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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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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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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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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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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Reading the tea leaves

Three years since the current wave began and $1 billion later, cryptocurrency / public blockchain ecosystem is experiencing such a level of “fast growth” that no one is able to publish any real usage numbers.1

Sarcasm aside, despite copious amounts of news coverage, interviews and conferences, very few VC-backed cryptocurrency-related startups are divulging any non-gamable numbers.

I had hoped to do a regular quarterly update (see previous January post regarding usage numbers) but there just isn’t much public data to go on.  In fact, there is less data today than 3 months ago.

For instance, at some point in the past couple of months, Coinbase removed its wallet transaction volume chart from its chart site.  This coincides with a public announcement made in February that ‘Coinbase is not a wallet.’  As Brian Armstrong, CEO of Coinbase stated:

Over the next year or so, you’ll see the Coinbase brand shift from being a hybrid wallet/exchange to focusing on purely being a retail and institutional exchange. It will take some time to update, but the transition will happen.

Interestingly, this somewhat conflicts with another statement made in a Forbes piece this past week covering Coinbase and Blockchain.info, stating:

Currently, 80% of Coinbase’s customers buy bitcoin as an investment, and 20% transact with it, though that balance is currently shifting more toward transactions.

Perhaps transaction volume overall is increasing, but if so, why remove the wallet transaction volume chart?  Or is it solely related to transaction volume on the exchange?

The same Forbes article also mentioned another specific aggregate number:

“Startups play a pretty integral role in the sense that we represent most of the end. If you look at users of Bitcoin on the network, most of them are represented by one of the major Bitcoin companies,” says Peter Smith, chief executive of Blockchain, adding that five or six companies, including Coinbase and Blockchain, represent about 80% of transaction volume on the network. Numerous startups are also using Bitcoin to enable their users to more easily send remittances, cross-border payments and peer-to-peer payments, as well as make mobile in-app purchases.

Maybe this is true, maybe there are 5 or 6 companies that represent the lionshare of volume on the Bitcoin network itself.  If so, we should be able to see that.


This is a simplified, color coded version of a tool that Chainalysis provides to its customers such as compliance teams at exchanges. The thickness of a band accurately represents the volume of that corridor, it is drawn to scale.  The names of certain entities are redacted.

The image is based on data for the first quarter of 2016 and is an update to the chart I published in an article back in January.

Based on the chart above, there are in fact 5-6 organizations that represent 80% of the volume; both Coinbase and Blockchain.info are among them (Blockchain.info also operates SharedCoin).

In fact, Chainalysis recently updated their methodology and found that Coinbase transactions represent every 6th or 7th transaction on the Bitcoin blockchain. 2 This specific area of data science is continuously undergoing refinement and should be looked at once again in the coming months.

The same Forbes article says that Coinbase has 3.5 million users and Blockchain.info has 6.5 million wallet holders.

But as we have looked at before, what does that even mean?  Few companies publicly define what a user or wallet actually represents.  I have looked at this twice in the past:

The bottom line is that “monthly active users” (MAU) — which is one of the standard methods for measuring real growth (and success) of an application, is still largely unreported by any cryptocurrency-related company that has raised a Series A or higher.3

Other public data

Where can we find data that is still be published and could reflect usage numbers of public blockchains?

P2SH addresses

Source: P2SH.info

As shown above, over the past month, the amount of bitcoins stored using P2SH addresses increased from 9.99% to 11.7%.

A large noticeable pop took place two weeks ago and some speculated that it could be a Liquid-related multi-sig movement.

opreturn total transactions

Source: opreturn.org

OP_RETURN has also seen increased usage.  Above is a chart measuring the past 15 months of usage.

As described in Watermarked Tokens, OP_RETURN is an opcode in Bitcoin’s scripting language that is commonly used by colored coin projects.

At the time of this writing, in terms of percentages, the top 5 projects that have used OP_RETURN the most are:

  • Blockstack: 107254 transactions (28.4%)4
  • Open Assets: 68069 (18%)5
  • Monegraph: 51601 (13.7%)6
  • Factom: 34007 (9%)7
  • Coinspark: 25223 (6.7%)8

Two of the five are colored coin-specific projects and all five cumulatively account for about 76% of all OP_RETURN usage.

Any other numbers?

  • Looking at the previous charts from January, the ‘Bitcoin Distribution by Address at Block 400,000‘ looks roughly the same as the distribution at a block height of 390,000.
  • According to CoinATMRadar, the ‘number of Bitcoin ATMs installed by Bitcoin machine type’ increased from 536 at the beginning of January to 612 at the end of March. This comes to roughly 0.84 ATMs installed per day or a rate slightly higher than the past 2 years (it is on pace for 308.2 installations altogether this year compared with 275 per year for 2014 and 2015).
  • In terms of market prices, there were some relatively big swings in volatility (about $100 from peak to trough) in the first quarter due in part to the continued block size debate which still remains unresolved.9
  • And activity on both BitWage and Blockchain.info wallets looks roughly the same as they did in January.


Some venture funding bounced back from the dearth in Q4 2015.

According to the venture capital aggregation at CoinDesk there was $148 million of publicly announced rounds for both Bitcoin-related and Blockchain-related startups spread among 14 deals in Q1 2016.  Though two investments alone (DAH and Blockstream) accounted for more than two-thirds of that funding tranche.

However, the list is probably not complete as two investments into Kraken’s Japanese subsidiary were for undisclosed amounts (first from SBI in January and then by Money Partners Group in March).  Similarly, Ripple also received capital from SBI in January (for a reported 3 billion yen or ~$25 million).

In addition, last week, CB Insights (a venture tracking firm) held a webinar that covered the “Bitcoin / Blockchain” ecosystem (deck) (recording).

While providing a good general overview, I think it lacks a number of recent developments in the overall “Blockchain” capital markets world.10

For instance, Tradeblock recently launched Axoni (a private / permissioned blockchain) and Peernova isn’t really a “Blockchain” company now. 11 The webinar is a little outdated on the cryptocurrency side of things too.  For example, Mirror is completely out of the ecosystem altogether, 21inc is basically a software company at this point, Buttercoin is bankrupt and Blockscore shouldn’t be included in either bucket.

Any other charts?

