[Note: I neither own nor have any trading position on any cryptocurrency. I was not compensated by any party to write this. The views expressed below are solely my own and do not necessarily represent the views of my employer or any organization I advise.]
Summer has nearly arrived in the northern hemisphere and several friends have reached out to ask several unanswered questions and rumors.
Note that many of the questions below are about commercial and trade secrets where there is no obligation to make the information public.
For instance, we could openly ask how much Cargill (the largest private corporation in the US) spends to manufacture its wares but they are under no obligation to provide that to anyone beyond their managers, shareholders, and regulators.
Similarly, most of the companies (and individuals) below are under no obligation to provide answers. However since we think it is in the public interest to know who benefits from certain decision-making (such as who first knew about #NoBugFix last year), we are publishing them here with the aim of answering them over time.
This is a non-exhaustive list and arranged in no particular order:
(1) We were promised a public audit, so who hacked Bitfinex in August 2016? Was it an inside job? Compromised BitGo account? Who was moving the ‘stolen’ coins last month? Will the current NY AG lawsuit versus Bitfinex/Tether reveal these details?1
(2) Ripple’s co-founders gave (granted?) ~80 billion XRP to Ripple Inc. back in January 2013 when it was still called OpenCoin. How much XRP was/is given to early investors like a16z and/or future partners?
(3) When R3 sued and settled with Ripple in 2018, rumors circulated that R3 won the equivalent of ~$500m in XRP and were limited to selling just as Jed McCaleb is constrained by.2 How much was the settlement for and how much XRP has been sold? How much do XRP sales account for R3 and other organizations revenue? For instance, Ripple has sold at least $1.1 billion in XRP to finance its operations through mid-2019. What are the ramifications if XRP is deemed a security?
(4) Three years ago several Bitcoin Core developers were allegedly involved with an astroturfing campaign (such as Antbleed) via coordination in a “Dragon’s Den” Slack room. Was this real and if so, who are these people? Are they still active?
(5) A couple years ago, Jackson Palmer and Angela Walch separately asked who were the people that had merge access in the Bitcoin Core repo. They were rebuffed and told this is a necessary secret to maintain. Is this a secret? If so, why the lack of transparency and who made this decision? How common is this secrecy in other coin projects?
(6) As Bitfinex is an investor in Blockstream, what’s the formal relationship between the two organizations today, specifically with respect to Tether?3 Do either organizations operate OTC trading desks? If so, where and how are those licensed or legally structured?
(7) It is alleged in a lawsuit that EOS organizers recycled its year-long ICO proceeds back into its own sale thereby inflating its raise and generating hype. How much actual coin money from retail investors was sent into this generally solicited ICO?
(6) In April 2017 Bitfinex (briefly) sued Wells Fargo regarding the cutting off of correspondence banking… and a week later withdrew the suit. What were the names of the Taiwanese banks that were supposedly at the center of this (non) compliance controversy? Did these banks eventually reopen accounts on behalf of Bitfinex or Tether?
(7) Based on an interview with George Fogg, a 2015 FT article pointed out that Bitcoin (and likely other coins) has a lien problem: that due to rampant thefts and DNM activity there were probably more claims on specific bitcoins than there were bitcoins.4 What percentage of bitcoin (or other coins) are encumbered today?
(8) A rumor since 2014 is that a US-based coin exchange signed a deferred adjudication agreement with the federal government due to money laundering issues. If true, will it be revealed if/when an IPO is filed?
(9) Since SAFTs are largely considered cadavers in the US, what (if anything) will happen to its creators and early promoters? Enriched and sauntering off into the sunset? Or disbarred and disgorged?
(10) Will deposit-taking coin intermediaries ever be required to comply with federal laws as banks do in the US? Will they simply end up lobbying and moving shell entities into the state of Wyoming for an SPDI?
(11) FinCEN carved out a loophole for proof-of-work miners in 2013. Yet in practice, mining pool operators can and do select or censor transactions.5 Will they be held liable as an MTO or PSP as more value is moved through their machines and regulators catch-on?
