirm ownership, only control.  Ownership implies property rights and a legal system, neither of which currently exist in the anarchic world of Bitcoin.

Furthermore, while it is not currently possible to reverse the hashes (hence the immutability characteristic), blocks can and have been reorganized which makes the Bitcoin blockchain itself revocable.

On p. 47 they write:

“No central authority or third party can revoke it, no one can override the consensus of the network. That’s a new concept in both law and finance. The bitcoin system provides a very high degree of certainty as to the outcome of a contract.”

This is empirically untrue: CLS and national real-time gross settlement (RTGS) systems are typically non-reversible.  And the usage of the word contract here implies some legal standing, which does not exist in Bitcoin; there is currently no bridge between contracts issued on a public blockchain with that of real world.

On p. 50 they write:

“That was part of Satoshi’s vision. He understood that, for people in developing economies, the situation was worse.  When corrupt or incompetent bureaucrats in failed states need funding to run the government, their central banks and treasuries simply print more currency and then profit from the difference between the cost of manufacturing and the face value of the currency. That’s seigniorage. The increase in the money supply debases the currency.”

First off, they provide no evidence that Satoshi was actually concerned about developing countries and their residents.  In addition, they mix up the difference between seigniorage and inflation – they are not the same thing.

In fact, to illustrate with Bitcoin: seigniorage is the marginal value of a bitcoin versus the marginal cost of creating that bitcoin.  As a consequence, miners effectively bid up such that in the long run the cost equals the value; although some miners have larger margins than others.  In contrast, the increase in the money supply (inflation) for Bitcoin tapers off every four years.  The inflation or deflation rate is fully independent of the seigniorage.

Chapter 3

On p. 56 they quote Erik Vorhees who says:

“It is faster to mail an anvil to China than it is to send money through the banking system to China. That’s crazy!  Money is already digital, it’s not like they’re shipping palletes of cash when you do a wire.”

This is empirically untrue, according to SaveOnSend.com a user could send $1,000 from the US to China in 24 hours using TransFast. In addition:

  1.  today most money in developed countries is electronic, not digital; there is no central bank digital cash yet
  2.  if new distributed ledgers are built connecting financial institutions, not only could cross-border payments be done during the same day, but it could also involve actual digital cash

On p. 59 they write:

“Other blockchain networks are even faster, and new innovations such as the Bitcoin Lightning Network, aim to dramatically scale the capacity of the bitcoin blockchain while dropping settlement and clearing times to a fraction of a second.”

This is problematic in that it is never defined what clearing and settlement means.  And, the Bitcoin network can only — at most — provide some type of probabilistic settlement for bitcoins and no other asset.

On p. 67 they write:

“Private blockchains also prevent the network effects that enable a technology to scale rapidly. Intentionally limiting certain freedoms by creating new rules can inhibit neutrality. Finally, with no open value innovation, the technology is more likely to stagnate and become vulnerable.”

Not all private blockchains or distributed ledgers are the same, nor do they all have the same terms of service. The common theme has to do with knowing all the participants involved in a transaction (KYC/KYCC) and only certain known entities can validate a transaction.

Furthermore, the authors do not provide any supporting evidence for why this technology will stagnate or become vulnerable.

On p. 70 they write:

“The financial utility of the future could be a walled and well-groomed garden, harvested by a cabal of influential stakeholders, or it could be an organic and spacious ecosystem, where people’s economic fortunes grow wherever there is light.  The debate rages on, but if the experience of the first generation of the Internet has taught us anything, it’s that open systems scale more easily than closed ones.”

The authors do not really define what open and closed means here.  Fulfilling KYC requirements through terms of service at ISPs and governance structures like ICANN did not prevent the Internet from coming into existence.  It is possible to have vibrant innovation on top of platforms that require linkage to legal identification.

On p. 72 the authors quote Stephen Pair stating:

“Not only can you issue these assets on the blockchain, but you can create systems where I can have an instantaneous atomic transaction where I might have Apple stock in my wallet and I want to buy something or you.  But you want dollars.  With this platform I can enter a single atomic transaction (i.e., all or none) and use my Apple stock to send you dollars.”

This is currently not possible with Bitcoin without changing the legal system.  Furthermore:

  1.  this is probably not safe to do with Bitcoin due to how colored coin schemes distort the mining incentive scheme
  2.  from a technological point of view, there is nothing inherently unique about Bitcoin that would enable this type of atomic swapping that several other technology platforms could do as well

On p. 73 they write:

“Not so easy.  Banks, despite their enthusiasms for blockchain, have been wary of these companies, arguing blockchain businesses are “high-risk” merchants.”

Once again this shows how the authors conflate “blockchain” with “Bitcoin.”  The passage they spoke about Circle, a custodian of bitcoins that has tried to find banks to partner with for exchanging fiat to bitcoins and vice versa.  This is money transfer.  This type of activity is different than what a “blockchain” company does, most of whom aren’t exchanging cryptocurrencies.

On p. 74 they write:

“Third, new rules such as Sarbanes-Oxley have done little to curb accounting fraud. If anything, the growing complexity of companies, more multifaceted transactions, and the speed of modern commerce create new ways to hide wrongdoing.”