Counterparty Transaction History

Source: Blockscan

I would be remiss to not include Counterparty, a platform has effectively plateaued (see image above) and has now been eclipsed by Ethereum based on multiple measurements including transaction growth (which actually may be eventually be gamed via “long chains” just like some Bitcoin transactions are).

What kind of other metrics are available?

Counterparty compared to Ethereum

Source: Coingecko

Ignoring the liquidity and market cap sections (basically all cryptocurrencies are illiquid and easily manipulable) there is a marked difference in terms of terms of social media engagement and interest between the two platforms.  For example, in terms of public interest, one measure that could be added to the Coingecko list is the amount of organized Meetup’s: Ethereum has roughly a hundred globally and Counterparty has about 10.

As an aside, I attended two Ethereum meetup’s last month: one hosted by Coinbase in San Francisco and another one hosted by IFTF in Palo Alto.  Both were well-attended with roughly 120 people showing up for the latter.

[Note: I do not own, control or hold any cryptocurrency nor do I have any trading position on them either.]

Why is no one actively publishing numbers?

It could be the case that some of the startups feel that any user / usage number is commercially important and therefore treat it like a trade secret.

Is there really less transparency in this market compared to other tech markets?

Maybe, maybe not.  What about public markets?

Last spring, Blizzard Entertainment announced it would no longer publish World of Warcraft subscription numbers.  This was done because of the continual decline in subscriptions (more than halving from its 12 million peak).  Similarly, last fall, Microsoft said it would no longer publish Xbox One unit sales and would instead share Xbox Live usership. ((Disclosure: I own an Xbox One))  At the time this move was seen as a way to downplay the growing gap in sales between Sony’s PS4 and the Xbox One.


Source: Statista / Zynga

An exception to this rule is Zynga — the mobile / social gaming company — which has seen continual drop offs in monthly active users for over three years, but still publishes numbers. 12

Back to the public blockchain sphere: why would 40+ companies that have closed a Series A or higher as a whole decide not to publish user / usage numbers in a market that claims to always be growing by leaps and bounds?

One of the problems appears to be that when you raise a lot of money, $50+ million for B2C applications your charts are expected to look a bit like other high-growth companies.

slack growth

Source: TechCrunch

For instance, above is a two-year chart displaying two types of users: daily active and paid for Slack.  With 3.5x daily user growth over the past year, Slack announced last week that it has closed its new round, raising $200 million at $3.8 billion post-money valuation.  About a third of its daily users which are paid users, a relatively high conversion rate.

Obviously social media commenters will point out that “cryptocurrencies” are not the same thing as communication tools, but the point remains that eventually the aspirations of investors will re-calibrate with the actual growth trajectories of a platform.  And as of right now, based on public data it is unclear where that traction is in the cryptocurrency world — perhaps it does exist somewhere but no one is publicly revealing those stats.

It bears mentioning, based on anecdotes there are several cryptocurrency-related startups that have gained relatively large customer bases in certain corridors focused on cross-border payments and remittances involving The Philippines.13 There are also several cash-flow positive companies in this space that have flown under the radar.  On the flipside, based on similar anecdotes, multi-level marketing scams like MMM Global also have seen continued traction.14


Where is the growth, where are the numbers?  Those are the two questions that continue to drive blog posts on this site.  Perhaps startups in the public blockchain ecosystem will be more forthcoming later this year as more capital is deployed.  We will try to revisit this topic once more information is publicly available.

It will also be interesting to see how many more cryptocurrency-related companies rebrand or pivot into the “private blockchain” sphere without actually changing how they interact with cryptocurrencies.  Thus, my older October post on the Great Pivot should be revisited at some point as well.  In addition, if “private blockchain” platforms are eventually flipped on into production mode, they may begin to yield usage numbers worth looking at in a year or so.

  1. For a concise explanation of “fast growth” in this context see the recent interview with Chamath Palihapitiya: Top V.C. on “Mostly Crap” Start-Ups, Mark Zuckerberg, and Early Facebook’s Grim Lunches by Vanity Fair. []
  2. And according to other data science companies I have spoken to in the recent past, several confirm this as well. []
  3. A notable exception was in December 2015 when BitPay provided a transaction chart to Forbes.  Additionally, BitGo has published numbers from time to time.  And while it hasn’t raised a Series A, Blockstack is also fairly open about its userbase. []
  4. Blockstack.org is not the same thing as Blockstack.io — two different groups. []
  5. Flavien Charlon, creator of Open Assets, also maintains Openchain. []
  6. Monegraph is a platform for managing digital artwork. []
  7. During its crowdsale last year, Factom sold about 4.4 million factoid (tokens) for 2,278 bitcoins. []
  8. CoinSciences, the team behind Coinspark, also has another product called MultiChain. []
  9. See: What is the blockchain hard fork “missile crisis?” and also Appendix B []
  10. One interesting stat they mentioned was in terms of ratios: in 2015 there was about $15 billion invested in “fintech” overall and about $450 million in the entire umbrella of “cryptocurrency / blockchain” ecosystem.  That amounts to about 3%. []
  11. Peernova has transitioned from being a Bitcoin mining company to creating “Blockchain-inspired” tools for other industries. []
  12. See Zynga quarterly earnings reports and Statista []
  13. This includes: Align Commerce, BitX and Coins.ph []
  14. This is based on actual data I have been shown. []
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Watermarked tokens and pseudonymity on public blockchains

As mentioned a couple weeks ago I have published a new research paper entitled: “Watermarked tokens and pseudonymity on public blockchains

In a nutshell: despite recent efforts to modify public blockchains such as Bitcoin to secure off-chain registered assets via colored coins and metacoins, due how they are designed, public blockchains are unable to provide secure legal settlement finality of off-chain assets for regulated institutions trading in global financial markets.

The initial idea behind this topic started about 18 months ago with conversations from Robert Sams, Jonathan Levin and several others that culminated into an article.

The issue surrounding top-heaviness (as described in the original article) is of particular importance today as watermarked token platforms — if widely adopted — may create new systemic risks due to a distortion of block reorg / double-spending incentives.  And because of how increasingly popular watermarked projects have recently become it seemed useful to revisit the topic in depth.

What is the takeaway for organizations looking to use watermarked tokens?