(12) It is alleged that Craig Wright has plagiarized and used ghost writers for publishing papers. Who are they and how much were they paid?
(13) Last year, a former senior executive at a US-based coin exchange is alleged to have undue influence on listing coins based on his bags. What, if any, are the internal controls erected to prevent this type of behavior in coin exchanges? Several coin creators and issuers have joined and/or created coin exchanges in the past.6 Have any of them used their position to profit off of the asymmetric knowledge on listing their coins (or others)? If so, how to prevent this in the future?
(14) Lightning Network was frequently marketed as being ‘just around the corner’ yet it appears to have stagnated in activity over the past 18 months. Who(m) is responsible for this continued delay? Will it reach its marketed potential in the next year or too much of a Rube Goldberg machine? When will LN hubs need to become compliant with the Travel Rule?
(16) Regarding the revolving door: how many former regulators now work at coin intermediaries? And vice-versa: how many former coin employees work with regulators? With the push for additional stablecoins and potential CBDCs, will there be transparent interactions between regulators (and politicians) and vendors? If a single vendor oversees a proprietary codebase, how will this not result in a Hold-Up problem?
(17) At least one Chinese exchange, pre-2017, went out of its way to support scams like MMM. How many exchanges knowingly profited from allowing MMM or BitConnect-like actors to operate? Are regulated stablecoin issues such as Paxos aware of this?
(18) bitFlyer was accused of knowingly laundering money for the Yakuza. How many other exchanges have done so as well? In a given year, what percentage of exchange revenue comes from laundering the proceeds of organized crime?
(19) A conspiracy theory (joke?) is that whenever a coin exchange operator in South Korea gets a tax bill, they hack themselves in order to reduce the tax liability. Is this true and if so, how much has been pilfered?
(20) Jackson Palmer, Gwern Branwen, and others have poked into the original source code of Bitcoin and found the seeds of a marketplace and poker lobby.7 Was the original goal to also include a coin exchange or DNM?
(22) Was that really Gerald Cotten’s body or is he just mostly dead? Did Cotten act alone as the narrative leads us to believe or did Michael “identity theft” Patryn have a roll in the missing funds? As it was during their honeymoon, is Jennifer Robertson aware of anything odd about the circumstances surrounding Cotten’s death?
(23) Late last year, one of the allegations against Virgil Griffith included somehow helping move a computer system to act as a mining rig across the border to North Korea. We have heard rumors of used, second-hand mining hardware making its way across the same border in the past. Hardware manufacturers have said it is difficult to police because even if they KYC the original buyer, they have no control of where used hardware is sold over time. How much hashrate for Bitcoin or Ethereum and other PoW coins are generated out of North Korea?
(24) Common conversations at events imply that virtually every coin exchange has been hacked yet most simply eat the losses without publicly disclosing it. How many major hacks of coin exchanges in the US have still not been disclosed?9
(25) Several podcasters have openly bragged about not paying taxes on their coin dealings. For instance, the co-creator of a coin launched in 2014 from an organization based in California, now avoids California due to not having paid the state’s capital gains tax. How many others are virtue (vice) signaling? Or are they still counting on lax enforcement?
(26) Ethereum Classic (ETC) is technically the original Ethereum chain. During the debates over the ETH-ETC hard fork in late July 2016, a small handful of investors including Barry Silbert were vocally claiming on social media to support ETC.10 Several subsequent separate investigations into Silbert’s social media activity raised questions around anti-touting provisions of securities laws. If ETH or ETC was a security in 2016 due to a coordinated hard fork that was not sufficiently decentralized, who could be held liable for actively promoting a coin to unsophisticated investors? For instance, earlier this year actor Steven Seagal was penalized for not disclosing his paid endorsement of Bitcoiin2Gen (B2G). Does touting matter if a coin is or is not a security?
(27) The scandal and fallout around Joi Ito (and MIT) knowingly accepting funds from sex offender Jeff Epstein is still on-going. Last year we learned that Epstein was not just interested in Bitcoin, but he reached out to invest and fund Bitcoin-related companies and efforts (perhaps even DCI). For instance, Elizabeth Stark (from Lightning Labs) pointed out that she turned down an investment offer. Did Epstein put money into entities such as Digital Garage, which Ito co-founded?11 What about Digital Garage’s portfolio companies?