This may be true, but what are the stats or examples of people violating Sarbanes-Oxley, and how do “blockchains” help with this specifically?

On p. 78 they write:

“The blockchain returns power to shareholders. Imagine that a token representing a claim on an asset, a “bitshare,” could come with a vote or many votes, each colored to a particular corporate decision.  People could vote their proxies instantly from anywhere, thereby making the voting process for major corporate actions more response, more inclusive, and less subject to manipulation.”

First off, which blockchain?  And how does a specific blockchain provide that kind of power that couldn’t otherwise be done with existing non-blockchain technology?

On p. 80 they quote Marc Andreessen who says:

“PayPal can do a real-time credit score in milliseconds, based on your eBay purchase history — and it turns out that’s a better source of information than the stuff used to generate your FICO score.”

But what if you do not use eBay?  And why do you need a blockchain to track or generate a credit rating?

On p. 81:

“This model has proven to work.  BTCjam is a peer-to-peer lending platform that uses reputation as the basis for extending credit.”

BTCjam appears to have plateaued. They currently have a low churn rate on the available loans and they exited the US market 2 months ago.

On p. 83 they write:

“The blockchain IPO takes the concept further. Now, companies can raise funds “on the blockchain” by issuing tokens, or cryptosecurities, of some value in the company. They can represent equity, bonds, or, in the case of Augur, market-maker seats on the platform, granting owners the right to decide which prediction markets the company will open.”

From a technical perspective this may be possible, but from a legal and regulatory perspective, it may not be yet. Overstock has been given permission by the SEC to experiment with issuance.

On p. 86 they write:

“Bitcoin cannot have bail-ins, bank holidays, currency controls, balance freezes, withdrawal limits, banking hours,” said Andreas Antonopoulos.

That’s not quite true.  Miners can and will continue to meet at their own goals and they have the power to hard fork to change any of these policies including arbitrarily increasing or decreasing the issuance as well as changing fees for faster inclusion.  They also have the ability to censor transactions altogether and potentially — if the social value on the network increases — “hold up” transactions altogether.

Also, this doesn’t count the subsidies that miners receive from the utilities.

On p. 98 they write:

“To this last characteristic, Antonopoulos notes: “If there is enough financial incentive to preserve this blockchain into the future, the possibility of it existing for tens, hundreds, or even thousands of years cannot be discounted.”

It can arguably be discounted.  What evidence is presented to back up the claim that any infrastructure will last for hundreds of years?

On p. 100 they write:

“And just imagine how the Uniform Commercial Code might look on the blockchain.”

Does this mean actually embedding the code as text onto a blockchain?  Or does this mean modifying the UCC to incorporate the design characteristics of a specific blockchain?

On p. 102 they write:

“What interests Andreas about the blockchain is that we can execute this financial obligation in a decentralized technological environment with a built-in settlement system. “That’s really cool,” he said, “because I could actually pay you for the pen right now, you would see the money instantly, you would put the pen in the mail, and I could get a verification of that. It’s much more likely that we can do business.”

I assume that they are talking about the Bitcoin blockchain:

  1.  there is no on-chain settlement of fiat currencies, which is the actual money people are settling with on the edges of the network
  2.  since it is not fiat currency, it does not settle instantly.  In fact, users still have a counterparty risk involving delivery of the pen versus the payment.
  3.  if a central bank issued a digital currency, then there could be on-chain settlement of cash.

On p. 103 they write:

“If partners spends more time up front determining the terms of an agreement, the monitoring, enforcement, and settlement costs drop significantly, perhaps to zero.  Further, settlement can occur in real time, possibly in microseconds throughout the day depending on that deal.”

The DTCC published a white paper in January that explains they can already do near real-time settlement, but T+3 exists due to laws and other market structures.

On p. 105 they write that:

“Multisig authentication is growing in popularity. A start-up called Hedgy is using multisig technology to create futures contracts: parties agree on a price of bitcoin that will be traded in the future, only ever exchanging the price difference.”

As an aside, Hedgy is now dead.  Also, there are other ways to illustrate multisig utility as a financial control to prevent abuse.

On p. 106 they wrote that:

“The trouble is that, in recent business history, many hierarchies have not been effective, to the point of ridicule. Exhibit A is The Dilbert Principle, most likely one of the best-selling management books of all time, by Scott Adams. Here’s Dilbert on blockchain technology from a recent cartoon…”

The problem is that the cartoon they are citing (above) was actually a parody created by Ken Tindell last year.

The original Scott Adam’s cartoon was poking fun of databases and is from November 17, 1995.

On p. 115 they write:

“But the providers of rooms receive only part of the value they create. International payments go through Western Union, which takes $10 of every transaction and big foreign exchange off the top.”

Western Union does not have a monopoly on international payments, in fact, in many popular corridors they have less than 25% of market share.  In addition, Western Union does not take a flat $10 off every transaction.  You can test this out by going to their price estimator.  For instance, sending $1,000 from the US to a bank account in China will cost $8.

On p. 117 they write about a fictional blockchain-based Airbnb called bAirbnb:

“You and the owner have now saved most of the 15 percent Airbnb fee. Settlements are assured and instant.  There are no foreign exchange fees for international contracts.  You need not worry about stolen identity. Local governments in oppressive regimes cannot subpoena bAirbnb for all its rental history data. This is the real sharing-of-value economy; both customers and service providers are the winner.”