The security specifications and transaction validation process on networks such as the Bitcoin blockchain, via proof-of-work, were devised to protect unknown and untrusted participants that trade and interact in a specific environment.

Banks and other institutions trading financial products do so with known and trusted entities and operate within the existing settlement framework of global financial markets, with highly complex and rigorous regulations and obligations.  This environment has different security assumptions, goals and tradeoffs that are in some cases opposite to the designs assumptions of public blockchains.

Due to their probabilistic nature, platforms built on top of public blockchains cannot provide definitive settlement finality of off-chain assets. By design they are not able to control products other than the endogenous cryptocurrencies they were designed to support.  There may be other types of solutions, such as newer shared ledger technology that could provide legal settlement finality, but that is a topic for another paper.

This is a very important issue that has been seemingly glossed over despite millions of VC funding into companies attempting to (re)leverage public blockchains.  Hopefully this paper will help spur additional research into the security of watermarking-related initiatives.

I would like to thank Christian Decker, at ETH Zurich, for providing helpful feedback — I believe he is the only academic to actually mention that there may be challenges related to colored coins in a peer-reviewed paper.  I would like to thank Ernie Teo, at SKBI, for creating the game theory model related to the hold-up problem.  I would like to thank Arthur Breitman and his wife Kathleen for providing clarity to this topic.  Many thanks to Ayoub Naciri, Antony Lewis, Vitalik Buterin, Mike Hearn, Ian Grigg and Dave Hudson for also taking the time to discuss some of the top-heavy challenges that watermarking creates.  Thanks to the attorneys that looked over portions of the paper including (but not limited to) Jacob Farber, Ryan Straus, Amor Sexton and Peter Jensen-Haxel; as well as additional legal advice from Juan Llanos and Jared Marx.  Lastly, many thanks for the team at R3 including Jo Lang, Todd McDonald, Raja Ramachandran and Richard Brown for providing constructive feedback.

Watermarked Tokens and Pseudonymity on Public Blockchains

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Creative angles of attacking proof-of-work blockchains

[Note: the following views were originally included in a new paper but needed to be removed for space and flow considerations]

While most academic literature has thus far narrowly focused under the assumption that proof-of-work miners such as those used in Bitcoin will behave according to a “goodwill” expectation, as explored in this paper, there may be incentives that creative attackers could look to exploit.

Is there another way of framing this issue as it relates to watermarked tokens such as colored coins and metacoins?

Below are comments from several thought-leaders working within the industry.

According to John Light, co-founder of Bitseed:1

When it comes to cryptocurrency, as with any other situation, an attacker has to balance the cost of attacking the network with the benefit of doing so. If an attacker spends the minimum amount required to 51% attack bitcoin, say $500 million, then the attacker needs to either be able to short $500 million or more worth of BTC for the attack to be worth it, or needs to double spend $500 million or more worth of BTC and receive some irreversible benefit and not get caught (or not have consequences for getting caught), all while taking into consideration the loss of future revenues from mining honestly. When you bring meta-coins into the equation, things get even murkier; the cost is less dependent on the price of bitcoin or future mining revenues, and depends more on the asset being attacked, whether it’s a stock sale or company merger that’s being prevented, or USD tokens being double-spent.

There’s no easy answer, but based on the economics of the situation, and depending on the asset in question, it doesn’t seem wise to put more value on chain than the market cap of BTC itself (as a rough benchmark – probably not that exact number, but something close to it).

Not a single study has been publicly published looking at this disproportionalism yet it is regularly touted at conferences and social media as a realistic, secure, legal possibility.

According to Vitalik Buterin, creator of Ethereum:2

There are actually two important points here from an economics perspective. The first is that when you are securing $1 billion on value on a system with a cryptoeconomic security margin that is very small, that opens the door to a number of financial attacks:

  1. Short the underlying asset on another exchange, then break the system
  2. Short or long some asset at ultrahigh leverage, essentially making a coin-flip bet with a huge amount of money that it will go 0.1% in one direction before the other. If the bet pays off, great. If it does not pay off, double spend.
  3. Join in and take up 60%+ of the hashrate without anyone noticing. Then, front-run everyone. Suppose that person A sends an order “I am willing to buy one unit of X for at most $31”, and person B sends an order “I am willing to sell one unit of X for at least $30”. As a front-runner, you would create an order “I am willing to sell one unit of X for at least $30.999” and “I am willing to buy one unit of X for at most $30.001”, get each order matched with the corresponding order, and earn $0.998 risk-free profit. There are also of course more exotic attacks.

In fact, I could see miners even without any attacks taking place front-running as many markets as they can; the ability to do this may well change the equilibrium market price of mining to the point where the system will, quite ironically, be “secure” without needing to pay high transaction fees or have an expensive underlying currency.

The second is that assets on a chain are in “competition” with each other: network security is a public good, and if that public good is paid for by inflation of one currency (which in my opinion, in a single-currency-chain environment, is economically optimal) then the other currencies will gain market share; if the protocol tries to tax all currencies, then someone will create a funky meta-protocol that “evades taxes by definition”: think colored coins where all demurrage is ignored by definition of the colored coin protocol. Hence, we’ll see chains secured by the combination of transaction fee revenue and miner front running.

Unsolved economics question: would it be a good thing or a bad thing if markets could secure themselves against miner frontruns? May be good because it makes exchanges more efficient, or bad because it removes a source of revenue and reduces chain security.

Cryptoeconomics is a nascent academic field studying the confluence of economics, cryptography, game theory and finance.3

Piotr Piasecki, a software developer and independent analyst explained:4

If a malicious miner sees a big buy order coming into the market that would move the price significantly, they can engage in front running – the buy order could be pushed to the back of the queue or even left out until the next block, while the miner buys up all of the current stock and re-lists it at a higher price to turn a profit. Alternatively, when they see there is a high market pressure coming in, especially in systems that are inefficient by design, they can buy the orders up one by one by using their power to include any number of their own transactions into a block for free, and similarly re-list them for people to buy up.

Or in other words, because miners have the ability to order transactions in a block this creates an opportunity to front run. If publicly traded equities are tracked as a type of colored coin on a public blockchain, miners could order transaction in such a way as to put certain on-chain transactions, or trades in this case, to execute before others.