(28) The IOTA mainnet was stopped for days then weeks, and the non-anonymous founders fought in public about past grievances including funds that were supposed to build hardware devices… that were unaccounted for. The IOTA network, like EOS and Cardano, are arguably still centralized due to the smattering of nodes operated by a handful of entities. At what point are these types of networks deemed centralized money transmission operators (MTO) with the need to register with FinCEN and other similar regulators?12
(29) Where is Binance’s headquarters? Their executives often claim to not have offices – even when they are visited by the police… yet these same Binance executives appear in photo-ops on islands and jurisdictions found on the FATF blacklist. Where are they domiciled from a legal perspective? Do they pay taxes somewhere?
(30) In 2017, OKCoin and Huobi were penalized for not disclosing to their customers that they were re-investing deposits in other financial products. It is rumored that other coin exchanges have used their customer deposits and cash reserves to manipulate various coin prices which ultimately wreck retail investors, all because they can see trader’s positions and know exactly what amount of manipulation will close positions. How common is this?
(31) What happened to all of the funds donated to the dubiously self-serving ‘DefendCrypto’ effort? Recall that Kik conducted an ICO because it was running out of fundraising options… and then later sued by the SEC. Were all of the ‘community donations’ simply handed over to their lobbying organization (Blockchain Association) to spend carte blanche?
(32) Why do some coin exchanges employ outspoken tribalists or maximalists? What does this mean for how the exchange treats trades and orders for non-tribal-approved coins?
(33) How much do coin lobbying organizations charge to get fines or sanctions reduced? At least one DC-based organization removed the name of a prominent coin exchange (despite accepting their funds) after a lawsuit from NY AG was announced. Do these types of advocacy / lobbying organizations return the funds from illicit actors? When will the coin holdings of staff at coin lobbying organizations be required to be disclosed?13
(34) Over the past five years, numerous corporates and enterprises have publicly announced partnerships with more than a dozen different coin issuers. Most of these are vanity projects that end after 3-6 months. However, prior to the public announcement, it is alleged that insiders acquire coins with the expectation of a jump in prices.14 How common is this and how to remove this temptation from future decision-makers?
(35) CryptoDeleted was silenced by embarrassed social media personalities as it screen grabbed their boisterous coin shilling. How many other times has this specific type of suspension occurred on Twitter and other platforms with respect to documenting coin shills?
(36) Without providing any proof at the time, several prominent coin promoters claimed to have – or will have – donated large quantities of money to charitable organizations. In the case of Brock Pierce, more than two years ago his plans to donate $1 billion was uncritically reported on. Binance and other coin intermediaries that are in continuous legal limbo, also frequently claim to donate to causes in developing countries or for COVID-19. How much has actually been donated? Do operators believe such donations make up for listing P&D coins that fleeced retail investors?
(37) During the height of the fraudulent ICO boom days of 2017, dozens of coin funds were purportedly spun up to capitalize off the quick pump-and-dump on retail investors that was taken place globally.15 At the time, one article listed 15 such funds, most of whom appear to have fallen to the way side, and at least one (Polychain) that was sued by multiple different LPs for lack of transparency. How many of these funds got early access discounts and quietly dumped coins as soon as the coin got listed? How many actually paid taxes on the rumored ill-gotten gains?
(38) Soldering ASIC mining chips into always-on devices has repeatedly proven to be a bad deal for the consumer due to the fixed unit of labor within each device. Yet nearly every year starting with the 21.co toaster and Bitfury light bulb, a new manufacturer jumps into the fray to release yet another one of these environmental hazards. As an aggregate, how many of these all-in-one Earth sizzling devices have been shipped to consumers?
(39) Whatever happened to Halong mining? Their Dragonmint rig was repeatedly hyped by prominent maximalists back in late 2017 and early 2018. They shipped some units but they’ve been silent for a couple of years. Just one-and-done?