The problem with their statement is that cash settlements, unless it is digital fiat, is not settled instantly.  Identities can still be stolen on the edges (from exchanges).  And, governments can still issue subpoenas and work with data analytics companies to track provenance and history.

On p. 119 they write:

“Along comes blockchain technology.  Anyone can upload a program onto this platform and leave it to self-execute with a strong cryptoeconomical guarantee that the program will continue to perform securely as it was intended.”

While that may have been the case when these cryptocurrency systems first launched, in order to acquire ether (for Ethereum) or bitcoin, users must typically exchange fiat first.  And in doing so, they usually dox themselves through the KYC requirements at exchanges.

On p.123-124 they write about a ‘Weather decentralized application’ but do not discuss how its infrastructure is maintained let alone the Q-o-S.

On p.127 they write:

“Using tokens, companies such as ConsenSys have already issued shares in their firms, staging public offerings without regulatory oversight.”

The legality of this is not mentioned.

On p. 128 they write:

“Could there be a self-propagating criminal or terrorist organizations?  Andreas Antonopolous is not concerned.  He believes that the network will manages such dangers. “Make this technology available to seven and a half billion people, 7.499 billion of those will use it for good and that good can deliver enormous benefit to society.”

How does he know this?  Furthermore, the Bitcoin network itself is already available to hundreds of millions, but many have chosen not to use it.  Why is this not factored into the prediction?

On p.131 they write:

“What if Wikipedia went on the blockchain — call it Blockpedia.”

The total article text of English Wikipedia is currently around 12 gigabytes.  If it is a public blockchain, then how would this fit on the actual blockchain itself?  Why not upload the English version onto the current Bitcoin blockchain as an experiment?  What utility is gained?

From p. 129-144 they imagine seven ideas that are pitched as business ideas, but in most instances it is unclear what the value proposition that a blockchain provides over existing technology.

Chapter 6

On p. 148 they write that:

“The Internet of Things cannot function without blockchain payment networks, where bitcoin is the universal transactional language.”

What does that mean?  Does that mean that there are multiple blockchains and that somehow bitcoin transactions control other blockchains too?

On p. 152 they write:

“Last is the overarching challenge of centralized database technology — it can’t handle trillions of real-time transactions without tremendous costs.”

What are those costs?  And what specifically prevents databases from doing so?

On p. 153 they write:

“Other examples are a music service, or an autonomous vehicle,” noted Dino Mark Angaritis, founder of Smartwallet, “each second that the music is playing or the car is driving it’s taking a fraction of a penny out of my balance. I don’t have a large payment up front and pay only for what I use.  The provider runs no risk of nonpayment. You can’t do these things with a traditional payment networks because the fees are too high for sending fractions of a penny off your credit card.”

Depositing first and having a card-on-file are types of solutions that currently exist.  “Microtipping” doesn’t really work for a number of reasons including the fact that consumers do not like to nickel and dime themselves.  This is one of the reasons that ChangeTip had difficulties growing.

Furthermore, the tangential market of machine-to-machine payments may not need a cryptocurrency for two reasons:

  • M2M payments could utilize existing electronic payment systems via pre-paid and card-on-file solutions
  • The friction of moving into and out of fiat to enter into the cryptocurrency market is an unnecessary leg, especially if and when central bank digital currency is issued.

On pages 156-169 nearly all of the examples could use a database as a solution, it is unclear what value a blockchain could provide in most cases.  Furthermore, on p. 159 they discuss documentation and record keeping but don’t discuss how these records tie into current legal infrastructure.

Chapter 7

On p. 172 they write:

“We’re talking billions of new customers, entrepreneurs, and owners of assets, on the ground and ready to be deployed. Remember, blockchain transactions can be tiny, fractions of pennies, and cost very little complete.”

Maybe some transactions on some blockchains cost fractions of pennies, but currently not Bitcoin transactions.

On p.177 they write that “David Birch, a cryptographer and blockchain theorist, summed it up: “Identity is the new money.”

David Birch is not a cryptographer.

On p. 179 they write:

“Financing a company is easier as you can access equity and debt capital on a global scale, and if you’re using a common denominator — like bitcoin — you need not worry about exchange rates and conversation rates.”

Unless everyone is using one currency, this is untrue.

On p.185 they write:

“Sending one bitcoin takes about 500 bits, or roughly one one-thousandth the data consumption of one second of video Skype!”

But users still need to cash out on the other side which requires different infrastructure than Skype, namely money transmitter licenses and bank accounts.

On p. 192 they write that:

“Second, it can mean better protection of women and children. Through smart contracts, funds can be donated into escrow accounts, accessible only by women, say, for accessing food, feminine products, health care, and other essentials.”

How can a smart contract itself detect what gender the user is?

On p.194 they write:

“In jurisdictions like Honduras where trust is low in public institutions and property rights systems are weak, the bitcoin blockchain could help to restore confidence and rebuild reputation.”

How does Bitcoin do that?  What are the specific ways it can?

Chapter 8

On p. 202 they write:

“People can register their copyrights, organize their meetings, and exchange messages privately and anonymously on the blockchain.”