Robert Sams, co-founder of Clearmatics, previously looked at the bearer versus registered asset challenge:5

One of the arguments against the double-spend and 51% attacks is that it needs to incorporate the effect a successful attack would have on the exchange rate. As coloured coins represent claims to assets whose value will often have no connection to the exchange rate, it potentially strengthens the attack vector of focusing a double spend on some large-value colour. But then, I’ve always thought the whole double-spend thing could be reduced significantly if both legs of the exchange were represented on a single tx (buyer’s bitcoin and seller’s coloured coin).

The other issue concerns what colour really represents. The idea is that colour acts like a bearer asset, whoever possesses it owns it, just like bitcoin. But this raises the whole blacklisted coin question that you refer to in the paper. Is the issuer of colour (say, a company floating its equity on the blockchain) going to pay dividends to the holder of a coloured coin widely believed to have been acquired through a double-spend? With services like Coin Validation, you ruin fungibility of coins that way, so all coins need to be treated the same (easy to accomplish if, say, the zerocoin protocol were incorporated). But colour? The expectations are different here, I believe.

On a practical level, I just don’t see how pseudo-anonymous colour would ever represent anything more than fringe assets. A registry of real identities mapping to the public keys would need to be kept by someone. This is certainly the case if you ever wanted these assets to be recognised by current law.

But in a purely binary world where this is not the case, I would expect that colour issuers would “de-colour” coins it believed were acquired through double-spend, or maybe a single bitcoin-vs-colour tx would make that whole attack vector irrelevant anyway. In which case, we’re back to the question of what happens when the colour value of the blockchain greatly exceeds that of the bitcoin monetary base? Who knows, really depends on the details of the colour infrastructure. Could someone sell short the crypto equity market and launch a 51% attack? I guess, but then the attacker is left with a bunch of bitcoin whose value is…

The more interesting question for me is this: what happens to colour “ownership” when the network comes under 51% control? Without a registry mapping real identities to public keys, a pseudo-anonymous network of coloured assets on a network controlled by one guy is just junk, no longer represents anything (unless the 51% hasher is benevolent of course). Nobody can make a claim on the colour issuer’s assets. So perhaps this is the real attack vector: a bunch of issuers get together (say, they’re issuers of coloured coin bonds) to launch a 51% attack to extinguish their debts. If the value of that colour is much greater than cost of hashing 51% of the network, that attack vector seems to work.

On this point, Jonathan Levin, co-founder of Chainalysis previously explained that:6

We don’t know how much proof of work is enough for the existing system and building financially valuable layers on top does not contribute any economic incentives to secure the network further. These incentives are fixed in terms of Bitcoin – which may lead to an interesting result where people who are dependent on coloured coin implementations hoard bitcoins to attempt to and increase the price of Bitcoin and thus provide incentives to miners.

It should also be noted that the engineers and those promoting extensibility such as colored coins do not see the technology as being limited in this way. If all colored coins can represent is ‘fringe assets’ then the level of interest in them would be minimal.

Time will tell whether this is the case. Yet if Bob could decolor assets, in this scenario, an issuer of a colored coin has (inadvertently) granted itself the ability to delegitimize the bearer assets as easily as it created them. And arguably, decoloring does not offer Bob any added insurance that the coin has been fully redeemed, it is just an extra transaction at the end of the round trip to the issuer.

  1. Personal correspondence, August 10, 2015. Bitseed is a startup that builds plug-and-play full nodes for the Bitcoin network. []
  2. Personal correspondence, August 13, 2015. []
  3. See What is cryptoeconomics? and Formalizing Cryptoeconomics by Vlad Zamfir []
  4. Mining versus Consensus algorithms in Crypto 2.0 systems by Piotr Piasecki []
  5. As quoted in: Will colored coin extensibility throw a wrench into the automated information security costs of Bitcoin? by Tim Swanson; reused with permission. []
  6. This example originally comes from Will colored coin extensibility throw a wrench into the automated information security costs of Bitcoin? by Tim Swanson; reused with permission. []
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Cryptoeconomics for beginners and experts alike

This past week Koinify and the Cryptocurrency Research Group (CCRG), a new academic organization, held a 3-day event — the first of its kind called Cryptoeconomicon, an interdisciplinary private event that included a cross section of developers, entrepreneurs, academics and a few investors.  It was purposefully scheduled to coincide with O’Reilly Media’s own “Bitcoin and the Blockchain” conference which took place in the middle of it.

I attended what amounted to four days of seminars, brainstorming and networking sessions.  Below are my summarized thoughts.  Note: these are my opinions alone and do not reflect those of other participants or the companies I work with.  You can view pictures/info of the event: #cryptoecon and @cryptoecon

Rather than going through each session, I will just highlight a few areas that stood out to me and include outside relevant content.

What is cryptoeconomics?

According to Vlad Zamfir, of the Ethereum project, cryptoeconomics as a field might be defined as:

A formal discipline that studies protocols that govern the production, distribution and consumption of goods and services in a decentralized digital economy.  Cryptoeconomics is a practical science that focuses on the design and characterization of these protocols.

Zamfir discussed this at length (slides) (video) and rather than going too in-depth with what he said I wanted to reiterate his main points he gave:

Cryptoeconomic security as information security

  • Mechanisms are really programs
  • They can distribute payoffs
  • The programs have a certain behaviour in the Nash equilibrium case
  • The NE has a cryptoeconomic security
  • We can be assured that a program will run a particular way

He also argues that “cryptoeconomics” should be see as more economics for cryptography rather than cryptography for economics:

  • Economic mechanisms can give guarantees that a program will run in a particular way that cryptography alone can’t provide.
  • Incentives are forward facing, cryptography is a function of already-existing information
  • How do we provide custom cryptoeconomic guarantees?

The last part in relation to his talk that really stuck out to me was on the final day.  In his view (slides) the technical term that should be applied is, “distributed cryptoeconomic consensus” which would assuage concerns from the academic “distributed consensus” community that uses different terminology.  Under this definition, this means:

  • A cryptoeconomic mechanism with the Nash equilibrium of assuring distributed byzantine fault tolerant consensus
  • We should be able to assert and prove the cryptoeconomic assurances of any consensus mechanism
  • Distributed consensus mechanisms can create a pure cryptoeconomy. Even the execution of the mechanisms is has a measurable assurance.