(40) With the release of the latest Raspberry Pi 4 and increasingly cheap SSDs, will node operators begin to (again) support larger block sizes? Aside from politics and ideology, what are the show-stopping technical reasons for not doing so? Too much to sync for a mobile device?
Bonus! Is ransomware fully dependent on the liquidity of cryptocurrencies? If so, will regulators and law enforcement eventually close down coin exchanges in order to snuff out this evergrowing parasite?
Again, this list is non-exhaustive and fairly US-centric. It also doesn’t even scratch the surface of C-level executives and apparatchiks who repeatedly use their social media platforms to push “buy the dip” memes onto unsophisticated investors.
For the future: what are some other types of questions that would serve the public interest in knowing the answer to? Recommended reading: Eight Things Cryptocurrency Enthusiasts Probably Won’t Tell You
Acknowledgements: many thanks to AC, GW, JS, CP, VB, AW, RS, AC, and CK for their feedback and suggestions.
- Tether Inc. has repeatedly misled the public about the 1:1 backing of its coin. As it has not regularly released an independent audit, some researchers such as Nicholas Weaver, hypothesize that there could be an imbalance that inflates bitcoins price level. [↩]
- Note: other partners, co-founders, and early employees are supposedly constrained by similar limits, not just McCaleb. [↩]
- Did Blockstream really own a Gulfstream IV? If so, why did a small software company need one? Why did they remove their team page a couple years ago? [↩]
- As we have mentioned elsewhere, a fundamental problem for all current cryptocurrencies is that they are not exempt from nemo dat and have no real fungibility because they purposefully were not designed to integrate with the legal system. [↩]
- Some mining pools have a service that enables certain customers to pay higher fees to expedite transactions. [↩]
- For instance, Charlie Lee (the creator of Litecoin), worked at Coinbase and claims to have had no influence on Coinbase’s decision to list Litecoin. Bobby Lee, his older brother, ran a coin exchange in China called BTCC. Back in 2014, BTCC introduced a marketing campaign for listing Litecoin (“Brothers Reunited“) which Charlie was purportedly involved in. [↩]
- Update 6/9/2020: According to a reader who compiled the code: “Original Bitcoin source code included the poker lobby and an eBay-like marketplace with a review system and essentially a sub-currency called “atoms” which were kind of like seller reputation / review kudos tokens.” [↩]
- As an aside, is there any additional connotation to Mt. Gox and the term Mutum Sigillium (which means a sealed deposit)? [↩]
- As an aside, one US exchange allegedly confiscated and sold CLAM coins that were airdropped on its user base, without their knowledge. [↩]
- Other ‘coinfluencers’ involved in the ETC split include Charles Hoskinson. [↩]
- Note: Epstein interacted with several prominent voices in the coin universe, including Brock Pierce and Reid Hoffman. [↩]
- Related: what about DeFi infrastructure, how many developers will be forced to adhere to rules and compliance requirements? Clearly most are not in-line with the PFMIs! Also, what was given (negotiated) with the dForce hacker? [↩]
- A couple sources claim that multiple personnel at three different DC-based lobbying groups including Coin Center have large undisclosed coin holdings (such as ZEC) which are believed to be a direct conflict-of-interest with how these organizations market themselves as “neutral.” [↩]
- For instance, a Fortune 100 company has investigated a former project lead who purchased a large quantity of a coin without disclosing it to the management team; it is believed this person may have even chosen to do this project with the coin issuer in the first place just for the ‘cheap’ coins because from a technical perspective, there was little merit in pursuing this architecture. [↩]
- One interesting story during this time frame was in September 2017, when several Chinese government agencies launched a large crackdown of ICOs and shut down many coin exchanges. Law enforcement perused WeChat chat histories to identify P&D ring leaders. A prominent coin investor based in Shanghai was supposedly tipped off and booked a seat on a private airplane from Shanghai for Los Angeles. Upon landing this person then flew to Georgia where they had a home and remained for several months. During this time this individual, in an agreement with Chinese governmental bodies, disgorged a large part of their ill-gotten coin earnings and later returned to China. [↩]