Which blockchain does this?  There are external services like Ascribe.io that purportedly let creators take a hash of a document (such as a patent) and store it into a blockchain.  But the blockchain itself doesn’t have that feature.

On p.214 they write:

“But surely a more collaborative model of democracy — perhaps one of that rewards participation such as the mining function — could encourage citizens’ engagement and learning about issues, while at the same time invigorating the public sector with the keen reasoning the nation can collectively offer.”


Chapter 10

On p. 255 they mention that Greek citizens during 2015 would’ve bought more bitcoins if they had better access to ATMs and exchanges.  But this is not true, empirically people typically try to acquire USD because it is more universal and liquid.  Perhaps that changes in the future, but not at this time.

On p. 260 they write:

“The cost for having no central authority is the cost of that energy,” said Eric Jennings, CEO of Filament, an industrial wireless sensor network. That’s one side of the argument. The energy is what it is, and it’s comparable to the cost incurred in securing fiat currency.”

Where is the citation?  The reason the costs of securing the Bitcoin network are currently around $400 million a year is because that is roughly the amount of capital and energy expended by miners to secure a network in which validators are unknown and untrusted.  If you know who the participants are, the costs of securing a network drop by several orders of magnitude.

On p. 261 they write about the BitFury Group, a large mining company:

“Its founder and CEO, Valery Vavilov, argued the view that machines and mining operations overall will continue to get more energy efficient and environmentally friendly.”

Actually what happens is that while the ASIC chips themselves become more energy efficient, miners in practice will simply add more equipment and maintain roughly the same energy costs as a whole.  That is to say, if a new chip is 2x as efficient as before, miners typically just double the acquisition of equipment — maintaining the same amount of energy consumption, while doubling the hashrate.  There is no “environmental friendliness” in proof-of-work blockchains due to the Red Queen Effect.

On p. 274 they write:

“There will be many attempts to control the network,” said Keonne Rodriguez of Blockchain. “Big companies and governments will be devoted to breaking down privacy. The National Security Agency must be actively analyzing data coming through the blockchain even now.”

With thousands of copies being replicated around the world, it’s unclear who actually is storing it, perhaps intelligence agencies are.  We do know that at least 10 companies are assisting compliance teams and law enforcement in tracking the provenance of cryptocurrency movements.

On p. 282 they write:

“Indeed, Mike Hearn, a prominent bitcoin core developer, caused a quite a stir in January 2015 when he wrote a farewell letter to the industry foretelling bitcoin’s imminent demise.”

Wrong year, it was in January 2016.

On p. 291 they write that:

“Licensed exchanges, such as Gemini, have gained ground perhaps because their institutional clientele know they’re now as regulated as banks.”

Actually, Gemini hasn’t gained ground and remains relatively flat over the past ~5 months.  Even adding ether to their list of assets didn’t move the dial.


Overall the book was published a little too early as there hasn’t been much real traction in the entire ecosystem.

The content and perspective is currently skewed towards telling the cryptocurrency narrative and seemingly downplays the important role that institutions and enterprises have played over the past year in the wider distributed ledger ecosystem.

If you are looking for just one book to read on the topic, I would pass on this and wait for a future edition to rectify the issues detailed above.

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Self-doxxing, dynamic block making and re-decentralization of mining

There are currently two popular interrelated narratives on social media surrounding participation of the block making process on a public blockchain.  The stories are most pronounced within the Bitcoin community but are also reused by Litecoin, Ethereum and other cryptocurrencies too.

This includes the unchallenged statements that:

(1) anyone can still participate in block making, it is ungated and “permissionless”

(2) following a reward halving (“halvening”), networks become more decentralized because large, centralized farms and actors split apart due to economic pressures

This post looks at both of these and show that in practice neither is really true as of April 2016.

Named block makers

A year ago I reflected on some of the debate surrounding permissioned and permissionless blockchains.  Part of that post involved looking at how the mining market actually evolved in practice; not just based on the generalized claims made by enthusiasts at conferences.

For instance, based on block height below is a list of the first time a pool self-doxxed and signed a coinbase transaction, courtesy of Organ of Corti.  Only the first 50 are chronologically included:

Pool name                Block height                   Date
Eligius 130635 14-Jun-11
BitMinter 152246 7-Nov-11
BTC Guild 152700 10-Nov-11
Nmcbit.com 153343 15-Nov-11
YourBTC 154967 27-Nov-11
simplecoin.us 158291 20-Dec-11
Ass Penny Pool 161432 10-Jan-12
btcserv.net 163672 25-Jan-12
Slush 163970 27-Jan-12
BitLC 166462 12-Feb-12
pool.mkalinin.ru 170937 13-Mar-12
Bitclockers 173863 1-Apr-12
MaxBTC 174819 9-Apr-12
Triplemining 175144 11-Apr-12
CoinLab 180947 21-May-12
wizkid057 184148 12-Jun-12
Generated by General 194247 17-Aug-12
HHTT 197602 7-Sep-12
Ozcoin 207017 8-Nov-12
EclipseMC 208419 18-Nov-12
MTRed 219115 2-Feb-13
50BTC.com 219933 7-Feb-13
Bitparking 226272 17-Mar-13
Discus Fish 236494 17-May-13
ASICMiner 237050 20-May-13
ST Mining Corp 238456 29-May-13
Satoshi Systems 245445 8-Jul-13
GHash.IO 250205 5-Aug-13
175btc.com 253884 24-Aug-13
For Pierce and Paul 259214 21-Sep-13
Alydian5335 261051 1-Oct-13
Megabigpower 261530 4-Oct-13
GIVE-ME-COINS 267919 4-Nov-13
Polmine 282943 29-Jan-14
KoiSystems 285715 14-Feb-14
AntPool 286681 19-Feb-14
MMPool 294747 8-Apr-14
KNC Miner 300700 14-May-14
Bitfinex pool 306406 18-Jun-14
BitAffNet 309657 8-Jul-14
Bitfury 311333 18-Jul-14
Hashmine.io 313882 4-Aug-14
Solo.ckpool 319980 10-Sep-14
Kano.is 325306 14-Oct-14
BTCChina Pool 327211 27-Oct-14
Tangpool 339210 16-Jan-15
For Pyra 339547 19-Jan-15
BW Pool 341167 30-Jan-15
Huobi 341760 3-Feb-15
Dot pool 342104 6-Feb-15