Most interesting comment of the event

I think the most apt comment from the economics discussion came from Steve Waldman, a software developer and trader over at Interfluidity on the first day of the event.

While there will likely be a recording posted on Youtube (video), in essence what he said was that in the blockchain space — and specifically the developers in the room — they are creating an enormous amount of supply without looking to see what the corresponding demand is.  That is to say, there is effectively a supply glut of “blockchain tech” in part because few people are asking whether or not this tech actually has any practical consumer demand.  Where are the on-the-ground consumer behavior surveys and reports?

Again, if Bitcoin (the overall concept) is viewed as an economy, country or even a startup, it is imperative that the first question is resolved: what is the market need?  Who are the intended consumers?  So far, despite lots of attention and interest, there has been very little adoption related to blockchains in general.  Perhaps this will change, maybe it is only a temporary mismatch.  Maybe it these are the chicken-egg equivalent to computing languages like Ruby or PHP and eventually supply somehow creates the demand?  Or maybe it suffers from the Kevin Costner platform trap (e.g,. if you build it, will they come?).

To illustrate this contrarian view:

why startups fail

Source: David Norris https://twitter.com/norrisnode/status/561262588466839553

Maybe there is no real market need for these first generation concepts?  Perhaps the network will run out of block rewards (cash incentives) to the miners before these blockchains can gain mainstream traction?  Maybe the current developers are not quite right for the job?

Or maybe, blockchains such as Bitcoin simply get outcompeted in the overall marketplace.  For instance, there are currently 1,586 Payment startups listed on AngelList and 106 P2P Money Transfer startups listed on AngelList.  Most of these will likely burn out of capital and cease to exist, but there are probably at least a dozen or so of each that will (and have) gained traction and are direct competitors to these first generation blockchains.

Perhaps this will change, but then again, maybe the market is more interested in what William Mougayar (who unfortunately was not part of the event) pointed out a few days ago.  Simply put, maybe there is more room to grow in the “Blockchain Neutral Smart Services” and “Non-Blockchain Consensus” quadrants:


We cannot know for certain a priori what market participants will decide.  Perhaps Bitcoin is good enough to do everything its enthusiastic supporter claim it can.

Or maybe, as Patrick Collison, CEO of Stripe, wittily stated in Technology Review:

“Bitcoin is kind of a financial Rorschach test; everyone projects their desired monetary future onto it.”

Now, to be fair, Collison (who was not part of the event) has a horse in the race with Stellar.  Fortunately there was not much emphasis on token prices going to the moon at the Cryptoecon event.  When incentives did come up, it was largely related to how a consensus mechanism can be secure through a self-reinforcing Nash equilibrium.

Perhaps a future event could discuss what Meher Roy (who unfortunately was not in attendance either) adroitly summarized and modeled in relation to how actors are betting on crypto-finance platforms:

meher roy table

Source: https://medium.com/@Meher/a-model-to-makes-sense-of-beliefs-and-associated-crypto-finance-platforms-f761a7d782cb

Back to the show

There were a number of startups at the event, probably around a dozen or so.  In my view, the most concise overview was from Sergey Nazarov co-founder of SmartContract.  The interface was clean, the message was clear and “issuance” can be done today.  I’m not necessarily endorsing the stack he’s using, but I think he has clearly talked to end-users for ease of use feedback (note: be sure to consult a lawyer before using any ‘smart contracting’ system, perhaps they are not recognized as actual “contracts” in your jurisdiction).  Also, drones.

It would have been nice to see a little longer debate between StorJ, Maidsafe and Filecoin groups.  I think there was probably a little too much “it just works” handwaving but thought that Juan Binet-Betez from IPFS/Filecoin gave the most thorough blueprint of how his system worked (he also showed a small working demo).

It was not recorded but I think messaging for Augur (a variation of Truthcoin) was pretty poor.  Again, just my opinion but I was vocal about the particular use-case (gambling) proposed as it would simply bring more negative PR to a space smashed with bad PR.  The following day other members of the team discussed other uses including prediction markets for political events (similar to what Intrade did).  I am skeptical that in its current form it will become widely adopted because futures markets, like the CME, already do a relatively competitive job at providing this service for many industries and these decentralized markets could likely just attract marginal, illicit activities as has been the trend so far.  I could be wrong and perhaps they will flourish in emerging markets for those without access to the CME-like institutions.

Things that look less skeptical

  • There were about 10-12 people affiliated with Ethereum at the event, all of them were developers and none of them seemed to push their product as “the one chain to rule them all” (in fact, there was a healthy debate about proof-of-stake / proof-of-work within their contingent).  I’ve been fairly skeptical since last summer when their team looked gigantically bloated (too many cooks in the kitchen) but they seem to have since slimmed down, removing some of the pumpers and focusing on the core tech.  This is not to say they will succeed, but I am slightly less skeptical than I was 3-4 months ago.
  • I also had a chance to sit down with a couple members of the IBM ADEPT ‘Internet of Things’ team.  They held a ~3 hour workshop which was attended by around 20 people.  The session was led by Henning Diedrich (IBM), David Kravitz (IBM) and Patrick Deegan (Open Mustard Seed Project).  Again, even though I’ve paged through the ADEPT whitepaper, I was hesitant to believe that this was little more than marketing on the part of IBM.  But by the time the session was over, I was a little less skeptical.  Perhaps in the future, when more appliances and devices have secure proplets, they could use a method — such as a blockchain/cryptoledger — to securely bid/ask on resources like electricity.  B2B and machine-to-machine ideas were discussed and piggybacked on.  Obviously there are all sorts of funny and sad ways this could end but that is up for Michael Bay to visualize next year.
  • This also intersects with another good comment from Stefan Thomas (CTO of Ripple Labs).  In a nutshell, on a panel during the first day, he thinks there is some confusion and conflation of the terms “automation,” “decentralization,” “smart contracts” and “blockchains.”  That is to say, while blockchains are automated, that is not to mean that it is the only means to achieve automation.  Nor is decentralization necessary for automation to be achieved in every use-case.  Nor are smart contracts the only way to control automated devices.  When the video is posted I’ll be sure to link it (video).
  • Ethan Buchman, lead dev for Eris, was both witty and on top of his form, noting that in practice users don’t need a new browser every time they go to a new site, so they shouldn’t need a new client to view a different blockchain.  Let’s keep our eye on Decerver to see how this germinates.
  • Lastly, the two investors that attended the VC panel on Wednesday included Shahin Farshchi from Lux Capital and Pearl Chan of Omidyar Network.  What I liked about them is they weren’t pushing a certain binary viewpoint.  They were both upfront and honest: neither had invested in this space, not because they hated it, but because they were taking their time to see what opportunities actually fit within their mandate.  Perhaps they will at some point.  One joke that Farshchi mentioned was that back when cellular telephony was growing, “everyone and their mom” was selling base station equipment and chips.  Similarly there were over 300 companies creating thin film solar cells before bankruptcies and mergers.  So the type of euphoria we see in the Bitcoin-space is not necessarily unique.