Recall that even though it didn’t initially sign coinbase transactions, Slush began publicly operating at the end of November 2010.  Eligius was announced on April 27, 2011.  DeepBit publicly launched on February 26, 2011 and at one point was the most popular pool, reaching for a short period in July 2011, more than 50% of the network hashrate.

While many enthusiasts claim that “anyone can mine,” in practice, very few choose to for a number of reasons that will be discussed below.

But more to the point, the reason cryptocurrencies allegedly have a “permissionless” characteristic in the first place has to do exclusively with the fact that there is no administrative gating or vetting process for allowing actors on the network to participate in the block making process.  In 2009 there was no whitelist, blacklist, KYC or KYM (know your miner) process.

That is to say, those wanting to create a block did not need permission from a network administrator.1  That is the sole context of the term “permissionless.”

It is not related to developing other platforms that plug into the network.  It is not related to whether the network codebase is open source or not.  It is not related to being able to build software products that somehow utilize the network.  It is not related to being able to view or not view transactions.

Yet due to how the market evolved, today in 2016 while everyone is still paying for the high marginal costs to maintain a network designed for pseudonymous and anonymous interaction, few participants, specifically block makers, are actually capitalizing off of that utility.

For instance:

(1) Acquiring the necessary hardware to become a profitable miner invariably leaves a paper trail.  If instead you acquire the hardware on the second-hand market — in order to remain anonymous — you will still likely leave a paper trail with your legal identity in order to pay for the large energy bill and property taxes.  This is one of the reasons why miners in locations such as China do not publicize their fundraising activities or annual revenue: they don’t want to leave a paper trail to pay any extra taxes.2

(2) The other main mechanism for vetting miners now is through the use of data science itself.  Roughly 10 companies globally provide law enforcement, compliance teams and regulators access to relatively robust analytics tools to track provenance of bitcoins (or other cryptocurrencies) back to coin generation itself.  And in order to sell these mined bitcoins (e.g., to pay for the electricity and the mining hardware), nearly every bitcoin conversion to fiat marketplace now requires some compliance of local KYC and AML regulations.

While there are workarounds such as LocalBitcoins and SharedCoin, generally speaking the pseudonymous network itself in 2016 has largely become doxxed.  Yet the high costs of maintaining pseudonymity, via proof-of-work, still remain.

Hashrate distribution

Above is a pie chart that estimates the hashrate distribution among mining pools over the past 4 days (as of late April 2016).  The 10 largest pools collectively made 97% of the blocks during that time period.3

What about beyond 4 days?


Source: Blocktrail

Above is the pool distribution of the past year based on coinbase data aggregated by Blocktrail.

The 10 largest pools collectively account for roughly 91.6% of all block making activity.  There is also a relatively long tail that includes roughly another 60 entities (some of whom do sign coinbase transactions) that represent the remaining 8.4% of all block making the past year.

Why do any actors sign transactions at all, after all, isn’t a core characteristic of a public blockchain pseudonymous consensus?  To my knowledge, no one has formally published a thorough explanation for the reasons why.  But one repeated rationale is that pools do so in order to prove to the miners (hashers) connected to the pool what the provenance of the block reward income is.

What does that mean?

For those who have never partaken in the mining process before, a quick history lesson: within the first two years of Bitcoin’s existence a division of labor arose in which block making became separated from hashing itself (e.g., generating proofs-of-work).

That is to say, the security of network security was outsourced to entities who create proofs-of-work and who are colloquially referred to as miners.4  Miners, in return for steady payouts of income, send their work to a pool operator who subsequently batches transactions together into blocks and pays workers based on a pre-arranged agreement (usually proportional, share-based).5

Today, if average Joe buys ASIC mining equipment, he typically does not connect them to his own pool but instead connects them to a pool run by Bob the devops professional.6  And how can Joe trust Bob not to shave off pennies from each share of work that Joe submits?

Block signing in theory provides some semblance of transparency: letting the hashers know if pool operators are skimming off the proceeds by not accurately reporting blocks found (e.g., income).

For instance, if a pool operator makes a block based off of the proof-of-work submitted by one of the hashers connected to a pool, such as Joe, but does not sign the coinbase, the pool operator can try to pretend that it didn’t win the block reward in the first place and therefore would not have to pay the workers (hashers).  This was allegedly more commonplace prior to 2013, before the advent of VC financed farms and pools.7 Now many of the medium and large hashing farm operators want to know the exact revenue number and hear good reasons for why some is missing or if the pool was just “unlucky.”8

Why doesn’t everyone become a block maker, after all, the process is billed as being “open” to all?

There are multiple reasons why, but the most important reason boils down to economics.  Dave Hudson has written about 10 different articles on the baked-in variance (inhomogenous Poisson process) that motivates individuals to continually pool  their mining effort versus solo mine.9 Spoiler alert: you are likely to be struck by lightning before you will ever create a block and reap a block reward by solo mining off of your laptop at home.

Other reasons for why few decide to become block-makers include: the added costs of providing DOS protection to your pool and the need to hire competent staff that can prevent and be on the lookout for problems like BGP hijacking which results in lost revenue.

This has not changed for multiple years and will likely not change for reasons discussed below.

Non-existent re-decentralization

With the upcoming Bitcoin block reward halving that is expected to take place in mid-July, there is a growing chorus of ‘hope’ that it will somehow lead to fewer large mining farms and pools.

This probably won’t occur for several simple reasons, namely due to economic incentives.

Recall that the major reasons why mining activity itself has gravitated to locations such as China isn’t due to conspiracy theories involving lizards but instead ancillary costs.

Specifically the following factors:

  • relatively low labor costs (e.g., professional hashing facilities need to be maintained by a workforce 24 x 7 and wages in China are lower than Russia and the US for this activity)
  • relatively low property costs (e.g., if you have good guanxi, you can utilize and own land at rates below those found in parts of Russia and the US)
  • lower energy costs; I and others have frequently written about this10
  • first-to-market with hardware; because a lot of the final assembly of hashing equipment takes place in southern China, in terms of logistics and transportation end-users have a lead-time advantage over other geographical regions
  • close personal connections with hardware manufacturers and fabrication plants in China and Taiwan; acquiring hardware for mining cryptocurrencies is just as relationship driven as other specialized non-commoditized industries.  Because medium and large miners know who the chip design teams are and what the ASIC roadmaps will be, they can stand in line at the front and acquire hardware before others.

What will happen after a block reward halving?

Just as oil producers with the highest marginal costs have been forced to exit the fracking market over the past couple of years, Bitcoin miners with the thinnest margins will likely exit the market immediately.

What this actually results in, at least the short run, is a more concentrated group of larger hashing farms and pools.


Because miners as a whole are effectively being given a 50% pay cut to provide the same utility as before.  And ceteris paribus, if Alice doesn’t currently have thick 50% margins, then she will likely exit the market.

In contrast, some of the most profitable miners in China and Republic of Georgia are now operating — even with the large difficulty rise over the past 6 months — with 50+% margins.  They may be squeezed, but they do not have to exit the market.

Basically, the less efficient players will be squeezed out and the more efficient players will remain.  Who is likely be be more efficient?  Larger farms in cheaper locations, or smaller pools made up of less sophisticated players with less capital?

But if the price of cryptocurrencies rise — in this case bitcoins — then won’t former miners come back into the market?

Maybe, but recall, we have seen this song and dance before and it is likely that the block reward halving is already factored into both the current market price and the hardware replacement cycle and as a result there probably will not be a doubling of the market price of bitcoins.  However, that is a topic for a different post.

Other public blockchains

What do mining pool distributions look like for other cryptocurrencies?

Above is the distribution of mining pools for Litecoin over the past day.  Interestingly, Coinotron — a pool I used when mining 3 years ago — currently represents 2.8% of the block making during that time frame.  Two years ago, in May 2014, it represented about 50%.

In August 2015, Litecoin underwent its first block reward halving.  Contrary to popular belief, its market price did not double.  In fact, nine months later the price of a litecoin measured in USD is just fifty cents higher than what it was pre-halving.11

Ethereum mining pool

Source: Etherchain

Above is the distribution of mining pools for Ethereum over the past day.

Interestingly Ethereum formally launched in August 2015 and has seen the same consistent pattern of 3-4 pools representing the majority of block making activity as other cryptocurrencies have witnessed.

In fact, Dwarfpool, despite its name, has flirted with the 50% threshold several times, most notably in March.  The Ethereum development team plans to transition the network from proof-of-work to proof-of-stake (Casper) later this year; it is unclear if the “staking” process will result in similar centralization.

Other cryptocurrencies continue to face similar pool centralization. This includes Namecoin which last year saw one pool, F2Pool provide more than 50% of the network hashrate for multiple months.  While it does not appear that F2Pool behaved maliciously, the fact that one block maker could potentially rewrite history by doing block reorgs motivated Onename to migrate away from Namecoin.


It is surprising that with the 60%+ hashrate located in China that there is scant detail in English about how that ecosystem works.  But there are reasons for this.

Recall that based on the current 25 BTC block reward, roughly $450 million in mining rewards has been divvied out over the past year to miners.  On paper that would mean that China-based miners received more than $270 million in revenue, which cements this industry as one of two that continually see large annual revenue flows (the second being exchanges themselves).