Room for improvement

Perhaps if there is a next event it could include representatives from Blockstream, Bitfury and other Bitcoin-centered projects.  It would be nice to have some perspective from those deeply concerned about with maintaining secure consensus and the Blockstream team has some of the most experienced engineers in this space.  Hearing their views next to what Peter Todd (who attended and had some interesting calculations for the estimated costs to attack a network), could help developers build better tools.  Similarly, developers from Peernova, Square, Stripe, M-Pesa and Western Union would also likely be good resources to provide empirical feedback.

Additional clarity for what a decentralized autonomous organization (DAO) actually is and is not could be spelled out as well.  And how do these intersect with existing legal jurisprudence (can they? as Brett Scott might ask).   For anyone who has read “The Cookie Monster” by Vernor Vinge, both Matt Liston and Vitalik Buterin made some not-entirely-unreasonable points about machine-rights and whether or not machines should trust humans (e.g., humans expect bots to provide truthful information, but can the reverse be expected?  And what happens if a bot, like a DAO, is deemed too successful or broke a law in some jurisdiction — does it get “carted” away in a truck?).

Lastly, I think by the time there is another event, there will hopefully be more clarity for what a “smart contract” is.  One panel I moderated, I tried to get the participants to use the word “banana” instead because the term “banana” is overused and often conflated to mean many things it is legally not.  Primavera De Filippi from the Cryptolaw panel made some good comments too about whether or not “bananas” are actual legally binding contracts; she previously did a workshop with Aaron Wright (also in attendance) at the recent Distributed Networks and the Law event held at Harvard/MIT.  Steve Omohundro also spoke realistically about these scenarios on the final day, where does liability start and stop for developers of DAOs?

[Note: I would like to thank Kieren James-Lubin, Vitalik Buterin, Tom Ding, Sri Sriram for organizing the event, Robert Schwentker for acting as emcee/photographer, and CFLD and Omidyar Network for sponsoring the event including the delicious food.]

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The Continued Existence of Altcoins, Appcoins and Commodity coins

Yesterday I gave a presentation at a Bitcoin Meetup held hosted by Plug and Play Tech Center in Sunnyvale.

I discussed the economic incentives for creating altcoins, appcoins, commodity coins and also covered several bitcoin 2.0 proposals.  The slides and video from the event are viewable below.  Download the deck for other references and citations.

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A panel on smart contracts with industry developers and educators

Earlier today I participated in a virtual panel covering smart contracts called, “Let’s Talk Smart Contracts.”

The panel included: Adam Krellenstein (Counterparty), Oleg Andreev (CoreBitcoin), Pamela Morgan (Empowered Law), Stefan Thomas (Codius, Ripple Labs), Stephan Tual (Ethereum), Tim Swanson (Of Numbers), Yurii Rashkovskii (Trustatom) and it was moderated by Roman Snitko with Straight.

Below are some transcribed notes of my own statements.

Introduction starting at 09:06:

Hey guys, great to be here.  Thanks for the invite, thanks for organizing this.  So I’m here because you guys needed another white guy from Europe or something like that (that’s a joke).  So the definition I have of smart contracts, I have written a couple books in this space, and the definition I use is a smart contract is “a proposed tool to automate human interactions: it is a computer protocol – an algorithm – that can self-execute, self-enforce, self-verify, and self-constrain the performance of a contract.”  I think I got most of that definition from Nick Szabo’s work.  For those of you who are familiar with him, look up some of his past writings.  I think that the primary work he is known for is the paper, “Formalizing and Securing Relationships on Public Networks.”  And he is basically considered the [intellectual] grandfather of this space.  I’m here basically to provide education and maybe some trolling.

From 22:02 -> 24:15

I think I see eye-to-eye with Adam here.  Basically the idea of how we have a system that is open to interpretation, you do have reversibility, you do have nebulousness.   These are things that Nick Szabo actually discussed in an article of his called “Wet code and dry” back in 2008.  If you look back at some of the earlier works of these “cypherpunks” back in the ’90s, they talked about some of these core issues that Oleg talked about in terms of being able to mitigate these trusted parties.  In fact, if you look at the Bitcoin whitepaper alone, the first section has the word “reverse” or “reversibility” around 5 times and the word “trust” or “trusted” appears 11 times in the body of the work.  This was something that whoever created Bitcoin was really interested in trying to mitigate the need for any kind of centralized or third party involved in the process of transactions to reduce the mediation costs and so forth.

But I suppose my biggest criticism in this space, it is not pointed to anyone here in particular, is how we have a lot of “cryptocurrency cosplay.”  Like Mary Sue Bitcoin.  I’m not sure if you guys are familiar with who Mary Sue is: she is this archetype who is this kind of idealized type of super hero in a sense.  So what happens with Bitcoin and smart contracts is that you have this “Golden Age” [of Comics] where you had the limited ideas of what it could do.  Like Superman for example, when he first came out he could only jump over a building and later he was pushed to be able to fly because it looks better in a cartoon.  You have only a limited amount of space [time] and it takes too long to jump across the map.  So that’s kind of what I see with Bitcoin and smart contracts.  We can talk about that a little bit later, just how they have evolved to encompass these attributes that they’re probably not particularly good at.  Not because of lack of trying but just because of the mechanisms of how they work in terms of incentives for running mining equipment and so on.  So, again we can talk about that later but I think Adam and Oleg have already mentioned the things that are pretty important at this point.