I contacted a mining operator in China that currently operates about 40 petahashes per second in equipment.  Note: miners use the abbreviated term ‘P’ and ‘PH’ to denote petahashes per second.

According to him:

“Our public hashing number is based on all our own hardware. This includes two facilities in western Sichuan plus a new Xinjiang site. All of these machines were originally S3’s from Bitmain but we have replaced them with S7’s.  We want to build larger operations than what we have today, but our goal is to maintain a specific percentage of the entire network.”

“Remember our electric rates changes from season to season: different time of year and that hydro power has problems in the winter because of less melt water which results in an energy price that is twice as the rate in the summer.”

“The land is basically free because it is in the mountains and no one is interested in buying property there. So all it takes is construction materials and labor. We hired 10 people last year. We intentionally hired more than we needed so we can build a team and send them places. Our front end operation probably only needs 4-5 people and we pay them $1,000 a month which is actually very competitive for that region.”

“We know a Chinese guy, Mr. LY.  He lives in Sichuan and was originally a hydroelectric operator but now owns his own hydro power station. He learned he could make more money mining than just running the station.”

“Why are people like us able to be competitive?  In Yunnan, Guizhou and Sichuan there was an overinvestment in hydropower last decade and now there is a surplus of electricity.12  Dam operators couldn’t sell the electricity generated so that’s where Bitcoin miners moved to. Also, in Liaoning, some people can free electricity because of the proximity to oil fields – they are given cheap electricity to local residents as compensation for confiscated land/polluting the environment — it is subsidized electricity.”

“No one really pays taxes because miners don’t generate something considered valuable. That’s to say from the perspective of taxpayer, miners don’t generate something of value, because the government doesn’t really recognize bitcoin. Bitcoin mining isn’t illegal, we still pay a small amount of taxes but it’s like running a company that doesn’t make money. Instead a miner just pays a small amount of taxes and all the profit is invisible to the law as it stands today.”

I also reached out to another mining operator based in southern China who explained that in practice, mining farms that produce 1 PH or more are usually not based in cities:

“Most of the time they are not in cities, more like in the middle of nowhere and it would be inaccurate to name towns.”

Instead he listed provinces where they are spread out including: Heilongjiang,Liaoning, Hebei, Sichuan, Tianjin, Anhui, Jiangsu, Ghuizhou, Inner Mongolia, Shanxi, Guangdong.  “Shenzhen for sure, there are testing facilities that are easily over 1P.”

What about ‘subprovincial’ locations?

“It is inaccurate to present information that way.  A lot of the time, the sites are between borders because it’s in the middle of nowhere.  And it normally spreads over lots of sites.  One place has nearly 200 sites crossing two provinces; a lot of small ones representing about 100KW of power each.  They are spread over several hundred kilometers; no economy of scale after a certain point.”

No service-level agreements

This type of self-doxxing, quasi-dynamic environment has led to another interesting phenomenon: ad hoc customer service via social media.

For example, two days ago, a user sent approximately 291.2409 bitcoins as a mining “fee.”13  A small pool called BitClub Network built the block that included this fee.  This fee is equivalent to about $136,000.

The community as a whole then began a crowdsourced investigation into who may have sent this fee and the motivations for doing so, with many believing it to be a mistake.  After all they reasoned, a typical “fee” that most mining pools require in order to be included in the next block is usually less than 25 cents on most days.

A user affiliated with BitClub has since publicly stated it would like to return the fee to the original entity that sent it, though it is unclear if he is speaking with any authority or if the whole thing was a ruse to begin with.

But, as I have argued before, this not only sets a bad precedent for miners as a whole due to a loss of revenue from the forthcoming ‘halvening,’ but the ability to contact a block maker sets a dangerous precedent for the core utility of the network: the disappearance of pseudonymous consensus.

Or as one redditor adroitly pointed out:

Or in other words, if block making was actually pseudoymous and decentralized, with 100+ unidentified pools creating blocks each day, it would be difficult if not impossible to locate and provide timely customer service to a user who made a mistake.

For instance, the most well-known block reorg occurred in March 2013 and it was only resolved when miners, including Slush and BTCGuild, contacted and coordinated with one another via IRC.  If the network was more decentralized and pseudonymous, this coordination would have been very difficult to do, and this was by design.

I pointed out this irony on Twitter earlier this week as well: that there are trade-offs with this approach and the downside of using a bearer asset-based system that had no service level agreement, no EULA, no terms of service results in a world in which users who make mistakes have to complain on social media and hope someone is charitable.

And this happens on a regular basis: earlier this month a user accidentally sent 13.65 bitcoins to the BTCC pool and used reddit as his customer service forum.

That type of friction is not what most consumers want.14  It is a poor user experience which has gradually led to the creation of ‘trusted’ intermediaries in this ecosystem which as described in previous posts, recreates the existing financial system but without the same level of oversight and financial controls.

The cryptocurrency community is learning the hard way why intermediaries exist, why SLAs exist, why legal identities are required for financial transactions, why consumer protection laws arose and so forth.  Pointing out these patterns is not malice or due to a lack of understanding of how cryptocurrencies work, but rather it serves as illustrations for why it has been hard to find real sustainable traction in the space.

How else is this visualized?

scaling bitcoin panel

Source: Jameson Lopp

This past December an event was held in Hong Kong called “Scaling Bitcoin.”

One of the sessions involved a panel comprised of the world’s largest mining farm and pool operators.

The individuals in the photo above allegedly represent about 90% of the network hashrate.

Thus, for all the hype around “trust anchors” tied into public blockchains such as Bitcoin, claims of decentralization and “trust-lessness” are empirically untrue.

In practice, due to centralization and identity leakage, the cost to successfully reorganize a block isn’t through a Maginot Line attack (e.g., via hashrate), but through cheaper out-of-band attacks, such as hosting events in which self-doxxed miners participate.  But that is also a topic for a different post.


16 months ago, Vitalik Buterin and others jokingly quipped that the trends towards centralization in Bitcoin mining (and other cryptocurrencies) resulted in a world where each coinbase transaction effectively arose from a multisig process.

To quote Buterin: “with Bitcoin, we’re paying $600 million a year on a 5-of-10 multisig.”

10 is roughly the amount of quasi-permanent block makers in a given day.  And $600 million was the amount of revenue that miners received at that time due to the higher market value of bitcoin.

In theory, anyone can turn on their computer and hope to become a block maker on a public blockchain — no one has to register with a “Blockchain Admin” because there is no admin.  However, in practice it requires a certain amount of technical knowledge and more importantly, capital, to profitably and sustainably operate a mining farm and pool.

And in order to scale this profitably, in practice, most miners at some point reveal their legal identities thereby negating the core characteristic of a public blockchain: pseudonymity.  How?  Miners, after having erected purpose-built facilities or to liquidate their holdings, may be required by external authorities to go through a gating / vetting process (such as KYC).

Ironically, a substantial increase in cryptocurrency prices may inevitably result in self-doxxing of all major farms. How?  As market prices increase, miners in turn expend more capital to increase their own hashrate to chase the seigniorage rents.

Because of the KYC requirements of utilizing resources like electricity at a hydroelectric dam and the subsequent identity leakage, this turns the block making process itself into a mostly known, permissioned activity.  Consequently, based on this past history, the term DMMS should probably be qualified with a “quasi” modifier in the front: QDMMS.

Similarly, while many enthusiasts have been led to believe a block reward halving will somehow re-decentralize the mining ecosystem, the fact of the matter is chip performance (as measured in hashrate efficiency) is only one factor in the total calculation that professional miners must account for.15

Furthermore, semiconductor engineering itself is effectively on a known, mature trajectory and which appears to be lacking any significant leaps in technological improvement.  The largest entities, such as Intel, see this relatively static path which is one of the reasons why they have formally abandoned their tick-tock roadmap and now plan to lay off 12,000 people.

In contrast, energy prices, land prices, labor costs and taxes are among other major components that professional mining operators look at as a whole and decide whether to stay in a market or not.  Even if there is some price increase after the halvening, home mining by amateurs outside of China will likely continue to remain unprofitable after July.

Thus a year from now the mining ecosystem will probably look a lot like it does today, with most farms and pools being self-doxxed and relatively centralized.16

[Special thanks to Antony Lewis for his constructive feedback]


  1. Censorship-resistance is an emergent property that arises from this design.  See also: Settlement Risks Involving Public Blockchains []
  2. There are other reasons too including not wanting to divulge any comparative advantage they might have that would incentivize new entrants to come into the market. []
  3. Note: it is believed that some large mining operators, such as Bitfury, may actually spread some of their hashers (workers) across multiple pools, in order to reduce their own pool percentage and thereby reduce the concerns over centralization.  This can only be proven with an on-site physical audit. []
  4. There has been research done on non-outsourceable block making. See Nonoutsourceable Scratch-Off Puzzles to Discourage Bitcoin Mining Coalitions by Miller et. al. []
  5. Analysis of Bitcoin Pooled Mining Reward Systems by Meni Rosenfeld []
  6. Most of the pools in operation do not require documentation of equipment or legal identification of miners. []
  7. Note: technically speaking nothing is stopping mining pools from signing blocks and in fact, some do it for advertising purposes. []
  8. There is also a term-of-art called “luck” which Organ of Corti and others analyze on a regular basis. []
  9. Incidentally for those wanting access to the block-making superhighway, to reduce orphan rates, there exists a centralized service: Bitcoin Relay Network. []
  10. See also Appendix B and Section 2 []
  11. Note: Dogecoin began to merge mine with Litecoin in September 2014 and in terms of hashrate the two have moved in tandem with one another ever since. []
  12. China’s water hegemony in Asia from Livemint []
  13. Note: a fee implies something that is mandatory.  The discussion surrounding what is and is not a fee or how it should be calculated and applied is a contentious topic in the cryptocurrency community. []
  14. Cryptocurrencies are effectively designed ‘for cypherpunks by cypherpunks.’  While caveat emptor may be desirable to certain demographics, others prefer consumer protection which bearer-based systems do not have. []
  15. Note: in terms of efficiency, 28nm chips are usually in the range of 0.25-0.35 watts/(gh/s), while the newer 14nm or 16nm ones are more likely 0.12 watts/(gh/s) or less. []
  16. See also: Permissioned-on-permissionless []
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