40:18 -> 41:43

I’m the token cynic, huh?  So actually before I say anything, I would like to mention to the audience other projects that you might be interested in looking at: BitHalo; NotaryChains is a new project that encompasses some of these ideas of Proof of Existence created by Manuel Araoz, he is the one who did POE.  NotaryChains is a new project I think that sits on top of Mastercoin.  The issue that people should consider is that proof of existence/proof of signature: these are just really hi-tech forms of certification.  Whether or not they’re smart contracts I guess is a matter of debate.

There is another project: Pebble, Hyperledger, Tezos, Tendermint, Nimblecoin.  With Dogethereum their project is called Eris which apparently is the first DAO ever.  A DAO for the audience is a decentralized autonomous organization, it’s a thing apparently. SKUChain is a start-up in Palo Alto, I talk about them in chapter 16.  They have this interesting idea of what they call a PurchaseChain which is a real use-case for kind of updating the process from getting a Letter of Credit to a Bill of Lading and trying to cut out time and mediation costs in that process.  There are a few others in stealth mode.  So I really don’t have a whole lot to add with cynicism at this point, we can go on and come back to me in a little bit.

59:41 -> 1:02:35

The go to deficiency guy, huh?  They’re not really saying anything particularly controversial, these things are fundamentally — at least from an engineering perspective — could be done.  The problem though I think runs into is what Richard Boase discussed in — if listeners are interested — he went to Kenya and he did a podcast a few weeks ago on Let’s Talk Bitcoin #133.  I really recommend people listen to it.  In it he basically talks about all of these real world issues that run into this idealized system that the developers are building.  And as a result, he ended up seeing all of these adoption hurdles, whether it was education or for example tablets: people were taking these tablets with bitcoin, and they could just simply resell it on a market, the tablet itself was worth more than they make in a year basically; significant more money.  He talked about a few issues like P2P giving, lending and charity and how that doesn’t probably work like we think it does.

I guess the biggest issue that is facing this space, if you want issues, is just the cost benefit analysis of running these systems.  There is a cost somewhere to run this stuff on many different servers, there is different ways to come up with consensus for this: for example, Ripple, Stellar, Hyperledger, they’re all using consensus ledgers which require a lot less capital expenditures.  But when you end up building something that requires some kind of mining process itself, that costs money.  So I think fundamentally in the long-run it won’t be so much what it can do but what can it economically do.

So when you hear this mantra of let’s decentralize everything, sure that’s fine and dandy but that’s kind of like Solutionism: a solution looking for a problem.  Let’s decentralize my hair — proof of follicle — there is a certain reductio ad absurdum which you come to with this decentralization.  Do you want to actually make something that people are actually going to use in a way that is cheaper than an existing system or we just going to make it and throw it out there and think they’re going to use it because we designed [wanted] it that way.  So I think education is going to be an issue and there are some people doing that right now: Primavera De Fiillipi, she’s over at Harvard’s Berkman Center — she’s got something called the Common Accord program.  And also Mike Hearn; listeners if you’re interested he’s made about 7 or 8 use-cases using the existing Bitcoin blockchain including assurance contracts — not insurance contracts — assurance contracts.  And he’s got a program called Lighthouse which hopes to build this onto the actual chain itself.  So there are things to keep in mind, I’m sure I’ll get yelled at in a minute here.

1:23:58 -> 1:28:10

Anyone listening to this wanting to get involved with smart contracts: hire a lawyer, that’s my immediate advice.  I will preface by saying I don’t necessarily agree with policies that exist and so on; I don’t personally like the status quo but there is no reason to be a martyr for some crusade led by guys in IRC, in their little caves and stuff like that.  That’s not towards anyone here in this particular chat but you see this a lot with “we’re going to destroy The Fed” or “destroy the state” and the reality is that’s probably not going to happen.  But not because of lack of trying but because that’s not how reality works.

Cases right now are for example: DPR, Shavers with the SEC, Shrem now with the federal government, Karpeles [Mt. Gox] went bankrupt.  What’s ended up happening is in 2009, with Bitcoin for example, you started with a system that obviated the need of having trusted third parties but as users started adopting it you ended up having scams, stolen coins, people losing coins so you ended up having an organic growth of people wanting to have insurance or some way to mediate these transactions or some way to make these things more efficient.  And I think that it will probably happen — since we’re guessing, this is speculative — I think that this will kind of happen with smart contracts too.  That’s not to say smart contracts will fail or anything like that.  I’m just saying that there will probably just be a few niche cases initially especially since we don’t have much today, aside I guess from Bitcoin — if you want to call it a smart contract.

What has ironically happened, is that we have created — in order to get rid of the middlemen it looks like you’ve got to reintroduce middlemen.  I’m not saying it will always be the case.  In empirical counter-factual it looks like that’s where things are heading and again obviously not everyone will agree with me on that and they’ll call me a shill and so on.  But that’s kind of where I see things heading.

I have a whole chapter in a book, chapter 17.  I interviewed 4 or 5 lawyers including Pamela [Morgan] of different reasons why this could take place.  For example, accredited investor — for those who are unfamiliar just look up ‘accredited investor.’  If you’re in the US, in order to buy certain securities that are public, you need to have gone through certain procedure to be considered a ‘sophisticated investor.’  This is one of the reasons why people do crowdsales outside of the US — Ethereum — because you don’t want to have to interact with the current legal system in the US.  The reason I mention that is because you end up opening yourselves to lawsuit because chains — like SWARM — cannot necessarily indemnify users.  That’s legal terminology for being able to protect your users from lawsuits from third parties; they just do not have the money, the revenue to support that kind of legal defense.  Unlicensed practice of law (UPL) is another issue.  If you end up putting up contracts on a network one of the issues could be, at least in the US, are bar associations.  Bar associations want to protect their monopoly so they go after people who practice law without a license.  I’m not saying it will happen but it could happen.

My point with this is, users, anyone listening to this should definitely do your due diligence, do your education.  If you plan to get involved with this space either as an investor or developer or so on, definitely at least talk to a lawyer that has some inkling of of an idea [on this].  The ones I recommend, in addition to Pamela here are: Ryan Straus, he is a Seattle-based attorney with Riddell Williams; Austin Brister and James Duchenne they’re with a program called Satoshi Legal; and then Preston Byrne, who’s out in London and he’s with Norton Rose Fulbright.

1:52:20 -> 1:54:43

Guys look, I understand that sounds cool in theory and it’s great to have everything in the background, but the reason you have to see these “shrink wrapped” EULAs [end user license agreements] and TOSs [terms of service] is because people were hiding stuff inside those agreements.  So if you hide what’s actually taking place in the contract you end up making someone liable for something they might not actually agree to.  So I’m not sure, I think it’s completely debatable at this point.  If we’re trying to be transparent, then you’re going to have to be transparent with the terms of agreement.

I should point out by the way, check out Mintchalk.com, it’s run by guys named James and Aaron in Palo Alto, they’re doing contract building.  ACTUS is a program from the Stevens Institute, they’re trying to come with codified language for contracts.  Mark S. Miller, he’s got a program over at Google, he does something with e-rights.

I mention all of this because, we already have a form of “polycentric law” if you will in terms of internationally with 200 different jurisdictions vying for basically jurisdiction arbitrage.  Ireland and the Netherlands have a tax agreement that Facebook, Google, Pfizer they take advantage of.  It’s this Double Irish With a Dutch Sandwich.  In fact my own corporation is incorporated in Delaware because of the legal arbitrage [opportunities].  Obviously smart contracts might add some sort of new wrinkle to that, but people who are listening to this, don’t expect to be living in some Galt’s Gulch tomorrow or something like that.

For example, when you have something that is stolen, there is something called Coinprism which is a colored coin project.  They can issue dividends on stock.  The cool thing with that is, “hey, you get to decentralize that.”  The double-edged side of that is if that when that get’s stolen: people steal stuff like bitcoins and so forth, what happens to the performance of that dividend?  If the company continues paying that dividend in knowing that the person had been stolen from: if somebody stole from me and I tell the company, “hey, it was stolen” and they continue paying, then I can sue them for continuing to pay a thief.  If they stop paying then it defeats the purpose of decentralization because anonymity is given up, identity has taken place.  Obviously this moves into another area called “nemo dat” it’s another legal term talking about what can be returned to the rightful owner, that’s where the term “bona fide” comes from.  Anyways, I wanted to get that out there.  Be wary of disappearing EULAs, those have a purpose because people were being sued for hiding stuff in there.

2:10:05 -> 2:12:23

So I think everybody and all these projects are well-intentioned and have noble goals but they’re probably over-hyped in the short-run, just like the Segway was.  It eventually leads to some kind of burnout, or over-promise and under-delivering.  I’m not saying this will happen, I’m just saying it could happen.  I actually think the immediate future will be relatively mundane, such as wills and trusts kind of like Pamela was talking about.

One particular program is in Kenya there is something called Wagenitech which is run by Robin Nyaosi and he is wanting to help farmers move, manage and track produce to market to bypass the middleman.  That doesn’t seem like something really “sexy,” that doesn’t seem like the “Singularity” kind of thing that everyone likes to talk about.  But that is needed for maybe that particular area and I think we might see more of that along with PurchaseChain, NotaryChains, some of these things that we already do with a lot of the paperwork.

Again, blockchains and distributed ledgers are pretty good at certain things, but not everything.  It has real limitations that vocal adopters on the subreddit of Bitcoin like to project their own philosophical views onto it and I think that it does it a very big disservice to this technology long-term.  For example, LEGO’s can be used to make a car but you wouldn’t want to go driving around in one.  A laptop could be used as a paper weight but it’s not particularly cost effective to do that.  And so what I think we’ll end up running into a tautology with smart contracts, it’s going to be used by people who need to use them.  Just like bitcoin is.  So what we’re going to have is a divergence between what can happen, this “Superman” version of Bitcoin and smart contracts, versus the actual reality.

So for example, people say it’s [Bitcoin] going to end war.  You had the War of Spanish Succession, there was a Battle of Denain, a quarter million people fought that in 1712 and it was gold-based [financed by specie].  Everyone that says bitcoin is going to destroy fiat, if the state exists as it does today there’s always going to be these institutions and types of aggression.  I do think smart contracts do add collateral and arbitration competition and it does take away the problem of having trust in the system itself, but the edges are the kryptonite.  And always will be.  So we need to focus on education and creating solutions to real actual problems today with the actual technology and not just some hypothetical “Type 2” civilization where we are using [harvesting] the Sun for all of our energy.

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Presentation covering Smart Contracts, Smart Property and Trustless Asset Management

Earlier tonight I gave a presentation at Hacker Dojo with the Ethereum project.  I would like to thank Chris Peel and Joel Dietz for organizing it.  Below is a video and accompanying slide deck.  In addition to the footnotes in the PPT, I recommend looking at the wiki on smart contracts and Nick Szabo’s writings (1 2 3).

Also, some quotes regarding synthetic assets in Szabos’ work:

Citation 1:  “Another area that might be considered in smart contract terms is synthetic assets[5]. These new securities are formed by combining securities (such as bonds) and derivatives (options and futures) in a wide variety of ways.”

Citation 2: “Creating synthetic assets or combinations that mimic the financial functionality of some other contract while avoiding its legal limitations”

Citation 3: “Reference to Perry H. Beaumont, Fixed Income Synthetic Assets”

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Quick update of the DAO space involving Mastercoin and Ethereum

A couple of updates: Mastercoin has released a new schedule for its upcoming distributed exchange. Milestones will take place over the next 5 weeks and will ultimately enable users to use real MSC.

And from last weekend’s Bitcoin Miami conference, here is Vitalik Buterin’s presentation of Ethereum:

Note: Ethereum’s testnet is now up and running, the IPO has been pushed back to allow for legal clarifications.

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Casual conversation with Mastercoin, Ethereum and Invictus (Bitshares/Protoshares)

A week ago, Let’s Talk Bitcoin sat down with three developers Charles Hoskinson (Ethereum), David Johnston (Mastercoin) and Daniel Larimer (Invictus/Bitshares).  Well worth your time as it covers all the hot topics in this space today: smart contract, smart property, DAX (decentralized autonomous corporation/organization/application/etc.).  Lot’s of great quotes, insights and vision.

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